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Guidance, Guidance and More Guidance: A bibliography of the new London Plan Guidance
As we reported in this blog earlier in the year, the GLA has recently published a raft of London Plan Guidance (LPG) documents. These LPGs were published to provide guidance to the application of the London Plan policies. At the start of the year, eight LPGs were out for consultation and nine others were expected to come down the line during 2022. Lichfields provided a Bibliography of the new London Plan Guidance at the time (the original can be viewed below). We also undertook a detailed look at the suite of Design and Characterisation documents published in February in our blog 'A test of Character'. As the year now comes to an end, we have again reviewed the status of the newly adopted and emerging LPGs, keeping you abreast of the documents that will be in play in the new year and key dates for your 2023 diaries: 2023 will see at least eight new LPGs adopted. Many are anticipated early in the new year, with several others to follow. All of these documents and the guidance within them will need to be considered and addressed in emerging developments and assessed within planning applications. It is important to ensure that these guidance documents are considered early in the design development process and they are evidenced and addressed in pre-application discussions and applications. As our previous blog noted, there is considerable new guidance to take on board on top of the already-lengthy London Plan. Lichfields continues to monitor the progress of these documents, ensuring we are able to advise on and respond effectively to the new requirements for all of our London projects. Keep an eye on our future blogs for further updates…   Adam Donovan 15 Mar 2022   February has seen the GLA publish a further suite of guidance documents in support of the London Plan. You would be forgiven for having a sense of deja vu as in the past 18 months, the GLA has published no less than fifteen London Plan Guidance (LPG) documents for consultation. Nine of these LPGs have been published since the publication of the London Plan in March 2021. For a development plan which was already stretched to 526 pages (including annexes) that is a lot of additional guidance to take on board. And that is not the end, it is understood that there are a further nine LPG documents which will be consulted on during this year. The tables below provide a list of these LPG and their current status. Keeping up with the guidance documents is important for those working in the London development market and bringing forward planning applications. The detail contained within some of the LPGs are changing the requirements for planning applications and expanding the list of documents which applicants need to submit. Circular Economy Statements, fire safety and urban greening factors are issues which Officers are looking at in considerable detail. An applicant’s ability to respond effectively to these requirements is key to the progression of schemes through pre-application discussions, validation and determination.  Some of the LPGs are targeted at developers and applicants whereas others are to support Local Planning Authorities in the preparation of their Local Plans and development management. Inevitably these documents will have an impact on the viability and feasibility of future schemes which will need to be carefully considered. My blog - A test of character: London’s new design guidance - takes a detailed look at the suite of Design and Characterisation Guidance documents which were published in February and out for consultation until 27th March 2022. Following the current consultation, we expect a further nine documents to be published before the end of the year. Looking ahead, we will provide updates on the publication of future guidance and prepare blogs on each of the LPGs to help you navigate your way through the process.   Previous consultations Current Consultations Anticipated Future Consultations Header image credit: Greater London Authority    


A test of character: London’s new design guidance
The New Year has brought in a new wave of London Plan Guidance (LPG) published by the GLA which are currently out for consultation. The five current LPG are: Large-scale Purpose-built Shared Living Guidance     Characterisation and Growth Strategy     Small Site Design Codes Optimising Site Capacity: A Design-led Approach Housing Design Standards All of these documents are currently out for consultation until 27th March 2022 and this blog focuses on the final four which fall under the heading ‘Design and Characterisation Guidance’. The four design and characterisation LPG were previously ‘modules’ of the Good Quality Homes for All Londoners Guidance which was first published for consultation between October 2020 and January 2021. Since the original consultation, the documents have been revised to each become a separate LPG and are now the subject of a fresh consultation. The consultation period for each of these documents closes on 27th March 2022 and the GLA intend to adopt the guidance in Autumn / Winter 2022. The documents form part of a growing list of London Plan guidance which have been published in the last 18 months. My related blog, Guidance, Guidance and more Guidance, provides an overview of these documents as well as a list of what else is in the pipeline.   Contents In combination, the LPG provide detailed guidance on design and urban characterisation for London residential schemes. There is a clear focus on residential quality and design both at the plan making and decision-making stage (particularly for applications that fall into the major development category) and the documents together provide a step-by-step approach to moving from the plan making level to detailed design. A brief summary of each of the LPG’s is set out below. Characterisation and Growth Strategy This document is intended to assist local planning authorities (LPAs) and neighbourhood planning groups in undertaking characterisation assessments and formulating a growth strategy for their area in accordance with the requirement of London Plan Policy D1. Whilst it is targeted at LPAs it is an important document for developers and landowners to understand as the methodology contained with the document will be key to the development of Local Plans. The characterisation and growth strategies will form a key part of the Local Plan evidence base, leading to potential site allocations, and will identify key areas for growth and, crucially, include the identification of tall building locations.  The LPG sets out a staged process for the preparation of these strategies. The first is focused around the collection of data relating to socio-economic, housing, environmental, urban form, land use, cultural and heritage considerations. The use of digital tools and data sources introduced by the GLA in recent years is encourage as well as the early engagement with local communities. The outcome and overlaying of this research stage will be a map of character types (also known as ‘area types’ within the National Model Design Code) and the following example is provided: Figure 1: Example of Character Types (Source: GLA Characterisation and Growth Strategy LPG) The second stage is the evaluation of the data to define boundaries and carrying out a quality and sensitivity assessment of each character area. This requires LPAs to split areas into one of three categories of change; conserve, enhance or transform and assess their capacity for growth. It is clear that this reflects the 2020 White Paper ‘Planning for the Future’ in terms of the categorisation of growth areas, in concept if not name. ‘Protected, renewal and growth has become ‘conserve, enhance and transform.’ Figure 2: Example of Areas of Change Map (Source: GLA Characterisation and Growth Strategy LPG) The LPG also requires LPAs at this stage to define what constitutes a tall building and includes a tall building definition for the whole borough based on storey height and AOD. This is directly linked to the requirement of London Plan Policy D9 which requires authorities to identify areas suitable for tall buildings. The LPG goes into detail in providing guidance or how to undertake this assessment and goes further than that which would typically be the case within a Local Plan strategic policies map. The LPG confirms that the Growth Strategy would typically form part of the consultation document for the Local Plan and form the basis for the production of the Small Site Design Code and Larger Site Capacity which are the subject to two other LPGs published for consultation. Figure 3: Extract for Characterisation and Growth Strategy LPG showing the relationship between the LPG Subject to the Feb 2022 Consultation (Source: GLA Characterisation and Growth Strategy LPG)   Small Sites Design Code This LPG is aimed at LPAs in the preparation of design codes for small sites in accordance with the National Design Guide and Policy H2 of the London Plan. A small site is defined as being no larger than 0.25 hectare. The Design Code will follow on from the characterisation and growth strategy and will apply to the character types (‘area’ types) identified in that stage. The LPG encourages the prioritisation of areas where small sites can come forward including the incremental intensification of existing residential areas with higher connectivity, due to proximity to transport infrastructure or town centres. Examples of intensification include back-land, corner infill plots and rooftop extensions. The design codes themselves are encouraged to be primarily visual documents which illustrates the key design parameters in graphical form. The precise content will be dependent on the area and code but could include the following topics:      -  Boundary conditions      -  Building line      -  Front to front and back to back distances      -  Building height      -  Green cover and landscaping      -  Block and building form      -  Roof form      -  Materiality and detailing The final design code will form part of the development plan and be subject to neighbour and stakeholder consultation. Optimising Site Capacity: A Design-led Approach The Optimising Site Capacity LPG follows on from the Characterisation and Growth Strategy guidance. It provides guidance on establishing the optimal design and capacity for large residential and mixed use sites following the identification of the character type. Unlike the preceding two LPGs, this document has a broader target audience in specifically targeting not just plan making LPAs, but also applicants during the design stage of major projects. We are aware of this document being referenced by Planning Officers during pre-application meetings. Stage one of the guidance focuses on the assessment of the existing site in its surrounding context and follows what many architect and planners would consider to be best practice. The analysis should include environmental, connectivity, permeability and access, built form, open space, heritage, building layout and infrastructure capacity. Based on this assessment, the guidance encourages establishing a ‘vision’ for each site, referencing back to the character area including opportunities for tall buildings. Once the vision has been defined, parameters must be established for the site which when followed will lead to the generation of a detailed site allocation or initial scheme design. The figure below shows the recommended parameters. Figure 4: List and sequence of parameters which should be defined for a site (Source: Optimising Site Capacity: A Design-led Approach) These parameters will then provide the basis for establishing a site capacity which is intended to be produced using 3D software such as sketch-up. The 3D model will produce a massing informed by the parameters and constraints. This information can then be inserted into the ‘Site Capacity Toolkit’ which will provide a detailed breakdown of all aspects of the scheme including floorspace, storeys, unit mix and car parking. The images below show the 3D model and how this translates into the Site Capacity Toolkit. Figure 5: Indicative Massing of a Large Site Informed by Parameters (Source: Optimising Site Capacity: A Design-led Approach) Figure 6: Indicative Site Capacity Toolkit Output (Source: Optimising Site Capacity: A Design-led Approach) Once the parameters and indicative site capacity has been determined for a site, the design parameters should be formalised. These design parameters will become a high-level strategic design code for the site and used either at the Local Plan or planning application stage. The LPG recommends that these formalised design parameters can be used within site allocations, neighbourhood plans, SPDs or opportunity area frameworks. At the application stage, the LPG encourages this work to be carried out during the pre-application stage and submitted as part of the planning application. The plan below shows the example of the design parameter output for these two purposes. Figure 7: Example of the Formalised Design Parameters   (Source: Optimising Site Capacity: A Design-led Approach) Housing Design Standards LPG The final LPG - and the most detailed - is the Housing Design Standards guidance. This is specifically focused at developers of residential schemes with the intention of providing additional guidance on how to achieve the policy requirements of the London Plan. The LPG covers three areas: Placemaking and the public realm; Shared spaces and ancillary facilities; and Homes and private outside space and relates to all housing developments which fall within Use Class C3 but excludes co-living. There is too much detail to summarise with this blog and much of the content will be familiar to those working in the residential market in London having been set out in previous GLA documents and guidance. However, what the LPG does do is consolidate the various pieces of guidance into one document and provide a checklist of issues to be worked through during the detailed design process.     Summary These guidance documents continue the trend of the GLA publishing what are quite detailed guidance documents to supplement the (already substantive body of) London Plan policies. Unlike previous LPGs these documents are focused on design and provide a step by step approach to understanding development potential for the purpose of informing Local Plans as well as planning applications. It appears, through this guidance, that the GLA is seeking to introduce a degree of consistency across all Boroughs and hence residential sites in London. This consistency will help LPAs in the development of their Local Plans (assuming they align themselves with the guidance) but also stakeholders and the public in understanding the plan making process. There is a clear focus on embracing technology and making the output graphical and visual. The LPGs all reference the National Model Design Code and build upon the instructions contained within that document. In addition, it is clear that they have also been informed by the 2020 Planning White Paper in terms of the identification of three ‘area types.’ How this will need to change or not once we finally see the response to the 2020 consultation document this year will need to be seen. To some extent, many LPAs will already be undertaking the best practice contained within this guidance but for those that are behind in their plan making, the documents are likely to be helpful in ensuring their plans are consistent with London Plan policy. But with many LPAs are under severe resource pressure so it is not clear how existing policy teams will deal with these additional requirements. For those involved in the promotion of land or the development of schemes for subsequent planning applications there are some things to note. Firstly, there is considerable emphasis placed on the process for establishing appropriate locations for tall buildings in accordance with London Plan Policy D9. Early engagement in this process will be key for those seeking to bring forward tall buildings on specific sites. Secondly, subject to the outcome of the consultation, it is likely that LPAs will use the guidance and particularly the Site Capacity Toolkit when assessing schemes for development. Undertaking this assessment, understanding the implications and associated challenges will be key to optimising development capacity. And finally, utilising the approach in the guidance will assist in the promotion of sites in the Local Plan process. There is a lot to consider here and remember, it won’t be long until the next guidance document is published!   Header image credit: Greater London Authority