Planning matters blog

National Portrait Gallery to be transformed

Lauren Ayers & Heather Marshall 24 Apr 2019

A culmination of an intensive and exciting period of work for Lichfields proved fruitful at Westminster City Council’s Planning (Major Applications) Sub-Committee, when planning permission and listed building consent were granted for the ‘Inspiring People’ project at the National Portrait Gallery.

This £35.5m project, designed by Jamie Fobert Architects working alongside conservation architects Purcell, will transform the Grade I listed Gallery, making it more accessible and welcoming to the public as well as restoring historic features. At its core is a comprehensive redisplay and re-interpretation of the Gallery’s permanent Collection across 40 refurbished galleries, presenting a greater and more diverse selection of portraits; the return of the Gallery’s East Wing to public use as the new Weston Wing, including restoring the original gallery spaces and the creation of new retail and catering facilities; and a new Learning Centre for visitors of all ages with studios, breakout spaces and high quality practical facilities.

Externally a new public forecourt is to be created on the northern side of the building leading to a new fully-accessible entrance in the north façade which is more open and welcoming to all and will create a step-change in the quality of the townscape at the southern end of Charing Cross Road.

Image credit: Jamie Fobert Architects + Purcell

For a high-profile central London site, the application ran particularly smoothly with not a single objection to the project received. The success of the project, while down to the Gallery’s vision and clearly articulated need for the alterations to take place together with the sensitive and inspired response of the architects, also lay in the strong consultative approach the project team took to the planning and listed building consent application.

Our pre-application strategy involved working closely with Westminster City Council, neighbours, stakeholders and relevant consultees to ensure any concerns were taken on board and addressed in the design of the scheme. As part of the integrated design team, Lichfields led early engagement with Westminster City Council to establish a positive working relationship with the Council from the outset.

In co-ordination with the Gallery and wider design team, we also carried out pre-application public consultation and engaged with statutory consultees including Historic England, the Victorian Society and the 20th Century Society, as well as local consultees such as the Westminster Society and the Irving Society. A series of design workshops were held jointly with Historic England and Westminster City Council to develop the scheme to a design that was supported in principal by all parties prior to the submission of the applications.

We entered into a Planning Performance Agreement with the Council which covered the determination period. The committee date of 23^rd April was agreed upon by all parties and a collaborative working relationship was established between the applicant team and the Council to ensure that the applications were submitted on time and any concerns and issues were dealt with speedily to enable the applications to be heard on the identified date.

We look forward to continuing to work closely with the Council over the coming months to discharge the planning conditions and sign the legal agreement.

The London Cultural Infrastructure Plan: A call for planners

Summer Haly 16 Apr 2019

The Mayor of London published his new Cultural Infrastructure Plan, last month (March, 2019); as noted in Lichfields’ planning news, it focuses on cultural spaces and how the Capital should best plan to meet its cultural needs. The report makes clear that these spaces are at risk from land pressures, increasing business rates and permitted development rights. A call for action from planners is at the centre of this Plan, not least because the NPPF regards ‘cultural wellbeing’ as a crucial component of sustainable development[1].

The Plan delves into how we can better understand our cultural infrastructure, from cultural ‘consumption’ (which includes spaces such as art galleries, museums and libraries) to the increasingly broad nature of cultural ‘production’ (including but not limited to artist studios, design workshops and creative co-working spaces). It coincides with the Mayor publishing a Cultural Infrastructure Toolbox, the first of its kind, which also includes an interactive map. By understanding the differing cultural venues which make up London’s world class cultural infrastructure, only then can we start to take action.

Planning effectively for cultural spaces in London has become increasingly complex. Unsurprisingly, cultural uses are experiencing much of the same pressures to that of industrial and office uses: rising land prices, increasing business rates and pressure from higher value residential uses.

In response, the Cultural Infrastructure Plan is intended to sustain and enhance the cultural spaces within London by advocating collaborative solutions on a site-specific basis, whereby planners work alongside, developers, local authorities and cultural organisations. The Mayor’s Plan proses a call to action to 1) map where cultural spaces are within each Borough and 2) consider how we can enhance these spaces. The following questions addressed within the Plan are particularly crucial for our sector:

What is cultural infrastructure?

Cultural infrastructure, whilst critical to London’s economy, is often ill-defined. The Plan states this infrastructure encompasses the buildings, structures and places where culture is either consumed or produced. With the recent announcement of the Creative Enterprise Zones – the first ones being designated in December 2018 – we are seeing an increasing emphasis placed upon the creative economy; a sector which generates ‘£52bn for London each year, is the reason most tourists visit, [and] employs one in six Londoners’.[2] Our cultural spaces, beyond contributing to ‘cultural wellbeing’, are critical in terms of job creation, sector growth and maintaining London’s position as a world leader in cultural capital.

The Mayor’s Plan stresses the need to map this cultural infrastructure across the Capital to plan effectively. The cultural infrastructure map allows users to choose from 36 indicators (spanning from artists workspaces, community centres, dance halls, heritage at risk, pubs and theatres) to explore different locations across the Capital. The map (see extract, below), allows cultural spaces to be viewed at both Borough and Ward level. This can then be combined with context layers such as transport, planning policy, audience and demographics, and open spaces. For instance, the map below shows the results of combining the museums indicator with the Opportunity Zone context layer. Developers, planners and architects proposing new developments are encouraged to consider cultural spaces, particularly those deemed to be at risk, and seek to incorporate these spaces within their proposals.

Source: The Cultural Infrastructure Map (2019)

Planning for cultural infrastructure

The Cultural Infrastructure Plan outlines how we can better plan for cultural infrastructure, in accordance with the Draft London Plan policies, towards a ‘roadmap to 2030’[3]. It identifies a ‘seven-point action plan’[4] centred around mapping, sustaining and enhancing cultural spaces. Action 2 explicitly calls for planners to ‘plan for and create cultural infrastructure’[5]. This includes reference to the role that Section 106 and Community Infrastructure Levey can play with regards to cultural infrastructure. Alongside funding, the plan calls for intensification of sites, re-purposing buildings and developing new sites to provide cultural spaces. It also highlights the potential role of meanwhile uses, a topic covered by Lichfields through our work for U+I (for more, read our recent blog).

As well as creating new sites however, the Mayor calls for a more collaborative approach to planning such spaces. This involves the co-operation of local authorities, cultural organisations, architects and planning organisations. For example, Hackney Borough Council, the London Legacy Development Corporation and creative co-working spaces are safeguarding cultural production sites by introducing planning policies which ensure rent is below market value. This is intended to safeguard 8,500 sqm of creative working spaces within new developments in Hackney.

Whilst we are already seeing a number of co-operative solutions being implemented across the Capital, more is needed to sustain our world class cultural assets which are vital to both London’s economy and our sense of cultural wellbeing. The Mayor seems resolute that planners must play a key role in delivering future cultural spaces to enable our creative economy to thrive and for all of London to enjoy. As the Cultural Infrastructure Plan states, a first step must be for planners to answer this call to action.

[1] National Planning Policy Framework, (2019), paragraph 8[2] The Cultural Infrastructure Plan, Greater London Authority, (2019) p.7[3] The Cultural Infrastructure Plan, GLA, (2019), p.35[4] The Cultural Infrastructure Plan, GLA, (2019), p.38[5] The Cultural Infrastructure Plan, GLA, (2019), p.40

Draft London Plan EiP: A change is gonna come

Jennie Baker 04 Apr 2019

Lichfields is currently monitoring the draft London Plan Examination in Public (EiP), which is scheduled to last until May 2019, and will report on relevant updates as part of a blog series. The seventh blog of the series focuses on some key further suggested changes proposed by the Mayor.

After months of hectic hearing sessions, lengthy written statements, endless words, minor suggested changes, followed by further suggested changes, we are now officially in the break-month of the London Plan Examination in Public (EiP), which will duly resume at the end of April.

In this context, you might well be forgiven for having lost the plot over where we are at with the draft London Plan, and the latest GLA position on some of the more contentious proposed policies. Whilst, we are still far from knowing any official recommendation from the Planning Inspectors (with the Inspectors’ report currently expected sometime in Summer 2019), the break creates an opportunity to look back at some of the changes the GLA has officially endorsed via published further suggested changes.

Below, I have listed six key policy changes (plus a little bonus) which are likely to significantly affect the development sector in London, if endorsed and confirmed by the Inspectors. All the references below to draft London Plan policies/paragraphs are taken from the latest version of the whole Plan (published August 2018, available here).

1. Housing targets and monitoring: a steep stepped approach?

One of the main concerns for London Boroughs has surely been the high annualised housing targets (set out in table 4.1 in the draft Plan) and their immediate application from April 2019. The GLA seems to have accepted that it is unrealistic (and procedurally questionable, given that the Plan is not yet adopted) for London Boroughs to step-up their housing delivery at the levels the GLA envisages from year one.

Accordingly, it proposes to allow Boroughs to increase their housing targets gradually, allowing them ‘to set out a realistic, and where appropriate, stepped housing delivery target over a ten-year period’ (Paragraph 4.1.3[1]). This might provide a short-term solution to address under-delivery in the first years, but the cynics among us might say that it will simply allow Boroughs to kick the can down the road.

Interestingly, the proposed change also touches on another very contentious point, this being the interplay between proposed housing targets, the Government’s standard method for assessing housing need, and the Housing Delivery Test. Boroughs wishing to opt for a stepped housing delivery target are to clearly articulate ‘how these homes will be delivered and any actions the boroughs will take in the event of under-delivery’; the draft Plan now notes that a ‘clear articulation […] would also fulfil the requirement of a ‘Housing Delivery Test action plan’’.

Notwithstanding the questions raised by London Boroughs on the potential impacts of this ad-hoc regime (with the new London Plan based on the 2012 NPPF, while Local Plans will be based on the 2019 NPPF), MHCLG concerns about London’s deviation from the standard method for assessing local housing need, and the draft Plan’s reference to the Housing Delivery Test, the Mayor seems firm in his view that housing delivery in London should be assessed against his targets, rather than the standard method-derived housing requirements.

This makes for a policy area of the draft London Plan worth following, particularly to understand what the Inspectors will recommend in light of these differing views between the Government and the GLA, as well as for the potential practical implications it may carry.

2. Small sites: yet, not too small to contribute

Another contentious policy, due to the draft Plan’s over-reliance on its potential achievements and the modelling assumptions behind it, is Policy H2 ‘Small sites and small housing developments’.

Further suggested changes proposed to this policy provide clarifications that any affordable housing requirement that Boroughs wish to apply to small housing developments of nine units or less should only be ‘a tariff approach rather than seeking on-site contributions’ (Policy H2 H[2]). Additional changes to supporting text further stress that ‘affordable housing requirements from development of nine or fewer units should be asked for as a cash in lieu contribution’.

Moreover, the presumption in favour of small housing developments[3] would also apply to change of use of non-residential buildings to residential use, which has now been deleted from the list of small housing developments exempted from the presumption; this was added to the list via August 2018 minor suggested changes (Policy H2 F, and related supporting text at paragraph 4.2.3A [4]).

The deletion of the above and other exemptions to the presumption in favour of small housing developments (including the exemption for designated Green Belt and MOL sites) suggests that the original assumptions behind small sites-related housing delivery might have been too optimistic.

3. Affordable Housing or employment land, that is the question

There is no doubt that the provision of affordable housing in London is the number one priority of the draft London Plan.

A suggested affordable housing change that is already worrying some in the Built to Rent sector relates to Boroughs being able to ‘require a proportion of affordable housing as low cost rent (social rent or London Affordable Rent) on Build to Rent schemes’. Furthermore, these potential low cost rent homes ‘must be managed by a registered provider’ (Supporting text 4.13.9A[5]). This could represent quite a conundrum for those Build to Rent developers who are not registered providers (the large majority), and could create issues around different managements within the same building.

The draft London Plan also includes affordable housing policies relating to residential development on London’s industrial land.

In order to achieve some form of planning benefit from future losses (beyond provision of new homes) and ‘given the difference in values between industrial and residential development’ the draft London Plan policy H6 proposes a threshold of 50 per cent affordable housing for development in certain industrial locations where there would be a net loss of industrial capacity.

The supporting text of Policy H6, as amended, refers to ‘industrial floorspace capacity’ and says ‘residential development proposals that would result in a net loss of industrial floorspace capacity on Strategic Industrial Locations, Locally Significant Industrial Sites or Non-Designated Industrial Sites are expected to provide at least 50 per cent affordable housing to follow the Fast Track Route’ (Supporting text 4.6.6[6]).

However, the concept of ‘industrial floorspace capacity’ comes with some caveats, in the form of recently proposed footnote 46E. This recognises that the floorspace capacity approach also applies to ‘sites used for utilities infrastructure or land for transport functions that are no longer required’ for the purposes of Policy H6; furthermore, the footnote acknowledges that ‘some surplus utilities sites are subject to substantial decontamination, enabling and remediation costs’. In these instances, and if ‘it is robustly demonstrated that extraordinary decontamination, enabling or remediation costs must be incurred to bring a surplus utilities site forward for development, then a 35 percent affordable housing threshold could be applied, subject to detailed evidence, including viability evidence, being made available’ (Footnote 46E[7]).

The above is a sensible change given that development on industrial land often incurs in greater costs in terms of site preparation. One might assume that such decontamination costs should be accounted for in the price paid for land, but it is also true that many sites might have been bought well before the fast-track route approach to affordable housing was introduced.

4. Industrial land: exempting from the plot (ratio)

Still on industrial land policies, significant debate emerged at the related hearing session on the introduction of a minimum floorspace plot ratio of 65% (industrial floorspace/total land) as benchmark against which the principle of ‘no net loss’ of industrial floorspace capacity should be measured. In the draft London Plan industrial floorspace capacity is defined ‘as either the existing industrial and warehousing floorspace on site or the potential industrial and warehousing floorspace that could be accommodated on site at a 65 per cent plot ratio (whichever is the greater)’[8].

However, the GLA recognises that not all industrial uses might be able to operate or being commercially viable if a strict 65% floorspace plot ratio were to apply. Accordingly, a further suggested change provides for exceptional circumstances, where ‘it should be demonstrated that it is not feasible to achieve no net loss of industrial floorspace capacity through alternative configurations, multi-storey industrial development, a wider mix of industrial uses, or other appropriate measures’ (Supporting text 6.4.5AB[9]). However, this exceptional approach will not apply to industrial developments proposed as part of SIL/LSIS consolidation processes, and for industrial/residential/non-industrial co-location schemes.

5. Green Belt and Metropolitan Open Land: national policy and no land-swap

Green Belt and Metropolitan Open Land (MOL) policies are always a contentious topic, and the draft London Plan is surely no exception.

However, and quite surprisingly, the GLA does not propose to amend Policy G2 B (i.e. Green Belt ‘de-designation will not be supported’), which many consider inconsistent with national policy. The Mayor of London written statement clarifies the reason for this, as the ‘policy wording has a different emphasis to the NPPF, with the NPPF requiring the demonstration of exceptional circumstances to justify boundary changes. The emphasis in the draft London Plan is considered justified as Green Belt release is not considered necessary, with the vast majority of London’s development needs being able to be met within London, without developing on the Green Belt’ (Paragraph 65.8[10]).

The capacity to meet the vast majority of London’s development needs within its own boundaries has been challenged by many stakeholders, particularly in light of the very high housing targets, industrial land policies, and over-reliance on small sites potential housing delivery. It will be interesting to learn the Inspectors’ view on this point.

In terms of further suggested changes, the GLA clarifies that MOL ‘is afforded the same status and level of protection as Green Belt’ and that this should be ‘protected from inappropriate development in accordance with national planning policy tests that apply to the Green Belt’. Interestingly, the supporting text reference to the principle of land swaps being potentially applicable to MOL had been removed (Supporting text 8.3.2[11]).

6. Affordable workspace with an expiry date

Low-cost and affordable workspace policies are an interesting innovation of the draft London Plan, although initially many of the details were to be left to the Boroughs for their decision.

More details have been provided in relation to affordable workspace, where spaces are provided at below market rate due to the ‘specific social, cultural, or economic development purpose’. Affordable workspaces can be provided ‘and/or managed directly by a dedicated workspace provider, a public, private, charitable or other supporting body; through grant and management arrangements; and/or secured in perpetuity or for a period of at least 15 years by planning or other agreements’ (Supporting text 6.3.1[12]). The removal of the expectation that affordable workspace should only be secured permanently will probably be a great relief to the development sector, given the uncertainty that surrounds this new policy.

Further suggested changes proposed to remove the reference to ‘reasonable proximity’ for the re-provision of lower-cost business spaces, possibly due to the difficulties in defining what ‘reasonable proximity’ might have meant in practice.

Bonus track: live hub of planning data

Not strictly policy related, but of interest to the development sector in the Capital is the recent update on the development of a live hub of planning data by the GLA.

As explained in a useful article[13], the London Development Database will be used to ‘monitor implementation of the London Plan’. To support the monitoring phase, the GLA has published Non-Technical Planning Data Standard which sets out the key information that will be collected up-front on planning applications ‘in machine readable fields, so that planning application information can travel automatically through systems and out to the public’. As stated on the GLA website ‘[a] Technical Planning Data Standard will follow with further information on schemes, fields, and other relevant details’.

Importantly, the goal is for this automation process to be ready ‘in conjunction with publishing the new London Plan. […] Based on the outcome of the London Plan EiP, [the GLA] will amend any fields in the Data Standard that do not align with the final London Plan before the automation project goes live’.

Having robust systems in place to collect information and directly feed-back to the GLA is crucial to ensure that the practical implications of new policy approaches are closely monitored, and potential unintended consequences addressed as soon as practicable.

The draft London Plan: a marathon, not a sprint

The London Plan EiP is still moving forward, with four additional weeks of hearing sessions scheduled until the end of May, and which will cover some crucial areas such as town centres, social infrastructures and viability.

We know that the Inspectors aim to write their final report on the draft London Plan between May-July 2019, and we could reasonably expect this to be published towards the end of Summer 2019. The current target is for the final version of the new London Plan to be published early in 2020, just before the next Mayoral Election takes place (May 2020).

As the Mayor has repeatedly said over the last three years, solving the housing crisis ‘is going to be a marathon, not a sprint’, and we can surely state the same for the new London Plan publication process.

However, as someone with a far better voice than mine used to sing:
‘It’s been a long, a long time coming

But I know a change is gonna come, oh yes it will’

[1] Appendix 1: M19 Further Suggested Changes[2] Appendix 2: M20 Further Suggested Changes[3] ’For the purposes of part D, the presumption in favour of small housing developments means approving proposals for small housing developments which are consistent with the policies of the London Plan while recognising that local character should evolve over time to provide new homes’ (Policy H2 E, Matter 20 Further Minor Suggested Changes to Policy H2)[4] Matter 20 Further Minor Suggested Changes to Policy H2[5] Appendix 1: M29 Further Suggested Changes[6] Appendix 1: M24 Further Suggested Changes[7] Appendix 1: M24 Further Suggested Changes[8] Supporting text at paragraph 6.4.5 (The draft London Plan showing minor suggested changes, August 2018)[9] Matter 62: Land for Industry, Logistics and Services, Further Suggested Changes[10] Mayor of London Written Statement on M65 Green Belt and Metropolitan Open Land[11] Matter 65 Further suggested changes to be made to Policy G3 Metropolitan Open Land[12] Matter 60: Low Cost and Affordable Business Space Further Suggested Changes[13] A live hub of planning data for London – update (Medium)

See our other blogs in this series:

Draft London Plan EiP: A new hope for industrial land?

Draft London Plan EiP: Heritage and culture are now dusted

Draft London Plan EiP, Affordable Housing: 3D snakes and ladders

Stand and deliver…

Draft London Plan EiP: ‘Willing Partners’ or not?

Draft London Plan EiP: Design – fit for purpose?

Lichfields will publish further analysis on the draft London Plan Examination in Public in due course. Click here to subscribe for updates.

This blog has been written in general terms and cannot be relied on to cover specific situations. We recommend that you obtain professional advice before acting or refrain from acting on any of the contents of this blog. Lichfields accepts no duty of care or liability for any loss occasioned to any person acting or refraining from acting as a result of any material in this blog. © Nathaniel Lichfield & Partners Ltd 2019, trading as Lichfields. All Rights Reserved. Registered in England, no 2778116. 14 Regent’s Wharf, All Saints Street, London N1 9RL. Designed by Lichfields 2019.

The battery storage revolution: planning for a brighter future

Andy McLaren 02 Apr 2019

A Changing Energy Mix

The UK’s energy mix is undergoing a process of rapid change in response to the global ambition to drastically limit global warming this century. The dependence on traditional methods of energy production is decreasing, and renewable energy is growing rapidly as a source of power generation. The capacity of renewable energy overtook fossil fuels in the UK for the first time ever in 2018 (Figure 1).

Figure 1 Renewable Energy Capacity Has Overtaken Fossil Fuels in the UK

Source: Guardian Graphic, Imperial College London, Drax (6th November 2018)

However, an increasing reliance on intermittent renewables such as wind and solar energy provision can create problems. As we make the switch to a more intermittent and less flexible low carbon generation mix, there is an emerging need to ensure that energy supply is resilient. Planning has a vital role to play in facilitating the provision of energy infrastructure in a timely way to ensure a consistency of supply.

This blog will explore how the planning system can strengthen its enabling role both at national and local level, with battery storage providing an important emerging technology to support the diversification of the energy market.

What we mean with battery storage?

Back-up energy facilities, such as battery storage energy plants, are emerging as potentially crucial elements of the UK’s energy mix, as excess energy can be stored and released during peak demand, or when renewable sources are not generating enough energy to meet demand.

Importantly, battery storage facilities have two key characteristics:

They can provide back-up electricity in seconds, as opposed to gas plants which can take more than 40 minutes to supply electricity when called upon.
They have an ability to operate with a significantly lower carbon footprint than conventional back-up generation plants (i.e. they do not produce emissions)[1].

Figure 2 battery storage Facility in the UK

Source: Edie.net (Edie Newsroom - 15th January 2019)

Battery Storage facilities are rapidly gaining market share and acceptance due to advances in their design, improved efficiency and lifespan. It is expected that this growth will continue, with a clear demand emerging in the market (coal energy production is expected to be phased out by 2025[2]).

For Battery Storage developments to become mainstream components of the energy mix and maximise their potential, support is needed from the planning system to boost the quantity of these schemes and speed up their delivery.

What changes are proposed in National Policy?

Large-scale storage projects with a generating capacity of more than 50MW are currently considered under the Nationally Significant Infrastructure Projects (NSIP) regime, introduced by the Planning Act 2008, with smaller schemes decided by Local Planning Authorities (LPAs).

At national level in England, the way energy storage projects are assessed by the planning system has been the focus of a recent Government consultation titled ‘The treatment of electricity storage within the planning system’, which closed on 25^th March 2019. The Department for Business, Energy and Industrial Strategy’s (BEIS) consultation sought to determine how best it can alter planning regulatory frameworks to support developers and businesses seeking to build energy storage facilities in England.

Specifically, the consultation aimed to gather opinions on the following proposals:

Retaining the 50MW NSIP capacity threshold that applies to standalone storage projects; and,
Amending the Planning Act 2008 to establish a new capacity threshold for composite projects including storage and another form of generation, such that composite projects in England would fall into the NSIP regime where either its capacity, excluding any electricity storage, is more than 50MW or the capacity of any electricity storage is more than 50MW.

The government states that findings so far indicate that the 50MW capacity threshold, “does not in itself distort storage developers’ sizing and investment decisions to a significant degree.”

However, it has been argued within the development industry that the threshold cap is currently impeding development of standalone Battery Storage schemes, and actively persuading developers to reduce the size of their proposals below 50MW. With the current pace of technological change, and the size of even the smallest schemes increasing, a continuation of this cap is clearly unsustainable.

It is also considered that removing this threshold cap could help to considerably improve the time taken to determine these schemes, and in the process significantly reduce associated costs.

The amendment to establish a new capacity threshold for composite projects would mean that a generating station would be determined under the local planning regime, where the capacity of both the storage and non-storage elements are less than 50MW individually. This could have positive implications if developers are encouraged to apply for composite schemes as a result, as these co-located projects bring significant benefits to the energy system by maximising the output and operational efficiency of projects.

It will be interesting to see the next steps the Government will take following the consultation, which could help shape the immediate future of Battery Storage’s treatment by the planning system. Nevertheless, LPAs need to start considering these matters now in their emerging local plans, as the provision of energy infrastructure and security of supply are vitally important elements for the development sector.

Local Plans: unfit for purpose?

The main pre-requisite for Battery Storage schemes is a connection to the electricity grid, and the locational requirements of such schemes present a significant constraint for their widespread implementation. This is because a storage facility must either be developed within close proximity to an existing power plant or sub-station with spare capacity, or brought forward alongside renewable energy infrastructure.

Currently, local plans provide nowhere near enough support to effectively enable implementation, and are largely ill-equipped to efficiently deal with the requirements of this emerging technology. LPAs must consider the way their local plans approach Battery Storage development, with particular regard to increasing delivery through the following actions:

Increasing the take-up of standalone schemes. This could potentially be improved through specific policies written into local plans, to provide an incentive to support their implementation; and
Promoting the integration of energy infrastructure schemes alongside new housing or employment developments. This could allow storage facilities to be delivered in tandem with renewable energy generation facilities.

Scope certainly remains to improve and maximise the ability of the planning system to help deliver these facilities on a widespread scale. Though an ability to improve delivery also relies somewhat on LPAs having an up-to-date, ‘modern’ local plan in place, with many LPAs across England yet to adopt innovative policies in this field.

This particular issue is highlighted in Figure 3 below, which illustrates local plan status post- original NPPF (2012). Just over 55% of LPAs have a post-NPPF 2012 plan in place as of December 2018.

Figure 3 Local Plan Status post-NPPF 2012 by LPA as at 31st December 2018

Source: Lichfields analysis

Without such innovation emerging from local plans, the delivery of standalone schemes, or integrated energy generation and storage facilities, is unlikely to come forward at the required rate. The local plan process simply cannot keep up with the current pace of technological change, and the UK cannot afford to get left behind in this regard.

To fully benefit from local energy storage, LPAs need to quickly consider the role their local plans can play in harnessing the rewards this technology can deliver.

Conclusions

As we move towards a flexible, de-centralised and de-carbonised energy system, the provision of localised energy infrastructure is vital, particularly through initiatives such as Battery Storage which bring numerous benefits.

The ability to provide electricity at short-notice in response to local demand is more important than ever before. The planning system must do all it can to help facilitate a general mainstreaming and the implementation of localised energy infrastructure. Currently, the majority of local plans are silent on these matters which is not helping the diversification of the energy market.

A widespread uptake of forward-thinking local plans, which directly support the diversification of the energy market, is essential in delivering the required change to help ‘keep the lights on’.

[1] Science for Environment Policy: Towards the battery of the future (September 2018)

[2] Reuters: Britain outlines plans for 2025 coal-power phase out (January 2018)

Planning matters

National Portrait Gallery to be transformed

The London Cultural Infrastructure Plan: A call for planners

Draft London Plan EiP: A change is gonna come

The battery storage revolution: planning for a brighter future

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