Author Archives: Kathryn Waldron


Delivering the Thames Estuary Growth Commission’s 2050 Vision


The Thames Estuary 2050 vision was published in June 2018 by the Thames Estuary Growth Commission. It sets out the vision of transforming the estuary into a tapestry of productive places along a global river.

The Vision: To create 1.3 million new jobs, £190 million GVA and 1 million new homes.

Context & Timeline  

The Thames Estuary is located to the east of the City London and stitches north and south of the River Thames from Tower Hamlets and Greenwich out towards Ebbsfleet and Thurrock.

Below is a timeline of the Thames Gateway.

  • 2003 – Formation of the Thurrock Thames Gateway Development Corporation
  • 2005 – Formation of the London Thames Gateway Development Corporation
  • 2009 – More than £9 million was earmarked by the Labour Government for projects on the Estuary
  • 25th Nov 2010 – Under the coalition Government the Minister for Thames Gateway addresses the Thames Gateway Forum giving the reins back to local decision makers through the Thames Gateway Strategic Group
  • 2011- Functions of the London Thames Gateway Development Corporation back to Local Authorities and the new London Legacy Development Corporation
  • April 2012 – Formation of the London Legacy Development Corporation
  • 31st October 2012 – Abolition of the Thurrock Thames Gateway Development Corporation
  • 2013– London Thames Gateway Development Corporation fully scrapped
  • March 2016 – Chancellor George Osborne announces creation of the Thames Gateway Growth commission headed by Lord Heseltine
  • March 2016 – Mayor of London Boris Johnson pushes for the creation of a new airport on the estuary
  • July-September 2016 – Commission runs consultation on call for ideas
  • March 2017– Lord Heseltine removed from post as chair and replaced by John Armitt
  • April 2017– Lower Thames Crossing preferred route announced
  • 19th December 2017– Growth Commission’s priorities announced as:
  • Creating internationally-competitive centres of excellence
  • Making the most of planned investments such as the Lower Thames Crossing, and assessing the case for other investments that have been proposed
  • Ensuring that people right across the corridor benefit from expected growth
  • Working closely with organisations and communities to develop a plan for delivering the vision
  • June 2018 – Publication of the Commission’s 2050 Report

 Thames Gateway Strategic Group

The Thames Gateway Strategic Group was created on 25th November 2010 when the Minister for the Thames Gateway addressed the Thames Gateway Forum giving the reins back to local people. The strategic group is made up of officers and elected members.

The Thames Estuary Growth Commission

The Growth Commission, created in March 2016 has been tasked with developing an ambitious vision and delivery plan for North Kent, South Essex and East London up to 2050.

The Commission is made of architects, academics consultants, housebuilders and economists including:

  • Sir John Armitt (Chair)
  • Sadie Morgan (Deputy Chair)
  • Lord Norman Foster
  • Alice Gast
  • Gregory Hodkinson
  • Sir George Iacobescu
  • Sir Stuart Lipton
  • Sir Edward Lister
  • Tony Pidgley
  • Nick Roberts
  • Geoffrey Spence

Jake Berry MP is responsible for the Growth Commission as the Parliamentary Under Secretary of State, Minister for the Northern Powerhouse and Local Growth.

Spatial Framework

There are 23 separate authorities within the Thames Estuary including the GLA. The London Plan sets a framework for regeneration of the Estuary by identifying the largest concentrations of Opportunity Areas on either side of the estuary.

The London Plan identifies potential to deliver 250,000 new homes and 200,000 new jobs.

The Mayor set his vision to transform the Thames Estuary into a hub for large scale state of the art production facilities with an initial focus on creative and cultural industries and commits to continue to work with the Thames Gateway Strategic Growth Group and the Commission to support and promote investment in the Gateway. The Mayor will support the Thames Gateway Kent Strategic Corridor by assisting Boroughs in seeking a government led project to extend the Elizabeth line through Bexley to north Kent (making that 24 different decision makers).

The 2050 Vision

The vision for the Estuary is to transform the Estuary into a tapestry of ‘Productive Places’. These Productive Places are identified as:

  1. City Ribbon
  2. Inner Estuary
  3. South Essex Foreshore
  4. North Kent Foreshore
  5. River Thames

A summary of each Productive Place is set out below:

City Ribbon

Location: Tower Hamlets, Barking &Dagenham, Havering Lewisham Bexley Greenwich and the LLDC


  • Growing cultural and creative industries sector
  • Significant projected population growth
  • Major regeneration programmes in areas including Barking Riverside and Thamesmead.


  • Integrating and delivering future connectivity projects
  • Highest levels of deprivation in London
  • High levels of
  • Unemployment and low skills.

Key objectives include:

  • A hub for production
  • Enhanced transport links
  • Implementation of a multi-generational skills strategy, the area will connect the creative and cultural industries to a highly skilled workforce

 The key areas of change within the city Ribbon are:

  1. Canary Wharf
  2. Greenwich
  3. Royal Docks
  4. Rainham Marshes
  5. Barking Riverside

 Two key projects identified include New Thames Crossings and an integrated skills strategy


2. Inner Estuary

Location: Thurrock, Dartford Gravesham, Ebbsfleet

• Connectivity (which supports a growing higher value logistics and freight sector
• £1 billion investment in the Port of Tilbury
• Planned growth of new town centres
• Innovation in construction through Modern Methods of Construction

• Unresolved approach to the Swanscombe Peninsula
• Air quality issues as a result of congested river crossings
• The slow pace of delivery at Ebbsfleet Garden City
• Poor education and skills attainment,

Key objectives include:
• to create higher value ports at Tilbury and London Gateway
• To upskill the aspirational population
• Create healthy town centres
• New medical campus
• Delivery of Ebbsfleet Garden City

The priority areas within the Inner Estuary are:
a) Dartford Crossing
b) Lakeside
c) Bluewater
d) Swanscombe Peninsula
e) Ebbsfleet Garden City
f) Port of Tilbury
g) Lower Thames Crossing
h) London Gateway Port

Significant projects to support the inner estuary objectives are
• Creation of a Medical Campus (delivery by 2022).
• Transport Innovation Zone

3. South Essex Foreshore

Location: Basildon, Castlepoint, Southend on Sea & Rochford

• Established and coordinated voice of Opportunity South Essex
• The unique wetland habitats of the river edge
• Emerging cultural sectors
• Medical and aviation related advanced manufacturing in Southend-on-Sea

• Poorly performing town centres
• Slow speeds of delivery linked to limited clarity on priorities across the area
• Skills and jobs mismatch
• Sea level rise

Key objectives:
• Creation of a statutory joint spatial plan
• Town centre transformation
• Unlocking post industrial landscapes to create a thriving and creative economy

Areas of Change for the South Essex Foreshore are:
a) Basildon
b) Canvey Island
c) Rayleigh
d) Southend-on-sea

Significant projects to support the south Essex foreshore objective are:
• Institute for Resilient Infrastructure
• Relocation of South Essex College

4. North Kent Foreshore

Location: Medway, Swale, Canterbury& Thanet

• Universities
• Historic assets
• Pproductive agricultural landscapes

• Connection between the skills needs of employers and the education and skills training
• High level of ‘digital deprivation’

Key objectives include:
• A new medical research corridor
• Creation of a joint statutory local plan
• A renewed focus on skills, and high-quality town centres set around world-class heritage and natural assets.

Areas of Change:
a) 1. Rochester
b) 2. The Hoo Peninsula
c) 3. Sittingbourne
d) 4. Canterbury
e) 5. Margate
f) 6. Ramsgate

The two main projects to support the vision for North Kent are:
• Education and Skills strategy Quick win building off existing skills strategies in place.
• Health Supercentre (delivery by 2023).

5. River Thames

Source: Thames Estuary Growth Commission

Location: River Thames

• Strategic role as a gateway to UK trade and industry.
• Unique natural qualities of ecology, habitat and landscape, which have long inspired the area’s cultural and creative industries. The River Thames defines the quality of place surrounding it.

• Fragmented governance for the management of the river.
• Mitigation of sea level rise.
• Water quality.

Key objectives include:
• continue to evolve, from freight to fishing
• from beach to boardroom
• emphasise the value of the river to its surrounding places
• ensure that the current level of flood protection is maintained

Priority areas are:
a) River Thames
b) English Channel
c) North Sea
d) River Medway

Key projects identified include:
• Great Thames Park with first section of a new Thames Path in 2020.
• Creation of Thames East Line with Long term delivery with measures in the short and medium term to commence project planning
• Celebrate the Thames festival in 2019

Delivering the 2050 Vision

In order to deliver the 2050 Vision, the Commission calls on the Government to work closely with local partners to determine the governance reform required to deliver the growth in the estuary.

The Commission recommends:
• A robust locally led review of governance arrangements to be concluded within 6 months.
• A single voice for the Thames Estuary through a strengthened and streamlined Thames Gateway Strategic Group.
• Development of statutory joint spatial plans for Kent and Essex.
• Revision of geographical boundaries of the South East Local Enterprise Partnership.
• Development Corporations with planning and CPO powers to drive delivery.
• Strengthened governance arrangements for the River Thames itself.

The Report itself is clearly very aspirational setting out short medium and long term goals to deliver the ultimate goal of more housing and capitalising on projects that have already been identified and in the pipeline. The Commission’s recommendations on delivering the 2050 vision could be considered disappointing in that it revisits ideas that are not new and would not be in place overnight. A statutory Local Plan would take years to prepare and reorganisation of governance structures will never be straight forward.

To place the role of delivery on existing Development Corporations is positive but when we consider that Ebbsfleet and the LLDC are behind delivery and there were existing Development Corporations for Thurrock and delivery vehicle mechanisms for the Medway Towns that delivered very little, can we really be sure that the existing development corps could drive the delivery that the Estuary desperately needs?

Read the report here:


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Brokenshire’s Warning to the London Mayor


Following the publication of the NPPF on the 24th July 2018, James Brokenshire wrote to the Mayor of London giving him a serious talking to on meeting housing need.

Consultation on the Replacement London Plan was undertaken between December 2017 and March 2018. The Replacement Plan proposed to go further than previous iterations of the London Plan, going beyond strategic policies and proposing an increased housing figure of 65,000 dwellings per annum. The increased numbers were proposed to be met through increased densities and more reliance on Brownfield Sites coming forward.

On the 27th July 2018, James Brokenshire wrote to the Mayor of London, stating that the Mayor is responsible for delivering the strategy to significantly increase housing delivery in London and will be held to account for delivering London’s housing targets, suggesting that the proposed figure of 65,000 is not enough. The Governments standard methodology for OAN results in a capped figure of 72,407dpa and an uncapped figure of 95,267dpa.

The HBF also argued that the figure of 65,000 is not enough taking into consideration the standard methodology as proposed by CLG in 2017. The GLA’s approach to calculating OAN differs from the standard methodology as they created their own demographic and households projections which resulted in figures that were lower than the CLG’s projections. The CLG’s approach would also require more adjustment for affordable housing.

Brokenshire writes:

“London faces the most severe housing pressures in the country with median house prices now over 12 times median earnings – comparing to an England wide ratio of below 8 – and far more than what an individual can typically expect to borrow for a mortgage”.

Nobody is denying that London is unaffordable, however, it is of note that the Conservative housing minister is placing blame on the current Labour Mayor. The issue of housing and affordability and it’s resolution in London needs to go beyond politics.

It may well be that the approach that the GLA have taken is suitable for London, however as the HBF have noted, it has more significant wide reaching implications for surrounding South-East authorities, and so the standard methodology should be adopted by the Mayor.

The New London Plan will continue to Examination which is programmed for later this year. But in accordance with the new NPPF, plans that don’t meet the full housing requirements will be subject to early review. This means that the London Plan will be adopted and then the GLA will need to go back to the drawing board with a new evidence base, an updated SHLAA and new models for capacity created (we can’t mention the Green Belt though!).

A newer London Plan can then be expected….

Start Promoting your Sites Now!

There are also a number of other concerns raised in the letter, including inconsistencies with National policies, the extent of details in policies going beyond the requirements of a Strategic Plan, the Plan does not provide enough information on delivery and collaboration and the Secretary of State requires a consistent approach to setting building standards through the framework of Building Regulations.

Examination in Public

On 13 August 2018 the Mayor published a version of the draft Plan that includes minor suggested changes as the GLA prepare for the Exmination in Public. More details can be found here:

What we think….

The housing industry will surely welcome Brokenshire’s letter to increase housing supply, whereas residents of a certain generation may not welcome it so much with the standard response likely to be destruction of green fields, increased number of cars and there’s already enough houses being built…

However, if they’ve got a grown-up child living at home trying to save their pennies or know a young professional spending most their wages on renting a room, maybe they’ll start the realise the harsh reality that we do need to provide for and build more homes….

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Local Plan Updates and Progression August 2018


Local Plan Updates – Tracking and Progression

We have been tracking and following the progress of Local Plans in the different regions of England.

A Local Plan sets out planning policies and identifies how land is used – determining what will be built where. We’ve developed this Local Plan Schedule which we hope will keep you up to date on what Local Authorities are doing on their Plans and if you have any questions contact us today.

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Greater Birmingham HMA Strategic Growth Study


In February 2018, the Greater Birmingham HMA Strategic Growth Study prepared by GL Hearn and Wood Plc was published. We provide a summary of the key findings of the report.

Birmingham’s functional HMA covers more than Birmingham and includes the Black Country and parts of Worcestershire, Warwickshire and Staffordshire. It also covers authorities which are within the Greater Birmigham and Solihull LEP and the Black Country LEP. North Warwickshire and Stratford-on-Avon Districts  are authorities with an area of overlap between the Birmingham and Coventry/Warwickshire HMA.


The study’s  four main aims are:

  1. Review of existing identified supply to consider whether, by positively applying policies that are consistent for each type of site across the HMA, more dwellings could be provided through increased densities.
  2. Consider the potential additional supply on other land outside of the Green Belt that has not been previously considered for housing development
  3. If a shortfall remains after aim 1 & 2, to then consider the development potential and suitability of any large previously developed sites within the Green Belt that may lie in sustainable locations.
  4. Should a shortfall remain after undertaking tasks (1) to (3), undertake a full strategic review of the Green Belt within the HMA utilising a consistent Green Belt Review methodology, which assesses Green Belt against its five purposes.

”Whilst a single plan is not being prepared, housing need is a strategic issue which the HMA authorities need to collaborate in addressing through the Duty to Cooperate”.

Objectively Assessed Need

Existing Evidence Base

The report looks at the findings already published by local authorities as follows and also reviews the housing requirements within the adopted plans There is a 38,000 dwelling unmet need arising from the Birmingham Development Plan to 2031. In addition, there is an unmet need from Tamworth (1,825 dwellings to 2031) and Cannock Chase (500 dwellings to 2028).

Local Authority OAN Plan period Housing requirement Shortfall
Birmingham 89,000 2011-2031 51000 -38,00
Bromsgrove 6,648 (2011-2030) 7000 0
Cannock Chase 5300 2006-2028 5300 -500
Lichfield 8600 2008-2029 10,030 0
Redditch 6400 2011-2030 6400 0
Solihull 14,277 2014-2033 15029
Tamworth 6250 2006-2031 4425 -1,825
Warwickshire 3150 2011-2029 9070
Stratford on Avon 14,600 2011-2031 14600
Black Country 78,190 2014-2036 63000
South Staffordshire 5933 2014-2036 3850
HMA total 11,500


The GL Hearn assessment of OAN has been considered using four projections:

Economic Projections

Economy Plus Scenario

The Economy plus is a scenario modelled in the Strategic Economic Plan for further and faster growth than predicted in the three LEP Strategic Economic Plans. This is an aspirational ‘policy on’ scenario based on a policy aspiration to improve economic performance.

The West Midland Strategic Economic Plan is based on the economy plus scenario( as set out in the West Midlands Combined Authority’s Strategic Economic Plan) up to 2036 this scenario suggests a requirements for 310,188 dwellings.

Baseline Economic Growth

The baseline economic growth projection is based on a continuation of past trends, but takes into account how different economic sectors are expected to perform in the future (relative to the past). It should be regarded as ‘policy neutral’. Up to 2036 this projection suggests a need for 240,012 dwellings

Demographic Projections

There are three demographic projections that the report considers:

2014 Based Subnational Population Projections

These were the latest official, 2014-based, Household Projections, which Government’s Planning Practice Guidance identifies as the ‘starting point’ for quantifying OAN and suggests 255,533 dwellings required to 2036. 

Rebased Sub National Population Projections

The rebased SNPP rebases the 2014-based Population and Household Projections to take account of population growth between 2014-15 shown in ONS Mid-Year Population Estimates. This projection suggests a requirement for  254,873 dwellings to 2036 .

10 year Migration

The 10 year migration projection considers the difference between the trends in migration over the input period to the SNPP (the 5 years to 2014 for domestic and 6 years for international migration) and those over a 10 year period (2005-15), and then adjusts future trends in migration based on the difference between these. This projection shows a requirement for 251, 647 dwellings up to 2036. 

Government Standardised Approach

The report also considers the Governments standardised approach to OAN which is to use latest official projections, with adjustments then applied based on the degree to which the affordability ratio is over 4, with a 1% increase in the ratio of median house prices to earnings over.

The report envisages a cap which is 40% above existing local plan figures where the local plan was adopted in the previous 5 years; or 40% above either the latest local plan or the household projections (whichever is the higher) where there is not an up-to-date local plan.

The uncapped need figures arising from this approach align broadly with the demographic baseline position to 2031, showing a need for 207,000 homes. To 2036 the uncapped need is for 265,000 homes which is around 4% above the demographic need shown by the projections within the report.

 Unmet Needs

North Warwickshire and Stratford-on-Avon have agreed to make provision for Coventry’s unmet housing needs. North Warwickshire is contributing 860 dwellings to meeting Coventry’s unmet needs to 2031 and 2,020 dwellings from Stratford-on-Avon, totalling 2,880 dwellings. If this was rolled forward to 2036 on a pro-rata basis, this would be 3,600 dwellings.

“GL Hearn conclude that on the basis of the current evidence provision of between 205,000 – 246,000 homes is needed across the Birmingham HMA to 2031; and provision of between 256,000 – 310,000 homes to 2036 (from a 2011 baseline) to meet the Birmingham HMA’s housing needs and taking account of Coventry’s unmet need of 208,000 dwellings to 2031 and 258,500 homes to 2036”. 

Land Supply


GL Hearn’s initial information submitted indicated a land supply of around 203,000 dwellings to 2036, of which 200,000 dwellings could be delivered over the period to 2031.

This is made up of

  • Completions –
  • Sites with Planning Permissions (i.e. Commitments) –
  • Extant Allocations without Planning Consent
  • Allocations in Emerging Plans
  • Additional Urban Supply
  • Windfalls

Land supply by Authority

Birmingham (April 2016):A total land supply for 51,458 dwellings is identified to 2031 and 59,858 to 2036.

Bromsgrove (April 2017): A total land supply of 5,099 dwellings is identified to 2031 and 5,299 dwellings to 2036.

Cannock Chase (April 2016): A total land supply of 4,615 dwellings is identified to 2031 and 4,685 dwellings to 2036.

Dudley (April 2016): A total land supply of 17,918 dwellings is identified to 2031 and 18,668 dwellings to 2036.

Lichfield( August 2017): A total land supply of 10,973 dwellings is identified to 2031 and 11,248 dwellings to 2036.

North Warkwickshir(April 2017): A total land supply of 9,060 dwellings is identified to 2031 and 9,360 dwellings to 2036. This includes making specific provision to meet an unmet need for 4,410 dwellings from other parts of the Birmingham HMA, as identified in Section 3 as well as 860 dwellings unmet need from Coventry.

Redditch (April 2017): 7,488 dwellings to 2031 and 7,543 dwellings to 2036.

Sandwell (April 2016): 19,930 dwellings is identified to 2031 and 20,813 dwellings to 2036. The land supply has been assessed to 2036.

Solihull (April 2016): 5,717 dwellings  to 2031 and 16,945 dwellings to 2036 including specific provision for a contribution of 2,000 dwellings to meeting unmet needs of the Birmingham HMA.

South Staffordshire (April 2017): 3,493 dwellings to 2031 and 3,643 dwellings to 2036

Stratford-on-Avon (April 2016):16,713 dwellings to 2031 and 19,358 dwellings to 2036

Tamworth (April 2017): 4,495 dwellings to 2031 and 4,680 dwellings to 2036.

Walsall (April 2017): 10,879 dwellings to 2031 and 11,284 dwellings to 2036.

Wolverhampton (April 2016):13,816 dwellings to 2031 and 16,495 dwellings to 2036.

Following the submission of the initial information, adjustments were made to ensure consistency with the windfall approach and non implementation discounts.

Approaches to Delivery

Existing Sites

The report explores in detail approaches to be taken to providing additional land to be identified within urban areas including brownfield land, disposing of surplus public sector land, estate regeneration, town centre regeneration and disposing of surplus open space.  The report also assesses in detail the potential to increase densities across the HMA and concludes that  it would be reasonable to assume minimum densities of 40 dph are achieved in the conurbation (Birmingham and the Black Country urban area), with minimum densities of 35 dph in other parts of  the HMA. This approach would yield additional supply of 13,000 dwellings, principally over the period to 2031.

Identifying and Allocating Additional Land

Taking into account the potential housing supply which could be achieved by increasing densities, there remains a need to identify capable of supporting delivery of over 15,000 homes to 2031, and a total of over 47,800 homes to 2036. Additional land needs to be identified and allocated to meet this. This provides a clear basis for progressing a strategic review of the Birmingham Green Belt.

Given the scale of unmet need, the report focuses on strategic development options as follows:

  • Urban Extensions (1,500 – 7,500 dwellings);
  • Employment-led Strategic Development (1,500 – 7,500 dwellings); and
  • New Settlements (10,000+ dwellings). –

Potential Areas of Search for Strategic Development beyond the Green Belt

South Staffordshire

  • Urban Extension: North of Penkridge
  • Urban Extension: South of Stafford
  • New Settlement: Around Dunston


The Study initially identifies three potential Areas of Search for Strategic Development:

  • Urban Extension: East of Lichfield
  • Urban Extension: North of Tamworth
  • New Settlement: Around Fradley and Alrewas

North Warwickshire

One potential Area of Search for Strategic Development is identified to be tested:  Urban Extension: East of Polesworth

Within the HMA, the only location which has been identified by Government for new strategic development is Long Marston, which is designated a Garden Village. Consideration has therefore been given to the potential for enhanced strategic development in this broad area.

The potential Areas of Search for strategic development identified to be tested are thus:

  • Urban Extension: South of Stratford-upon-Avon town
  • New Settlement: Around Wellesbourne
  • New Settlement: South-West of Stratford-upon-Avon District

Potential Areas of Search in the Green Belt

The Study undertook a Strategic Green Belt Review, assessing the form and strategic function of the Green Belt against the purposes of Green Belt policy set out in the National Planning Policy Framework (NPPF) (Para 80).

Four spatial development models were created:

  • New settlements
    • Scale attracts greater opportunity for central government investment
  • Urban Extensions
    • Lead in times of typically 5+ years
    • Larger and more costly infrastructure requirements
  • Employment focus
    • Lead in times of 3-5 years
    • Larger infrastructure requirements
  • Proportionate Dispersal
    • These have the shortest lead in times and have typically lower requirements for strategic infrastructure

Six Areas of Search for new settlements and six for urban extensions are identified; together with three Areas of Search for employment-led development.

Recommended Areas of Search for Strategic Development


  • I54
  • East of Birmingham
  • Birmingham Airport/ NEC

These Areas of Search have the following characteristics:

  • Strategic employment areas with a key employer and/or clustering of employers
  • Likely to be located adjacent to, or in the vicinity of, a Motorway junction.
  • Potential to support some housing provision as part of mixed-use development (1,500 to 7,500 dwellings).

Urban Extensions

The Study concludes that the strongest performing Urban Extension options which should be taken forward for more detailed consideration by the HMA authorities are:

  • South of Dudley
  • North of Tamworth
  • East of Lichfield
  • North of Penkridge.

New Settlements

The report recommends the following areas of search should be taken forward:

  • South of Birmingham
  • Between Birmingham and Bromsgrove/Redditch
  • Around Shenstone
  • Around Balsall Common


There is a minimum housing need for 205000 up to 2031 and 255,000 up to 2036. Taking into account shortfalls this increases to 208,000 up to 2031 and 258,00 to 2036.

The current evidence suggests provision of between 205,000 – 246,000 homes across the Birmingham HMA to 2031; and 256,000 – 310,000 homes to 2036.

There is a developable land supply of 180,000 to 2031 and 197,000 to 2036. Bringing together the need and currently identified supply, there is an outstanding minimum shortfall of 28,150 dwellings to 2031 and 60,900 dwellings to 2036 across the Birmingham HMA.

New strategic allocations will be required to address this shortfall across the whole HMA.

Next Steps

It is envisaged that further technical and feasibility work will be underway to assess the suitability of the areas of search as identified by the report along with a process of iterative Masterplanning and consultation with local residents.

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Is the NPPF Trying to Nationalise the Sale of Land?



The draft NPPF was published in March 2018 and stated at Paragraph 34 that “plans should set out the contributions expected in association with particular sites and types of development. This should include setting out the levels and types of affordable housing provision required, along with other infrastructure (such as that needed for education, health, transport, green and digital infrastructure). Such policies should not make development unviable, and should be supported by evidence to demonstrate this. Plans should also set out any circumstances in which further viability assessment may be required in determining individual applications”

Paragraph 57 then went on the state that “planning obligations should only be sought where they meet all of the following tests: a) necessary to make the development acceptable in planning terms; b) directly related to the development; and c) fairly and reasonably related in scale and kind to the development.”

The HBF have argued that Paragraph 34 was not consistent with paragraph 57 in that it moved away from the rules set out in paragraph 57 (and the tests set out in Regulation 122 of the Community Infrastructure Levy Regulations 2010) into the realms of value capture.

The revised 2018 Framework which was published on 24th July 2018 has been revised to state at paragraph 57: “Where up-to-date policies have set out the contributions expected from development, planning applications that comply with them should be assumed to be viable. It is up to the applicant to demonstrate whether particular circumstances justify the need for a viability assessment at the application stage”.

Viability has moved from a standalone matter to a key consideration within planning decisions in both policy and development management. This significant shift now requires viability to be dealt with at the plan making stage, thus shifting responsibility on LPAs as opposed to developers. Essentially, LPAs will now be required to set strategic site allocations, infrastructure requirements and a minimum level of affordable housing which they consider viable.

Viability in short is the difference between the price paid for a site compared to the costs of building a development. A development scheme is only viable if, after taking into account all development costs into account including site value, the scheme provides a competitive return so that a scheme can be implemented and the land value is sufficient to incentivise a landowner to sell.

Components of Viability

I’m no surveyor but my simple mind understands that viability comprises:

  1. Value of land
  2. Development costs
  3. Return to Developer

1.Land Value

The starting point to assessing viability is to establish the benchmark land value. The Benchmark Land Value is made up of the Existing Use Value with a premium to the landowner which should reflect the minimum price at which a landowner would be willing to sell their land.

The price at which a landowner would be willing to sell their land can be subjective as an individual may wantmore than the actual value of a site. Where a local authority may be under pressure to deliver sites and their preferred sites undeveloped by landowners not wishing to sell as depressed values, sites may be granted permission either by either LPA or on appeal. As the HBF rightly point out this will not result in homes being developed faster or more sustainably.

Existing Use Value (EUV) is defined as the value of the land in its existing use together with the right to implement any development for which there are extant planning consents, including realistic deemed consents, but without regard to other possible uses that require planning consent, technical consent or unrealistic permitted development

EUV can be established by assessing the value of the specific site or type of site using a range of sources of information. The NPPG advises that:

“Determining the existing use value of the land should be based on the assumption that no future planning consents will be obtained, but including the value of any consented use”.

The NPPG requires Benchmark Land Value to:

  • Fully reflect the total cost of all relevant policy requirements including S106 and CIL
  • Include abnormal costs, site specific infrastructure costs and professional site fees
  • Allow for a premium to landowners (including equity resulting from those building their own homes); and
  • Be informed by comparable market evidence of current uses, costs and values wherever possible. Where recent market transactions are used to inform assessment of benchmark land value there should be evidence that these transactions were based on policy compliant development. This is so that previous prices based on non-policy compliant developments are not used to inflate values over time.

The Benchmark Land Value would be established through engagement with plan makers, landowners, developers, infrastructure and affordable housing providers. Whilst engagement makes sense, it is not clear who would intervene if parties disagree on what the Benchmark Land Value should be.

A premium to the landowner above the Existing Use Value would be determined by plan makers in consultation with developers and landowners and a minimum premium can be established by looking at comparable sites which would establish the price paid having regard to outliers in market transactions, the quality of land, expectations of local landowners and different site scales.

2. Development Costs

Costs are defined as follows:

  • Build costs based on appropriate data, for example that of the Building Cost Information Service;
  • Abnormal costs, including those associated with treatment for contaminated sites or listed buildings, or costs associated with brownfield, phased or complex sites. These costs should be taken into account when defining benchmark land value;
  • Site-specific infrastructure costs, which might include access roads, sustainable drainage systems, green infrastructure, connection to utilities and decentralised energy. These costs should be taken into account when defining benchmark land value;
  • The total cost of all relevant policy requirements including contributions towards affordable housing and infrastructure, Community Infrastructure Levy charges, and any other relevant policies or standards. These costs should be taken into account when defining benchmark land value;
  • General finance costs including those incurred through loans;
  • Professional Fees, project management, sales, marketing and legal costs incorporating organisational overheads. Any professional site fees should also be taken into account when defining benchmark land value; and
  • Explicit reference to project contingency costs should be included in circumstances where scheme specific assessment is deemed necessary, with a justification for contingency relative to project risk and developers return.

 The NPPG requires as far as possible for costs to be included at the plan making stage

3. Return to Developers

A return to developers is assumed at 20% of Gross Development Value or 6% in consideration of affordable housing. The NPPG advises that Plan makers may choose to apply alternative figures where there is evidence to support a different figure according to the type and scale of development.

Gross Development Value is defined as total sales and/or capitalised net rental income. These can be calculated using market evidence from the site itself or from comparable existing developments and adjusted to suit the site circumstances.

The HBF argue that The proposal to include just 20% of gross development value as a suitable return to a developer (with a lower figure of just 6% on the delivery of affordable housing) will not be appropriate in all circumstances or for all types of developer. While the guidance on viability acknowledges this fact it gives no guidance on when deviation from this standard approach would be necessary. It is also unclear from the guidance as to whether the application of “alternative figures” might result in a lower return to a developer as well as a higher one.

Transparency & Commercially Sensitive Information

The NPPG sets out in detail the approach to be taken to ensure accountability of assessments, and that assessments should be prepared and published in such a way to aide and support decision makers. The NPPG requires the preparation of a summary report using a standard template currently being created by CLG.

Assessments should be drafted on the basis that they will be made publicly available other than in exceptional circumstances. This aligns with the London Mayor’s approach that assessments would be made public where a developer would not commit to providing 50% affordable housing on public land, and 35% on private land.

The HBF would agree with the NPPF at paragraph 58 which suggests that where a site cannot support a policy compliant application (for site specific reasons) then a viability assessment should still, in exceptional circumstances, be submitted. However, there would still be elements of such appraisals that are commercially sensitive and have suggested that applicants should be allowed to agree with local planning authorities where this is the case and why and agree that this limited information is redacted.

The HBF also believes that there should be a clear transition period to move towards this radical new approach of development viability. Many sites and projects will be considerably advanced towards development using the current assumptions and methodology of site by site negotiation. An overnight change to this regime will threaten many sites in terms of meeting agreed minimum land values. A transition period of at least five years is considered appropriate.

All in all, the proposed change to viability assessments could well result in a slow down with less homes being delivered faster and in a sustainable manner.

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Silvertown Tunnel Consent Order Granted


The Development Consent Order for the Silvertown Tunnel has been approved by a Statutory Instrument (No 574). The Silvertown Tunnel Order 2018 was made on the 10th May 2018 and comes into force on the 31st May 2018. The decision was delayed for six months to take into account additional measures for air quality.

The consent order, found on the Planning Inspectorate Website allows for 21 separate items of work including:

  • Construction of a twin bore highway tunnel for a length of 1,440 metres from a portal on the Greenwich peninsula.
  • Improvement of the existing two-lane A102 Blackwall Tunnel southern approach. southbound carriageway over a length of 595 metres from a point 260 metres south of the existing Blackwall Tunnel Southbound South Portal to a point 20 metres south of the existing gantry on the existing slip road.
  • Improvement of the existing two-lane A102 Blackwall Tunnel southern approach northbound carriageway over a length of 500m.
  • Improvement of the existing Tunnel Avenue from a point 65 metres south of a point level with the junction of the existing Tunnel Avenue with Morden Wharf Road.
  • Construction of a new two-lane carriageway over a length of 150 metres forming the southern approach northbound carriage, and construction of new two lane carriageway for 160m forming the southbound carriageway.
  • Improvement of 45 metres of the A102 Blackwall Tunnel southern approach southbound carriageway two-lane diverge slip road leading to the existing Millennium Way.
  • Construction of a new cross-over between the northbound and southbound carriageways of the improved A102 Blackwall Tunnel southern approach.
  • Construction of a new bus-only carriageway linking the existing A102 Blackwall Tunnel southern approach southbound carriageway.
  • Improvement of the existing Pavilion Lane to provide a new bus-only carriageway,
  • Construction of a new Boord Street foot and cycle bridge to provide access for non-motorised users across the A102 Blackwall Tunnel.
  • Works associated with the construction of a Silvertown Tunnel services compound on the north and south portal.
  • Construction of a replacement gas pressure reduction station.
  • Permanent diversion of statutory undertakers’ apparatus and works associated with such diversions, located in Boord Street and Millennium Way.
  • Construction of the new Silvertown Tunnel northern approach
  • Improvement of the existing Tidal Basin Roundabout for a length of 415 metres,
  • Construction of Dock Road on a new alignment.
  • Improvement to the existing Tidal Basin Road to include resurfacing works to the existing Tidal Basin Road.
  • Construction and subsequent removal of a temporary jetty for transportation of materials to Royal Victoria Dock.
  • Dredging and mooring works.

The order allows TFL to construct, operate and maintain the Silvertown Tunnel. The Order would permit Transport for London to acquire, compulsorily or by agreement, land and rights in land and to use land for this purpose. The Order also includes provisions in relation to the operation of the existing Blackwall Tunnel regarding speed limits, penalty charges and byelaws. The order also allows for the implementation of user charging at both tunnels.

A Silvertown Tunnel Design Review Panel will be set up along with the Silvertown Tunnel Stakeholder Design Consultation Group

There are 14 schedules attached to the 187 page document. Schedule 2 part 1 reads like a set of conditions which require:

  • Time limit-5 years
  • The authorised development must be designed and implemented— (a) in accordance with the design principles; and (b) in general accordance with the general arrangement plans
  • TfL must consult with the Silvertown Tunnel Design Review Panel; and the Silvertown Tunnel Stakeholder Design Consultation Group, during the detailed design of the authorised development
  • specific work items details to be submitted and approved
  • code of construction practice
  • No part of the authorised development may be commenced until the following plans and strategies, required by the code of construction practice, have been prepared
    • Construction Site River Strategy:
    • Emergency Plan:
    • Fire Plan;
    • Lighting Management Plan:
    • Site Waste Management Plan
  • No part of the authorised development may be commenced until the following plans and strategies, required by the code of construction practice, have been prepared
    • Air Quality Management Plan
    • Archaeological Written Scheme of Investigation
    • Community Engagement Plan
    • Construction Materials Management Plan ;
    • Construction Traffic Management Plan
    • Ecology Management Plan
    • Flood Warning and Evacuation Plan
  • Groundwater Monitoring and Verification Plan
  • Noise and Vibration Management Plan;
  • Passage Plan
  • Construction Environmental Management Plan:
  • Landscaping scheme
  • Monitoring and mitigation strategy
  • secure implementation of measures approved in accordance with the approved programme
  • TfL must— (a) implement a monitoring programme in consultation with the members of STIG; (b) prepare— (i) quarterly monitoring reports for a period of one year from the Silvertown Tunnel opening for public use; and (ii) annual monitoring reports thereafter, derived from that monitoring, and submit them for consideration by the members of STIG
  • Not less than three years before the Silvertown Tunnel is expected to open for public use TfL must install Nitrogen Dioxide (“NO2”) monitors at locations determined in accordance with paragraph 3.7.4 of the monitoring and mitigation strategy.
  • The authorised development must be carried out in accordance with the flood risk assessment.
  • No part of the authorised development may open for public use until a written scheme of proposed noise mitigation measures in respect of the use and operation of that part has been submitted to and approved in writing
  • Prior to the opening of the authorised development for public use, TfL must install noise barriers to protect properties in the Siebert Road, Invicta Road/Westcombe Hill area from the effects of traffic noise from the A102.
  • TfL must secure a cross-river bus service provision using the tunnels which delivers the same or greater levels of public transport
  • TfL must secure the provision of enhanced river crossing facilities for cyclists and pedestrians between the Greenwich Peninsula and Canary Wharf and Silvertown for at least the duration of the monitoring period,
  • authorised development must be carried out in accordance with the biodiversity action plan and mitigation strategy.
  • No part of the authorised development may commence until a site investigation and risk assessment has been carried out
  • The Silvertown Tunnel must not open for public use and the tunnel services buildings at the South Portal comprised in Work No. 12 must not be occupied after their practical completion until the hazardous substances consent for the East Greenwich Gasholder Station site has been revoked or modified
  • The Silvertown Tunnel must not open for public use until the hazardous substances consent for the Brenntag Inorganic Chemicals Ltd site has been revoked or modified
  • Re-use of excavated material on-site
  • Local business transitional support

Part 2  of Schedule sets out the procedure for discharging the requirements of Part 1 of the order including submitting draft documents to Newham, Greenwhich and Tower Hamlets prior to formal submission.

Schedule 3 sets out the approach to stopping up roads including roads to be temporarily closed, permanently closed or substituted.

Schedule 4 sets out the land in which only new rights may be acquired

Schedule 5 Details Approach To  Modification Of Compensation And Compulsory Purchase Enactments For Creation Of New Rights

Schedule 6 Land In Which Only Subsoil Or New Rights Above Subsoil And Surface May Be Acquired

Schedule 7 Land Of Which Only Temporary Possession May Be Taken

Schedule 8: Removal Of Motor Vehicles And Recovery Of Penalty Charges

Schedule 9: Blackwall And Silvertown Tunnels Byelaws

Schedule 10:Classification Of Roads, Etc.

Schedule 11: Article 61 Traffic Regulation Measures, Etc

Schedule 12 :Deemed Marine Licence

Schedule 13: includes protective provisions

Schedule 14: Article 65 Documents To Be Certified

Tfl’s website states:

“Now that the DCO has been granted, we are working with local boroughs, landowners and other stakeholders to outline the next steps for the project. This includes agreeing details of land acquisitions, construction plans and access requirements for residents, visitors and local businesses as the scheme progresses”

“We are now working to procure a contractor to design and build the tunnel. We hope to confirm a preferred bidder in winter 2018 and award the contract in early 2019 so that construction can begin later in that year” 

Construction could begin in early 2019, with the new tunnel expected to open in 2023.

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Girl on The Tube Returns


This years Girl on the Tube starts on the River, the Limehouse Cut to be exact.

The Limehouse cut is a part of my local area I haven’t really explored until recently, mostly because it wasn’t very inviting. But my interest has peaked recently since seeing paddle boarders and canoers enjoying the waterway, as well as unusual bird species.

The Limehouse Cut is one of London’s oldest waterways dating back to 1766 according to the Canal and River Trust. It was created to save barges having to wait for the tide before navigating the long southward loop of the Thames around the Isle of Dogs.

The Canal and River Trust itself acknowledges that this section of river has previously attracted an unsavoury reputation. However, the Cut’s fortunes have changed since it was adopted by 19 local organisations led by Poplar Harca in September 2016.

Now seems like the perfect time to explore the Canal a bit more.

There’s so much to absorb along the river including…

…New green spaces

Three Mills Green is the first completed part of the Lea River Park which will see new open spaces including Twelvetrees Park, situated around seven Victorian gas holders, and Poplar River Park.

…Major Infrastructure Works

Opposite the Three Mills Park, the Pudding Mill Lane to Stepney Green Crossrail tunnel is being constructed.

…Historic Conservation

The Three Mills has been in existence since the Saxon times. The historic buildings form part of the Three Mills recording studios.

…Historic Regeneration in progress

In the distance, you can just make out Robin Hood Gardens.

This building  has had  a controversial history as attempts to save the building from demolition were made by the 20th century society.

“The Smithsons were the first architects of twentieth century Britain to make a hugely significant contribution to world architectural discourse, and Robin Hood Gardens is an outstanding example of post-war British architecture”,

Robin Hood Gardens is included in the Blackwall Reach development which was approved in 2012, and two attempts to save the building from demolition by world renowned architects were rejected, most recently in 2015. Demolition started in August 2017.

Part of the building is currently on display  at the V&A’s Venice Architecture Biennale.

…Retention & Repurposing of warehouses 

There are a few pockets of industrial pieces of land still to be seen on the riverside as the majority of the buildings move into residential use. Some have cleverly retained the warehouse facades as part of redevelopment.

…New Development

Such as this new block of apartments going up by Fairview Homes.

Whilst there is a lot of change going on, I think the local wildlife are enjoying the cleaned up waterway.

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The London Plan- In case you Missed it


The London Plan is the strategic planning policy document for all London Boroughs and forms part of the statutory development plan for each authority. It sets the strategic housing requirement for the whole of the metropolitan area and how this will be delivered as well as setting the strategic approach to other matters such as economy, design, heritage open space and landscaping and technical details such as renewable energy and drainage.

The current version of the London Plan was first adopted in 2011 with changes made during the course of 2015 and 2016.

The new London Plan or ‘Replacement Plan’ as it is also known was published for consultation in December 2017. This revised plan sees a step change in approach to planning decisions as it goes much further than being an overarching strategic planning document. Upon its anticipated adoption in 2019, it will come into effect straight away and the way in which it written means that authorities would not need to prepare a Part 1 Local Plan.

Whilst the Mayor is seeking to take some of the control of the function of the Boroughs, it doesn’t look to take all of them including the duty to co-operate. As the HBF wrote in their representations, the Mayor cannot pick and chose which functions they want to perform. The Mayor also proposes to set a metropolitan wide level for affordable housing at 50%
The Replacement Plan will run from 2019 to 2041 and sets a requirement of 64,935 dwellings over the first 10-year period. The capacity is made up of 400,470 homes from large sites and 245,730 homes over the 10 year period from small sites of less than 0.25 ha.

There is also reliance on increasing the number of units on those opportunity areas identified in the current London Plan and identifies approximately 9 new Opportunity Areas.

Development at Kings Cross Opportunity Area

Current and emerging Opportunity Areas. London Plan SHLAA 2017

There is a heavy reliance on brownfield land and optimising potential on:

  • Sites of PTAL 3-6
  • Mixed use redevelopment of car parks and low density retail parks
  • Intensification of residential on commercial leisure and infrastructure sites
  • Redevelopment of surplus sites
  • Small sites
  • Industrial sites
  • Sites that are allocated for residential and mixed-use development

There is also a general presumption against single use low-density retail and leisure parks.

Green Belt
The plan identifies that all the dwellings proposed can be provided within the City without extending out into the Green Belt. Policy G2 London’s Green Belt states that:
A The Green Belt should be protected from inappropriate development:
1) development proposals that would harm the Green Belt should be refused
2) the enhancement of the Green Belt to provide appropriate multifunctional uses for Londoners should be supported.
B The extension of the Green Belt will be supported, where appropriate. It’ s de-designation will not.

Given that 800,000 people commute between the City and the wider South East on a daily basis, it is questionable as to whether 65,000 dwellings can be delivered within the boundary of London. Nevertheless, the approach to Green Belt reviews should be undertaken by local authorities within their Part 1 Plans.

Commuting Patterns across London and wider region. London Plan 2017

The Plan Identifies 12 infrastructure priorities that the mayor will support within the Wider South East as they are of importance to the city. These include:

  1. East West Rail and new Expressway road link (Oxford – Cambridge)
  2. North Down Rail Link (Gatwick – Reading) including extension to Oxford
  3. A27 / M27 / A259 and rail corridor (Dover – Southampton)
  4. West Anglia Mainline, Crossrail 2 North (London – Stansted – Cambridge -Peterborough) and M11
  5. Great Eastern Mainline (London – Ipswich – Norwich) and A12
  6. Essex Thameside, A217 and A13 corridor
  7. Thames Gateway Kent : Elizabeth Line Extension and HS1 (London – North Kent -Channel Tunnel)
  8.  Lower Thames Crossing
  9. Brighton Mainline (London – Gatwick – Brighton)
  10. South West Mainline, Crossrail 2 South West (London – Surrey / Southern Rail Access to Heathrow) and A3
  11. Great Western Mainline (London – Reading / Western Rail Access to Heathrow)
  12. Midlands and West Coast Mainline (London – Luton – Bedford / Milton Keynes)
  13. Felixstowe – Nuneaton / Midlands and A14

There has been a lot of discussion regarding the removal of the density matrix within Policy DM6 of the Replacement Plan in favour of higher densities across all sites. Policy DM6 requires the submission of a Management Plan where density is exceeded in the following cases:

  1. 110 units per hectare in areas of PTAL 0 to 1
  2. 240 units per hectare in areas of PTAL 2 to 3;
  3. 405 units per hectare in areas of PTAL 4 to 6

All of these units per hectare standards are those applied to central locations suggesting that a higher density approach to new developments will be the normal approach. A high-density scheme in a suburban location may not be appropriate.

The Policy also requires that
“measures of density should be provided for all planning applications that include new residential units:

  1. Number of units per hectare
  2. Number of habitable rooms per hectare
  3. Number or bedrooms per hectare
  4. Number of bedspaces per hectare.”

So, the density matrix whilst not there will still clearly play a part in the decision-making process for authorities.

Tall Buildings

Policy D8 states that the definition of a Tall building can be made by each local authority, again suggesting the approach to higher density development wherever possible. A tall building is still referable to the GLA if it exceeds 30m.

Policy D2 requires design reviews to be undertaken at least once in addition to pre-application advice if they are:
– Above the density indicated in Policy D6
– Propose a building defined as tall building or that is more than 30m in height where there is no local tall building definition.

The approach to design should be taken by each authority within their Part 1 Plans. The approach to tall building design reviews is not helpful when read with Policy DM8.
Within Policy D3 inclusive design is promoted but no clarification is provided as to the threshold for inclusive design.

The Replacement Plan states that Boroughs should identify Strategic Areas for Regeneration in Local Plans based on a thorough understanding of the demographics of communities and their needs.

Affordable Workspace
The Replacement Plan emphasises the need to provide affordable workspace and low cost business space through Policy E3 Affordable Workspace

Basement Development
A Policy is now included on the need to assess large scale basement development along with a Policy also stating that any applications for fracking should be refused.

Public Houses
More protection for pubs is now included along with a policy requiring the provision of public toilets in proposals that involve people standing for long periods of time.

There is now clear guidance on how to deal with managing heat risks, requiring an assessment of overheating through CIBSE TM59 for domestic developments and TM 52 for non-domestic developments. In addition, TM 49 guidance and datasets should also be used to ensure that all new development is designed for the climate it will experience over its design life. The

Air Quality
Whilst air quality is addressed in reference to other policies in the current London Plan, air quality requirements are addressed as a standalone policy in the Replacement Plan, requiring development to not lead to further deterioration of existing poor air quality, or create areas that exceed air quality limits.

The Replacement Plan sets a Policy aim for development to achieve greenfield run off rates as the starting point. Development proposals for impermeable paving should be refused where appropriate, including on small surfaces such as front gardens and driveways.

Car Parking
Car-free development should be the starting point for all development proposals in places that are (or are planned to be) well-connected by public transport, with developments elsewhere designed to provide the minimum necessary parking (‘car-lite’) with maximum standards.

Those proposals with parking included need to include electric vehicle charging points.

Strategic Approach to Transport

The Replacement Plan sets out a significant list of transport infrastructure projects proposed to deliver the strategic target of 80% of all trips in London to be made by foot, cycle or public transport by 2041 and authorities in preparing development plans would need to support these projects. Such projects include the Silvertown Tunnel, Crossrail 2 and the provision of a new bridge linking south to east at Rotherhithe and Canary Wharf.

Next Steps
The Examination in Public will take place in the Autumn of 2019 with the adoption of the final London Plan in the Autumn of 2019.


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What’s on in London?


Urbanissta’s ‘Girl on the tube’ Kathryn Waldron, has been catching up with what’s on in London. The London landscape is forever changing – new plans, new infrastructure and more air pollution.

With a draft of the new London Plan expected in the autumn, we thought now was a good opportunity to look back at what’s been going on in London over the past couple of months.

  • Silvertown Tunnel
  • Supplementary Planning Guidance
  • Opportunity areas
  • Air pollution
  • Planning applications

1 . Infrastructure – Silvertown Tunnel

With the decision made on the preferred option for the Thames Crossing through Thurrock and Gravesend, further west into the city, the planning inspectorate has recommended the nationally significant Silvertown tunnel project to the Secretary of State. The application was submitted in April 2016 and been the subject of six month of public examination.

The Secretary of State now has until October 2017 to decide whether or not to grant the application. Should the application be successful, TFL anticipate that Silvertown Tunnel construction would begin in 2018.

The earliest the Silvertown Tunnel could become operational is 2022/23.

The new tunnel would:

  • Reduce the impact of unplanned incidents at the Blackwall Tunnel by providing a nearby alternative route
  • Cut down on queuing at the Blackwall Tunnel and approach roads
  • Include user charging at the Blackwall and Silvertown Tunnels to manage demand and provide a source of revenue to help build and maintain the new tunnel
  • Provide an opportunity to create new cross-river bus links in east London
  • Improve road connections to and from Docklands and east London from South London
  • Improve journey times and make travel, deliveries and servicing more reliable

The tunnel will also create opportunities for new jobs in the local area, help local employers to access new markets and reduce the environmental impact of traffic congestion.

An extensive range of detailed information about the Silvertown Tunnel scheme is in the application documents. Find out more here.

 2 . Supplementary Planning Guidance- Affordable Homes and Night Time Economy

Information about Affordable Housing and Viability Supplementary Planning Guidance.

The Mayor’s long-term aim is for half of all new homes to be affordable.

Consultation on an ‘Affordable Homes SPG’ ran from 29th November 2016 to 28th February 2017. Last week, the Mayor published the new SPG Affordable Housing and Viability Supplementary Planning Guidance. 

This SPG supersedes section 3.3 (Build to Rent) and Part 4 (Affordable Housing – Viability Appraisals) of the March 2016 Housing SPG. The rest of that SPG remains current.

The SPG sets out the Mayor’s preferred approach to implementing London Plan Policies 3.11 (Affordable housing targets), 3.12 (Negotiating affordable housing on individual private residential and mixed use schemes), and 3.13 (Affordable housing thresholds).

The SPG’s main aim is to increase the number of affordable homes delivered through the planning system. Importantly, it will help embed the requirement for affordable housing into land values and make the viability process more consistent and transparent. It will help ensure that where development appraisals take place, they are robustly and consistently scrutinised, whilst its innovative approach will also reduce the risk and increase the speed of the planning process for those schemes which deliver more affordable homes.

The threshold approach

Two approaches to affordable housing viability are being proposed depending on the amount of affordable housing being provided.

Over 35% provision

Applications that meet or exceed 35 per cent of affordable housing provision without public subsidy, provide affordable housing on-site, meet the specified tenure mix, and meet other planning requirements and obligations to the satisfaction of the LPA and the Mayor where relevant – are not required to submit viability information. Such schemes will be subject to an early viability review, but this is only triggered if an agreed level of progress is not made within two years of planning permission being granted (or a timeframe agreed by the LPA and set out within the S106 agreement).

Less than 35%

Schemes which do not meet the 35 per cent affordable housing threshold, or require public subsidy to do so, will be required to submit detailed viability information. Where an LPA or the Mayor determines that a greater level of affordable housing could viably be supported, a higher level of affordable housing will be required which may exceed the 35 per cent threshold. In addition, early and late viability reviews will be applied to all schemes that do not meet the threshold in order to ensure that affordable housing contributions are increased if viability improves over time.

Where an LPA currently adopts an evidenced approach which will deliver a higher average percentage of affordable housing (without public subsidy) the local approach can continue to apply.

On the matter of vacant building credit the Mayor’s view is that in most circumstances in London it will not be appropriate to apply the Vacant Building Credit.

Viability appraisal approach

The Mayor’s preference is for using Existing Use Value Plus as the comparable Benchmark Land Value when assessing the viability of a proposal. The premium above Existing Use Value will be based on site specific justification reflecting the circumstances that apply.

Build to rent

Build to rent is a distinct form of affordable housing being promoted by the Mayor with Discount Market rent as the affordable housing offer with homes let at London Living Rent. Any on-site affordable housing must include provisions to remain at an affordable price in perpetuity or that the subsidy (this includes the Section 106 ‘subsidy’) must be recycled for alternative affordable provision. Guidance is also provided on how Build to Rent viability assessments differ from traditional appraisals.

Culture and the Night Time Economy Supplementary Planning Guidance

A draft Supplementary Planning Guidance on Culture and Night time economy was the subject of consultation between April and May 2017. Perhaps following a number of high profile events including the closure of the famous night club Fabric and the closure of pubs in favour of residential conversion.

The SPG cites that London has 103 fewer nightclubs and live music venues than it did in 2007 and 35% of its grassroots music venues have been lost. 140 pubs are also lost each year.

This work ties in with the work of The London Assembly Economy Committee which is investigating London’s night time economy and working towards a 24-hour city.

The investigation will look at what a diverse NTE could look like, how it might be sustained and its likely impact on those who will work in it.

This supplementary planning guidance (SPG) provides guidance on implementing London Plan policies that have a bearing on London’s culture and the night time economy including:

  • Protecting pubs
  • Sustaining existing venues
  • Providing new facilities
  • Creating a more diverse and inclusive night time
  • Culture and economy
  • Agents of change
  • Places

We can expect the new London Plan to have a stronger more defined stance on London’s evening economy.

3. Opportunity Areas – Old Park and Park Royal and Isle of Dogs and South Poplar

Old Park and Park Royal

Old Park and Park Royal were identified as an Opportunity Area within the London Plan.

The Old Park and Park Royal Development Corporation (ODPC)was created in April 2015. The Development Corporation is responsible for the regeneration of the 650 hectare site where Crossrail and HS2 will meet in the north west of London. It includes areas of Brent, Ealing and Hammersmith and Fulham.

The ODPC is essentially the local planning authority, and are responsible for preparing and maintaining a Local Plan or Development Plan.

OPDC carried out the first consultation on the draft Local Plan and its supporting evidence base documents between 4th February and 31st March 2016. The public consultation on the revised draft Local Plan and associated documents runs from 29th June until midnight and on 11th September 2017.

The spatial strategy for Old Park and Park Royal is the creation of one main town centre stretching from Willesden Junction to North Acton, and three Neighbourhood Town Centres. The commercial centre is to be located around Old Oak with Wormwood Scrubs to be retained as open space.

The anticipated adoption of the ODPC Local Plan is spring 2018.

Isle of Dogs and South Poplar Opportunity Area

The GLA are working with Tower Hamlets to create an opportunity area at the Isle of Dogs and South Poplar. This additional opportunity area would add to the 44 other Opportunity Areas adopted or in progress within London.

An Opportunity Area Planning Framework is being prepared with a target of 30,000 new dwellings and 110000 new jobs, 9% of the total minimum housing requirement identified for the Opportunity Areas.

A Draft Opportunity Area Planning Framework is anticipated at any time now.

4. Air pollution

The GLA are preparing detailed guidance on air quality. Four stages of consultation are programmed of which three have already been undertaken.

16,000 Londoners commented on stage one and over 15000 on stage two. Stage 3a closed in June and responses are to be published in the autumn.

The most recent consultation considered the public’s views on proposals to:

  • Introduce the ULEZ in central London on 8th April 2019, to reduce overall exposure to air pollution and bring forward the health benefits to Londoners. This is around 17 months earlier than the currently approved date of 7th September 2020. Additionally, ULEZ resident’s vehicles that are not compliant with ULEZ emission standards will benefit from a three-year “sunset period” or “grace period” from the start of the ULEZ
  • A change to the required ULEZ emission standard for diesel vehicles to include Particulate Matter (PM) to ensure alignment with the national standards set as part of the government’s National Air Quality Plan

Whilst consultation on the London Air quality plan is on-going, the GLA has set out that the Mayor will be launching a £10 toxicity ‘T-Charge’ aimed at the oldest, most polluting vehicles on London roads from 23rd October 2017, and introducing a requirement for all newly licensed taxis to be zero emission capable from 1st January 2018.

5. Planning Applications- referrals and directions to refuse

Application referrals

For the week commencing 21st August 2017, 4 applications were referred to the GLA, including a minor material amendment for a mixed use development in Bishopsgate, redevelopment of a fitness club in Fulham and a Waste Transfer Station in Havering. .

Directions to refuse

On July 17th 2017, the Mayor directed Bexley and Barnet to refuse applications in their boroughs.

Bexley were directed to refuse redevelopment of the Howbury Park to provide a strategic rail freight interchange. The scheme is considered inappropriate development in the Green Belt.

Barnet were directed to refuse an application at Hasmonean High School for redevelopment of the school to create a combined Boys and Girls school. The scheme was considered inappropriate development in the Green Belt and it was considered that there was a lack of sustainable transport measures.

Do you need more information about planning applications? Find out more here.

Follow our series of ‘Girl on the tube’ and see what London really looks like to a Planner.

“I’m the girl on the Tube, no stranger to the fast-paced life of London and I take the underground every day to and from work.

I rise up from the tunnels of bustling business people and enthusiastic tourists and step out into the streets of London. Sensibly putting comfort and practically before fashion, wearing my well-worn trainers instead of 6-inch stilettos.”

Girl on the tube Part One

Girl on the tube Part Two

Girl on the tube Part Three

Girl on the tube Part Four

Girl on the tube Part Five


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PIP- The Newest Acronym to the Planning Dictionary


Brownfield development planning article

Permission in principle (PIP) was first established in planning law when Section 150 of the Housing and Planning Act 2016 inserted sections 58A, 59A and 70(2ZZA) to (2ZZC) into the 1990 Act.

The Housing and Planning Act 2016 (Permission in Principle etc.) (Miscellaneous Amendments) (England) Regulations 2017 was made on March 6th 2017. This instrument makes a number of consequential or miscellaneous amendments to four Acts of Parliament.

In our planning reforms blog, we set out a number of statutory instruments that would need to be made before the implementation of PIP. These include the Permission in Principle Regulations and the Brownfield Land Register Regulations which have now been made and came into force in the middle of April 2017.

There are three options for PIP:

  1. A qualifying body or local authority chose to allocate the site within an emerging plan
  2. The site is identified on a brownfield register. “brownfield land register” means a register kept under regulation 3 of the Town and Country Planning (Brownfield Land Register) Regulations 2017(b);
  3. An application to the authority for PIP

A PIP in itself does not constitute a permission, a technical details submission in required in accordance with the amended Development Management Procedure Order. A technical details consent would be required within 5 years of receiving the PIP.

We set out below the regulations for option 2- Brownfield Land Register

Brownfield Land Register

The Town and Country Planning (Brownfield Land Register) Regulations 2017 were made on 20th March 2017, Laid before Parliament 23rd March 2017 and came into force on 16th April 2017.

Article 4 of the Permission in Principle Order states that:

“Permission in principle is hereby granted for development of land allocated in Part 2 of a brownfield land register consisting of—

(a) housing development for the provision of a number of dwellings falling within the range specified in the relevant entry in the brownfield land register; and

(b) Where the relevant entry in the brownfield land register specifies non-housing development of the land, non-housing development of a description falling within the description in that entry


The regulations place a duty on local authorities to prepare a register of previously developed land (Brownfield Land Register) within their area and meets criteria of paragraph 1 of regulation 4, i.e. suitable for housing development. This register must be published by December 31st and it must be in 2 parts.

Part 1

To be within part 1 of the register, the following criteria applies in accordance with article 4.—(1):

  • The land has an area of at least 0.25 hectares or is capable of supporting at least 5 dwellings;
  • The land is
    1. Suitable,
    2. Available

Suitable meaning

  • allocated in a local development plan document
  • planning permission for residential development
  • has a grant of permission in principle for residential development
  • Appropriate for residential development with regards to natural environment and local built environment.

Available meaning

  • the owner expressed an intention to sell or develop the land, or
  • the local authority believe there to be no issues relating to ownership and legal impediments which might prevent residential development

Achievable meaning

  • The development is likely to take place within 15 years.

Note that this is different to deliverable which is taken to mean that there is a reasonable prospect that residential development will take place on the land within 5 years beginning with the entry date;

The part 1 register must include:

  • the local authority’s own reference for the land;
  • the name and address of the land;
  • a plan which identifies the land;
  • site co-ordinate and co-ordinate reference system used
  • the area of the land in hectares;
  • the name of the local authority;
  • the uniform resource identifier “URI”
  • the ownership status of the land
  • where the land is “deliverable” a note to that effect;
  • the planning status of the land, expressed as—
    • “permissioned”,( including full, outline or reserved matters, or permission in principle or technical details consent)
    • “not permissioned”, or
    • “pending decision”;
  • a description of any proposed housing development; or
  • the minimum and maximum net number of dwellings, given as a range, which, in the authority’s opinion, the land is capable of supporting;
  • the minimum net number of dwellings which, in the authority’s opinion, the land is capable of supporting;
  • where the development includes non-housing development, the scale of any such development and the use to which it is to be put;
  • the date that the land was first entered in the register; and
  • where applicable, the date that information about the land was last updated in the register.


The LPA must also show that they have undertaken the publication of the site in part 1 in accordance with the regulations. They must also show that they have given requisite notice of their intention to enter that land in Part 2,

Part 2

In accordance with article 4 of the Town and Country Planning (Permission in Principle) Order 2017, sites that are within part 2 of the register are allocated for Permission in Principle.

The site has to meet all of the requirements of part 1, and the Local Authority have decided to allocate the site for residential purposes and have undertaken consultation as required. This includes giving requisite notice in at least one place on or near the land for not less than 21 days stating the date in which representations may be made, where and when to view the information and how to submit representations. Spefic information must be published on a website maintained by the local planning authority.

In relation to each entry of land in Part 2, the register must contain—

  • the minimum net number of dwellings, and the maximum net number of dwellings, given as a range
  • where the development includes non-housing development, the scale of any such development and the use to which it is to be put.

The register must contain the information required by paragraph (3) of regulation 26 of the Planning (Hazardous Substances) Regulations 2015(a) where—

  • development of that land would, in the opinion of the local planning authority, be a relevant project for the purpose of that regulation; and
  • The local planning authority is the competent authority for the purpose of that regulation.


The register must, in relation to that land, contain the statement “allocated for residential development for the purposes of section 59A of the Town and Country Planning Act 1990 (permission in principle)” and the statement in Part 1, required by paragraph 1(2), if any, must be removed.

The regulations place a duty on local authorities to notify parishes or neighbourhood forums where they have requested notification of a proposed entry of land into part 2.

The regulations also set the requirements for undertaking consultation with neighbouring authorities, the Mayor of London and procedures for consulting other bodies.

Exemptions for certain types of land

Schedule 1 EIA development is excluded from entry into part 2 of the Register.  Schedule 2 development may be included within part 2 if the authority have the information available in accordance with the EIA regulations to be able to adopt a screening opinion that development on the site would not constitute EIA development.

Review and revision

Review must be undertaken at least once within each register year. Where land no longer meets the criteria, it must be removed. The local planning authority must not update the information required under paragraph 2 of Schedule 2 in relation to an entry of land in Part 2.

Where the land no longer meets criteria of paragraph 1 of regulation 4, it must be removed from part 1 and where applicable part 2

The local authority will need to consult as necessary and make updates to the entry

The LPA must not update the information relating to the minimum and maximum no of units and scale of non-housing development (paragraph 2).

Where an update to the minimum and maximum no of units and scale of non-housing development is required, or development of that land has been granted permission in principle under Section 59 of the TCPA

The land must be removed from part 2 and information amended in part 1. They must consult before making changes.

Where PIP has expired (5 years) the site must also be removed from part 2.

If you are looking for sites, come and talk to us. We can support your land acquisition activities using the brownfield land register and prepare a schedule that suits you to provide the greatest exposure to identify viable opportunities within any number of Local Authority areas.


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