Planning matters

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Life after UNESCO: Liverpool’s Approach to Heritage
Liverpool’s historic waterfront is one of the most recognisable in the world. Once a powerhouse of global trade, its docks and warehouses are steeped in industrial and maritime heritage. The City is second only to London in the number of Grade I listed buildings it contains. But it is also a place that continues to evolve, and in recent years, not without tension. The loss of Liverpool’s World Heritage Site status in 2021 was a high-profile moment, raising questions about how cities manage growth in a heritage context.
 In the years since, there has been a noticeable uptick in urban development activity - from residential-led schemes in the Baltic Triangle, to holistic masterplanning of the North Docks, and, most recently, proposals for the city’s tallest building at King Edward Triangle. Liverpool City Council has responded with a renewed focus on how best to understand, protect and shape its historic environment. The draft Historic Environment Supplementary Planning Document (SPD), now out for consultation, is a key part of that response. It provides detailed guidance on how the city’s planning policies should be applied to developments affecting heritage assets, helping applicants and decision-makers navigate what can often be seen as a complex part of the planning process.
While many of its core messages reflect established national and local policy, the SPD stands out for its broad scope, and its level of practical detail on issues that regularly arise in heritage decision-making. It embraces the current direction of travel for the sector in terms of climate adaptation and retrofit.
For developers or owners of heritage buildings, or for authorities facing similar pressures around change in historic places, Liverpool’s SPD is likely to be of interest.

 

A clear and comprehensive framework
The SPD brings together a wide range of planning policy, legislation, guidance and good practice into a single accessible framework. It advocates all the core principles you would expect; early engagement, establishing an understanding of significance, and using this to shape a contextually appropriate design response.
However, it provides a level of detail that goes beyond broad policy interpretation. It also includes a characterisation of different parts of the city, providing context for understanding how Liverpool’s historic areas have developed over time.
It covers all types of heritage asset, including non-designated assets, and provides detailed practical advice on matters such as shopfront design, often the subject of their own separate SPD.

 

Clarity on specific development scenarios
This is a real strength of the document. It goes further than most historic environment SPDs, by providing detailed, practical guidance on a wide range of common development alterations. These include extensions, window replacements, rooftop alterations, boundary treatments, shopfront changes, and public realm schemes. It sets out clear expectations for what is likely to be supported and when listed building consent is required. 
The detailed guidance on what is likely to be acceptable, and the thresholds for listed building consent, should give applicants greater certainty and improve the quality of submissions. The result, in theory, should be more predictable outcomes and a smoother planning process. Whilst similar guidance has been provided by authorities in other jurisdictions, this has occasionally proved too prescriptive. Liverpool's approach appears to strike a better balance, offering clear expectations without being overly rigid.

 

Responding to climate change in historic places
The SPD also addresses climate resilience, sustainability and energy efficiency, embracing Historic England’s recent guidance[1] on retrofitting historic buildings. It provides detailed guidance on interventions such as breathable insulation, secondary glazing, double glazing, heat pumps, solar panels and microgeneration, setting out the circumstances in which these are likely to be appropriate.
 It is encouraging to see the SPD align with this guidance, which in some regards can be seen as quite a progressive stance. This will be particularly important as pressure increases for existing buildings to meet higher environmental standards.

 

Part of a wider toolkit
Although this SPD serves as a city-wide document, it also sits alongside other emerging tools, including the separate draft Waterfront Historic Environment and Design SPD. Taken together, these tools reflect a coordinated and proactive approach to heritage-led planning across Liverpool, providing a foundation for managing change.

 

Final reflections
The draft Historic Environment SPD offers a useful and detailed guide to managing change across Liverpool’s historic environment.
While many of its principles will be familiar to heritage professionals, the way in which the document brings these issues together in one place, particularly its focus on everyday development pressures, makes it a worthwhile reference. It is also notable for its integration of current thinking on sustainability and climate adaptation.
In the context of Liverpool’s loss of World Heritage Site status, the SPD can be seen as a constructive and practical step in reaffirming how the city manages and communicates the value of its historic environment.
For other authorities, the SPD may offer a model for how heritage guidance can be made more accessible and tailored to common issues. For those working in Liverpool, it is a document worth becoming familiar with as it will become a material consideration in planning decisions.
If you would like to comment on the document, the consultation runs until 3rd September 2025. If you are a working with historic buildings in the city and require more tailored, project-specific heritage advice, then please get in touch.
Lichfields has a dedicated team of heritage specialists who appraise historic buildings and places of all periods and condition. We successfully manage change to heritage assets through consideration of their heritage significance and impacts on setting. Our experience encompasses work locally in Liverpool, and nationally on World Heritage Sites, Listed Buildings, Conservation Areas, Scheduled Monuments, Registered Parks and Gardens and Archaeology.
 

 

Footnote
Image credit: Chris Porter from Unsplash

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Reforms to Infrastructure Planning: Insights from the NIPA Annual Conference
At a time of significant proposed changes to infrastructure planning, I was fortunate to attend the National Infrastructure Planning Association (NIPA) Annual Conference on Monday this week. With the Government’s recent announcement of mandatory Biodiversity Net Gain (BNG) for NSIPs from April 2026, and the second reading of the Planning and Infrastructure Bill in the House of Lords now complete, the Conference was a timely opportunity to hear a range of views on these changes. The key question is whether they go far enough to encourage the industry to promote more NSIPs, to enable the Government to meet its ambitious target of making 150 major infrastructure project decisions in this Parliament.
With further guidance promised and consultation on BNG ongoing (The Government’s BNG consultations explained (and why you should care)), this blog sets out key issues and takes a reading of the industry’s response.

 

Implementing DCOs post-consent
Key to the utility of any DCO is its future compatibility with updated technology, and there is increasing recognition of the benefits of using the ‘Rochdale Envelope’ to build in flexibility to a DCO. However, the rapid pace of technological advancement seems to be increasingly incompatible with the current DCO process. It was noted that a high proportion of consented DCOs are now incompatible with the latest technology, meaning many consented projects may not be built at all, or will require a post-consent change application to incorporate updated technology. 
 
The Planning and Infrastructure Bill removes the distinction between non-material and material changes post-consent to streamline this process. This is a welcome amendment that will help to ensure that major infrastructure projects can be built to optimal design.
 
One of the most interesting sessions for me was the talk by Ed McCann of Expedition Engineering on ‘Fit for purpose consents’ looked at key issues in project delivery. As Planners, we are not often involved in the ongoing implementation of major projects, but restrictions agreed to as part of the consent (for example construction working hours) can have severe cost and time implications, undermining project deliverability. Costing impacts must be fully interrogated at the consent stage, and we can hope that a simplified process for post-consent changes may also assist in this area.
 
Another issue requiring a strategic view relates to the use of the Rochdale Envelope. Whilst many developers are making use of opportunities for design optimisation post-consent, protracted pre-application timescales and delayed decisions often see this activity curtailed. It is hoped that time savings through reforms will re-establish opportunities for this refinement.

 

Consultation
Changes to DCO consultation requirements was another key topic of the day. One key message from NIPA’s engagement with members was the need for consultation to focus on outcomes, as a proportionate exercise that is meaningful, open and transparent. This feedback was complemented by the case law update session, with a talk given by Daniel Kozelko on discarded alternatives during consultation. Drawing on case law including Mosely v LB Haringey (2014) and R (Possible (The 10:10 Foundation)) v SST (2025), Kozelko recommended that alternatives should be set out during consultation, relevant to the scope of the consultation. It is best practice to include brief commentary on arguable alternatives, setting out why they were rejected or considered non-viable.
 
Currently, it has been suggested that many developers are ‘gold plating’ consultation to avoid the risk of judicial review. Future guidance must establish clear requirements so that this does not carry over. Clarity on alternatives would be a welcome addition to this guidance, and confirmation of the applicability of these changes to post-consent change applications should also be included.

 

Biodiversity Net Gain for NSIPs
Biodiversity Net Gain (BNG) is set to apply to NSIPs from May 2026. I attended the workshop run by DEFRA on the Government’s ongoing consultation and heard views from delegates on the proposals.
 
The government proposes using the Order Limits to calculate the baseline BNG value and has suggested that it should apply to all NSIP types. Numerous participants raised the significant implications of this for linear projects, especially above ground or underground installations where there would be limited impacts to most of the land, and where wide lateral parameters are often used.
 
It was suggested that a maximum construction footprint should be used in the initial calculation, and the government’s proposal to enable later re-calculations was welcomed. The government is set to produce further guidance on BNG calculations to account for the use of parameters and design flexibility, which will be especially important in light of the increasing need for flexibility.
 
Further details of the consultation can be found on Lichfields’ blog: The Government's BNG consultations explained (and why you should care). The consultation is running until 24th July 2025.
Key takeaways
The government’s recognition of the essential nature of major infrastructure projects to the UK’s growth strategy via the Planning and Infrastructure Bill has brought optimism to the industry, but also a high degree of uncertainty. The industry is keenly awaiting clear guidance on updated consultation requirements, and whilst there is support across the sector for the introduction of BNG for NSIPs, this is tempered by concern that a rigid application of the requirement will undermine project deliverability.
 
DCOs establish essential design flexibility which is of increasing importance in the context of rapid technological advancement. The compatibility of BNG with this process is yet to be confirmed. In this same vein, whilst there was little discussion of the proposed amendments to the post-consent change process, it is clear that this will contribute to better project outcomes: enabling the process to keep pace with technology, rescuing undeliverable projects, and opening up more avenues for post-consent design optimisation.
 
There is reason for optimism. The government is listening to the industry, and if recommendations are taken on board, it is hoped that the package of reforms currently underway will help to improve efficiency, flexibility, and proportionality in the DCO consenting process.

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The 77th Housing Design Awards 2025

Charlotte Walker 02 Jul 2025
This Spring the Housing Design Awards judges visited 22 completed housing schemes travelling 1266 miles each, over five days of visits in England.
They saw uplifting design excellence in a range of schemes, from moderate to high density, including suburban, urban, and rural sites.  They saw the best of housing for refugees, affordable homes, co-housing, student housing and homes for the more fortunate in later life.  They saw sites ranging from 8 homes to over 500, delivered by a variety of design teams including those starting out in their careers to well-known multi-disciplined practices commissioned by small scale and large-scale housebuilders, local authorities, charities, and community-led clients.
Amongst these schemes were a number of local authority-led projects focused on providing 100% affordable housing. This blog provides some personal views on the design lessons and potential replicability of some of the shortlisted projects, including a number of high quality local authority-led projects focused on providing 100% affordable housing we want to highlight.

 

Kidbrooke Park Road
The first phase of Kidbrooke Park Road is complete providing 117 high quality affordable homes across four distinctive blocks for the Royal Borough of Greenwich, along with an onsite nursery, community space and associated public realm.

 

Lessons in design quality
High quality accommodation: the scheme sets a high standard for affordable housing in the Borough. The schemes’ central block (‘Block B’) is comprised of 20 dual-aspect family units with private amenity spaces across four levels of maisonettes and family sized flats on the top floor. These homes overlook two shared amenity spaces to the rear and front of the building: the ‘Green’ is dedicated to play spaces for younger children (0-4 year olds and 5-11 year olds) and the ‘Communal Garden’ designed with play spaces for older children and informal spaces for adults. The bottom tier of maisonettes in Block B have their front doors facing the Green. These enclosed and surveyed amenity spaces are framed by the attractive brick-dominated facades of the building, articulated with arches and recessed balconies to reflect its central location and to amplify the sense of arrival to the site.

 

Highgate Newtown Community Partners
The site is located at 25 Bertram Street, London, within the Dartmouth Park Conservation Area, Camden. Completed in 2024, the Council-led scheme forms part of the Community Investment Programme (CIP) and includes the provision of 41 homes, 7 of which are affordable, public realm improvements, new routes through the site and the reprovision of the existing Highgate Newtown Community Centre (HNCC) and Fresh Youth Academy (FYA) community facilities.

 

Lessons in design quality
Community and residential interfaces: The right of way, linking Croftdown Road and the rear of Bertram Street was diverted, widened and improved as part of the scheme to provide a more attractive route through the centre of the site and across the public courtyard. A key benefit is the improved safety and security for properties to the west of the site as the rerouting of pedestrians through the public courtyard now allows for rear gardens to directly face adjacent rear gardens. Activity is directed past the accessible ground-level community building entrances, creating a more dynamic interface between the community building and enhanced public realm.
 
  
Bulrush Court
Completed in 2024 as part of a wider regeneration project, Bulrush Court in Bromley-by-Bow, London, is a seven to nine-storey mansion block offering 114 affordable homes. The 1930s style mansion block is U-shaped in footprint and features curve-cornered balconies.
 
Lessons in design quality
Designing a mansion block typology to create high density, viable, human scale development: the enclosed and generously sized communal courtyard with play spaces creates a human scale and welcoming centre to the mansion block. This courtyard also forms a green interface with the private amenity spaces of the ground-floor flats and to main corner entrances. The façade incorporates lighter, red banded brickwork for the courtyard, compared to a mix of darker banded brickwork on the civic side, which enhances light levels for the flats and visually defines the communal space.
Plashet Road
Plashet Road is a 100% affordable housing development in Newham, London. Completed in 2024, the scheme provides 65 new homes, including 74% family dwellings and a nursery. Plashet Road was part of the Affordable Homes for Newham Programme 2018-2022.
 
Lessons in design quality
Gallery access location: gallery access is located to the north or east of each building to enable the majority of balconies, living rooms, and bedrooms to be south- or west-facing where they benefit from solar gain in winter months and higher daylight levels.
 
Developing three typical flat typologies to improve viability and living comfort: each typology is greater in width than depth. This ensures that all flats are dual or triple aspect with optimised natural ventilation and daylight and floor plans can be designed to locate bedrooms and living spaces away from the semi-private gallery access.

New Kingsland Housing
Completed in January 2025, Bristol City Council have developed 16 low energy and affordable homes on the site of a former 1950s Church on Passage Road in Henbury.
 
Lessons in design quality
Attractive affordable homes: the site comprises a crescent shaped terrace of 10 two storey family homes which front the street and a two storey block of smaller 1 bedroom flats to the rear. The family homes are all attractive and are well designed to support family living in numerous ways. Homes feature large windows to take advantage of natural light from the southwest facing orientation and large inset porches feature glazed tiles to create distinctive and welcoming entrance spaces. There are dedicated refuse stores for each property which are inconspicuously sited within individual front gardens, and each home has a parking space, private rear garden with cycle storage and access to a communal garden. Overall, the homes have been successfully designed to be attractive and support the daily activities and needs of families.

 

 

Bancroft and Wickford Street
Completed in 2024, the scheme has regenerated two sites on the Bancroft Estate in Tower Hamlets, London by providing two contemporary buildings offering 33 homes for council tenants and community facilities including a new neighbourhood park.
 
Lessons in design quality
Being a 'good neighbour' in estate regeneration: many aspects of the design are neighbourly, including the scale and mass being driven by the need to safeguard daylight and sunlight levels received by surrounding residential buildings. Height was appropriately directed to terminate the taller residential block to the north. Streets are activated by generous semi-recessed balconies and roof terrace, carefully fenestrated ground floor offices for the local Bancroft Tenant Management Co-operative and Women’s Inclusive Team, a local community organisation. The surrounding public realm is extended and enhanced for exisitng and future residents with pedestrian routes, tree planting, lighting and a new neighbourhood park.

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Streamlining Planning for Housing in Wales: Welsh Government Changes to Permitted Development Rights
The Welsh Government has launched a consultation titled “Changes to Permitted Development Rights”, inviting stakeholders to provide feedback on proposed new permitted development rights (PDRs) and also a potential change to the definition of major development.
The consultation aims to modernise and streamline the planning system in Wales, making it more efficient, effective, and responsive to current needs.
Key Proposed Amendments
This blog focuses on three key areas of the consultation:
 
  • Definition of Major Development; 

  • Affordable Housing Sites as Meanwhile Uses; and, 

  • Permanent affordable housing sites via permitted development.

Definition of Major Development (Housing)
The following types of residential development are currently considered major development:
 
  • The provision of dwellinghouses where:
    1. There are 10 or more dwellinghouses.
    2. Sites are of 0.5 hectares (ha) or more.
Where developments fall within this category, this triggers Statutory pre-application consultation (PAC) requirements, which requires the complete draft application to be consulted upon for a period of 28 days prior to its submission to the Local Authority. A Design and Access Statement is also required for major development and the cost of pre application advice is higher.
The Welsh Government proposes increasing the threshold from 10 to 25 dwellinghouses, reducing the need for pre-application consultation for smaller schemes. A corresponding increase in the 0.5-hectare site threshold is also under consideration. Lichfields consider this proposal could go further, aligning with the 50-dwelling and 2 ha site area thresholds used in Scotland[1] and Northern Ireland[2]. This would provide greater consistency across the UK and further reduce barriers to development. The Welsh Government Affordable Housing Taskforce: report and recommendations (15 May 2025)[3] also recommends the threshold is raised to 50 dwellings, in-line with Scotland and Northern Ireland. It is therefore unclear why a lower threshold has been used.  
It is considered that the benefits of such changes include:

  1. Reduced Planning Delays: Smaller projects can proceed without 28-day pre-application consultations. The time saving is greater because of the additional time needed to organise the PAC and to write the PAC Report.
     
  2. Cost Savings: Lower administrative costs associated with planning applications. This includes costs of preparing websites and notices, consultant costs and development finance over a shorter period of time.
     
  3. Faster Project Delivery: Accelerates the timeline for housing projects, allowing quicker market entry.

The downside of this change is that the views of the public and specialist consultees may not be heard ahead of planning submission. However, applicants can still choose to carry out public consultation but in a way that suits their timescales and budget.
Lichfields queries why this change only applies to housing development and whether there is an opportunity to further increase the 1 ha and 1,000 sqm thresholds for wider land use proposals.
Affordable Housing Sites and Meanwhile Uses

Meanwhile Uses
“Meanwhile uses” are uses of land which are undertaken temporarily while a longer term intended use of the land is being prepared. 
Under the existing Part 12A of the Town and Country Planning (General Permitted Development) Order 1995, local authorities can carry out emergency development without planning permission. However, this right is: 

  • Time-limited to one year, after which a full planning application is required.

  • Intended for short-term emergency responses, not long-term housing solutions.
This restricts the ability of local authorities and developers to use land flexibly for temporary housing needs, especially in the context of affordable housing.
 
The Welsh Government proposes to extend and adapt the existing PDR to allow for affordable housing as a meanwhile use. Key features include: 

  • A bespoke PDR specifically for temporary affordable housing, such as modular or prefabricated units.

  • The right would extend beyond one year, offering greater flexibility and reducing the need for planning applications. 

  • It would include specific conditions, such as:
    1. Controls on window placement for habitable rooms.
    2. Consideration of proximity to neighbouring properties.
    3. Potential restrictions in sensitive areas (e.g., Conservation Areas, Areas of Outstanding Natural Beauty, National Parks).

The proposed changes also reflect recommendations made by the Welsh Government’s Affordable Housing Taskforce (15 May 2025), which advocated for:

  • Greater use of meanwhile uses to address short-term housing needs.

  • Permitted development flexibilities to enable rapid deployment of modular and temporary housing.

  • A more streamlined planning process to reduce delays and costs associated with temporary housing delivery.
The Taskforce highlighted successful examples in places including Cardiff’s Grangetown and Llantwit Major, where meanwhile uses have been used effectively to meet urgent housing demand.

 

Benefits of Proposed Changes
This change is designed to support faster development of temporary housing solutions while maintaining appropriate safeguards, representing a pragmatic and progressive step towards addressing housing need in Wales.
Permanent Affordable Housing
The Welsh Government is exploring the introduction of a new PDR that would allow certain permanent affordable housing schemes to proceed without the need for a full planning application. Instead, a prior approval process would be used to agree specific details such as:

  • Design and layout.

  • Access and transport.

  • Impact on neighbouring properties.

This would represent a significant shift from the current system, where all permanent housing developments – regardless of affordability – require full planning permission, including public consultation and detailed scrutiny by planning officers.
It is acknowledged by Welsh Government that delivering permanent affordable housing sites via PDRs would be challenging due to the need for localised placemaking and lack of scrutiny by consultees as well as the ability for local people to submit comments. Therefore, Welsh Government seeks views on:

  • Whether PDRs should apply to Local Development Plan (LDP) allocations only or include windfall sites too.

  • The scope of prior approval processes to maintain design quality.

  • The potential use of a pattern book of pre-approved house types to reduce assessment burdens.

  • The potential of restricting PDRs in sensitive areas, such as:
    1. Conservation Areas;
    2. Areas of Outstanding Natural Beauty; and,
    3. National Parks.

 

This proposal reflects recommendations made by the Welsh Government’s Affordable Housing Taskforce (15 May 2025), which called for:

  • Streamlined planning routes for affordable housing;

  • Greater use of permitted development to reduce delays and costs; and,

  • Consideration of design coding and pattern books to maintain quality while simplifying approvals.

The Taskforce recognise that the current planning system can be a barrier to delivering affordable homes at pace and scale. Lichfields therefore consider this proposal is a positive and pragmatic step towards accelerating the delivery of affordable housing but consider it could go further by supporting all allocated housing sites and not just 100% affordable housing.
Benefits of Proposed Changes
The proposed PDR for permanent affordable housing would remove the requirement for a full planning application, relying instead on prior approval for specific details, this raises important considerations. The main benefit lies in the significant reduction in time and cost, as developers would no longer need to navigate the full planning process – streamlining approvals and enabling quicker responses to housing needs. However, this comes at the expense of reduced scrutiny by planning officers on design details and a lack of opportunity for public consultation, which could impact the quality and local acceptability of schemes.
That said, this may be less of an issue for allocated sites, where the level of detail required at the Local Development Plan (LDP) stage is already high, providing a degree of pre-established design and policy alignment. To maintain quality while benefiting from efficiency, the use of design coding and pattern books could offer a valuable solution – ensuring consistency and placemaking standards. A limit on the size of schemes that could be delivered via this method could also be introduced.
Conclusion
At Lichfields, we broadly support the proposed changes to PDRs and widening the definition of major development considered within this blog. These amendments will contribute to a more efficient and streamlined planning system in Wales, helping to accelerate the delivery of affordable housing which is a key priority of the Affordable Housing Taskforce.
In a planning system that is getting more and more burdensome it is refreshing to see the Welsh Government seeking to reduce the barriers to development. However, we question whether the consultation goes far enough, querying if the definition should go up to 50 dwellings and whether both housing and non-housing thresholds should also be increased. We would also support all allocated housing developments below certain thresholds being able to make use of the proposed PDRs.
The consultation runs until 1 July 2025.

Footnotes
[1] Town and Country Planning (Hierarchy of Developments) (Scotland) Regulations 2009 (as amended).

[2] Planning (Development Management) Regulations (Northern Ireland) 2015 (as amended).
[3] Affordable Housing Taskforce: report and recommendations | GOV.WALES

 

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