Following this week’s Q&A session on the public consultation draft of the Industrial Land and Uses London Plan Guidance (LPG) hosted by the Greater London Authority, we wanted to share some of our thoughts.

DRAFT LPG'S FOCUS ON IMPORTANCE OF INDUSTRIAL LAND IN LONDON

Acknowledging the competing demands on land availability in London, with increasing pressure to deliver sufficient industrial capacity to support the capital’s economy and meet local housing needs, the aim of the draft LPG is to support the application of the London Plan policies (notably Policies E4 and E7) to ensure that sufficient industrial space that is fit-for-purpose is planned for. Industrial uses are defined within the LPG to include a range of Class B2, B8, and specific Sui Generis uses, in addition to some Class E uses (E(g)(ii) and E(g)(iii)). The term ‘industrial’ is, therefore, used to describe the sector broadly (i.e. from manufacturing to logistics to data centres etc.). Importantly, the LPG identifies the need for Local Planning Authorities (LPAs) to appropriately consider, and plan for, the wide range of different industrial sectors, noting the different operational needs of contrasting industrial uses (such as data centres and logistics), and recognising that a ‘one-size-fits-all’ approach cannot be taken. The suggestion that LPAs supplement their evidence-based studies with up-to-date market intelligence should be seen positively – encouraging a level of commerciality that should, theoretically, ensure that local needs are truly captured.  

ALIGNING WITH CLASS E AND DESIGN GUIDELINES

The LPG recognises that the adopted London Plan does not explicitly align with the current Class E requirements and acknowledges the opportunities presented, with the potential for some industrial operations to now take place within previously non-industrial Class E premises, including in town centres. However, it is also mindful of its challenges – notably the ability to change between Class E uses without restrictions, as well as to residential through permitted development – which has the potential to undermine the supply of industrial floorspace. The LPG’s recommendation for LPAs to take a clear approach to its application of Class E and, where appropriate, consider how the capacity of industrial floorspace can be protected in the long-term (through, inter alia, allocations, planning conditions, Article 4 Directions etc.) should be considered in order to minimise the impact on supply. 

A key focus of the LPG is to support the application of London Plan Policy E7, which relates to industrial intensification and co-location. The LPG asserts that intensification and co-location could improve land use efficiency and, in the right location, support an LPA’s strategy for industrial capacity whilst also maximising the potential for much-needed housing delivery. The LPG emphasises the London Plan requirement for a strategic, plan-led, or master-planned approach to the co-location of uses, which is admirable but not without its challenges – particularly when considering the time that it takes to adopt new Development Plan documents. More fundamentally, the challenge remains of the potential conflict between residential amenities and operational requirements of industrial space (especially where 24/7 activity is non-negotiable), which may require site-specific technical and design mitigation to ensure an appropriate environment is achieved. Furthermore, the deliverability of industrial floorspace is often compromised in the co-location scenario, with options for yard consolidation or multi-level development to create the space for non-residential uses alongside industrial uses often unviable to occupiers. Our residential colleagues have undertaken their own review of the draft LPG and will be providing their thoughts on how the proposed guidance for bringing forward intensification and co-location could support housing delivery in London. 

Finally, the LPG seeks to establish industrial-specific design guidelines for development, relating to things such as yard space, structural grids and floor-to-ceiling heights, which appear overly prescriptive. Whilst the LPG notes that only some industrial typologies are covered, for which the design advice will apply, it does not consider how proposals that do not fit within the representative model typologies are to be approached and assessed, both by applicants and LPAs. I took the opportunity to raise this matter with the GLA’s Principal Strategic Planner, Jorn Peters, during the Q&A. Whilst he confirmed that the design guidelines are intended to support those less familiar with the technical requirements of industrial schemes, and reinforced that the guidelines should not be seen as a constraint to innovation, flexibility or bespoke solutions, or override technical expertise that dictates otherwise, he did agree that this position perhaps needs to be strengthened in the wording of the draft LPG. With developers and applicants facing ever-growing competing pressures, including the need to balance operational and market demands, site optimisation and the requirement for meaningful landscaping, urban greening and biodiversity net gain, providing further detail and clarity regarding how the design guidelines are to be interpreted within the LPG will be essential to ensure that developers are not put at risk, with LPAs left to determine when divergence from the LPG will be accepted on a case-by-case basis.  

SUMMARISING REMARKS

In conclusion, the draft LPG presents many positives, particularly in terms of its guidance towards appropriately assessing industrial supply and demand for the full range of industrial typologies. However, there are areas that lack detail and a commercial appreciation of the genuine requirements of industrial operators, both in a standalone and mixed-use context. The guidance has the potential to impact how the industrial and logistics market and developments evolve in London, and we would encourage industrial developers and operators to engage with the consultation process. The consultation closes on 28 February 2024. 

Together with our residential colleagues, we have prepared a more detailed review of the draft LPG, which will be posted next week. Should you require any further information or wish to discuss, please do not hesitate to contact Harriet Humphrey, Kirill Malkin or Craig Blatchford.