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Hotbed of need: What does the new Standard Method mean for London?
Yesterday was officially #planningreformday and as part of this, my colleague Bethan Haynes almost immediately crunched the numbers for the new Standard Method (‘SM’) across the country. The results of can be viewed here. This blog forms part of a mini-series of more in-depth look at the impact of the new SM on different regions of England; in this case London – which is now (unofficially) England’s hotbed of housing need. It sits under an in-depth national blog prepared by Bethan which looks at the new SM and its calculation. The new SM figures The table below sets out all the new SM local housing need figures for all the London Boroughs. It also provides a lot more detail in terms of the average delivery in the past three-years, the emerging London Plan (2019) requirement, and the current SM figure. Overall, London’s housing need figure has jumped from c.56,000 under the current SM to c.93,000 as calculated using the new draft SM: a 67% increase. More importantly, it is c.44,000 homes greater per annum that is set to be required under the emerging London Plan (2019): an increase of 92%. Some highlights to note: Westminster – The City of Westminster sees an increase of 4,254 dpa from the current SM figure under the new methodology (+285%). This is the largest absolute rise in need across the country. Importantly, this is also even greater 4,765 dpa (+484%) against its emerging London Plan (2019) annual average requirement of 985 dpa. Kensington & Chelsea – Under the new SM, Kensington and Chelsea would have the largest increase as a proportion above its emerging London Plan (2019) requirement: from 448 dpa to 2,837 dpa – a +633% increase. Croydon – Along with Barking & Dagenham, Croydon sees a reduction in housing need under the new SM compared to the current methodology: a reduction of 104 dpa (or -5%). Albeit, the new SM is still slightly above its emerging London Plan (2019) requirement. Barking & Dagenham – The authorities old SM was below its emerging London Plan (2019) requirement anyway: 1,944 dpa compared to a local housing need of 1,730 dpa calculated through the current SM. The new SM figure for the borough would be 1,657 units: 73 units less than the current SM and 287 units (-15%) below the emerging London Plan (2019) figure. To help unpack the data, the below map shows spatially the difference (as a proportion) between the emerging London Plan (2019) requirement and the proposed new SM for that Borough. The inner London Boroughs north of the river are particularly affected by the changes to the new draft SM seeing the greatest increases. So are (in general) the very outer Borough’s such as Richmond upon Thames, Sutton, Bromley and Bexley. What does the new SM mean for London? Rt Hon Robert Jenrick himself has made it very clear that he thinks London should be planning for and crucially delivering more homes that the emerging London Plan (2019) currently proposes. The SM would result in a huge jump in housing need across the capital to a minimum of c.93,000 dpa. This is itself well above the 66,000 dpa need figure set out in the emerging London Plan; which Jenrick himself noted as being what “most commentators think is the real need of London”[1]. Indeed, the new SM would confirm London as the hotbed of housing need in England, being 28% of the national need figure. All of the top 10 greatest increases under the new draft SM compared to the current SM are also London Boroughs. But what practical impact could the new draft SM have on these London Boroughs? Well, potentially very little. In the short term the new draft SM should have no impact. The new draft SM is under a separate 8-week consultation to the White Paper (12-week consultation) and is described in the White Paper as a ‘short term’ change. Looking back at previous changes to the NPPF (2018), a consultation began at the end of October 2018 and changes were published in mid-February 2019 – c. 4 months. By that reckoning we could be in a situation where potentially this side of Christmas a new SM would be adopted through a revision to Planning Practice Guidance. Now, by that time the adopted London Plan (2016) will not be more than five-years old. So, for the purposes of five-year land supply there shouldn’t be a major jump in the requirement. In the medium term, there should again be no direct impact either. Assuming the emerging New London Plan (2019) is adopted prior to the adopted London Plan (2016) becoming more than five-years old, Boroughs will be protected for another five-years from that date. But what about the next London Plan that the Secretary of State has said needs to begin preparation, as a condition for signing of the emerging New London Plan? And what if that next London Plan is prepared under the auspices of the new planning system set out in the White Paper? There are two questions to consider: 1.   Is the higher number achievable, and if not what happens? If maintained as the basis for considering housing need, this proposed standard method would add to the level of need with which the London Plan would need to grapple; it would increase the pressure for moving beyond the current capacity-based approach that has driven London Plan-making to date. But whether the number is 66,000 or 93,000 does it make a practical difference? From a starting point – no. The emerging London Plan (2019) minimum requirements are quite a jump from the adopted London Plan (2016) and are capacity-based figures not need-based. If London only has capacity for c.56,000 homes – on average – per annum to 2029; in reality where will an extra c.44,000 units per annum meant to be built? The increase is it itself more than 7,000 above the current three-year average total delivery in the capital (37,000 units1). Such a jump in need would require more than simply finding some extra sites down the back of the sofa. Any housing need figure in London above 40,000 puts pressure on London’s plan makers to do something different, but that will take time to have practical effect. Even with some creative regeneration and renewal, there is clearly going to be a lot of unmet needs floating about unless there is some serious cross-boundary strategic thinking beyond London. The White Paper released yesterday does say that such thinking will occur (with the removal of the Duty to Co-operate) – but this is yet to be worked through. This, I would say, brings us back to and only emphasises more the biggest conundrum for planning in the South East of England – If London doesn’t have the capacity to meets its needs, where does the rest go? 2.   Will the current SM be superseded by the time the next London Plan is prepared? The new SM is in reality only a short-term change for current emerging plans. It is designed to set a need figure that plan makers then set against the various constraints in their area, to set a ‘policy on’ requirement figure. The White Paper’s Proposal 4 proposes to replace the SM for need with a new Standard Method for requirements which would taking account of need, land capacity, constraints and other ‘policy-on’ factors. This nationally set requirement would be non-negotiable. The Government is seeking to have this new system (and Local Plans – taking no more than 30 months to prepare) in place by the end of this parliament, which means the current SM proposals might have a shelf life of just two years. So, rather than vexing about the 93,000 dpa need figure, the next London Plan may find itself more focused on how the Government intends to standardise the exercise of carrying out its own balancing exercise of need and demand to set London’s housing target. This will leave is for a future London Plan to distribute it and decide what gives. For implications of what the New Standard Method means for other regions, see below perspectives: North West   |   South West   |   Thames Valley   |   West Midlands  |   Yorkshire [1] Letter to the Mayor of London, 13 March 2020


Planning for climate change: The influence of infrastructure
This is the second in Lichfields’ series of blogs examining the climate emergency in planning, following on from ‘Planning for climate change: Is London leading the way?’. The Committee on Climate Change’s (‘CCC’) report ‘Progress Report to Parliament’, published last month, identified investment in low-carbon and climate-resilient infrastructure to be a key measure that is vital to achieving the UK’s climate targets in the short and long term. But what is it? The OECD[1] states that climate resilient infrastructure is planned, designed, built and operated in a way that anticipates, prepares for and adapts to changing climate conditions. Why do we need to climate-proof infrastructure? The World Economic Forum[2] has claimed that investment is vital to future proofing our communities for the decades ahead. By investing heavily in climate resilient infrastructure right now and adapting our transport networks, housing and businesses, we will be better set to counteract flooding, heatwaves, drought, cyclones, wildfires, and other extreme climate events. Infrastructure networks are already affected by the physical impacts of climate variability and change. For example, OECD modelling of the potential impacts of a major flood in Paris found that 30% to 55% of the direct flood damages would be suffered by the infrastructure sector, while 35% to 85% of business losses were caused by disruption to the transportation and electricity supply and not by the flood itself. This is particularly relatable to the logistics sector, which is arguably one of the most susceptible industries to the increasingly tangible effects of climate change. Extreme weather events, such as winter storms and floods, can disrupt and influence supply chains globally – particularly in the UK where a downturn in the weather conditions can wreak havoc on transport systems. However, this industry is also a major contributor to climate change. Transport is embedded in the door-to-door supply chains, and in the CCC’s Progress to Parliament Report, it revealed that surface transport is now the highest emitting sector in the UK. However, these key infrastructure networks will also play an essential role in building resilience to climate impacts in the future. What infrastructure do we need to invest in? Examples of climate resilient infrastructure that are key to reaching the UK’s climate change goals are explored below. 1.  Carbon capture and storage (‘CCS’) infrastructure: CCS encompasses technologies for capturing carbon dioxide that would otherwise be emitted to the atmosphere, transporting and storing it deep underground in geological formations where it will be permanently contained. This storage requires pipelines to transport the CO2 to the storage destinations. The CCC estimates that up to 175 million tonnes of CO2 – around half the UK’s 2019 emissions – will need to be captured annually by 2050 to reach the goal of net zero greenhouse gas emissions.  We are already seeing progress in this industry globally, for instance, energy giants Equinor, Shell and Total have signed off on a plan to build what would be the world’s first carbon capture and storage network in Norway. The project will be developed in stages, with phase one developing the infrastructure to transport, inject and store up to 1.5 million tonnes of CO2per year in the seafloor thousands of metres (2,700 metres to be precise) below sea level. However, this infrastructure is currently very expensive and cost reductions are necessary to be able to deploy CCS cost effectively in the UK[3]. 2.  Low-carbon hydrogen: As an alternative to fossil fuels, hydrogen production has the potential to contribute to decarbonisation in the UK. Hydrogen is a low-zero carbon, energy dense fuel that can be stored and transported over long distances. Climate experts therefore agree it is likely to be crucial for decarbonising the UK’s heavy road transport and manufacturing industries, which can’t get enough power from electricity alone. It could also prove crucial for cutting carbon emissions from home heating, by replacing natural gas in the gas grid. Currently the vast majority of hydrogen is produced using natural gas, which can only be made low-carbon by bolting on CO2 capture technology. Hydrogen can also be produced using renewable electricity via a process known as electrolysis. Earlier this year, the Government announced a low carbon funding package, where £70 million will fund two of Europe’s first-ever large scale, low carbon hydrogen production plants - the first on the banks of the Mersey, the second planned for near Aberdeen. 3.  Zero Carbon Freight: As discussed above, surface transport is now the highest emitter in the UK, and the logistics sector contributes significantly to this. The CCC makes recommendations within its recent report for the Government to implement a strategy to transition to zero-carbon freight (potentially through use of hydrogen), including stronger purchase incentives, schemes to reduce HGV and van use in urban areas (e.g. e-cargo bikes and use of urban consolidation centres), infrastructure plans and clean air zones. London is leading the way in the journey to zero carbon transport – with Sadiq Khan announcing on Friday plans for London’s entire tube network to be powered by renewable electricity by 2030. How will climate resilient infrastructure be achieved? As would be expected, this area of addressing the climate emergency is mostly dependent on coordination at a Government level. The CCC places a lot of emphasis on the measures and investment plans that will be implemented through the National Infrastructure Strategy that is due to be published later this year – following a delay announced in March 2020. It is suggested that all new infrastructure investments should assess and plan for the impacts of climate change. The private sector also has a role in supporting this action, through financing research and initiatives. Lastly, planning is a key driver in the delivery of climate resilient infrastructure. Well-aligned national and local planning frameworks are vital to guiding progress in support of climate resilient infrastructure. This is already being recognised, for example, this week, Defra published its ‘Flood and coastal erosion risk management policy statement’, setting out the Government’s policy on flood and coastal erosion risk management in the face of climate change. This document states that the government will "ensure that planning policy is being appropriately applied and effectively implemented on a consistent basis across the country”. Lichfields is well suited to help respond to the climate change emergency in planning, and across a range of specialities – our next blog in the series looks at how aviation is responding to the climate emergency. Contact us for further information. [1] Policy perspectives: Climate resilient infrastructure[2] Why it's time to invest in climate resilient infrastructure[3] UK carbon capture and storage government funding and support