Agenda item

City of London Local Plan Review: Proposed Submission version of City Plan 2036

Report of the Director of the Built Environment.


The Sub Committee considered a report of the Director of the Built Environment highlighting the main changes that are now proposed to the November 2018 draft Local Plan and including those sections of the Plan which were not considered by the Sub-Committee at its last meeting on 14th January 2020.


With reference to the target dates for final Committee approval of the Plan, the Chair clarified that the March 2020 meeting of Planning and Transportation would now take place on 6th March and not the 10th March as suggested within the covering report.


Officers highlighted that those changes proposed by Members at the 14th January meeting of this Sub Committee were detailed using bold text at Appendix 2 of the report. Members indicated that they were satisfied that the amendments made here reflected their comments and concerns. Appendix 1 contained text relating to Section 4.2 of the draft Plan ‘Safe and Secure City’ which was a city-wide policy and had now been considered by the Senior Security Board, Section 7 of the plan ‘Key Areas of Change’ and Section 8, ‘Implementation’.


A Member questioned why more prosaic crime such as knife crime, burglary and assault were not referenced at paragraph 4.1.1 of the ‘Safe and Secure City section given that these types of crime tended also to be of concern to those living, working in and visiting the City. Officers highlighted that paragraph 4.1.2 did mention violent and acquisitive crime and reflected current priorities set out in the Policing Plan.


A Member commented that rough sleepers and anti-sociable behaviour had been a big topic at this morning’s rate payers meeting and asked if this also might be covered here. Another Member commented that Strategic Policy S2 specifically covered the need to minimise the potential for crime and anti-social behaviour by ‘designing out crime’ and encouraging a mix of uses and natural surveillance of streets and spaces. Officers agreed that the point around good design in relation to this concern would be more adequately covered in the Design section of the draft Plan.


A Member questioned the appropriateness of the phrase ‘designing out crime’ and was advised by Officers that this was a national term adopted by the Police.


In response to questions around how skateboarding in the City was to be tackled going forward, Officers reported that there was reference to this and the need to reduce opportunities for ‘skaters’ within the public realm policy of the Local Plan.


The Sub Committee then turned their focus to the Key Areas of Change with the Chair suggesting that Members should discuss each of these in turn. Colour diagrams to accompany the text for each Key Area were tabled. Officers clarified that they were not attempting to prescribe exactly what each of the key areas should look like going forward but were attempting to give a clear steer on these within the draft Plan. The Chair commented that it was envisaged that defining each of these key areas would serve as a catalyst for encouraging design briefs going forward.


Officers highlighted that 7 Key Areas of change were identified within the draft Plan as follows:


Thames Policy Area

Officers reported that it was a requirement of the London Plan that the City’s Local Plan identified a Thames Policy Area.


A Member questioned whether there was enough within the Strategic Policy here to cover the opening up/widening of the riverside to the general public. Officers reported that, generally speaking, the aim here was to make the riverside area more vibrant. The Chair suggested that the first bullet point at paragraph 3 of Strategic Policy S17 could be amended to read ‘protecting and enhancing public access and river views along the riverside walk and securing completion of the riverside walk at Queenhithe’ to cover this point more robustly.



Officers reported that reference to open space had to be changed to public realm here to address legal concerns. They highlighted that work in this area would be focused on renewal and better permeability, particularly around The Mermaid and Baynard House.


In response to questions regarding the identified Flood Risk Area, Officers stated that this reflected the City’s Strategic Flood Risk Assessment and Environment Agency requirements and reflected the situation without the Thames Barrier. They added that this was not necessarily all attributable to river flooding but also took account of surface water flooding through heavy downpours.


Pool of London

Officers noted that there were a number of sites within this key area that were being vacated including Custom House and Adelaide House. The Chair added that the development of Planning Briefs for this area had also been discussed.


A Member questioned how public realm improvements were defined. Officers responded that this had been kept purposefully broad but reassured the Sub Committee that they were content that this was appropriate at this stage.


Members questioned the final bullet point at paragraph 5 of Strategic Policy S19. Officers undertook to give further consideration to the wording here in order to ensure that it accurately reflected their intended outcomes.


Members also requested that the word ‘very’ be reinstated at paragraph 7.4.2 given that Lower Thames Street continued to be the worst location within the City in terms of air quality. 


Aldgate and Tower

Officers recognised that this area had already undergone improvement around Aldgate Square but stated that they were keen to maintain momentum here commenting that the Mansell Street Estate could be significant in this respect. There was also a desire to improve connectivity here given that the area was currently very fragmented by transport links.


A Member referred to Petticoat Lane Market which he noted was referenced in the Liverpool Street Key Area of Change section but questioned why it was not also referenced here . Members were supportive of this being referenced under both Key Areas.


City Cluster

Officers noted that this had previously been referred to as the Eastern Cluster and that the focus here would be around managing the intensification of the area given that it had been identified as the most appropriate location for tall buildings in the City. This would include managing the effects of such intensification on the ground in terms of public realm and pedestrian flows.


In response to questions, Officers clarified that buildings referred to as being ‘in the pipeline’ were only those that had received Committee approval to date. The Chair added, however, that there was clearly more to come in this area, including on the renewal opportunity sites.


A Member questioned whether Renewal Opportunity Sites was a defined term. Officers indicated that this would be defined in the glossary of the draft Plan.


Fleet Street

Officers recommended that this key area be extended with a focus on delivering public realm and transport improvements along the processional route to St Paul’s Cathedral.


A Member commented that he felt that the environment and amenity of the Carter Lane area was particularly poor and should therefore be included in any transformational plans for this area. A Member highlighted that paragraph 7.7.10 referred specifically to Carter Lane and questioned whether this could be elaborated on to address concerns here.


Another Member commented that he felt that the public realm offering in Whitefriars was lacking in comparison with the rest of the City, in terms of trees and greenery and that the area contains a number of characterful buildings that could be improved. He added that the retail offer on Fleet Street, to the west of Ludgate Circus was also lacking and questioned how improvements might be encouraged.


Smithfield and Barbican

Officers highlighted that this was aligned with the area identified for the Culture Mile. The City Solicitor has advised that the movement of Smithfield Market and the Museum of London planning application should not be prejudged within the draft Plan given that both were still under consideration. Members were appreciative of this point but, nevertheless, suggested that paragraph 7.8.3 could be firmed up. Officers commented that a bill would be put before Parliament in November 2020 and that references to this in the draft Plan could be factually updated in due course.


A Member questioned what was meant by the word ‘appropriate’ in the context of bullet point three of Strategic Policy S23. Officers clarified that this related to the fact that the market buildings were listed buildings. Members asked that this point therefore be elaborated on to read that uses ‘appropriate to its status as a Grade II listed building’ were to be encouraged.


The Member went on to refer to Citigen suggesting that this was not likely to be an environmentally friendly, viable, long-term option. It therefore seemed inappropriate, in the penultimate bullet point of Strategic Policy S23, to mention that continued connections would be supported and that all new development would be designed to enable connection to the Citigen network which would seem to impose an additional cost on developers. It also seemingly imposed a cost on buildings in this vicinity. The Chair agreed with the point being made and asked that this bullet point be reviewed to make it clear that this was only a holding position and that, going forward, power was to be obtained in the most environmentally friendly way possible. Officers clarified that the wider policy in the draft Plan addressed this point and that the draft Plan was London Plan compliant in relation to heating networks at present. Members suggested that the organisation could consider pushing back on the London Plan on this point and question whether they were satisfied that this is viable long-term.


Liverpool Street

Officers reported that relatively minor changes were proposed here to stress the importance of public realm and diversifying the occupier base.


Members commented that this area in particular had the potential to become an area that was used seven days a week.


A Member questioned whether there was anything that the City Corporation could do to signal to TfL the need for improvements at Bishopsgate.


The Chair commented that Liverpool Street Station has a substandard environment compared to other mainline rail stations in London and asked whether the need for improvements to the station itself could be addressed within the policy. Officers undertook to add appropriate wording to the policy.



Members went on to discuss section 8 of the draft Plan – ‘Implementation’. Officers highlighted that changes here were to update and reflect the new Mayoral CIL2. They also underlined the fact that viability studies were required to be public.


In response to questions, Officers stated that national regulations required that authorities produce an Infrastructure Funding Statement. The Chair reiterated a point that he had made previously at the grand Committee, that it was erroneous that Planning and Transportation were not the spending Committee. He hoped to be able to explore this further as part of the forthcoming Governance Review. 


A Member commented on Paragraph 2 of Policy PC1 – ‘Viability Assessments’ and underlined that it should be for applicants, in all cases, to highlight any exceptional circumstances. Another Member commented that he felt that the original wording used at this paragraph was preferable. Officers undertook to revisit the wording here.


A Member questioned how Officers would ensure that the City Corporation was meeting targets in terms of housing now that the new Housing Minister was talking frequently of penalising those that were not.


Officers reported that one approach going forward could be to allocate housing sites within the City – something that had not been done historically. Members were informed that the Government was due to publish its Housing Delivery Test shortly and, should this highlight any difficulties, this could be an option going forward. Officers highlighted that this would, however, be a long process in itself.  In response to further questions regarding potential penalties, Officers reported that the ultimate penalty could be to remove the planning powers of an authority.


Officers went on to highlight that a particular problem here was short-term market volatility which did not work well for authorities working on medium-term policy.


The Chair requested that the next meeting of this Sub Committee, scheduled for 10 February 2020, should consider options to address this issue and asked officers to look at  what other authorities were doing to address this issue. Officers added that they would also seek to engage colleagues within City Surveyor’s and the London Plan team on this point. The point was made that build to rent could help address this point in terms of meeting targets for the City going forward without ‘sterilising’ the land. Members asked that the report to the next meeting also address this point.

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