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Planning matters

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NPF4, out with the 5-year land supply and in with the Housing Delivery Pipeline
The revised draft NPF4 was approved by the Scottish Parliament on 11 January 2022 and will be adopted and published on 13 February 2023. Once adopted, NPF4 will form the national position for planning policies for decision-making and outline new processes for plan-making at a local level, becoming part of the statutory development plan for each planning authority in Scotland. NPF4 will replace Scottish Planning Policy (SPP) and the Strategic Development Plans (SDPs). NPF4 removes the requirement to maintain a 5-year housing land supply and replaces this with an expectation that the LDP delivery programme will establish a deliverable housing land pipeline for the Local Housing Land Requirement.  Phasing is expected to be identified for the short (1-3 years), medium (4-6 years) and long (7-10 years) term. The purpose of the pipeline is to provide a transparent view of the phasing of housing allocations so that interventions, including infrastructure, which enable delivery can be planned.  NPF4 says the pipeline is to represent when land will be brought forward.  We are all hoping this means when it will be delivered rather than when planning permission will be applied for but that isn’t clear.  As Lichfields have explored before, there are significant lead in times for housing sites and it can be some years from an allocation, to an application, to a consent, to the delivery of new homes.  It should not be underestimated how long it takes to deliver new homes from new allocations By way of illustration we have looked at Edinburgh’s housing pipeline based on the allocations in the 2016 LDP.  If we assume 2017-18 is the first year of delivery after the LDP was adopted (November 2016) we are currently at the end of the medium term period. A quick review of the latest Housing Land Audits shows us that there are a number of housing sites allocated in the 2016 LDP that haven’t yet been developed out and some of these sites were even carried forward from previous local plans. Looking at the 2016 allocations: 53 housing sites were identified 28 of these were existing proposals and 25 were new 24 sites identified in 2016 LDP are to be carried forward into the new LDP, 15 of the carried forward sites were existing sites in 2016 So, looking at how Edinburgh’s 2016 LDP allocations have delivered and are programmed to deliver we can see how this breaks down over the short, medium, long and 10 years plus timeframes: 22% of new homes in the short term 18% of new homes in the medium term 36% of new homes in the long term 24% of new homes beyond the 10-year period A very large proportion of sites identified were already in the planning system before the LDP was adopted in November 2016 Short term sites - 99.6% of new homes - first application was made before the LDP was adopted Medium term sites - 84% of new homes - first application was made before the LDP was adopted Long term sites – 73% of new homes - first application was made before the LDP was adopted All this tells us that lead in times are important in terms of the delivery pipeline and that a large proportion of delivery will be dependent on sites that that are in the planning system before the plan is adopted.  For Edinburgh more than 80% of homes delivered / programmed to be delivered in the 10-year period following the adoption of the 2016 LDP were in the planning system before the plan was adopted. We haven’t yet looked to see if this is uniquely an Edinburgh problem, but it is something the industry needs to be alive to when assessing housing allocations and proposed delivery pipelines. If NPF4 is to deliver the housing that Scotland needs, there will have to be a forensic understanding of the housing pipelines based on past experience as well as future ambitions.


Sky's The Limit: Go Tall to Meet Housing Needs
Whilst the development industry remains occupied by the latest raft of proposed changes to the planning system (see my colleague, Jennie’s Baker’s succinct blog), I cannot help but feel that the persistent political meddling will result in less homes being delivered, rather than more. Whilst the Government continue to bang the drum for LPAs to prepare and maintain up-to-date Local Plans, the recent political turmoil is actually slowing down LPAs from doing this, and the proposed changes to the NPPF dilute the requirement to meet objectively assessed needs in full. This is typified by the consultation on reforms to the NPPF which propose a transitory reduction in the minimum number of years of supply that LPAs are required to maintain for housing, watering down the soundness tests insofar as needs are now met “so far as possible” with strategies no longer needing to be justified, as well as a strengthening of Green Belt protection by ruling out boundary reviews to meeting housing needs (even though the amount of green belt has actually increased over recent years!). By way of offering up some sort of solution, the Government has, however, been making positive noises around the ‘brownfield first’ approach. This isn’t anything new, far from it, and won’t deliver all of the homes we need (see my colleague, Matthew Spry’s musings on this issue), but if we are to optimise the density of brownfield sites then we need to braver and deliver an efficient use of these often sacred pieces of real estate. Whilst doing this we need to be careful not to promote development considered “out of character” with existing context, or out of line with design guides, codes, or supplementary guidance that advocate higher densities (i.e. to address proposed amendments to NPPF Para 11 (b) ii.). The indicative changes to the NPPF now specifically reference uplifts to the Standard Method figures for urban local authorities in the top 20 most populated cities and urban centres. From a London perspective, this shouldn’t be anything new since the London Plan already designates Opportunity Areas (often supported by OAPFs) and there is a requirement in Policy D9 to identify tall building zones (as was originally requested by the Secretary of State in 2020 in the interests of ‘character’ and empowering local communities). It is clear that national policy is being strengthened in this sphere, but does it go far enough on tall buildings and higher density residential? Footnote 30 to the NPPF consultation version states that ‘brownfield and other under-utilised urban sites should be prioritised, and on these sites density should be optimised to promote the most efficient use of land… This is to ensure that homes are built in the right places, to make the most of existing infrastructure, and to allow people to live near the services they rely on, making travel patterns more sustainable.’ – well that sounds simple enough, hurrah! However, having spent my professional career advising on urban development projects, in particular higher density residential schemes and tall buildings, there is usually a default position in most urban communities, local planning authorities and committee chambers that tall buildings are a bad thing, often using heritage, townscape or daylight impacts to beat down heights, or concerns around capacity of local infrastructure provision (whether that be transport, health, education or open space). Of course, our historic environment is important, and so is the ability of our community infrastructure to meet the needs of residents, but does it warrant depriving people of a place of their own whether that be owning, renting or to take them off Council waiting lists and out of emergency accommodation and into purpose built affordable homes? A balance needs to be struck between these competing issues, and we must remember that many affordable homes are brought forward as part of private sector development, including those that include tall buildings. Aside from the typical consideration of townscape and heritage impacts on listed buildings and conservation areas, one restrictive London planning policy in respect of height and density is the protection of ‘Strategically Important Landmarks’ from views identified in the London View Management Framework (LVMF). Published in 2012 as a follow-on to the 2011 London Plan, I would suggest this strategy needs a refresh to ensure it is fit-for-purpose as our Capital’s housing needs continue to go unmet. For example, the continued protection of views towards St. Paul’s Cathedral – is it still a ‘strategically important landmark’ given there are many other buildings in the Capital that allow a viewer to orientate themselves within the City, and it could be said that its setting has already been compromised in medium and longer range views. Just imagine how many additional homes could be provided in some of its viewing corridors! The Mayor’s office don’t seem shy when it comes to preparing new guidance, so I’d suggest a refresh of the LVMF might be a worthwhile exercise. Gentle densification, mansion block typologies and even mansard roof extensions (which have for some reason slipped into the NPPF consultation!) are all ways to deliver beautiful new development in urban areas, but the reality is that tall buildings offer much quicker wins to deliver the market and affordable homes that our communities need, at scale. Comparatively, London is not a tall building city compared to many others around the globe, and our Capital stands out against our regional cities which have few *very* tall buildings, save for a couple of recent developments in Birmingham or Manchester. I was lucky enough to spend 2019 travelling the globe and to my surprise I saw that the rest of the world has made far greater progress on delivering new homes in many a tall building, located conveniently near transport hubs, health and education services, and open spaces for residents to enjoy. You only need to scan some of the world’s leading cities to see that we are lagging behind when it comes to optimising site capacity through the use of tall buildings. Of course, many of our Asian counterparts have higher population densities that dictate such building typologies, and there are some examples of unnecessarily elaborate tall buildings in Middle Eastern cities that were more about architectural statement and status than residential needs, but we could certainly catch-up if the political will was there to support a new-age of ‘beautiful’ tall buildings, designed to achieve the highest sustainability standards to combat the effects of climate change. There has rarely been much concern about going bigger in North America, whether that be your fast-food meal or the tall buildings of New York – in Manhattan alone there have been three very tall residential buildings completed since 2015 which rise in excess of 425 metres. In comparison, London’s tallest buildings are sub-300m, and are often non-residential office uses (see the City of London cluster) or indeed mixed-use (the Shard being the most obvious example). Tall building developments are not straightforward, and there are a myriad of planning matters to consider (viability, design, heritage, fire safety, aviation, wind microclimate, daylight/sunlight and overshadowing let alone how to deliver high performing buildings in carbon terms to combat the climate emergency), but they will certainly help us reduce pressure on green belt and green fields, providing liveable new communities in close proximity to the services that people need. If our elected politicians are going to deliver the homes we need on brownfield land, then they need to introduce specific national policy support for tall buildings within urban areas, in particular the top 20 most populated areas, taking a lead from the London Plan’s approach to strategically planning tall building areas, and winning the hearts and minds of local communities in these areas who could all see the benefit of such development. Perhaps it might be too late for the incumbent Government, but it could be possible for a future Labour administration to put cranes in the air given their typically strong mandates in urban areas – the sky’s the limit when it comes to meeting our housing needs. Lichfields’ has a demonstrable track record advising on some of London’s tallest residential buildings. We are currently advising on the Borough Triangle development in Southwark, a residential-led tall building scheme comprising 838 new homes in buildings up to 46 storeys, a new public piazza, retention and refurbishment of two local heritage buildings, and new commercial space. The proposal is designed by RIBA Stirling Prize winning architects Maccreanor Lavington. The scheme’s two tall buildings will enable the delivery of high quality new homes in an accessible location that has been identified for high density in an adopted Local Plan, coupled with delivery of new public open space and amenity areas, urban greening and other benefits to the local community that will help to reinforce and enhance its opportunity area character. I sincerely hope that more high quality schemes like this will be brought forward to deliver the homes we urgently need in London and urban areas across the country. Image Credit: Maccreanor Lavington, Cityscape, Berkeley Homes (South East London) Limited