The London Plan Inspectors’ Panel Report has been released and from an industrial perspective, there were many positive points to be taken.
Beyond the acknowledgment that a 65% plot ratio is unfeasible for many schemes and the panel taking into account detailed evidence which highlights that by meeting the proposed urban greening factor requirements, many schemes become unviable due to steel reinforcement taking the increased load weight of Green Roofs (which largely negates the environmental benefits), the most interesting points relate to London’s industrial needs and how these could be met (spoiler alert: it involves the Green Belt).
Looking at storage and distribution uses, the Mayor’s evidence expects that between 280-400 hectares of land is required (depending on which plot ratio is used). However, this same evidence also acknowledges that of the existing 7,000 hectares within London, up to 944 hectares could be lost to other uses. That’s potentially a 330 hectare surplus in East London if vacancy levels were brought down to 5%.
This means that more industrial land is needed to meet future demand over the plan period to 2041 than what is assumed. The plan also doesn’t sufficiently consider the potential for lost floorspace through redevelopment, changes in shopping habits or the significant population growth. Whilst the Report doesn’t quantify the additional amount needed, it could be ‘many hundreds of hectares’. As such, the Panel Report is very clear that seeking to meet this increased industrial requirement through co-location, intensification and targeted allocation simply isn’t enough.
The way the report has decided to deal with this is through amendments to the industrial policies (Policies E4 – E7) that will require the Boroughs to find more industrial land within their individual local plans. Recommendation PR28 will require a sufficient supply of such land to be provided and maintained which is a pretty clear steer of what should happen.
One way this could be done is through targeted Green Belt release and Recommendation PR30 will require the Mayor to add wording in to direct the Boroughs to consider whether the Green Belt needs to be reviewed to provide additional capacity. Other recommendations to Green Belt policy within the plan will bring it in line with the NPPF and allow for development on Green Belt, or amendments to boundaries, in certain circumstances. This points towards a potential change in approach and the potential for sustainable Green Belt areas, many of which are brownfield (Brown Belt), to be released for much needed development.
The location of this development is vital and needs to be considered carefully given the spatial requirements of industrial uses and, with a climate change agenda in mind, the location of the people and businesses they will serve. The report quite correctly points out that the need for industrial floorspace, particularly storage and distribution, is rising in line with population growth. This is compounded by changing shopping habits and the growing need for last mile logistics.
While it is clear the London plan isn’t captured by the Duty to Cooperate, the report also directs the Mayor to carry out a strategic Green Belt Review and work with neighbouring authorities to do this before the London Plan is reviewed (likely to start in 2023). This is another way in which the industrial need could be catered for. However, the authorities around Heathrow (which the panel report requires the Mayor to support) cannot accommodate any unmet need, and are struggling to provide for the baseline, two-runway needs of Heathrow, let alone that created by the proposed third runway) this may not be the answer. This route may also run the risk of not identifying sites which align with the supply chain and emerging last-mile technology. Allocating land on the edge of Greater London may not help the need on the edge of the centre.
So, while positive and a step in the right direction, I believe the inspector’s report could have been more forceful in requiring the Mayor to provide for this need and directing the boroughs to respond accordingly. The reference to this need being ‘medium to long term’ also smacks of “kicking the can down the road”. There is an evidenced need now, in areas such as Heathrow, and a strategic plan is the perfect opportunity to bring forward sustainably located space.
It’s also likely that there will be strong political opposition to any release of the Metropolitan Green Belt, but, if we ever do get to building 300,000 homes a year, one important question would be where will these people work? And also, mindful of the British Property Federation’s findings that 280 football pitches worth of new space is required, what warehouse would store their Christmas presents?
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London Plan, Industrial, Green Belt, Brownfield