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What to take from the GLA’s draft co-living London Planning Guidance?

After a long period of ‘will they, won’t they’, the GLA has now published draft London Plan Guidance on Large-Scale Purpose-Built Shared Living (otherwise known as co-living or LSPBSL) for public consultation. The deadline for comments is the 27 March 2022.

The guidance has been prepared to provide information on how to apply the London Plan Policy H16, and is considered necessary by the GLA to fill a standards vacuum for this housing product.

The draft guidance starts by clarifying what is understood to be ‘LSPBSL’ (sui generis) in the London context, which notably is done by comparing it to other forms of housing and confirming it is not:

  • standard residential C3 as the product is for non-self contained dwellings with an emphasis on communal living;
  • a house in multiple occupation (HMO) (use class C4 or sui generis) due to the size of the developments and extent of communal spaces and facilities;
  • a hotel (use class C1) or hostel (sui generis) due to the requirement for minimum three month tenancies; or
  • a residential institution (use class C2) as there is no significant element of care or training provided.

Other than reiterating points of adopted Policy H16, the real highlight of the draft Guidance is its position on standards for LSPBSL. A summary of some of the key requirements are provided in the table below.

Greater London Authority Co-Living Table

In terms of private units, the guidance even goes as far as stipulating the required internal furnishings and facilities. These must include a double bed, bedside cabinet, wardrobe, desk, seating area, bathroom, small kitchenette for convenience food, sink and draining tray space, and mini-fridge.

In our ongoing review of both GLA and non-GLA referable co-living schemes across Greater London, we note that most GLA referable schemes would be considered compliant with the standards for rooms and unit sizes in this draft guidance. Many, however, would not be considered to comply with the communal amenity requirements in terms of floorspace quantum and distribution of the space.

Conversely, whilst the non GLA referable schemes often fall short of the minimum unit size requirement, with c.16sqm rooms often being popular - a high number do provide above average quantums of amenity space per unit that would meet these requirements.

Nevertheless, it remains clear that the majority of schemes across London submitted or permitted to date would unlikely comply fully with the standards set out in this new draft guidance.

The published draft guidance follows a growing movement towards policies and guidance being put in place by local authorities across the country. In London, LB Lambeth and LB Croydon are examples where specific LSPBSL policies have been prepared, and elsewhere in the country the likes of Bristol and Leeds are likely to follow suit. No doubt other authorities will look to the GLA’s draft published guidance with interest. 

For some, this will be seen as a positive; providing clear rules of play for planning applications to follow and hopefully streamlining the planning process (particularly for those that are GLA referable). For others, this is potentially a heavy handed move that could hinder the evolution of what is a still a relatively new housing product for the UK.

For developers and operators, the opportunity must be taken now to engage in the London planning guidance consultation process to help inform the standards for LSPBSL going forward.

For further information please contact Freya Turtle or Alice Hawkins. 

28 January 2022

 

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