The new London Plan: using inclusive design to create good growth

London has a problem: it’s not inclusive because it isn’t affordable to live in.

This is explicitly acknowledged in the draft London Plan with bold policies to deliver genuinely affordable homes for Londoners.  We discuss the new London Plan and the impact it could have on this diverse city.

The London Plan is a strategy shaping how London evolves and develops, setting a policy framework for local planning across London. The draft Plan, under Mayor Sadiq Khan and the Greater London Authority (GLA), is a more detailed approach than any strategic plan that we have seen before.

It aspires to and defines ‘Good Growth’, with a new set of six Good Growth policies forming the framework for the Plan. These set out key principles that include how to build strong and inclusive communities, create a healthy city and deliver the homes that Londoners need. It acknowledges London’s diversity and what we need to consider in our approach to development. It’s interesting to see how this new Plan represents a very different voice for London, offering a more holistic approach to inclusive communities than has been thought of in London before.

The big change is that this plan recognises that London isn’t affordable. It acknowledges that if we are to be inclusive, people need to be able to afford to live in London. London now has a population of nearly 9 million and it is growing rapidly.

“Our teachers, our nurses and doctors can’t afford to live near the schools and hospitals they work in”

The draft Plan acknowledges the challenge of a significant percentage of the city’s key workers not being able to afford to live in London. It introduces policies promoting the build-to-rent sector, where homes are purpose-built for rent and can be offered at a discounted market rent. This will deliver affordable rent to Londoners, doing so through planning gain*, without the need for grants.

The London Living Rent, which is a type of affordable housing for middle-income Londoners, is part of the Mayor’s housing strategy and will also contribute to what is considered as affordable in the Plan.

Developers have been set the target to achieve 50% affordable housing within the housing strategy. The challenge, however, is delivery. The Mayor has therefore proposed a fast-track route, indicating that if developers promise at least 35% affordable housing in any proposed development, they are offered a surer, more certain route through the planning process. This approach can alleviate the need for detailed viability assessment required for build-for-sale under the new Plan.

Source: GLA 2015

The Mayor is looking at different models and at the densification of the suburbs, recognising the importance played by transport and infrastructure in delivering the Mayor’s target.

One policy that does need some further consideration is the Small Sites Policy. London needs to develop small sites (1-25 homes) to achieve the target of 65,000 new homes, while also diversifying the developers’ market. But it should not be at the cost of delivering accessible homes. I believe this new policy will receive some strong challenges in the consultation response and the following Examination in Public (EiP).

I am pleased to see that the approach to older persons’ housing is more rigorous than at present.  The draft Plan sees the policy position shift from a suggestion that Boroughs take account of London’s ageing population, to a requirement for the Boroughs to work with providers of specialist older persons’ housing to identify sites which may be suitable.

The Mayor is also demanding that designers comply with good practice in terms of fire safety, implying that they need to aim higher than the minimum standard of current building regulations. Fire has not previously been seen as an issue for planning; it has gone without saying that a building should be safe. The equation has been simple: access = egress.

In the wake of the Grenfell Tower fire, however, designers need to be able to demonstrate that they have thought about minimising risk and that their designs meet fire safety standards for both dwellings and non-dwellings. The minimum evacuation standard deemed acceptable by the Building Regulations in the event of a fire is for people to be carried down stairs, while the draft Plan puts an emphasis on evacuation by lift. While this clearly has cost implications, I think it is a very positive development for older and disabled people.

“Inclusive design is all about people”

The draft London Plan also addresses faith, age, gender and sexual identity when considering inclusive communities. This is a question of extending the language around inclusive design rather than dismissing past policies.

The plan ties into work that I’ve been involved in, developing a new British Standard on inclusive and accessible design. The British Standards Institute has taken a fresh approach to the former standard, Access to the built environment for disabled people, to create a new British Standard BS 8300:2018 Design of an inclusive and accessible built environment. The draft Plan promotes the adoption of this standard, recognising London’s multicultural mix and how this needs to be considered in promoting inclusive communities.

“Inclusive environments are not a design detail.”

I would like to see the Plan describe the detailed process of inclusive design more clearly. Inclusive environments are not just about buildings, but about the space between buildings, the quality of the social infrastructure, and our approach to masterplanning. It’s disappointing that the Plan mentions a new housing guidance document to replace the Housing Supplementary Planning Guidance (SPG) that is in line with current policy, but doesn’t recognise the need to refresh and update the Accessible London SPG. Our experience, sadly, is that inclusive design is still largely misunderstood by developers, clients and the construction industry.

As someone from one of the country’s leading design consultancies, I recognise that the solution isn’t a question of simply referring to a building regulation or standard, but about the design process itself. I think the draft Plan is an important step forward and I’m looking forward to the debates in the EiP to help finalise this ambitious strategy.

The consultation ends this Friday 2 March 2018. This is the last chance to comment and influence the direction of the Plan before its Examination in Public.

* ‘Planning gain’ is a term applied to the provision by a developer of some additional benefit, which is offered to – or more usually requested by – the planning authority as an incentive or requirement for regulatory approval. It is not necessarily located on the development site.

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