GLA Draft Central Activities Zone Supplementary Planning Guidance (Sept 2015) London First Consultation Response 8 th December 2015 London First is a business membership organisation with the mission to make London the best city in the world in which to do business. We represent the capital s leading employers in key sectors such as financial and business services, property, transport, ICT, creative industries, hospitality and retail. Our membership also includes higher education institutions and further education colleges. London First welcomes the opportunity to respond to the GLA s draft Central Activities Zone (CAZ) Supplementary Planning Guidance (SPG) on behalf of our members. General Comments The publication of the draft CAZ SPG is a welcome step change in London Plan guidance, recognising the important role that the CAZ plays both in the London and UK economy. London First supports its publication and the additional guidance it will provide on the implementation of London Plan policies for new development in the CAZ. In particular, we welcome recognition of the need to promote and safeguard the CAZ and the north of the Isle of Dogs (Canary Wharf) and its strategic functions. We also support the intention to provide clarity weight to be afforded to office use and CAZ strategic functions relative to residential uses across the CAZ. However, to ensure that these particular objectives of the SPG are delivered through the plan making and decision-taking process, the guidance should be reflected by London Plan policy. As a general comment, the SPG is quite lengthy and replicates significant tracts of London Plan policy and the Draft Interim Housing SPG (2015). As such, there is considerable scope for the draft SPG to be reduced in size and non-essential content removed. Section 1: Promoting the CAZ as a competitive business location London First supports the general thrust of this section of the draft SPG and the objective of addressing the conflict between residential and CAZ Strategic Functions. In particular, we support the intention of the SPG to provide additional clarity on the weight to be given to residential within various locations in the CAZ. We agree in principle that residential development is not appropriate within the commercial core of the City of London and the north of the Isle of Dogs and support reinforcement that these areas are exempt from the requirements of mixed use policy (4.3b). We agree, in general terms, that CAZ strategic functions and offices uses should be a priority use compared to new residential uses in the West End, Soho, City Fringe/Tech City, some Opportunity and Intensification Areas (within the CAZ) and clusters of specific uses within the CAZ.
However, this should not preclude residential development coming forward in these locations where it can coincide with and not compromise the continued operation and viability of CAZ Strategic Functions. As such, we consider that the approach taken in table 1.1 is overly restrictive and should be revised to be more welcoming of residential within the CAZ. We are in accord with the statements of para. 1.16 that in order for London to maintain its globally competitive status, that London Plan policy should be implemented in ways that promote and incentivise office and other commercial development and that regard should to be given to the way that business space is being used including new technologies, working practices and employment densities. We agree that in order to accommodate the growth that London needs more intensive and higher density development in parts of the CAZ and potential revisions to the CAZ boundary. The additional devolved powers for the Mayor through the Planning and Housing Bill will enable the GLA, in conjunction with boroughs, to define and amend the CAZ boundary as required through the London Plan to ensure that the Mayor s strategic policies for the CAZ are applied where support for strategic functions is required. Office Development (section 1.2): The Mayor s strategic support is essential in securing the ongoing protection of London s office stock within the CAZ from office to residential permitted development rights as a nationally significant area of economic activity. We support the proposed coordinated approach to Article 4 directions to cover the currently exempted areas. Loss of Offices (Section 1.3): London First supports the objective of this part of the SPG to seek to protect and maintain employment capacity in Central London and rebalance any losses of office floorspace. We consider it important, however, that the CAZ SPG provides greater flexibility in respect of how office floorspace is re-provided. A requirement to provide replacement floorspace on site or nearby in all cases is too restrictive an approach and is not sufficiently flexible to allow the circumstances of each site to be considered. There is greater scope to deliver this flexibility through the use of land use swaps and credits and payment in lieu.. It is positive and welcomed that the SPG includes more detailed guidance on the scope of demand, viability and marketing evidence that should be provided by applicants. However, the SPG should make it clear that viability evidence should be appropriate and proportionate. Furthermore, it is disappointing that the GLA did not develop a set of bespoke London-wide criteria (with the assistance of the London Office Review Panel) instead of citing the City of London s planning guidance (figure 1.1). We recommend figure 1.1 should be replaced with a set of criteria which more appropriately reflect the office market within the CAZ. Page2
Small offices (Section 1.5): We note that the Ramidus report (as cited by the SPG at para 1.5.4) states that there is no need for CAZ wide policies specifically to protect small offices. However, in direct conflict with this London Plan policy 4.3c provides for Local Planning Authorities to bring forward policies within the CAZ to protect small offices. Given the clear conclusions of the Ramidus report, London First is concerned that overrestrictive planning policies at local level to safeguard office use do not appear necessary, given the ability of London as a whole to cater for office demand and address affordability, particularly in fringe locations. It is therefore crucial that the flexibility to consider the circumstances of each site (as set out in section 1.2) is provided in local planning policies. However, in short, it is critical that boroughs do not seek to retain small offices in aged stock that would be better redeveloped for another use and further that they do not put at risk the delivery of large floorplate offices. London First understands the broad objectives behind the introduction of benchmarks for monitoring small office supply and rental levels within the CAZ. However, these benchmarks are too restrictive and fail to recognise the important role of specialist providers who deliver smaller and shared offices including space for start-ups and SMEs within larger floorplates, with flexible and shorter term leases. The monitoring benchmarks should be amended to take this into account. Furthermore, we consider that the SPG should be amended to contain clear guidance on how boroughs should respond (in terms of plan making and decision taking) when these indicators show a supply side issue. Mixed use policy (Section 1.4): It is critical that office developments in the CAZ remain financially viable and are not put at risk by mixed use policy requirements. London First therefore strongly endorses the need for a sensitive approach to the application of mixed use policy within the CAZ and are supportive of the proposals that boroughs should consider raising the floorspace threshold triggers for such policies (para 1.4.8). The suggested default threshold of 200 sq.m (para 1.4.9) is too low to be applied CAZ wide in our view. We consider that a higher default threshold of 500 sq.m is more robust and more likely to ensure that office developments within the CAZ remain viable whilst also delivering a contribution towards housing delivery where feasible. We support the application of alternate thresholds based on percentage uplift in office floorspace, alongside a higher threshold of 500 sq.m. A threshold of 30% (with greater flexibility for offsite provision and payments-in-lieu between 30% and 50%) is proposed in Westminster. Similar approaches should be considered in other Boroughs, to help re-balance the delivery of commercial and residential uses in the CAZ. However, it should be recognised that this will not be suitable on all sites, for example, large vacant sites within Opportunity Areas, which may be suitable for commercial-led regeneration. Page3
We agree with the proposed approach that only the floorspace above the threshold should be used as the basis for assessing the appropriate level of residential floorspace to be required (para 1.4.10). It is paramount that the viability and prosperity of office and commercial uses are not undermined by the requirement to include residential uses, we therefore strongly support the SPG s acknowledgement at para 1.4.14 that there should be a flexible approach to the requirement for on-site housing within mixed use schemes e.g. not necessarily an equivalent amount. The use of land use swaps and credits within and outside of the CAZ will form an important part of this. However, this should be extended to enable swaps and credits across borough boundaries this will deliver additional flexibility to meet London wide housing need whilst ensuring that commercial/office development within the CAZ remains deliverable and viable. Industrial Land (Section 1.8): We note that the SPG encourages boroughs to consider whether all industrial sites within the CAZ would merit designation as Locally Significant Industrial Land. Whilst London First understands the objective to protect and maintain London s industrial capacity within the CAZ in the face of a reducing supply, we are of the view that such sites should not be maintained in low value/low intensity uses, but that the boroughs should be required to explore the scope for redevelopment for urban logistics including as part of mixed use schemes where appropriate. Section 2: Managing the attractions of the CAZ as a global retail, cultural and visitor destination We welcome the identification of the importance of cultural and evening uses including those outside of Strategic Cultural Areas to the role and function of the CAZ and London as a global cultural and visitor destination. Central London s cultural and evening sector also underpins the economy in terms of providing an environment that makes offices successful. Lifestyle factors for employees are often more important to businesses establishing here than access to finance or sector expertise. The SPG does not make any distinction between the evening and night time economy, which, in our view, should be incorporated, as both have a different profile of user and scope of potential impact on the CAZ and surrounding uses. We note, however, that the advent of the 24-hour tube could result in widening of the type and number of night time uses emerging potentially highlighting a need for local policy approaches to inform how these are managed through the planning decisions process. This reinforces the need to clarify the definition of evening and night time economy within the SPG. We support, in principle, the widening of the definition of cultural uses this will form a central part of borough approaches in identifying emerging clusters of cultural uses and Page4
evening activities, for example, Shoreditch and Clerkenwell and inform the need for any local policies to strengthen, promote and protect these areas. Such emerging clusters are often a precursor to a rise in demand for new residential development in these areas. We therefore view the guidance within the SPG on managing the conflict between residential and cultural venues as very positive in enabling London s cultural offer to flourish. In particular, the identification that residential uses should not strategically constrain the diverse mix of cultural, leisure, entertainment and evening uses within the CAZ and the requirement that mitigation measures are embedded within the design of any proposed residential development at an early stage. In tandem with this, we believe that the SPG should acknowledge that the standards of amenity expected for residential development within the CAZ should be different to those expected outside of the CAZ e.g. that the CAZ will have a naturally higher level of traffic, noise and night time activity and a set of criteria should be developed accordingly. Coupled with this, the SPG should identify the need for the planning and licensing applications to support the cultural and evening economy in respect of planning conditions on hours of operation and deliveries etc. This should sit alongside the SPG s guidance at para 2.2.15 that addressing the cumulative effects does not necessarily require boroughs to reduce or restrict evening uses within existing or emerging clusters. Retail (Section 2.4): In order to strengthen the role of the West End as an international shopping centre, we consider that there needs to be a more flexible approach at a local level to expanding the defined retail centres. For example; to the north and south of Oxford Street where developments like Crossrail will increase accessibility of the area and therefore potential visitor numbers. Such retail policies also need to allow international shopping centres to include a wider variety of uses (not just retail) that support and diversify the town centre offering and retail shopping experience. We consider that the SPG should contain strategic guidance on the need for more flexible approaches to the West End s shopping streets, including greater flexibility to introduce restaurant, cafe and leisure uses, particularly on its secondary retail frontages. Furthermore, we consider that the provision of active frontages throughout the CAZ should be supported through the SPG. This will ensure a vibrancy of uses throughout the CAZ whilst contribute to London s thriving economy. Section 4: Housing in the CAZ As per our comments on the previous sections, London First welcomes intention of the SPG to provide additional clarity on the weight to be given to residential within various locations in the CAZ. The SPG guidance will form an important part of ensuring central London s continued economic success. Page5
We support the objective that CAZ strategic functions and the viability of office developments should not be constrained or undermined, however, the SPG should not preclude residential within the CAZ outside of the core commercial area of the City of London and Canary Wharf. We are concerned that as drafted it does not positively welcome residential development where can coincide with and not compromise the continued operation and viability of CAZ Strategic Functions. The SPG should be revised accordingly. Our specific comments on the housing elements of the SPG are: Where boroughs straddle the CAZ boundary, focusing housing delivery on sites that are suitable for higher density, residential-led development on sites within the CAZ fringes and outside of the CAZ boundary to relieve pressure on the CAZ s core commercial, cultural and entertainment areas is supported (para 4.5.1); We agree that residential development should be delivered at higher densities within Opportunity Areas (para 4.5.1). This will optimise on land use in the CAZ and enable the delivery of more housing; Estate renewal also offers capacity to deliver new housing and broaden the mix of tenures within housing estates (para 4.5.2). We welcome the SPG s acknowledgement of the need for careful consideration of appropriateness of the CAZ for affordable family housing in including the impact of the benefit cap and viability of the provision of larger units (para 4.7.2). In this respect, we support the use of land use swaps within and beyond the CAZ and across borough boundaries to enable required residential development (including affordable) to be delivered viably and for London wide housing needs to be met. We consider that there is greater scope for the application of land use swaps other than in exceptional circumstances. In our view, the SPG should contain guidance, reflective of the draft Interim Housing SPG, that acknowledges that the CAZ may be more suitable to the provision of smaller homes (e.g. 1 and 2 bed) and that boroughs should take a flexible approach to the application of their housing mix policies within the CAZ and not expect a large proportion of bigger sized homes to be provided. There should be a more flexible approach to the application of the national described space standards within the CAZ which should be reflected within the CAZ SPG. This should acknowledge that within the CAZ there is a market for high quality homes that do not necessarily meet the national space standards but deliver a high standard of living in a central London location. Given land values and development viability in central London, this could enable more lower cost homes to be delivered which meet an identified need. The CAZ SPG could also deliver greater support for the build to rent and private rented sector. The suggested additional flexibility in the application of unit size standards and housing mix expectations will be necessary to support the rental sector in London. Page6
Education Uses The SPG should provide greater recognition of the presence of third level education institutes and universities and their contribution to the vitality, diversity, role and success of the CAZ and include relevant guidance. Social and other infrastructure In our view, the SPG needs to go significantly further to identify the need for supporting amenities and social infrastructure within the CAZ and the north of the Isle of Dogs to meet the needs of residents, workers and visitors alike including healthcare. In this respect, the SPG and future London Plan policy needs to positively promote the provision of such facilities alongside new commercial and residential floorspace. Section 5: Transport, Movement and Infrastructure London First have a number of comments on this section of the SPG including: References to planning obligations (Figure 5.5) need to acknowledge the pooling restrictions that apply to funding of infrastructure through Section 106; Whilst we support the objective to expand the Cycle Hire network, we query whether this can be funded through Section 106 or whether it should fall within the scope of CIL; We strongly support objectives to improve the walking and pedestrian experience within the CAZ; The identification of micro-consolidation centres to support the CAZ is critical to ensure that the CAZ can sustain last mile deliveries for residents and businesses. We believe that there is a role for review of the potential for existing underused industrial sites within the CAZ to accommodate urban logistics. London First welcomes the recognition of the need for improved digital connectivity within the CAZ however, strategic support is required in order to improve the level and speed of service from operators including installation. This is critical in order to provide the right environment to support start-up businesses, the tech and creative sector within the CAZ. Page7