Following the publication of the recent draft Industrial Land and Uses London Plan Guidance (LPG), we share some thoughts on the specific points relating to intensification and co-location schemes in London.
INTENSIFICATION & CO-LOCATION
Section 4 of the LPG aims to provide further guidance to support the application of London Plan Policy E7, which relates to industrial intensification and its co-location with other uses, as part of wider mixed-use developments.
For context, London Plan Policy E7 provides a strategic framework and a policy approach for implementation, but also a clear objective to intensify existing industrial uses alongside other uses, such as residential accommodation. Given the importance of maximising housing delivery, including the provision of affordable housing, the need for new homes is undisputable, and alternative solutions need to be found to provide the housing need set out in the London Plan (a ten-year target of 522,870 new homes), with many LPAs in London struggling to meet individual delivery targets.
In most instances, the reinforcement of support for co-location and intensification should be welcomed, and the LPG suggests a plan-led approach to considering co-location opportunities. This will assist with identifying areas where this is capable of being achieved without having a detrimental impact on the purpose and successful operation of the existing industrial function through the introduction of sensitive uses.
The fundamental issue remains in terms of the potential for conflict between residential amenities and operational requirements of industrial space (especially where 24/7 industrial activity is non-negotiable), which will require careful technical and design mitigation to ensure an appropriate environment is achieved. This is something which can be achieved but will require appropriate expertise in order to be successful. Linked to this is the deliverability of industrial floorspace in a co-location scenario, with options for yard consolidation or multi-level accommodation to create the space required for non-residential uses alongside industrial uses, often unviable or unattractive to industrial occupiers, for a wider range of reasons.
Whilst the use of a plan-led approach is admirable, it remains to be seen if this is most appropriate in practice. Not least because of the length of time it can take to introduce new Development Plan documents, along with the inherent risk of the planning system and the need to respond swiftly in the face of changing market conditions, especially as commercial space needs to be designed with the flexibility to ensure it is future-proofed.
This approach could have unforeseen implications on the delivery of both industrial uses and its co-location with other uses, especially where co-location schemes are relied upon to assist the delivery of other policy objectives. Similarly, development viability needs to be considered from the outset due to the increased structural and mitigation requirements needed to ensure the co-location of uses is technically sound. Market conditions will fluctuate over the lifetime of the plan period, and it could potentially compromise the ability to deliver such developments.
Another consideration is the level of technical expertise required to ensure projects are deliverable. This has the potential to impact on planning timescales due to the level of technical assessment required. This also poses the question as to whether wider Development Plan policies are structured in a way that allows for appropriate application to developments that co-locate contrasting uses.
This has the potential to impact the development pipeline, and in order to meet the ambitions of the London Plan and the LPG, LPAs may have to compromise on some wider policy objectives to be able to positively and creatively consider planning applications that promote co-location.
Section 5 of the LPG sets guidelines for proposals such as transport, environment and amenity, and industrial-specific design considerations.
Whilst some guidelines seek to establish general principles, others provide technical details of the requirements to be applied by developers, applicants, and LPAs. On the face of it, this should be welcomed, but it will be important to ensure a balance can be found between designing-in flexibility to ensure that the commercial space can be used by a range of industrial occupiers vs providing as much certainty as possible on the use, to give confidence to a residential market that is perhaps already unsure of the co-location concept.
Whilst the LPG acknowledges that the design advice cannot be applied mechanistically, it does not address how proposals that don’t fit within the representative model typologies are to be approached and assessed.
With developers facing competing pressures, the lack of guidance regarding how some typologies are to be approached could put them at risk, with LPAs left to determine what constitutes another typology and when divergence from the LPG will be accepted.
Paragraph 5.3.7 makes a series of design recommendations in respect of co-location schemes; however, it’s likely that in the vast majority, these have already been adopted. That said, the reference to LPAs seeking industrial expertise as part of the Design Review Process is welcomed to seek to ensure that these reviews are informed and cognisant of the competing demands that co-location schemes present.
The LPG presents many positives, particularly in terms of its guidance towards LPAs appropriately assessing industrial supply and demand for the full range of industrial typologies, along with clear support and guidance for bringing forward intensification and co-location schemes. 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.
Furthermore, it is worth considering the timing of the LPG – is this an admission that the current London Plan co-location policy is failing to have the desired effect? And with this in mind, does it actually provide any greater flexibility? Or is it simply another initiative to be seen to be promoting housing delivery, particularly in the run-up to regional and national elections and pressure from the Central Government in relation to past delivery? As such, the reiterated support for co-location schemes that arguably doesn’t go far beyond the content of the London Plan, could be seen to be the latter.
Together with our industrial colleagues, we have prepared a more detailed review of the LPG, which can be found here.