Report of the Director of the Built Environment
The Sub-Committee considered a report of the Director of the Built Environment responding to the questions and further clarification sought by Members on suggested changes to the City Plan 2036 at their last meeting on 20 October 2020. A revised schedule of changes was also proposed.
With regard to the timetable for the Plan, Officers reported that, since the last meeting, they had had further confirmation from the Government’s Chief Planner that, although there is a wider planning reform agenda which will impact upon the planning system over the next 12-18 months, her strong advice to all local authorities was to continue with their Local Plan preparation process in so far as they could.
A Member made reference to the cross-cutting London Recharged Report which was touched upon within the paper and questioned whether anything more specific would be done with regard to planning and fed into the Local Plan. Officers agreed that the London Recharged Report was quite wide ranging and was tailored to a range of audiences including the City of London Corporation and other bodies. In preparing the report, the consultants had consulted widely with key individuals who have an influence on or view upon the future of the City. Whilst it was recognised that the report was not a specific plan in the sense that a local authority land use plan was, it was noted that it did set out some broad aims that it would be desirable for the local authority and other stakeholders to bear in mind in order to ‘recharge’ London as a vibrant City going forward. It was therefore one element of a growing evidence base that the City as a commercial centre would rebound after the current pandemic. This presumption was also reflected within the City’s own draft Plan. In the meantime, Officers reported that they were now considering taking active steps in engaging a retail consultant to provide further commentary on the current situation and the likely future prospects. Consultants would also be engaged to consider the future of the public realm and transport in the City. As the current situation improved, thought would also be given as to whether there were any employment or mix of land use implications of COVID-19 to consider. It was expected that information around this would emerge in the coming months and that this would inform the examination of this Plan in 2021. Officers underlined that it was simply not possible at this stage to predict with any certainty what the short or long-term effects of the pandemic would be but that it was nevertheless important to proceed with the best possible estimates of the likely future direction of travel whilst also remaining flexible, through discussions at examination, to ensure that the Plan remained relevant once the pandemic had passed.
Officers went on to report that they felt that there was generally good synergy between the London Recharged Report and the draft Local Plan and that much of what was in the Local Plan was supported by this report. It was recognised that there was a lot in the London Recharged Report that covered non-planning issues and so, whilst Officers could provide the Built Environment elements of it, much of the implementation of it would be delivered by other Departments within the City Corporation and also other parts of London.
The Member thanked Officers for their response and went on to refer to The Tulip Inquiry which had opened this week and had already made reference to the London Recharged Report. He commented that it should therefore be assumed that the report would also be raised at examination and that how this fitted in with the Local Plan should therefore be made clear from the outset. Officers responded by stating that the London Recharged Report was not a plan document in itself but was part of an evidence base which complemented the Plan.
Another Member spoke to refer to the 15 minute City concept and highlighted that there were many facilities that were very close to the City within neighbouring boroughs and that this was another reason why he felt that the concept should not be embraced for such a small area. Officers agreed with the point made and undertook to refer to neighbouring boroughs and the social and community facilities used by City residents within the suggested wording in the schedule for the new paragraph which follows 6.2.1 within the draft Plan.
A Member referred to the office Development Pipeline noting that almost 70% of the target was likely to have been completed by the end of 2021. He therefore questioned what it was that would be being delivered over the remaining 15 years of the Plan. Officers reported that work to reach the target was currently ahead of schedule but highlighted that the phasing of the works had always been of that order in that it was always anticipated that a greater proportion of development would be delivered during the first half of the Plan’s lifespan than the second half. Officers went on to state that it may be the case that, when the Plan is reviewed in 5 years’ time, in line with Government guidance, the balance between demand and supply and the appropriate mix of uses may have changed and different targets might be required going forward. Members were also informed that the baseline used for the draft Plan was 2016 and that, since this time, there had been a large amount of construction in the City with over 500,000 square metres of office space already developed. Before this, in 2011-16 there was actually a net loss of approximately 400,000 square metres due to the demolition of buildings that led to the replacement scheme that the City was now seeing come to fruition.
The Deputy Chairman cautioned against over reliance on long-term forecasting of this type as, in his experience, most Plans such as these needed to be able to adapt to increasingly fast changing circumstances. Given the fact that the country was currently in the centre of an immense social, medical and economic crisis, it was difficult to plan with any certainty for the longer-term and the real key for the City Corporation was to ensure that it worked holistically across all Committees and Departments to ensure that it was quick and flexible enough to adapt retail and office space, open space and highways to respond to the City’s recovery from the pandemic and emerging requirements in due course. Officers went on to state that the target for development in the City was deliberately broad brush and that this was a sufficiently flexible Plan to enable targets to be adjusted in response to changing circumstances.
The Sub-Committee went on to focus on mix of uses. A Member questioned whether Officers were satisfied that the emerging Plan was providing the market with enough clear direction on this matter. Officers stated that they hoped it was the case that developers were clear on what the Plan was trying to say on this matter and that there had been a shift between the current Local Plan and this emerging Plan to a more favourable approach to encouraging housing within or nearby to existing residential areas. Previously, the approach had been to provide, but not encourage, housing within these areas. The justification for this shift was to provide greater confidence around meeting housing targets going forward. Alongside this, Officers also had reasonable confidence that they were going to meet office supply targets which would allow for greater flexibility for sites nearby to existing residential areas and allow both targets to be met. It was felt that the emerging Plan ought to enable professional developers with sites in or near existing residential areas to reach the conclusion that they should be considering housing as a possible use depending on the circumstances of each site. Officers added that, through discussions taking place at the pre-application stage on a number of schemes across the City, they were now beginning to see developers taking a more flexible approach to the sorts of uses they want to see in their buildings. Many were also beginning to understand, not least because of the ongoing pandemic, that a greater mix of uses gave them greater certainty of income as well as flexibility going forward. As a result, it was felt that this approach would become more prominent in future years. Officers did, however, caution that the residential market in central London was not very buoyant at present.
The Deputy Chairman commented that he was of the view that the City of London was particularly vulnerable to the pandemic, more so than outer London boroughs which had a greater mix of residential, retail and leisure offerings. The emerging Plan should therefore be as flexible as possible in terms of changing the mix of uses in the City if the market demands it.
The Chair noted that Local Policy OF2 allowed for the loss of office accommodation within and near residential areas where it would not compromise the potential for office development in the vicinity and suggested that this also needed to be kept in mind. Officers stated that as the City was primarily a commercial centre with residential locations, it made it quite different to other central London locations in terms of the balance of the mix of uses, and recognised that this had worked to the area’s disadvantage in the short-term, during the ongoing pandemic. However, the USP of parts of the City being almost exclusively a mix of different types of commercial and supporting uses was not generally available in other locations. Officers hypothesised that a possible consequence of the pandemic was that, overall, the total demand for office floorspace across London might decrease with an increase in remote working and that this might lead to a decrease in office space in other parts of London with some looking to relocate to the City because of this USP and its commercial mix. Officers recognised that there was a need for balance between addressing short-term consequences and addressing long-term objectives.
The Deputy Chairman went on to state that one of the few certainties at present was that those living and working in large cities would increasingly desire and demand cleaner air and quieter, safer, cleaner streets in general as well as a mix of retail and cultural offerings going forward. In this respect, those cities that tended to thrive were those who invested and opened up and did not retreat or retract. The Deputy Chair therefore underlined once more the importance of a holistic approach across the City Corporation to help create a plan that would welcome people back to the City in the longer-term.
Another Member spoke again on the London Recharged Report and noted that this made reference to hyper-flexible working and hyper-flexible offices. He questioned whether this same language ought to now be used within the emerging plan to keep the two documents clearly aligned. Officers clarified that it was their intention to look again at the detailed wording of the Plan in areas where there was already good alignment with the London Recharged Report and to nuance this to more clearly align the language used within the two documents. This work would be undertaken ahead of submitting the revised City Plan to the Planning and Transportation Committee later this month. Officers also took the point made by Members around flexibility and, in particular, how office floor space was likely to be used differently in the future, recognising that there should be not constraints within the Plan around this. Another Member requested that ‘consultant speak’ phrases such as ‘hyper-flexible workspace’ were not used within the Plan and commented that a move to more flexible working was not a new phenomenon with many City firms having introduced this a long time ago. The current pandemic had simply served to accelerate this trend. The Member commented that one possible outcome of this was that offices would be able to take on more staff without acquiring more office space. The Chair commented that reference to hyper-flexible workspace was made within the London Recharged Report and that the general consensus of the Sub-Committee was that this should therefore be reflected within the emerging Plan to tie the two together where possible.
Officers thanked Members for their input and anticipated that a likely debate on the Plan at the Grand Committee would be around the fact that there was currently too much uncertainty to proceed with the suggested timetable however, as discussed by this Sub-Committee, the City Corporation had an obligation to show some leadership and to continue to progress the Plan as highlighted by the Government’s own Chief Planner.
Officers also highlighted that Westminster City Council were currently going through a Local Plan Examination and Inspectors had subsequently written to them with ‘main modifications to the Plan’. Two of the points raised were also relevant to the City’s draft Plan – the first of these was around seeking affordable housing contributions from commercial development which the Inspectors had suggested was not in line with national policy and should be removed. Whilst this was a new policy for Westminster, the City had taken this approach for many years and it was not proposed that this be changed. Members were, however, asked to note that this point may be made during consultation. The second comment made by Inspectors had been around the Use Classes Order where Westminster CC had suggested that they will use planning conditions to manage the change of use within classes whilst Inspectors considered that this was not in line with national policy. The City’s draft Plan suggested that planning conditions might be used for this purpose where necessary and it was proposed that this approach continue to be taken forward for consultation. The Sub-Committee noted these points and the Chair underlined that, whilst Westminster was a neighbouring borough and that there were some similarities with the City, the two were different entities and it was felt that what was being presented here was a coherent plan for the City. Officers added that the whole purpose of an examination was to consider the extent to which local authorities could locally justify any exceptions to a national approach and make their case for these adequately on a range of grounds.
RESOLVED – That, Members agree the suggested approach outlined in the report and the schedule of proposed changes, for onward consideration by the Planning and Transportation Committee.