Comment
New Southwark Plan to be adopted
The long awaited New Southwark Plan (NSP) was accepted by the Council Assembly yesterday and will now be formally adopted.
This adoption will mark almost ten years since the last NPPF review of Southwark’s policies in 2013. The ambitious polices that make up the NSP went through several rounds of consultation, including two rounds of consultation at Regulation 19 stage and another round shortly after submission to the Examination in Public. Read our summary on the consultation here. The NSP was finally found sound by Inspectors on 17 November 2021 and then approved by Cabinet on 7 December 2021. On that basis the NSP policies have been applied to all planning applications submitted since 8 December 2021.
The adoption of the NSP is the start of a new era for Southwark and allows them to move forward with confidence to increase housing delivery and economic growth, albeit with some challenging provisions which many of our clients will be aware of. The policies set out within the NSP are ambitious and in some areas push the boundaries of the London Plan, for example their student accommodation Policy P5.
Below, we reflect on its ambitious growth targets and a selection of key new policy positions which in some cases present tensions with the London Plan.
Growth
Southwark is a key central London borough which has seen a lot of growth and development over the past ten years and the plan makes clear that there are still prospects for a significant scale of new development. The NSP sets out targets of 40,035 new homes over the plan period (2,335 per annum), and 58,000 new jobs delivered over 550,000 sq m of office and employment, as well as over 80,000 sq m of retail floorspace delivered primarily within the CAZ and the Borough’s four Opportunity Areas.
The NSP sets out to achieve this growth spatially through a number of Area Visions and a total of 85 site allocations across the Borough. The scale of this approach is likely to be welcomed by a number of investors as they will help provide greater certainty on land use and scale. This will be key to ensuring that these allocations successfully guide development and provide the flexibility on elements that the site allocations specify ‘must’ and ‘should’ be delivered, and importantly remain a ‘guide’. Where site allocations are overly prescriptive or limiting in terms of fundamentals such as land use, there will be a need to press for flexible application of policy to allow for commercially deliverable schemes.
Carbon reduction
Following Southwark’s announcement of a Climate Emergency in March 2019, carbon reduction has remained high on Southwark’s agenda with the plan targeting carbon net zero by 2050. The NSP sets requirements significantly in excess of the London Plan by specifically requiring all major developments achieve 100% of carbon reductions over Building Regulations 2013 on-site, (compared to the minimum of 35% required by the London Plan). It notes that offsite provision or a financial contribution for shortfall, should only be used in exceptional circumstances. How Southwark will apply judgement of ‘exceptional circumstances’ will be a critical issue and require expert advocacy.
Affordable housing
The NSP requires a viability appraisal for all housing development but sets out a Fast Track Route where this would not be required. It notes that this route should only be followed in ‘exceptional circumstances’ and sets a higher threshold than the London Plan, requiring 40% ‘affordable’ housing with no grant subsidy (60% required in the Aylesbury Action Area Core), as well as requiring a policy compliant tenure split of a minimum of 25% social rented and a minimum of 10% intermediate housing. This specifically notes that all policy compliant development must provide social rented tenures with other ‘affordable rented’ products such as London Affordable Rent, Affordable Rent and Discount Market Rent, not considered to be affordable products that the council will accept.
Build-to–Rent (BTR) / private rent
Following the London Plan’s publication of a specific BTR policy over 50 units, the NSP includes a specific policy for development of Private Rented Homes over 100 units. In addition to the higher threshold (for the provision of Discounted Market Rent homes) other key deviations from the London Plan include:
- a requirement for a 30 year covenant with clawback mechanism which is double that of the 15 years required by the London Plan; and
- a requirement for a minimum of 15% social rent equivalent units (within the 35% minimum total affordable) with the remainder of affordable rents capped at London Living Rent levels.
Agreeing the tenure split with the Borough will be necessary under the terms of the London Plan Fast Track. Southwark policy also refers to nominations from both social and intermediate tenure housing lists.
Student accommodation
Whilst the London Plan requires the majority of student bedrooms within a purpose built student accommodation scheme to be secured by a nominations agreement with a higher education institution (with 35% to be nominated and at affordable student rents), the NSP policy sets out two potential routes; either via nominations or via Direct Let. Both routes have a varying emphasis on affordable rents and on the provision of conventional affordable housing in both routes. Southwark have been supportive of both routes while the policy has been in a draft state and this official adoption of the plan now affords full weight to this policy. We will continue to engage with the council on the application of policy on a site-specific basis on behalf of our clients, including with regards to GLA referable Direct Let schemes and the nominations requirement within the now adopted London Plan.
Tall buildings
The approach to tall buildings follows a spatial hierarchy approach, with tall building areas shown on the policy map and typically within Major Town Centres, Opportunity Area Cores, Action Area Cores and the Central Activities Zone. Individual sites where taller buildings may be appropriate have also been identified in the site allocations.
The NSP sets a definition of a tall building as only being those above 30m (except in Thames Special Policy area). This reflects the approach of the old London Plan and Mayor of London referral criteria and is a significantly higher threshold than the London Plan minimum of 6-storeys or 18m, signifying a taller local townscape context across specific areas within Southwark deemed appropriate for taller buildings.
If you would like to discuss the NSP or development opportunities within Southwark, please get in touch with Alice Hawkins or Cat Fraser.
24 February 2022
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