How Much is Too Much? Or, rules for the 1,000 year old city

I am currently working with colleagues on a study of New Cross in south London. Part of the study explores how a new London Underground station and better environment on one of London’s oldest and busiest roads, the A2 New Cross Road, could influence the location and quantity of future development. These issues are linked because improving transport connectivity usually means that higher density development – more homes in less space – becomes possible in the future.

New Cross, and Deptford immediately to the north, are some of London’s most historic neighbourhoods. The A2 New Cross Road is a Roman road – Watling Street – and Henry VIII was building ships at Deptford Dock Yard from 1513. Positioning and designing new buildings that last 100 years to complement this context, whilst accommodating constantly changing demographics, business requirements, construction methods, and land values, therefore requires careful consideration.

Designing for context is important because the identities and communities of historic parts of London are inextricably linked to their surroundings – history has shown that ignoring these links can cause significant harm to the life of cities and how they see themselves. It is the job of planning policy to produce the best outcome for the city as a whole by ensuring new development takes its surroundings into account. In my opinion, this should be accomplished by simple and accessible rules, underpinned by rigorous analysis of the city.

These simple and accessible rules have to acknowledge the challenges facing our cities. In London, this means considering how available land can be used as efficiently as possible. Pertinently the new draft London Plan, issued earlier this month for consultation, makes reference to extremely ambitious development targets, with space for at least 649,350 new homes having to be found over the coming decade. There will also need to be space for people to work, study, hang out and get fresh air. Finding space for new people is not just London’s problem – the recently released UN Population projections estimate that the world’s population will increase by 83 million people each year up to 2100.

New development in London (and pretty much every other global city) is therefore going to be need to be dense – more people on smaller sites. So what kind of simple, accessible guidance is being produced to ensure this is produced to the benefit of the city and its people? Preventing the growth of over-crowded, squalid slums and ensuring new homes are well designed and appointed was after all one of the fundamental reasons the English planning system was established.

Since 2015 the London Plan has contained a density matrix which acted as a starting point when assessing an appropriate density for a given site. The matrix categorised all of London into three character categories – Central, Urban and Suburban – and linked these to accessibility to public transport to produce an approximate density e.g. 270 units per hectare on an urban site. This system didn’t reflect the intricacies of London, but it did provide some clear and simple guidance – ‘how much was too much’ could quickly be established.

The new draft London Plan has abandoned this matrix, with development instead expected to achieve ‘optimal density’. Local authorities are expected to determine whether this has been achieved through ‘an evaluation of the current characteristics of a place, how its past social, cultural, physical and environmental influences have shaped it and what the potential opportunities are for it to change will help inform an understanding of an area’s capacity for growth.’

This appears to be a much more sophisticated approach, acknowledging how historic areas can often overlap with areas of significant development opportunity. The inclusion of social and cultural criteria also sees the people of London being taken into consideration by those making design decisions, which seems appropriate given its their home.

However, whilst good design often flourishes from constraints, I wonder whether the new approach to density substitutes (overly) simple guidance for (potentially) problematically complex policy.

I think there are a number of challenges to producing this replacement guidance, which if not forthcoming, could leave London open to overly dense, squalid development that fails to respect its context:

Who Will Prove How Much is Too Much? One of the key problems is the capacity of London local government to produce the kind of practical whilst visionary guidance required to establish ‘optimal density’ beyond dispute by the time the new London Plan is adopted. Many local planning authorities are staffed by skilled, professional planners (and occasionally) urban designers who are only on temporary three month rolling contracts – the churn of personnel is immense. This would make the in-house production of ‘character guidance’ extremely challenging, whilst even clienting consultants would be complicated by the lack of in-depth local knowledge developed over time across the project team. This is not to say its impossible, just that current structures are not favourable.

Policy is Now Optional? HM Government is currently consulting on the text of a new draft National Planning Policy Framework (NPPF). In terms of guidance, or plan-making, it would seem Local Planning Authorities (LPAs) are now only obligated to produce “a plan which addresses the strategic priorities for their area”. The type of policies and guidance which would cover density are optional – “local policies can be used by authorities and communities to set out more detailed policies for specific areas, neighbourhoods or types of development.” In an era when LPA funding is 60% smaller than a decade ago, how to make the case for ‘optional extras’ like design guidance? As the draft NPPF seems to place LPA Local Plans and Neighbourhood Plans on the same level, why not let those places which have ‘a community’ protect their (existing) place, whilst hoping for the best elsewhere. I’m unsure how many Neighbourhood Plans consider nine metre sea level rises, and the design feats necessary to address this, but I’m sure it’s all in hand…

Everywhere is an Opportunity Area? In the era of ‘Good Growth’ every backyard is a potential development site – an assumption that won’t escape the notice of the development industry. There is no reason why these sites wouldn’t have come forwards under previous iterations of the London Plan, it’s just now there’s a presumption in favour of development. Developing cheek by jowl with people’s homes needs careful design – for the reasons above there is room to doubt this can be ensured.

Moving from what was a discretionary system underpinned by some detailed policy, to a more laissez faire system based on strategic guidance sounds simpler – isn’t this how ‘zoning’ planning systems work? If you’ve worked in the USA or Australia you know that producing zoning plans takes time and resource – New York City Zoning regulations run to 1,300 pages, for example, and are updated regularly.

Cause for Optimism? There is a fascinating example of what a London zoning ordinance might look like produced recently by Allies + Morrison Urban Practitioners for Historic England. This award-winning research shows the kind of granular analysis required to show how strategic development guidance could be implemented at local level. It is a major task, but shows against the odds (the new draft NPPF), the talent exists to make it happen.


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