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Planning Reform:  Spatial Awareness – The Role of the SDS

Planning Reform: Spatial Awareness – The Role of the SDS

Sally Furminger & Simon Slatford 24 Nov 2021


It seems a long time ago now that the Government issued the White Paper on planning reform and, as they say, a lot of water has passed under the bridge since then. Many radical new ideas were set out and slowly but surely many seem to be slipping by the wayside – along with Messrs Jenrick and Cummings.

Notwithstanding the current ‘pause’ on planning reforms, Mr Gove has recently assured the MPs on the cross-party housing, communities and local government select committee that there will be some reforms coming forward and he has given us several clues. His priorities seem to include: simplifying plan-making; a greater focus on beauty in new schemes (already in the NPPF); achieving net zero carbon emissions in new housing; giving communities a greater say over development; reforming infrastructure funding and digitalising the planning system.

Many of these would be commendable, but we will clearly need to wait, likely for some time, to see what he has up his sleeve to keep Tory MPs in the south and south east happy, while ensuring that we build the homes that we need, where we need them.

The Role of Spatial Planning?

This has led us to go back to when the planning reforms were first announced in August 2020 and to reconsider one of our original, but still pertinent thoughts – ‘do spatial development strategies have a role in a new planning world?’. Being Londoners with a keen interest in the progress of various London Plans, we started with analysis of the SDS for London (the ‘London Plan’). However, there are a number of other spatial development strategies coming forward across the Country and we consider that our findings and thoughts will still be of relevance for planning in our other great conurbations.

Our analysis commenced at the beginning of this year. We first reviewed historical information to identify how spatial planning has evolved in London over the last 45 years (since the Greater London Development Plan) and how the more recent London Plans have performed ‘in numbers’.

As a key second strand, we sought a clearer view of the role of the London Plan over the last 20 years and how this has helped or hindered planning in a major city. To achieve this, we organised workshops with the people who really knew – developers, housebuilders and local planning authorities. We were not only interested in exploring whether spatial planning in London was viewed as working well, but also in examining lessons learned and, whether there could be better way forward.

Our aim was simple – to understand, fully, where we are today and to seek to inform and influence government thinking about the future of spatial planning for our cities and how best this could be delivered.

This blog is the next step towards the completion and publication of an Insight on Spatial Development Strategies.

Life Before the London Plan

Our starting point was to consider the previous options for spatial planning in London – what form it has taken and how successful it was. We looked at the GLDP (1976), the role and actions of LPAC, including the ‘1994 Advice’ Notes on strategic planning in London, and the function, role and success of RPG3 (1996).

In summary, our overall conclusions were that these were, generally, ineffective in guiding and, more significantly, in delivering the growth that London needed.

The London Plan – The Objective

That would explain the birth of the London Plan, as set out in the 1999 GLA Act, through the formation of the GLA and a London Mayor who had responsibility for producing a Spatial Development Strategy (SDS) for London and keeping it under review. The Mayor is required by law to produce a range of Strategies for London, each being consistent with the other, with the SDS acting as the integrating framework for all.

But, as set out in the Act, a key factor is that the London Plan should deal only with matters that are of ‘strategic importance’ to Greater London. This became a key theme of our analysis.

The first London Plan was adopted in 2004, under Mr Livingston, the second iteration came under Mr Johnson in 2011 and now we have the latest (and most controversial) version produced by Mr Khan which was adopted at the beginning of this year. Each Mayor has stamped their own mark on the London Plan and each version has become steadily more complex, more demanding and, as an inevitable consequence, longer. The Inspectors into the current London Plan noted that ‘There is clearly a balance to be struck between allowing for autonomy whilst at the same time setting a strategic direction. The Plan’s policy requirements should therefore be restricted to those that are essential to achieving the Mayor’s strategic vision and objectives’

Having trawled through each and every one of the London Plans many times, and having had to apply the policies on numerous planning applications over the years, we do not need to tell you that these include policies that go way beyond matters of ‘strategic importance’.

However, is this to say that they are ‘bad’ documents …?

The London Plan – The Reality

… the answer is a categoric ‘no’. But if we were asked the question, ‘could the latest version be improved?’, the answer is an undoubted ‘yes’.

We are not alone in this view.

There are undoubted issues with the London Plan, particularly the current one, and some of these were expressed by the EiP Inspectors and the then SoS, as well as the representatives from the development sector and the local planning authorities that we spoke with. The main issue being that it was too long and detailed and that it has strayed well beyond covering matters that are of ‘strategic importance’. As the Inspectors kindly put it …

‘we would encourage the Mayor to consider setting out a more concise spatial development strategy, focussed on strategic outcomes rather than detailed means of implementation, when the Plan is next replaced’

In completing their work, the Inspectors concluded that:

‘It is clear from many of the representations made about the Plan, and the discussions that took place throughout the examination, that its length and complexity raise a number of significant issues about the fundamental role and purpose of a spatial development strategy in a three-tiered plan-led system..’ (our emphasis).

But, having said this, within our workshops there was also a lot of positivity about the London Plan, acknowledgement for what it does achieve and the role of the GLA in delivering the development we need. It was considered that:
  • In complex urban areas there is a need for a layer of higher-level policy that can cover cross-boundary issues both within, and beyond, London. Having a Strategic Plan was regarded as being vital and the London Plan is necessary to perform this role.

  • It is important to have a single driving force capable of making tough and locally unpopular decisions to facilitate and deliver the growth that London needs.

  • As the Mayor put it, in his response to the White Paper: ‘The London Plan remains the most appropriate mechanism for determining the quantum and distribution of housing and other land uses to meet the needs of London. The Plan ensures that sufficient land is allocated for these and other uses.’

  • All parties welcomed the strategic clarity in development policies to provide consistency across London as a whole.

  • The London Plan has been successful in delivering overall growth, encouraging more progressive planning outcomes. The London Plan and the GLA have been highly successful in pushing forward development across London, when some Boroughs may have been reluctant to take on that role.

  • The development industry accepted and agreed that in some sectors, the London Plan has set a higher bar for development, as the GLA was seen as being innovative in policy terms, such as energy and build to rent.

Conclusions – and how you could help

Overall, our conclusions so far are that the London Plan is an important and necessary document for spatial planning in London and that it has played a fundamental role in bringing forward growth and quality development. To achieve this successfully, there is a need to pull away from seeking a consensus view of local planning authorities across the conurbation.

However, it is back to basics on content, as the clear consensus is that the Plan’s policy requirements should be restricted to those that are essential to achieving the Mayor’s strategic vision and objectives. In our Insight we will set out what we regard, based on the input from those at the sharp end of delivering development in London, to be the key strategic policies that an SDS should focus on and our recommendations for change in content and process.

This is not quite the end of the story as our Insight piece is not yet completed. So, if you have any views on the London Plan and the role of SDS’s generally, that either concur or differ from this blog, please do let us know before Christmas.


What can we learn from the past about flood resilience?
Flooding has become one of the biggest dangers to heritage assets in the UK and as more rain is predicted to fall in intense downpours the impacts to the historic environment will be significant. This will undoubtedly have implications for the sustainability of significant heritage assets along with their contribution to local communities and tourism. With the effects of climate change being felt across the country the Government consulted this year on proposals to change England’s planning policies to better respond to flood risks. It was announced planning guidance will be amended to make it clear that all planning applications opposed by the Environment Agency on flood grounds should be referred to the Secretary of State to make the decision. This means that developers who want to build on flood-prone areas will have to demonstrate that their proposals are climate resilient. Owners of listed buildings, who want to make alterations to their properties, should also manage flood risk and establish protective measures while retaining and respecting the existing structure and materials.
In 2018, the Environment Agency identified that flooding posed a significant harmful consequence to cultural heritage. Working with local communities and carrying out a thorough flood risk assessment are therefore important exercises that help developers to understand the potential complexity of delivering their proposals within flood prone areas. Increased protection for heritage assets was spurred by the introduction of The Climate Change Act 2008 and the Flood and Water Management Act 2010 requiring Local Planning Authorities to address flood risk by delegating to them responsibility for flooding from local water courses, with the Environment Agency retaining responsibility for main rivers.
This threat isn’t new however. Historically, our ancestors had a good eye on the landscape locating a number of settlements and structures on topographic highs or by using materials that can tolerate a degree of saturation. Building design from the past includes features such as pitched roofs, which ensure water is shed quickly, preventing it from sitting long enough to penetrate the roof material, whilst wide eaves and cornices keep falling water away from the walls. A study of historic properties at Hebden Bridge in 2017 showed that there were virtually no post-flood problems on buildings that retained most of the historic features and fabric, and the ones that made remedial works such a removing plaster with modern materials experience problems with months of repairs followed by damp issues. The important lesson from the flooding was that the traditionally constructed buildings, maintained and repaired with traditional materials, were far more resilient. Alterations to listed buildings with these components therefore should respect the original function not only for outwardly aesthetic purposes but for their continued use and flood protection elements they offer.
Climate change is not an entirely new issue and our ancestors have been altering the landscape to deal with the effects of flooding since at least the medieval period. Between c. 950–c. 1250 there was the Medieval Warm Period, a time associated with an unusual temperature rise that created unusually wet conditions. The flood defence at Botolph's Bridge, for example, was probably constructed to protect the fertile agricultural land behind it from flood water. Other responses to flooding can also be seen in urbanised environments such as London. Tottenham Court Road for example is a medieval rerouting of the Roman Ermine Street due to its flood prone location.
The modern construction of permanent infrastructure and other tools such as habitat creation, however, can also have negative effects on the historic places. For example, in 2015, the construction of a bund (an embankment to contain flood water) affected the setting of the Grade I listed St Michael’s Church in Mytholmroyd. Unfortunately, despite this defence, the church was inundated during the December floods of 2015. During that flooding event, which was a consequence of the river bursting its banks and increasing groundwater levels, the bund was overtopped, and water rose through the floor of the church. Unfortunately, the bund was very efficient at retaining the flood water in the building, so the church took longer to recover than would have been the case in the absence of that flood defence. Later in 2020, the village experienced further flooding caused by Storm Ciara affecting the church yet again. The church was flooded to a depth of four feet and has been undergoing extensive restoration ever since. All the pews were removed to safe storage and the wooden floor was replaced before the pews were re-installed. The church installed glass panels next to and opposite the church and the river channel has been widened (up to 8m). Rewilding is another example of natural flood management response, such as expanding woodland, reintroducing species that have been absent for a millennia, they usually have an adverse effect on the setting and character of heritage assets.
As demonstrated historic buildings, structures and spaces are vulnerable not only to climate change, but the infrastructure created to protect them. Therefore, consideration should be given to whether its immediate area and whether the dwelling located in a floodplain or an area that is at high risk from flooding. The granting of consent to carry out works to protect a historic structure from flooding will be influenced by the impact of the proposals on the architectural, evidential or historic interest of the site. In some cases, such as Ironbridge, the building and insurance industries’ standard procedures for making buildings habitable again after a flood can be damaging to the special architectural, historic interest. The world heritage site has relied on temporary barriers to protect it during recent devastating floods. Permanent flood alleviation infrastructure has been denied due to its special historical and scientific significance meaning that temporary barriers are a better alternative in order to preserve its special historic and architectural quality. Proposals that affect character and setting are concepts deeply entwined in both planning and heritage protection frameworks. This is important for historic buildings and other features that are located near rivers or on the coast and have close links to the water environment, which will require novel approaches to heritage management. In the past water meadows, for example, have been a feature of many English river valleys and helpfully act as temporary water storage facilities in times of high tide.
Flood defence infrastructure can also contribute to impacts on archaeology through altering ground conditions with potential implications for paleoenvironmental remains. Paleoenvironmental remains are key to understanding past environments and how climate change affected people in the past. Floodplain environments can also illustrate the varied nature of archaeological remains encountered in dynamic coastal and river environments threatened most by the effects of climate change. These remains such as organic deposits, wooden structures and relict channels, tell the story of climate change, flooding and coastal erosion and one that can span hundreds of thousands of years.
The threat of flooding, especially in places which have been on built historic floodplains will continue to become more intense and destructive in the future, and with that many historic places are at risk of flooding as well as coastal change. Heritage professionals are working together to produce effective responses to the impacts of flooding to the historic environment by using lessons from the past to provide holistic approaches to land and building management. Heritage, by default is resilient by the fact it has survived, and we must support the local communities within these rich historic landscapes to adapt to our ever-changing environment.