Comment

London Plan: A new industrial and housing revolution?

It’s been just over three weeks since the Publication Version of the London Plan was sent to the Secretary of State (SoS), who has only two weeks left to respond before the Mayor intends to adopt this version of the plan. The latest iteration has brought significant changes to previous versions, most notably to the industrial policies.

See our recent article for further information on the broader changes.

The industrial policies of the draft new London Plan have arguably ‘been through the mill’ since the first version of the plan published back in 2017. The policies are working hard to ensure that designated industrial sites remain the main reservoir of land for industrial, logistics and employment functions across London. Whilst also recognising, where appropriate, that such sites/land can play a key role in contributing to the city’s much needed housing supply. This is notwithstanding the Government’s recent announcements on the new standardised methodology for calculating housing need which will likely place even further pressure on the capital to deliver additional housing (see our latest article).

Going back to 2017, the industrial policies set out a clear framework that for any proposed release of industrial land there would be a requirement to ensure a ‘no net loss’ of industrial capacity position. This requirement followed through every version of the plan, until March 2020, when the SoS made directions to the Intend to Publish version (ItP) which saw the requirement to remove this position. The main reasoning behind this change was the requirement to be ‘realistic’ and to ensure that the policy could be effective in its application. The SoS insinuated that should this position not change in policy, appropriate release of industrial land for much needed housing development could be stifled.

Whilst the emphasis of the amendments continues to encourage boroughs to ‘provide’ industrial land and uses, the removal of the ‘no net loss’ principle offers boroughs greater flexibility in managing their industrial land. To supplement this, the SoS’s directions also encourage boroughs to give further consideration to releasing industrial land for alternative uses where vacancy rates are higher. This introduces further flexibility, subtly shifting the management of such sites towards an approach influenced more significantly by market conditions.

These amendments are complemented by the most recent direction from the SoS at the end of last year which saw an encouragement in the supporting text to Policy E4 for boroughs to consider the re-allocation of industrial land for alternative uses in exceptional circumstances, instead of considering the release of Green Belt or Metropolitan Open Land. These have all been accepted by the Mayor and inserted in to the Publication draft.

The fundamental changes to the sentiment of the industrial policies sees a clear shift for boroughs to think differently about their industrial land and to ensure that, of course, industrial functions are retained but where appropriate, and through a clear and co-ordinated masterplan or plan-led approach, other non-industrial uses could be introduced to such areas to optimise use of land in the capital.

The changes show opportunity and potential for London to reinvigorate its industrial capacity, whilst linking to the Government’s mandate of making effective use of under-used land. It could see innovative design-led approaches to industrial development, which could deliver a range of modern intensified industrial and employment uses housed within potentially multi-storey buildings. Perhaps more excitingly, the policy offers the scope, where appropriate, for designers to go one step further and create places and buildings where a more innovate mix of uses is delivered; co-locating industrial uses with other non-industrial uses such as new homes, offices and other town centre uses.

As we look forward to a post-pandemic economic recovery, there is now genuine scope for borough’s to support truly mixed-use places where people can live and work. How this plays out in practice across the capital could present a variety of exciting opportunities for boroughs, developers, investors and designers alike through the Local Plan process, albeit the challenge will be to ensure that industrial land still plays the role and fulfils the legacy it has been allocated for.

Please contact Catriona Fraser for more information.

19 January 2021