Comment

Adoption of Royal Borough of Kensington and Chelsea’s Local Plan

Following Royal Borough of Kensington and Chelsea’s (RBKC) Full Council meeting on 24 July 2024 it was agreed that the boroughs’ updated Local Plan will be adopted, effective immediately.

The New Local Plan Review document will replace RBKC’s current Local Plan (adopted in 2019), though with a number of ‘saved policies’ carried over from the previous plan. Whilst many of the borough’s priorities remain consistent with those set out in the current plan, the new Local Plan seeks to address the borough’s enhanced green ambitions, reaffirm an emphasis on housebuilding and further prioritise employment land, following an updated evidence base which reflects on market changes in response to changing working patterns.

Key takeaways from the new plan are as follows:

Growth Areas

• RBKC places an emphasis on ‘good growth’ by focussing development in new neighbourhoods within Opportunity Areas such as Kensal Canalside and Earl’s Court, designated ‘Employment Zones’, town centres and local centres (all of which are existing spatial designations).

Site Allocations

• Following a Call for Sites exercise in 2022, a new list of site allocations has been included within the plan, in addition to the defined growth areas. Site Allocations are now divided into three sub-categories defined by the size of the site, setting appropriate expectations reflecting RBKC’s view of site capacity. The site allocation categories are: Opportunity Areas, ‘large sites’ of 0.25 Ha or more and ‘small sites’ with capacity for at least five homes.
• A variety of allocated sites are now in place to underpin the delivery of new homes, business space and social and community uses, in line with policy targets.

Housing, Build-to-Rent (BTR) and Co-living

• The new Local Plan provides a response to the 2021 Housing Needs Assessment, with a phased strategy of targeted completions, which assumes comparatively lower housing figures for the first five-year period and a higher level of delivery during years 6-20 but with a peak delivery rate in years 6-10. This responds to modifications required through Examination, which were considered to make the overall plan target more deliverable and achievable, given a recent shortfall in housing delivery. The timeline for the delivery of some of the key strategic sites in the borough is reflected in this phasing of completions. The annual housing targets are as follows:

- Years 1 – 5: 250 p.a.

- Years 6 – 10: 646 p.a.

- Years 11 – 20: 448 p.a.

• A revised approach has been taken to smaller sites, strengthening support for the development of small sites within the policy wording and increasing the level of detail within each small site allocation to guide their development, consistent with an emphasis in the London Plan on small sites.
• The Examiners also required revised policy wording for BTR and Co-living schemes. These tenures had been resisted by RBKC in earlier drafts of the replacement plan. The wording has since been softened to allow such schemes subject to London Plan criteria, and as long as they make ‘positive contribution to the variety and mix of housing products in a scheme’.
• Housing standards have been altered to align with the Nationally Described Space Standards, with all homes expected to meet the minimum standard. At the same time, the policy on amalgamation of units has been strengthened, now restricted to very specific circumstances.

Employment Land

• The new Local Plan is supported by an updated Employment Land Study (2021), confirming that, in spite of post-pandemic changes to working patterns, RBKC will still protect and plan for new employment space (in hand with Article 4 directions already in place). Policy wording has been updated to ensure development provides high-quality office space, to meet a projected demand for 60,500 sq m of additional space by 2043. 

Affordable workspace

• The new Local Plan takes the opportunity provided in the London Plan for borough-level policy to require affordable workspace. A new policy is adopted within the plan, which seeks 10% or more of on-site Class E(g) commercial floorspace as affordable, within Opportunity Areas and for all new developments comprising of over 5,000 sq m elsewhere.

Design and Sustainability

• A new tall buildings policy has been introduced, with two definitions of what constitutes a tall building depending on the site location. Suitable areas for tall buildings are also identified within the policy. Fire safety policy has also been updated, linked to building height and scale of development.
• Sustainability policies have been enhanced – specific policies now indicate that retrofitting of all existing building stock is supported (as long as it does not harm listed buildings or conservation areas) for the purposes of energy conservation and sustainability.
• All developments must consider overheating from the outset, in accordance with the cooling hierarchy in the London Plan.
• Major developments are policy-bound to follow circular economy principles and should aim to be net zero waste (following London Plan standards). Major developments will also require Whole-life Carbon Assessments, and net zero in operation, replicating London Plan requirements.

Turley has an extensive track record within the borough. One notable example includes the recent grant of planning permission for the major redevelopment of Buspace Studios in Kensal. Our relevant experience in the Royal Borough of Kensington and Chelsea ensures we are well-equipped to advise clients in delivering high-quality, sustainable and commercially attractive schemes under the new policy framework. Please reach out to Laurence Brooker, Oliver Jefferson or Jordan Bishop for more information.

26 July 2024