Planning matters blog

Town and City Centre Living - Environmental Challenges and Opportunities

Emma Callaghan 30 Nov 2023

This is the third in Lichfields’ blog series on town and city centre living. It looks at the environmental factors to be considered and addressed when promoting strategies based around the growth of residential populations in our centres.

In our last blog Ryan Barrett and Jennifer Heron looked at the demographic groups who are choosing to live in town and city centres, identifying that demand is already strong among younger age groups, and there is obvious potential for the market for city centre living to grow among older generations.

There is, however, more limited evidence of interest in city centre living among those with families – and while research in this area is quite limited, it appears that environmental factors, and concerns about what it would be like to live in town and city centres might be acting as a barrier to success in town and city centre living strategies.

The reasons why young people like to live in central areas are well known – and range from high levels of public transport accessibility and enjoying the ‘buzz’ of city centre life, through to easy access to employment, shopping, leisure and cultural facilities. But those with families and older generations have different priorities - and are often more sensitive to the environment around them, whether that be the noise environment, air quality, access to green space, access to healthcare or even real and/or perceived levels of crime.

Noise and Air Quality

Without doubt, urban centres experience higher levels of noise and air pollution than suburban and more rural locations – and this is, in large part, attributable to transportation networks (railways, roads and in larger cities/conurbations, air traffic). In this context, it is clearly important for city centre residential accommodation to be designed in a way which ‘designs out’, or at least minimises the impact of noise and air pollution upon daily life e.g. through the development of higher levels of greenspace in close proximity to residential areas, which recent research[1] confirms results in lower day-evening-night noise levels.

This is particularly important given that there is now much greater awareness of these issues than has been the case in the past and exposure to noise is now rightly recognised as a risk factor related to both physical and mental health. This is, in part at least, due to the lived experience of many people during the Covid-19 pandemic, when lockdown restrictions resulted in huge drops in noise and air pollution[2].

Access to Greenspace

The World Health Organisation states that “urban green space is a necessary component for delivering healthy, sustainable, and liveable cities. Urban green space interventions can deliver positive health, social and environmental outcomes…There are very few, if any, other public health interventions that can achieve all of this”[3].

Of course, green spaces also offer other benefits – and can help address flood risk, mitigate climate change and improve biodiversity. New green spaces for people to enjoy also benefit social and community life by providing additional places to meet and relax[4].

However, an analysis carried out by the environmental charity ‘Keep Britain Tidy’ has revealed that 70% of people who live in UK towns and cities do not have access to good quality greenspace, which rises to 75.8% in the most deprived areas³⁰.

Poor access to greenspace, and indeed amenity / play space, is a particular issue in UK town and city centres – much more so than in many other parts of Europe – and a clear challenge for local authorities wishing to promote town and city centre living – though many authorities recognise this and are actively looking for opportunities to address this issue e.g. through the promotion of ‘pocket parks’. Indeed, although of a different scale, Lichfields has been pleased, over recent years, to support Stockton Borough Council in its promotion of a new Urban Park in the heart of Stockton Town Centre. This scheme, on the site of a former shopping centre, will create new green space within the town centre, including new play equipment and other recreational spaces, and support other initiatives aimed at diversifying the mix of uses, including new residential development, within and around the centre.[5]

Image credit: Ryder Architecture

Crime

Crime – or the perceived risk of crime of crime / threat to personal safety / security - is another environmental factor which influences public attitudes towards living in town centres, and from Lichfields’ wider experience working across town centres around the UK, we know that many people share concerns that incidence of public disorder and anti-social behaviour are much higher in town centres – and this contributes to a sense that town centres are not a safe place to live.

However, on the basis of recent analysis of UK Crime Statistics (April 2022) undertaken by Lichfields as part of an analysis of a range of large town and city centres across the North East and Yorkshire region, these concerns are not necessarily reflected in the available data on reported crime. Our analysis of 5 different centres identified that in broad terms, levels of reported crimes are very similar across both town centres and the wider local authority areas they form part of.

Levels of crime were essentially the same in town centres as elsewhere. More specifically:

Public Disorder: marginally higher (around 3%) in town centres than wider local authority areas;
Criminal Damage and Arson: marginally lower (around 3%) in town centres than wider local authority areas; and
Anti-social Behaviour: marginally lower (around 2%) in town centres than wider local authority areas.

Access to Health and Education Facilities

Those who don’t currently live within town or city centres often have concerns that, if they were to live in a more central location, they would have reduced access to health and / or education facilities. However, such concerns are not necessarily borne out in reality.

In terms of the population as a whole, 94% of people residing in urban centres areas live within a 20-minute walk of a General Practice (GP). This compares with rural areas, where just 19% of people live within a 20-minute walk of a GP surgery[6].

In relation to access to educational facilities, colleges and universities are often located in urban centres, while the high levels of public transport accessibility in town and city centres mean that, certainly, in terms of secondary education, schools are typically quite accessible. Access to primary education can be more problematic as few primary schools are located in centres – but generally educational facilities are accessible from town and city centres – and more accessible than rural areas.

City Centre Living in Practice

Many larger urban authorities in the UK have started to develop strategies aimed at promoting city centre living in recent years – and while each local authority takes a slightly different approach, they all generally highlight the importance of the wider environment. Glasgow City Council first developed its City Centre Living Strategy in 2014 and the strategy was updated in 2020 to see the city through to 2035 with an aim to double the population living in the city centre. The Glasgow approach seeks to identify different character areas within the different parts of the city, and then set out specific recommendations on the approach to be taken to promote residential development / communities in each area – ranging from dealing with vacant commercial floorspace to wider place-making and environmental improvement strategies.

Smaller towns are also getting in on the act. Stockport Metropolitan Borough Council launched its Development Framework for Town Centre Living in 2018 and provides a clear understanding of what needs to change in order to create the right conditions to promote residential development in the town centre and it clearly identifies the need for improved access to amenity space / greenspace to support town centre living, whilst also highlighting that this can have implications for development viability.

Challenges and Opportunities

It’s clear therefore that environmental conditions are important in shaping people’s views on living in town and city centres – and consideration of the wider environment is key when developing residential uses in central areas and strategies aimed at promoting town / city centre living.

Factors such as noise, air quality and access to greenspace are all significant challenges but are all issues that can be addressed through good planning and design. In other respects, town and city centre environments offer distinct advantages – not least by being well connected and offering convenient access to health and education facilities, as well as shops, services, arts and cultural events – and can often support a high quality of life. Furthermore, at least at a statistical level, crime is no more of an issue in town and city centres than elsewhere – though public perception of crime is probably still an underlying concern for some.

Our experience at Lichfields over recent years is that where the environment is right – or at least there is a plan in place to create an environment where people want to live – there is commercial interest from the development sector in promoting city centre living. Our challenge as planners – both through development management and plan preparation is to make the most of this opportunity by creating environments where people choose to live.

In our next and final blog in this series – to be published next week - Isaac Vango will explore the economic benefits that town and city centre living can unlock.

[1] https://www.centreforlondon.org/blog/noise-pollution-why-it-matters

[2] https://www.centreforcities.org/reader/city-centres-past-present-and-future-their-evolving-role-in-the-national-economy/the-performance-of-city-centres/

[3] https://greenflagaward.org/news/environment-charity-reveals-green-space-gap-as-northsouth-divide-identified/

[4] https://www.planningyourworld.org.uk/what-can-planners-change/access-to-green-spaces/

[5] https://lichfields.uk/content/products/revitalise

[6] https://sma.org/the-uk-national-health-service/

The big squeeze: Reading Local Plan partial update

Florence Leung & Sarah Moorhouse 28 Nov 2023

Reading Borough Council strategic environment, planning and transport committee resolved to approve the ‘Local Plan partial update consultation on scope and content’ for consultation on November 15. The consultation process has commenced and will run until January 2024.

Although not (yet) a city, Reading has been named one of the best places to live in the South East and over the past decade has experienced population growth of nearly 12 per cent – much higher than the average for the South East (7.5 per cent) and England (6.6 per cent).

Reading Borough Council (RBC) adopted its current Local Plan in 2019 and is currently undertaking a partial update to address future growth. This includes reviewing policies on housing and employment as well as current -and potential future- site allocations.

Reading is one of the 20 largest urban centres in England where a 35 per cent uplift to the housing need figure calculated using standard method is applied. This uplift, dating back to the aftermath of the 2020 White Paper is a uniform percentage increase based solely on the identified housing needs of the 20 largest towns and cities, rather than their abilities to meet such needs.

RBC states that, based on most recent figures, there is therefore a need for 877 homes per year in Reading up to 2041, a substantial increase from the existing plan figure of 689 per year.

RBC has commissioned its own evidence to understand what the need for homes would be using an alternative methodology, rooted in local need, so this matter may be revisited further down the line.

Where shall we live?

As set out in our ‘Your Official Top 20’ blog, Reading has already built up to its boundaries with some other development needs already being met on adjacent land in neighbouring authorities.

RBC acknowledges this in the consultation document, recognising that future development proposals will rely almost wholly on previously developed land and that the spatial strategy is to a large extent dictated by where sites are available.

Further to this, RBC also acknowledges that there is a general expectation that figures for housing provision are likely to increase whilst needs for commercial forms of development are not expected to significantly increase. Therefore, they anticipate that housing needs will become more dominant than employment needs in the borough over the coming years.

How shall we live?

In addition to overall levels of housing need, RBC is also looking at the different types of housing need, including affordable and family-sized housing, and the needs of other specific groups.

Existing policy places an emphasis on delivering family housing of three or more bedrooms but, as noted in the consultation document, this is difficult due to the emphasis on high density town centre sites and therefore current family housing needs are not being met.

Notwithstanding this recognition of the current constraints, changes to policy being explored include an increase in the policy requirement for three or more bedroom dwellings in town centre proposals from five to 10 or even 15 per cent.

This is alongside the suggestion that policy should explicitly state that in the event of conflict between meeting minimum densities and delivery of family housing, family housing will take priority. On sites outside centres RBC is proposing increasing the requirement for family housing from 50 per cent to 67 per cent.

The consultation document highlights that Build to Rent (BtR) will continue to have a role to play in housing development in Reading and proposes no change to the policy guiding the provision of student housing.

It also introduces the option of a new policy on co-living. As set out in our co-living blog, this is a type of community housing in which residents share facilities such as kitchens, bathrooms and living rooms which has emerged in recent years – primarily to date within Greater London.

RBC notes that ‘we have not yet dealt with any applications for co-living in Reading but . . . we expect to see proposals in Reading within the plan period’.

The council goes on to note a number of matters they anticipate will need to be addressed with this new form of housing including differentiating co-living from more traditional HMOs and student accommodation, such proposals competing with general residential schemes for sites and the relationship between them and affordable housing provision.

The big squeeze?

So, how does RBC intend to deal with its rising housing need, given the spatial constraints and widening range of housing needs?

The consultation document states that RBC proposes to place ‘an even stronger focus on Central Reading’ with the proportion of new homes to be delivered in the town centre anticipated to increase from around 50 per cent to 60 per cent through the Local Plan review. There are two elements outlined in the document to achieve this:

Higher density in the town centre – including setting a minimum density for development in the town centre at 200 dwellings per hectare (dph) – doubling from the indicative density of above 100 dph in the adopted Local Plan; and
Assessing a number of potential sites in Central Reading for consideration as additional housing/mixed use allocations.

But will this be enough to meet the required housing provision for the plan period?

A number of options are set out in the consultation document for each of the potential additional site allocations including the density and use of each site (the analysis for which is at an early stage).

Higher density development is often associated with taller buildings and to achieve the highest housing density options on the additional allocations, in many instances, there will be a need to build tall buildings on the sites.

However, the adopted Local Plan restricts the construction of tall buildings to three specific cluster areas in Central Reading and only one of the potential additional site allocations is within one of these clusters.

The consultation document states that the adopted tall buildings policy is up-to-date and it is not currently part of the partial review.

The council meeting on November 15 is the next step in a long road towards the adoption of the Local Plan partial update, with further evidence still to be prepared, responses to the consultation process to be reviewed, possible changes to Central Government policy to address and ultimately a key role for the Local Plan inspector.

Can this partial review of the Local Plan address Reading’s housing requirements, meet the needs of a widening range of housing types and achieve higher density in the town centre without placing an increased reliance on tall buildings?

The emerging Local Plan process will be the forum for this debate.

Autumn Statement 2023: will tax cuts prove good for growth as well as for party politics?

Edward Clarke & Ed Welch 22 Nov 2023

This year’s Autumn Statement was promoted by the Chancellor as one of optimism. Less than two months ago, the Chancellor warned that tax cuts would be virtually impossible. However, in the lead up to next year’s election, the Chancellor delivered a highly politically targeted Autumn Statement with the Conservative’s record in power defended and debated from either side of the house, with dividing lines being drawn. The Chancellor claimed that: enabled by the priorities and stability set out a year before, the economy is “back on track” and able to sustain personal and business “tax cuts” before the next election.

The good news - that emerged over the last month - and was celebrated by the Government is that inflation is lower and public sector finances are healthier than expected, providing the Chancellor with £27bn fiscal head room. The Autumn Statement provides a platform for the Government to set out how they plan to spend it.

Progress against the economic priorities

Economic Growth

The top priority - agreed by both political parties - for the country’s economy is growth. Although real GDP is set to marginally outperform March’s OBR forecast in the short term (figure 1 ), growth in 2024 is expected to be just 0.7%, compared to 1.8% forecast in March, and in 2025, growth is forecast to be 1.4%, rather than 2.5%. All this means that “Real GDP per person remains 0.6 per cent below its pre-pandemic peak and in the central forecast only recovers that peak at the start of 2025”. This will remain the key long term challenge for the rest of this and the next Parliament.

Figure 1: Real GDP forecast

Borrowing less

The key fiscal target the Government set itself, is that public sector net debt (excluding the Bank of England i.e. associated quantitative easing measures) will fall in the final year of the forecast (2028-29 in this forecast, figure 2). Using the OBR’s central forecast, this target is met, albeit this is due to underlying forecast changes that reflect lower borrowing in cash terms in 2027-28 rather than policy decisions set out in the Autumn Statement, which instead will offset some of the improvements in headroom. The OBR reports that almost all of the headroom will be spent on National Insurance Contributions, business investment tax reliefs and welfare reforms, “leaving debt falling by a narrow margin in five years” in keeping with the Government’s pledge.

Figure 2: Public sector net barrowing

Inflation down

The Government also set itself the target of halving inflation. This is also on course to be met, with the October rate at 4.8%, down from 11.0% a year ago, and with ‘core inflation’ falling. Although others will debate whether Government measures have a significant impact on this, as opposed to the economy more generally and interest rates set by the Bank of England, the OBR do say that measures will reduce inflation further.

However, this good news had sceptics reaching for the OBR’s independent analysis on inflation “We…expect inflation to remain higher for longer, taking until the second quarter of 2025 to return to the 2 per cent target, more than a year later than forecast in March.” Indeed, as figure 3 shows, the OBR forecast inflation to hit the long term Bank of England 2 per cent target in the second quarter of 2025, about a year later than forecast in the latest Budget (March 2023).

Figure 3: CPI inflation

The Headline Measures

The messaging for the Autumn Statement was clear: “backing business and rewarding workers for growth”. The headline measures therefore were:

Cuts to National Insurance contributions - the main rate for employees will be cut from 12% to 10% from 6 January 2024.
Invest for less – businesses will benefit from full expensing (invest for less) becoming permanent.
Maintaining the triple lock for pensions – meaning the state pension will increase by 8.5% in April 2024.
Welfare reform launched - benefits to rise but alongside stricter return to work expectations, especially for the hugely increased numbers of people unable to work due to ill health.
Increase in the minimum wage - the national living wage will rise to £11.44 an hour, up from £10.42.

The counter narrative, as the Opposition set out, is that the higher fiscal headroom, that enables tax cuts and the Government to keep to its deficit promises, is predicated on real term cuts of between 2.3% - 4.1% a year after 2025 amongst ‘unprotected departments ’ following the last spending review period (and most probably following a general election).

It is also noted that the drop in National Insurance contribution rates is somewhat tempered by the ‘fiscal drag’ of frozen income tax? brackets that, by 2029, are expected to create 4 million new income tax payers and £45bn in tax receipts.

The outlook for the development industry

Supply Side Reforms

While the headline tax cuts will be welcomed ammunition for Conservative MPs in the run up to the election, the Chancellor will have also been concerned about the risk of re-stoking the temperamental inflation rate by putting more money in peoples’ pockets. To that end, he has looked to target his cuts and spending to promote growth: encouraging investment and expanding the nation’s productive capacity.

Often critiqued as being a break on investment and development, the planning sector was once again the target for a number of these supply side measures, with a particular emphasis on encouraging investment on energy infrastructure, commercial projects and new housing.

New funding was announced for the areas already earmarked for significant housing delivery in DLUHC’s Long-Term Plan for Housing published in July. As part of the proposals, housing delivery in Leeds and East London’s Docklands will be accelerated, while a new ‘urban quarter’ will be delivered in Cambridge.

Additionally, a new £110 million Local Nutrient Mitigation Fund to help unlock development sites currently constrained by nutrient neutrality rules by offsetting nutrient pollution from housing development. DLUHC estimate that the funding will help to unlock 40,000 homes over the next five years and will be welcomed in areas that have seen stasis since the nutrient neutrality decisions.

A third round of the Local Authority Housing Fund will also begin in 2024, providing £450 million to assist local authorities in obtaining affordable housing for those on resettlement schemes. It is estimated that the fund will help to provide a further 2,400 affordable homes across the UK.

Aside from the promises of new funding were proposals to reform the planning system for commercial and infrastructure projects. At the centre of these plans was the proposal for an Action Plan to halve the time to build new grid infrastructure to seven years and accelerate the UK’s movement towards net zero.

Proposals incentivising households living close to new energy infrastructure to accept developments, by providing money off their energy bills, and reforms to the grid connection process to remove wait times for significant energy infrastructure projects were also introduced.

A new premium planning service for businesses in England will be set up, allowing businesses to pay extra to guarantee accelerated decision dates for major applications and fee refunds wherever these are not met.

The Government are also consulting on introducing a new Permitted Development Right that would allow for the subdivision of houses into two flats without requiring prior approval, to be introduced in 2024.

Levelling up and economic development

The Government announced further support for UK high streets by maintaining a freeze on business rates for small retail, hospitality, and leisure businesses which was introduced in the wake of the pandemic. However, the standard business rate multiplier will be uprated in line with inflation which will hike up rates for almost two-thirds of businesses on the high street.

Earlier this week, the Government announced the award of around £1bn in the third round of its flagship Levelling-Up Fund (LUF). The package was the first of the three rounds to be uncompetitive, with funding distributed to 55 high scoring but unsuccessful bids from Round 2 which concluded in August 2022. The focus of Round 3 has been on regeneration and transport orientated projects, with a further £100m of funding to be subsequently allocated to cultural regeneration projects. However, given the shifts in the macro-economic landscape and the high inflation since the searing heat summer of 2022, there are concerns over the financial viability of projects first put forward in Round 2. The allocation of LUF funding will only be confirmed after consultation with Councils and a re-scoping exercise to ensure the projects remain viable.

An expansion of the Levelling-Up Partnerships programme, which brings together public and private partners to deliver targeted Levelling-Up investment, was also announced. This included an £80 million package to expand the programme to four local authorities in Scotland, as well as a further £50 million to support regeneration in Bolsover, Warrington, Monmouthshire, North Norfolk, Eden, and the Isles of Scilly.

Following the launch of the third of 12 English Investment Zones in West Yorkshire yesterday, the Chancellor launched a further three Investment Zones in the West Midlands, East Midlands and Greater Manchester. The West Yorkshire Investment Zone will be focused around the region’s life sciences cluster while the others are targeted at promoting advanced manufacturing and have already received anchor investment from the private sector. As part of the launch, the Chancellor announced that the Investment Zones programme in England will be extended from five to ten years and that the investment and tax relief offered to each Zone by Central Government will also be doubled from £80 million to £160 million.

Further devolution deals were announced for the West Midlands and Greater Manchester Combined Authorities and include a commitment to implement a single funding settlement for both authorities at the next spending review. Level 3 devolution deals as set out in the devolutionary framework, were agreed with Greater Lincolnshire and Hull and East Yorkshire, while non-mayoral Level 2 deals were agreed for Cornwall and Lancashire.

Housebuilding

With the LURA recently passed offering new planning ‘hardware’ for change, and the upcoming NPPF update providing new policy ’software’, it is also notable that the OBR’s forecast for mortgage rates and house prices were also updated. The longer tail of high mortgage rates (figure 4) will be a significant concern to the industry and a reflection of the persistent inflationary forecast.

Figure 4: Mortgage rates and house prices

The combined effect for the development industry is acutely concerning, the OBR housebuilding forecast shows a significant drop in housebuilding both from today’s already low rates and March’s forecast. The result is that housebuilding is set to drop to 199,100 in 2025/26, almost 30,000 down on March’s forecast and just two thirds of the Government’s target (figure 5).

Figure 5: OBR housebuilding forecasts March vs. November

Conclusions

The Chancellor took the opportunity today to celebrate that the economy is primed for growth and used the resultant headroom to offer pro-growth tax cuts and investment boosting measures. This seemingly positive news however was cast against a troubling economic outlook in the OBR’s forecasts; together, persistent low economic growth, low productivity and lingering inflation will bring serious challenges for the remainder of this and the next Parliament.

This economic outlook and the drop in housebuilding shows the importance of the upcoming policy and legal changes to the planning system, through the NPPF and LURA, both to the development industry and as part of the Government’s push for economic growth more widely.

As easy as child's play? Addressing London's play space requirements

Clare Catherall & Josh Hymer 21 Nov 2023

The provision of safe, stimulating and inclusive play space is a critical planning issue that can often be the making of or… breaking of… a successful planning application. When done right, play can help support children and young people’s development and mental and physical health, as well as delivering high quality placemaking that benefits all ages.

In London (home to over 2 million residents under the age of 18[1]), play space needs to be delivered within the limitations of spatially constrained sites, requiring design imagination and a careful balance with other space demanding design and policy requirements within a scheme. When it comes to play space provision in the capital, quality is as important as quantity.

At a strategic level, the policy requirements for play are set out within Policy S4 (Play and informal recreation) of the London Plan (2021) and the somewhat dated^[2], Shaping Neighbourhoods: Play and Informal Recreation SPG (September 2012). At a local level, more detailed policy criteria is provided within Local Plans or SPDs.

Given that 2023 marks the 2-year anniversary of the London Plan, and in anticipation of a new London Planning Guidance (‘LPG’) document[3] on play space to supersede the 2012 SPG[4], we reflect below on the key planning issues that are commonplace with the delivery of play space for London’s development and provide our insight on best practice and lessons learnt.

The Population Yield Calculator

You cannot have a conversation on play space without first understanding the GLA’s Population Yield Calculator (which superseded the previous GLA Play Space Calculator). In short, it works by modelling the variables listed below to produce a child yield and play space requirement (based on 10sqm per child), split by age group.

Number of homes
Unit mix (1 bed (inc Studio), 2 bed, 3 bed, 4 bed+)
Tenure mix (note- intermediate homes are counted with private homes)
Geographical aggregation (London, Inner London, or Outer London)
PTAL (0-2, 3-4 and 5-6).

Typically, the highest play space requirements come from schemes with more homes (of course!), larger unit sizes, a greater proportion of Social Rent homes, ‘Outer London’ Geographical aggregation and lower PTAL. The difference in play space requirements can be quite dramatic, even for a modest 100-unit scheme, as illustrated in the table below:

This notional example illustrates how developments that offer the greater public benefit from housing (e.g., more social rent homes/ family sized homes) must deal with more onerous child play space policy requirements (than an open market equivalent). This can mean that schemes which deliver a high proportion of affordable housing (including Estate Regeneration projects) must work harder to balance other policy requirements and deliver a viable scheme.

It is worth noting that some LPAs use their own versions of this calculator, with the London Borough of Tower Hamlets, for example, having a calculator that removes variable such as geographical aggregation and PTAL, applying a consistent standard across the borough, regardless of accessibility.

In this context, it can be useful for developers and the design team to consider the above variables at an early stage when working on the design of schemes and engage with planning officers at the earliest possible stage to discuss the challenges, particularly on schemes that will provide a high proportion of affordable housing or larger unit sizes.

Older Childrens’ Play Space (12+)

Play space requirements are not homogenous and are split by different age groups (0-4, 5-11, 12-15 and 16-17).

Understandably, the London Plan has an onus on ensuring that dedicated and integrated play space for younger age groups (0-4 and 5-11) are delivered on site, given the need for door stop play with easy access and passive surveillance. However, for older age groups (12+), there is greater policy flexibility with capability for offsite provision, particularly where there are existing facilities nearby (e.g., parks), given that delivering appropriate play facilities (e.g., a sports court) can be challenging and can lead to conflicts with the amenity of residents, particularly around noise.

Accordingly, the London Plan (para 5.4.6) supports the principle of off-site provision through an appropriate financial contribution (either via CIL or in the S106 agreement), stating:

“Off-site provision, including the creation of new facilities or improvements to existing provision, secured by an appropriate financial contribution, may be acceptable where it can be demonstrated that it addresses the needs of the development whilst continuing to meet the needs of existing residents. This is likely to be more appropriate for the provision of play facilities for older children, who can travel further to access it, but should still usually be within 400 metres of the development and be accessible via a safe route from children’s homes. Schools, school playing fields and other facilities can also provide an important contribution to play and informal recreation facilities and should be encouraged to allow community access to facilities out of hours.” (Lichfields emphasis)

Whilst we find that LPAs are typically supportive of offsite 12+ play provision, we would caution that satisfying the need for existing older play facilities to be within 400 metres of the development, can prove to be stumbling block for developers, particularly in areas of insufficient existing provision. We would therefore always encourage clients and design teams to explore local provision early in the due diligence process and design feasibility so the principle of an approach to older play can be agreed with an LPA during pre-app engagement.

Balancing play space with other policy requirements

The provision of play space, particular on small urban sites, can lead to design challenges and tension, when balanced against other competing policy requirements, including providing sufficient open space for residents to use, meeting Urban Greening Factor requirements (residential schemes in London should hit a score of 0.40) and, for schemes approved from January 2024, providing Biodiversity Net Gain of 10%+.

We find this can be a tricky issue as there is an inconsistency of guidance across LPAs whether dedicated and integrated play facilities need to provide on-site for all age groups and/or if more incidental play space provision can be delivered in public realm which can also be used as, and count towards, open space. Often green spaces are multifunctional in nature, providing space for play, recreation, biodiversity enhancement and visual amenity. In this context, there can be debate on how play space is counted within a multifunctional space.

We encourage all developers and design teams to carefully consider the feasibility of meeting children’s play space and other policy requirements early in the design process and look for any opportunity for these spaces to serve multiple purposes, where appropriate, without overloading the development and diminishing from the scheme benefits.

Design Considerations

Anther issues for residential schemes in London, particularly those schemes with tall buildings, is where to locate the play space?

This is arguably more straightforward for larger sites where ground floor or podium level provision is an option as it typically allows a safe play environment with passive surveillance from surrounding homes, however, this needs to be carefully balanced with any noise amenity issues of existing residents particularly, those with private amenity space facing out on the play environment.

It can, however, be more challenging for constrained sites, say where a single tall building is proposed, as provision at grade or podium level is just not feasible and therefore alternative play options need to be explored, including terraces, internal or roof level play. Whilst the London Plan does not stipulate a preference in location, there is a difference in the approach adopted by LPAs which need to be considered early in the design process; for example, some LPAs may not be supportive of roof level play due to fire safety concerns, access and microclimate.

In any design solution, careful consideration needs to be given to accessibility to ensure there is no segregation in access to play space by tenure; for example, in a mixed tenure scheme both affordable and market residents must have equal access to the same play spaces. If play space is located a podium or roof level this can sometimes be more difficult to achieve.

Build to Rent and Co-Living

As many reading this will be aware, there has been a pronounced shift in London’s residential market over the past couple of years with growth in the Build to Rent and Co-Living sectors, compared to traditional homes for sale. This in turn, raises questions for both developers and LPAs on play space provision requirements.

Build to Rent is a C3 use and is treated the same way as traditional the homes for sale model. The only nuance is that the affordable housing requirements for Build to Rent comprise Discount Market Rent homes, a proportion of which is let at London Living Rent levels (i.e., an intermediate product); therefore, the play space requirements for such schemes would be lower than a mixed tenure for sale scheme providing social/affordable rented homes. Of course, BTR typically (but not exclusively) has a greater market demand for smaller unit sizes which in turn results in lower play space requirements.

Co-Living is markedly different given that is a sui generis use targeted towards single person households. As such, it does not attract a requirement for play space.

Gender Inclusive Play Spaces

Increasingly (and as touched on in my colleague, Georgia Crowley’s blog) we are (understandably) seeing greater attention from architects, developers and local planning authorities in providing less gendered play environments that are welcoming for girls and young women, as well as boys[5]. This is also reflected in the GLA’s Women, Girls and Gender Diverse good growth by design report[6], albeit the focus of this report is focused on safety in public space rather than how play space itself is designed to be gender inclusive.

Examples of LPAs at the forefront on this include Tower Hamlets in their Regulation 18 consultation version of their emerging Plan (here)- see Policy PS5 Gender inclusive design We would anticipate this policy direction to continue from other LPAs in their Local Plans and the GLA when they issue their updated SPG/ new LPG on Play Space.

We would therefore encourage developers to plan for this early in the design process and be cognisant of changes to policy both at a strategic and local planning authority level.

Conclusions

Play space important design consideration: The provision of safe stimulating, and inclusive play space is an important design consideration that needs to be designed into schemes at an early stage rather than as an afterthought. Developers should be aware of the implication of changes to housing numbers, mix and tenure on child play space numbers and requirements.
Offsite provision for older children: It is important to check early in the design process the location of the Site in relation to existing play space facilities and any identified under provision in the locality. Where necessary, we encourage agreement on the principle of offsite provision for older age groups is established through pre-app discussions with the LPA and any other relevant statutory bodies.
LPA variance in policy requirements: We recommend an early review of any local policy requirements and nuances on design and location of play space, particularly around rooftop and internal play options and acceptability of informal play provision in the public realm. We also recommend checking any LPA-specific play space calculators as these can yield different results to the GLA’s population yield calculator.
Alternate residential products: If schemes with Build to Rent are being explored, it is important to be aware that play space provision may be required and should be included in the scheme’s design.
Gender Inclusive Play Spaces: Consideration should be given at the earliest possible stage to providing gender inclusive play environments (especially for older children), that are welcoming to both boys and girls. We anticipate this will be the direction of travel for policy guidance going forward.
Possible update/replacement of the Shaping Neighbourhoods: Play and Informal Recreation SPG (September 2012): Finally, we would recommend keeping an eye out for any update to the GLA’s current play space Playspace SPG, to bring it in line with the London Plan 2021 and provide further guidance and direction for developers. We certainly hope that updated guidance encourages a focus on quality rather than the mechanistic application of play space standards.

The delivery of good quality play provision is increasingly recognised as a central tenet of successful housing schemes across London. London’s two million children and young people all deserve safe, stimulating and inclusive play space close to home. The planning system has a critical role to play in ensuring that good quality, appropriately located play is delivered across the capital. As ever, the Lichfields’ team is well placed to advise on your project’s play space requirements and on all other planning matters. Please do get in touch.

[1] ggbd_making_london_child-friendly.pdf

2] We understand from the ggbd ‘Making London child friendly’ that a new London Planning Guidance Document is on the way.

[3] There have been 17 draft or adopted LPG documents in the past 2 years.

[4] See London Plan (para 5.4.5) and the Making London Child Friendly, Designing Places and Streets for Children and Young People, Good Growth by Design Document

[5] For further information see: (for further information, please see my colleague, Georgia Crowley’s Blog: Breaking the biases in gendered urban environments).

[6] Safety in Public Space - Women, Girls and Gender Diverse People Revision A_0.pdf

Planning matters