Report of the Executive Director, Environment.
The Committee considered a report of the Executive Director Environment summarising the outcome of the consultation exercise on the City Plan and highlighting the key issues arising.
Officers reminded the Committee that they had agreed a draft plan for public consultation last Spring. Consultation had had to take place virtually owing to the ongoing pandemic and a very high number of responses had been received to this – over 1,300 representations which were summarised within the appendix to this report. Among these responses, it was highlighted that the Mayor of London considered that the Plan needed to be more prescriptive in terms of the City Corporation’s approach to tall buildings in order to achieve general conformity with the London Plan. It was noted that there was also a substantive group of responses in relation to heritage concerns and the need to strike the correct balance between development pressures and heritage issues. It was reported that the result of all of this was that it was now felt appropriate to pause the process and revisit the draft Plan accordingly to ensure that it was found to be sound at examination and did take into account new issues that have arisen in the past 12 months. The report set out six policy areas where it was suggested that the Plan now be sense checked – tall buildings as per the Mayor’s concerns, climate change where Officers could now build upon the momentum of COP26 and further embed the organisation’s own Climate Action Strategy, offices and office floor space given the changing nature of work and the increase in hybrid working, the role of retail and town centres in a changing environment, housing and housing delivery and finally health and inclusivity which the pandemic had brought to the forefront more so than ever before. Officers proposed that next steps would involve refining the Plan, consulting on it further in 2022 and then submitting this to the Secretary of State. A draft timetable for the Plan preparation process was suggested at Appendix B. This included the need to ensure that evidence collected pre-pandemic was updated and still valid. This would also include a call for housing sites to ensure that if there was private sector interest in more housing in the City, Officers were made aware of this. The process also encouraged member involvement to help steer any policy refinements. The proposal that the end date for the Plan be rolled forward to 2040 would mean that it was consistent with the end date for the London Plan and would also bring it into line with the evolving end date for the Transport Strategy.
A Member commented that he was pleased that there would now be a further opportunity to consider the housing issues. He went on to refer to the risks stipulated within the report particularly around the weight attached to the emerging City Plan. He expressed the view that the emerging Plan was a lot better than the existing Plan in a number of areas such as carbon and therefore questioned how, during this pause, the emerging Plan policies might still be applied. Officers responded to clarify that the emerging plan would, unfortunately, now carry less weight than when it had been intended to submit it. However, Members were provided with some reassurance in that the policies within the draft plan did carry some weight given that many were hung upon strategic policies within the London Plan or national policy guidance. Officers added that it was the case that, when an application was considered, the development Plan and any other material considerations were relevant.
Another Member commented that the responses to the consultation had come as no surprise, particularly in relation to tall buildings, heritage and residential amenity. She added that she was, however, surprised that, given that the Secretary of State had directed the Mayor of London to amend the London Plan with regard to tall buildings back in December 2020 and that this consultation exercise had concluded in May 2021, it had taken this report seven months to be brought to this Committee. She expressed concern that, in the meantime, this Committee had approved planning applications for the construction of seven tall office buildings which would impact upon heritage assets and residential amenity. With regard to the comments on health and wellbeing, the Member stressed the need to use the planning system to ensure that proper gains were made for the City of London in terms of health centres and the like. She added that she was pleased to see the number of responses received and hoped that those respondents would continue to engage with the process. Officers apologised for the delay in bringing forward this report but explained that there were 1300 responses to process before that could happen. In relation to the tall buildings implications, Officers reiterated that the GLA’s comment was that the City should be more prescriptive in its policy approach here and not necessarily that tall buildings should not be permitted per se.
A Member noted that the Barbican association had responded to note that the spatial strategy aspirations did not include protecting residential amenity. He questioned whether Officers had subsequently made any adjustment to the Plan as a result of this representation. Officers clarified that this would be a process for Members to work through when considering all of the responses received and changes to the Plan in 2022. It was highlighted that there were policies within the draft Plan to protect residential amenity and that it would be for Members to decide upon the degree of importance that those policies should have when weighed against other policies.
A Member raised a question on office space, recognising that the organisation were aiming for a cumulative total. She questioned where the City were in this process at present and how close they were to reaching this target. She queried how the provision might be more evenly spread throughout the lifetime of the Plan. Officers reported that the existing Local Plan had a target of 2 million square meters of growth and that, at present, this target was half way met. The existing, adopted 2015 Plan contained phasing to reflect what the pipeline looked like at the time of adoption and progress was being made broadly in line with this. Going forward, a key consideration would be what type of office space would be needed and how much of it. It was recognised that the introduction of hybrid working may well have consequences. Officers added that their professional opinion was that the City would continue to be an attractive place to do business and that it would therefore continue to need more office space and not less. However, this proposed pause would now allow this matter to be revisited and for further evidence gathering to take place so that an informed decision could be taken as to the appropriate amount and type of office space required going forward.
Another Member questioned the City Corporation’s real ability to control the pace of office delivery in the City. He stated that once an application had been approved, whether or not it then proceeded presumably depended upon economic conditions and the developer’s view as to whether or not it was actually needed. Officers stated that this was correct and that the pace of delivery was a private sector driven process. This was seen as a positive in terms of surplus stock not being needlessly delivered with developers taking a view as to viability. One consequence of this however was that a healthy pipeline of schemes permitted was needed, in excess of the target, to allow for those schemes which subsequently fell away.
A Member questioned the sources that were to be used as part of the intelligence gathering exercise to estimate future office demand. He referred back to the fact that the City was already half way to meeting its target of 2 million square meters of growth in office floorspace from 2015-2035. Officers reported that one key component of office needs in the future was how office floorspace would be used and the nature of office occupation going forward. A second key component would be employment projections – how many would be working in the City and on what basis/how often. It was noted that the GLA employment projections were due to be revised and reissued in the New Year which would be the first indication from such a body as to the impact of the pandemic on employment in London as a whole and its key sub-markets such as the City.
A Member stated that this future Plan would seek to guide developers, something which the current Plan did not seem to do given the number of times that planning applications that were in contradiction to its policies were brought forward. He questioned how this Committee and Officers could ensure that any future Plan was more stringently upheld. He went on to express concern that the end date for the future plan was to be moved from 2036 to 2040 and stated that he hoped that this would not unduly delay its adoption. He added that there was a clear need to have the Plan in place to protect the City’s genuine heritage assets. Officers stressed that the Plan was a large document containing various different policies and that was to be read as a whole. Members were informed that it was inevitable that most applications were a compromise that complied with many but not all policies. Officers made recommendations based on this and it was then for Members to make a judgement as to whether or not the correct balance had been achieved in terms of policy application.
RESOLVED – That Members:
· Note the summary of key issues raised during consultation on the Proposed Submission draft City Plan 2036 set out in Appendix A;
· Agree the revised City Plan timetable proposed at Appendix B; and
· Agree to amend the City Plan end date to 2040 to align with the Climate Action Strategy.
Thank you to Paul Beckett
The Chair wished to place on record his thanks to Paul Beckett for his counsel ahead of his imminent retirement. He reported that Paul had started at the Corporation 33 years ago, initially on a temporary contract. He added that Paul had served under numerous Chairs of this Committee as well as several different Chief Planning Officers and described him as very wise, persuasive and steady with an encyclopaedic knowledge which had been hugely appreciated by all. In terms of the City’s position on planning policy, the Chair highlighted that the Corporation was seen as a leader in London and that much of this was due to Paul and his team’s very hard work and dedication. The Chair, on behalf of the Committee, wished Paul a very happy retirement.