Greening London’s Grey

Written by Jenny Massingham, Technical Director

On Tuesday 1 May 2018, my colleague Mark Furlonger and I were invited to present at an event kindly hosted by MDR Associates in association with the RIBA South East London Architects group, on the emerging New London Plan. Central to the Plan is the concept of “Good Growth” –  growth that is socially and economically inclusive and environmentally sustainable. Our presentation focused on policies relating to optimising housing density and urban greening, and how they can contribute to Good Growth. Though the Plan is not due to be adopted until winter 2019/20, its approach is still relevant in determining planning applications and it will carry ever increasing weight, so we also set out ways in which both architects and planners can manage the delivery of new schemes during this transitional period.

What is the status of the New London Plan?

Following on from an informal consultation in winter 2016, the New London Plan was subject to a formal consultation in December 2017 which finished on 2 March 2018. The next stage of the process for the Plan is an Examination in Public (EiP) where an independent panel will review the comments received during the consultation and produce a report recommending any changes to the Plan for the Mayor’s consideration. The New London Plan is expected to be published in winter 2019/2020, but the emerging policies are already useful and can be given some weight in the determination of current planning applications and the design of new schemes. Although the policies themselves are emerging, the overarching political and planning agenda on fostering economic development, climate change adaption and the unavoidable issue of the housing crisis are unlikely to disappear anytime soon.

Optimising housing density in London

This brings me on to our first area of interest. The changes to policies on housing density (Policy D6) seek to optimise housing density using a design-led approach to determine the capacity of a site based on the existing context, its connectivity (walking, cycling, public transport) and the capacity of surrounding infrastructure, in order to make the most efficient use of land. Minimum room standards have also been developed to ensure that new dwellings have adequately sized rooms which are convenient and efficiently laid out. Following on from the principle of sustainable development, higher densities are also encouraged close to town centres, transport links and on growth corridors including the Elizabeth Line West, Bakerloo Line extension and Crossrail 2. Good transport links encourages the use of more sustainable transport methods thus sites require less car parking spaces. New proposals are expected to double the existing provision for cycle parking which will help to encourage healthier lifestyles and of course reduce carbon emissions. Importantly, sites that do not optimise density will be refused planning permission.

So, surely if we increase densities we will also increase the demands on infrastructure as well as developers given that a higher number of units may increase viability. There are clearly benefits to increasing housing densities, not least that it is a proactive response to the housing crisis and in particular the issue of affordability for Londoners. Policy D6 would help to promote sustainable urban living and economic growth, as well as the regeneration of neighbourhoods or buildings but consequentially there are a number of impacts as we build at higher densities. For example, high volumes of high density can create microclimates such as wind tunnels which may affect the connectivity of a site – one of the determining factors of a site’s capacity. How would an increase in high density affect the aspect for those residents, as well as their access to sunlight and daylight? Furthermore, as we continue to build on London’s limited land supply, will we see a loss in open green space? Not necessarily.

Research from London First indicate that London has an average of 138 people per hectare whilst in comparison Paris has 213 people per hectare with Madrid being significantly higher at 286 people per hectare. On that basis, one might assume that the percentage of green space within those cities decreases with the increasing population. However, figures from the World Cities Culture Forum suggest that in fact Madrid has the greatest proportion of public open space at 45% with Paris having just 10% and London 33% which comes as a result of a series of initiatives using nature to address Madrid’s rising summer temperatures. So where is the link between housing density and urban greening?

Greening London’s grey

About 18 months ago, the Temple and Green Infrastructure Consultancy, were asked by the Greater London Authority (GLA) to assess the potential for an urban greening factor for London. Looking at cities with existing urban greening policies including Berlin, Helsinki and Seattle and undertaking our own research, we presented a series of issues and recommendations on the merits of an urban greening factor for London which was published in July 2017. The urban greening factor establishes a target score for a development to achieve and attributes an individual point system to various landscaping elements such as trees, green roofs and permeable paving to achieve the score. The urban greening factor is not about protecting existing assets, but is  about ensuring new development provides suitable levels of green infrastructure which can be tailored to local circumstances by each of the London Planning Authorities. For example, authorities with lower levels of tree cover can award more points for the planting of trees, or where drainage is an issue, emphasis can be placed on rainwater gardens and SuDs.

There are inevitably concerns about the consequential impacts of emerging policy with one being that if developers take a rigid interpretation of Policy G5, and in isolation from other policy, will we see developments that meet the target score only and look to achieve nothing more. This will discourage the provision of other spaces not required by threshold-based policies such as private or communal amenity space. Moreover, the urban greening factor does not measure the quality of the design, only the quantum and as 2D calculations, there is a risk that there could be insufficient provision of urban greening around tall buildings that have a small ground level curtilage. But the urban greening factor is just one of a number of policies governing development in London and will be assessed in the context of other applicable policies including those on design. Moreover, the urban greening factor can bring about some positive changes. Through early engagement with your planning authority, the urban greening factor can bring greater certainty and prevent last minute Conditions or Planning Obligations that delay the grant of permission and construction. It is also a simple, flexible and cost-effective process which  does not need to be based on surveys, calculations and reports evaluated by qualified persons, and can also be applied to entire planning zones or neighbourhoods.

Managing projects during the transitional stages of the New London Plan

So, given that the policies of the New London Plan are still emerging but do carry some weight, how do we manage this over the next 18 months? Here are some of our recommendations:

• As Planners we would recommend that a good place to start is engaging with the planning authority and undertaking pre-application discussions. We recommend giving the local authority as much information as you can, including your justifications for the site design as this will help to progress discussions;
• Challenge any onerous questions, if it sounds completely unreasonable, it might be a misinterpretation or simple misreading – the policies are new for us all!
• Use Planning Performance Agreements to help set a programme with the LPA, the fee will also help provide them with additional financial resources to deal with your application efficiently;
• Don’t shy away from emerging policies and trends: be a pioneer, set the standard and tell your clients, consultants and other Officers what you have achieved;
• Planning authorities gather lots of background evidence for infrastructure capacity and delivery, use their evidence, where it’s sound, for the basis of your designs and justifications;
• Think about phasing your development. If your development is contingent on infrastructure coming forward, work with the planning authority and infrastructure providers to agree a strategy; and
• Consider using Masterplans or strategic frameworks especially for larger sites. Front loading of the design will pay dividends in your negotiations with the planning authority and in showing the efficient use of land and promotion of good growth.

As we established, the New London Plan is underpinned by the concept of Good Growth including six core policies that represent the overarching objectives of the New London Plan which should be taken into account for all planning and development in London. The Plan seeks to build thousands of affordable homes whilst creating an inclusive, greener, safer city and this is where taking a design-led approach to optimising the capacity for housing density and greening comes into play – or as we like to call it, Greening London’s Grey.

Surely as Londoners, even if its only from Monday to Friday, Good Growth would be good for all of us and therefore we should support it and promote it in our professional work as much as possible.