Agenda item

Report of the Director of the Built Environment.

The Sub Committee considered a report of the Director of the Built Environment focusing on certain strategic issues in the draft Local Plan where consultation responses suggested either a significant change in policy approach or identified a policy conflict.

 

Officers reported that alongside each of these issues was a set of potential options and Officer recommendations on the way forward.

 

Draft Plan Public Consultation Response

Officers drew attention to the breakdown of responses received to the draft Plan, highlighting that there was a fairly even split here between residents and workers. Officers also highlighted those responses received via Social Media on this occasion.

 

The Deputy Chairman commented that he did not feel that the number of responses received, which totalled 181, was adequate given that there were approximately 8,000-9,000 residents in the City and that over half a million workers were also here each weekday.

 

Other Members concurred with his point and also went on to question why there was no consistency between how the responses on this Plan and the Transport Strategy were coded.

 

The Chair reported that he had recently discussed with the Chief Planning Officer and Development Director how the City consulted generally on such documents and who the main consultees tended to be. He added that he was also aware of certain social media apps which promoted greater input.

 

Officers clarified that they had written to every residential address in the City seeking input in to the consultation process. They had also written to all commercial occupants, statutory bodies (including Local Authorities and Amenities) and had also held workshops and public meetings on the draft Plan. Lunchtime and evening sessions in office foyers and other public places had also taken place across the City, but Officers were keen to underline that these efforts did not always translate into comments/feedback.

 

Members were informed that the draft Plan was a 180-page document and therefore a very different type of document to the Transport Strategy. The Transport Strategy had also had its own dedicated website set up requiring respondents to register and provide details on their background before commenting on the Strategy.

 

A Member questioned whether Officers had any statistics as to the number of times that the draft Plan had been viewed/downloaded. Officers stated that the draft Plan webpages had had approximately 5,000 ‘landings’ to date.

 

A Member went on to express concern about the organisation seeming to still operate in siloes in terms of consultation on these types of documents. He suggested that Officers needed to work harder in order to get a better strategic base in terms of who was to be consulted. He added that the GLA had recently done a fantastic job consulting on their Sports Strategy.

 

A Member referred to recent consultation on Bank Junction which had been very focused and specific. He stated that a strategic document such as this was more complex and suggested that the job of Officers and Members should perhaps therefore be to develop strategy and then consult, more specifically, around outcomes. Another Member agreed with a more specific approach and questioned what might be done going forward to direct particular consultees to particularly relevant recommendations within larger strategic documents such as this.

 

Members were generally of the view that it would be preferable to seek professional skills in terms of engagement in order to achieve optimum outcomes going forward.

 

In response to further questions, Officer stated that they would be happy to recirculate the information previously provided to this Sub Committee on what media advertisement was used regarding the draft Plan consultation. Officers also reported that the City Corporation’s Comms Team had been fully engaged with this exercise.

 

Officers were keen to point out that some of the responses received were from bodies such as the CPA and the Barbican Association which, whilst only counting for a single response, were actually quite significant in that they represented the views of many.

 

The Chair questioned whether there was sufficient time for further consultation on the Local Plan without significantly delaying the progress of the Plan. He suggested that he and the Deputy Chairman look to explore this further with Officers outside of the meeting given that the general mood of this Sub Committee was that the outcomes to date were not as hoped. He went on to recognise that budget and timescales would need to be considerations and also stated, in defence of Officers, that the same consultation process tended to be carried out elsewhere with a similar exercise in Westminster at the end of 2018 attracting almost identical levels of response.

 

Evidence base

Officers highlighted that further evidence would need to be gathered through the summer and autumn to support the next iteration of the Local Plan. This would the take the form of an Infrastructure Delivery Plan. It was also highlighted that there was a requirement to undertake a viability assessment of the entire plan which was seen as a key test – Officers clarified that this was not only in relation to housing but on a combination of policies within the plan.

 

The Chair underlined that it would be essential to make that as robust as possible. He questioned whether it was intended that there be any Member oversight of the Infrastructure Delivery Plan. Officers reported that a session to look at this in more detail alongside Members would be held in the Autumn. This would be separate to the Local Plan Sub-Committee consideration and utility firms would also be invited to attend.

 

Officers concluded by stating that the current target dates for Committee approval set out within the report were partly dependent on the progress of the wider London Plan and may, therefore, be subject to change.

 

Appendix 1 – key strategic issues

 

Strategic Policy S3: Housing

Officers reported that responses suggested that there was overall support for the amount of housing to be delivered and also the suggested approach to this within the draft Plan. There were some specific comments from the Mayor of London to respond to in relation to this policy. Officers highlighted that they were of the view that there was a need to provide further evidence to support what had been done/what was going to be done but that they did not recommend the identification of any specific sites.

 

S3 Housing Delivery

A Member stated that there seemed to be a desire from the Mayor  to move planning policy away from the traditional approach and more towards a ‘zoned’ approach with clearly defined residential zones going forward.

 

Another Member stated that, whilst housing sites existed elsewhere, he was of the view that the City was a justifiable exception.

 

S3 Affordable Housing

A Member questioned why there was no specific reference to Social Housing here. Officers reported that the requirement was for 35% affordable housing and that most of what was needed as part or this, in the City’s case, would be Social Housing as opposed to shared ownership or other low cost properties.

 

A Member, also the current Chairman of the City’s Community and Children’s Services Committee, stated that the organisation currently operated a policy where they financial contributions for delivery off-site which, in his opinion, was not working. He added that he was very strongly of the view that the commuted sum should never serve as an incentive and highlighted that this was already being looked at in more detail at present. Other Members welcomed this move.

 

Officers reported that they were of the opinion that whilst 35% affordable housing was realistic in the City, the Mayor’s 50% strategic target was potentially not. It was therefore suggested that an approach stating that 50% would be delivered on the City’s own estates and at least 35% within the City itself be agreed. A Member highlighted that there was a difference between affordable and Social housing and suggested that the two might be blended in order to achieve the 50% target.

 

As an aside, a Member observed that housing development within central London was virtually at a standstill at present which seemed to suggest that the Mayor’s policy here was failing.

 

Policy H3: Residential Environment

Officers reported that many responses here had referenced policies concerning Culture Mile and restrictions on on-street activities.

 

Officers highlighted that there were limits as to how much planning could control in terms of control of on-street activities. This could, however, be clearly linked to transport and licensing policies within the draft Plan. There would also be more detail on the Agent of Change principle although no significant changes to draft policy were recommended at this stage.

 

Members recognised that Licensing were often tightly constrained around what powers they had and what conditions they might apply. It was felt that Planning was a crucial element here in terms of applications centring around the night-time economy and could often have more “teeth” in terms of setting out requirements for certain hours of operation, management plans and the construction of double lobbies for noise control for example.

 

D8 daylight and sunlight

Members stated that they were supportive of the Officer recommendations set out here.

 

The Chief Planning Officer and Development Director reminded Members that a report setting out some suggested guidelines and clarification around this was due to be considered by the 30 July meeting of Planning and Transportation.

 

Strategic Policy S4: Offices

Officers reported that comments on this policy had centred around four areas – the scale of office delivery, where offices would be delivered, affordable workspace and protection for existing office floorspace.

 

S4 Office Delivery

Officers referred to the target of providing 2 million square metres of additional floorspace and highlighted that this figure was well founded and that evidence around how this would be achieved  would be provided to support the Plan. The present situation was being monitored with over 800,000 square metres currently under construction and a further 400,000 square metres approved but with works not yet commenced. 

 

In terms of identifying specific sites for future development, information on where new floorspace is expected to be delivered would be included in the next  iteration of the plan.

 

In response to a question, Officers reported that progress against the target is monitored annually and would be reviewed every 3-4 years.

 

S4 Affordable Workspace

Some responses, had suggested that a policy requiring large developments to set aside space for affordable workspace should be introduced, including from the GLA and neighbouring boroughs. Others, such as that from the CPA argued that there should not be a formal affordable workspace policy. Officers were not, however, in agreement. It was felt that the market was offering such space anyway and Officers cited WeWork as a specific example of this. They were confident that this could be evidenced as an argument against prescribing the need for affordable workspaces. Members were generally supportive of this and favoured allowing the market to continue to move organically.

 

O2 protection of existing office floorspace

Officers reported that office space was protected in the current Local Plan with more flexibility around listed buildings/heritage sites. Many responses were of the view that the 18-month marketing period was overly prescriptive and Officers suggested that the new plan may provide the opportunity for greater flexibility.

 

A Member stated that expertise suggested that marketing evidence was important. He added that the London Plan referred to a marketing period of 12 months as opposed to 18 and suggested that the draft Local Plan could look to adopt this going forward on the basis that it was likely to have been much debated already.

 

Another Member added that he felt that there needed to be a substantial and genuine effort to market and retain existing office space and that the wording around this should be more robust, particularly if there was to be a move from an 18 to a 12 month marketing period as proposed.

 

Officers undertook to look into this matter further on the back of Members comments and to then report back further to the Sub Committee in due course.

 

Strategic Policy S6: Culture, Visitors and the Night-Time Economy

 

C3 Hotels

Officers reported that there had been a major growth in hotels in the City within the last 15/20 years. The City’s current approach to this was relatively neutral with assessments carried out on a site by site basis. It was felt that this continued to be generally the right approach.  Members were informed that some surrounding boroughs were looking to be more restrictive. There was, however, generally a feeling that we might look to promote more hotels given the cultural offerings in certain parts of the City – this was an argument put forward by the CPA. It was recognised that where a hotel was looking to occupy an existing office building (which tended to be the case) balance was needed and there may be opportunities for some mixed office/hotel use.

 

The Deputy Chairman questioned the importance of the growth related to the Culture Mile on this policy and how Officers intended to measure what this might look like. He also referred to the demand by businesses for hotels (bednights) and the need also for conference venues within the City. He questioned how this could be evidenced. He concluded by stating that he tended to be supportive to the call for more hotels in the City although recognised that these should not be situated in predominantly residential areas.

 

A Member questioned whether Officers had consulted the Cultural & Visitor Development Director in terms of demand for hotel space in the City. Officers confirmed that hey had held discussions with him around this and had established that approximately 80% of the demand for hotels came from businesses as expected. The leisure element was, however, growing and some further work could be undertaken to look into this further.

 

A Member questioned whether any preference had been expressed in terms of hotel size, recognising that there were quite a few 20 bed hotels in the City. He questioned whether smaller venues such as these were to be encouraged. Officers reported that some hotels in London had now taken to occupying floors of existing office buildings which was another factor that could be taken into consideration going forward.

 

At present, Members were of the view that a neutral stance with each site considered on its merits was probably still the correct stance to adopt.

 

C4 Evening and night-time economy

Officers reported that responses from the Mayor on this matter were generally supportive. Some comments around a more restrictive approach and greater planning control over things such as dispersal routes and some design/management issues had been received.

 

The Deputy Chairman stated that there had been huge organic growth in this area in the City over the past 20 years which, to his mind, was part and parcel of becoming a 24/7 city – something that was vital in order to remain globally competitive. He agreed that this needed adequate monitoring but stated that he felt that the City could endure more growth yet in terms of evening and night-time economy without being saturated.

 

Another Member referred to a recent speech by the Mayor’s night-time tsar at which she had made clear that the night-time economy involved offerings from 6pm-6am. He added that he felt that the City’s night-time economy was now relatively vibrant and that this should be allowed to continue ensuring that there was sufficient and appropriate crossover with licencing.

 

A Member, who also currently sat on the Licensing Committee, stated that it was clear that the night-time economy in the City had evolved organically but was more prolific in certain areas which had also led to policing issues. He added that he felt that care therefore needed to be taken, from a planning perspective, to not exasperate these issues. He suggested that police input on this policy should therefore also be sought.

 

Strategic Policy S9: Vehicular Transport and Servicing

 

S9 freight and servicing

Officers reported that comments from industry as to the low threshold for physical consolidation had been received. The Chair stated that any movement up from this should not in any way weaken the policy given that the Transport Strategy very clearly set out that the desire was for consolidation to be the norm going forward.

 

A Member questioned what was meant by other forms of consolidation and virtual consolidation. Officers reported that this could be things such as using joint suppliers and that virtual consolidation could be considered as an alternative to physical consolidation.

 

A Member objected to this and stated that he felt that virtual consolidation was not consolidation at all and was, at best, a small efficiency. He clarified that he was very sceptical as to the merits of this and was not personally aware of this happening in any multi-tenanted buildings at present.

 

Officers undertook to take this matter back and report further to the Sub Committee in due course.

 

A Member questioned why responses objecting to weekend deliveries in certain areas had been forthcoming given that, if these were timed correctly, there tended to be no particular noise issues associated with these.

 

A Member spoke of future proofing the plan and referencing, for example, the use of drone deliveries and allocated rooftop space for these within the City. Officers stated that they would look to reference that possibility within the draft Plan.

 

Strategic Policy S12: Tall Buildings

 

S12 definition and location of tall buildings

Officers highlighted that this mater was closely related to that on protected views. At present tall buildings within the City were defined as those over 75m. It was felt that this threshold was reasonable and was higher than other surrounding boroughs. There were, however, lower thresholds for riverside developments which were currently capped at 25m.

 

S12 public space and tall buildings

Members were in favour of greater flexibility in terms of a wider range of potential public uses going forward although they emphasised that all new tall buildings should provide some public space.

 

A Member questioned how public realm at ground floor level might be more actively encouraged.

 

Strategic Policy S21: City Cluster

Officers reported that a mix of views as to whether the indicative boundary should be extended or made more precise had been received. Comments around what was being done at street level to manage intensification here had also been received with the general consensus being that this should not be overly prescriptive.

 

A Member was concerned that the Plan seemed to ignore the fact that the majority of workers within the City Cluster used London Liverpool Street station which was not included in this key area of change. He added that footfall here was vital. Officers reported that the station was incorporated within a separate area but that the relationship between this and the City Cluster could be clearly highlighted within the Plan going forward in order to raise its profile.

 

Strategic Policies S23: Smithfield and Barbican; S24 Culture Mile Implementation; and S25 Smithfield

 

Officers reported that there was a call from some for the Plan to emphasise that there were cultural offerings elsewhere in the City beyond the Culture Mile.

 

Comments were also received around the need for the Plan to provide greater clarity around the future use of Smithfield Market. Officers were of the view that whilst some options could be explained, the policy should not be prescriptive at such an early stage. A Member agreed that it was too early to comment on this in any detail at this stage and that any wording in the Plan should be tentative. He added that the public realm around this site would also be very important and reference to this should also feature in the Plan.

 

Members were also of the view that it would be helpful to add further supporting text to the Plan to reassure residents that major projects will be required to undertake detailed assessment of issues such as noise and pedestrian flow and to identify appropriate mitigation of any adverse impacts.