Jenryck’s ‘Gentle Density’ Cap in London will lead to Massive Greenfield Development Outside London

Some background. The latest draft revision of the London plan removed the density matrix and relaxed tall building policy so boroughs had to define suitable areas not confined to opportunity areas, town centres etc.

This caused some concern in outer London boroughs. Even subsequent to the EIP outer London Boroughs lobbied the SoS and yesterday the mkinister issued a final direction.

Innpracgice in terms of stage 2 directions there has been uncertainty over how the policy would be applied. In Mitcham next to a tram stop the Mayor has insisted on a 10 storey scheme rather than the ‘gentle density’ scheme favoured locally. In Barnet he has failed to intervene in the local rfusal of a 6-8 story scheme.

The letter : and direction.

I am issuing a new Direction regarding Policy D9 (Tall Buildings). There is clearly a
place for tall buildings in London, especially where there are existing clusters. However, there
are some areas where tall buildings don’t reflect the local character. I believe boroughs should
be empowered to choose where tall buildings are built within their communities. Your draft
policy goes some way to dealing with this concern. In my view we should go further and I am
issuing a further Direction to strengthen the policy to ensure such developments are only
brought forward in appropriate and clearly defined areas, as determined by the boroughs whilst
still enabling gentle density across London.

Policy D9 Tall buildings
A Based on local context, Development Plans should define
what is considered a tall building for specific localities, the height
of which will vary between and within different parts of London
but should not be less than 6 storeys or 18 metres
measured from ground to the floor level of the uppermost

The draft plan definition was the same as the notification limit i.e. 30m , 40m in City.

The reality in London is that where large sites come forward in Outer London such as estate regeneration or industrial estates the abolition of the density matrix meant the expectation was these would be at least 8-10 storeys and this would not be classified as a tall building. The large majority of such sites not being in areas allocated for tall buildings.

Now they would be and would be contrary to development plans. With this one stroke of a pen Jenryk has halved development capacities for large sites in London. You will note that his predecessors have been saying to the Mayor development in LOndon should double. Where, how?

The letter concludes intriguingly

I am pleased that the communication between our
teams is ongoing and positive. I would like to see details of work on a strategy with the wider
south east authorities.

Of course now Lon is required to undertake a Green Belt review and the changes mean Boroughs can choose to lose employment land instead even if occupied. Though if occupied I cannot see how such land could be considered ‘available. Even if all of Londons strategic industrial sites were developed it would only take up a small proportion of Londons land shortfall. It is simply too high and the shortfall will be much higher given Jenryks new ‘gentle density’ definition.

The numbers dont lie. With the policy change, even with massive sacrifice of industrial land, Jenryks change means massively increased loss of greenfield sites, including for replacement industrial land in the wider south east. Planning is about trade offs and the minister just made one. More gentle density in London, in favour of dramatically increase greenfield development outside London.

Just an observation here. If you are owner of a large site how to do you value it? Without firm standards there is a risk of overvaluation and a squeeze on affordable housing.

Policy is also too crude. Gentle density and tall buildings are the nodes but the majority of large sites in reasonably accessible locations should be in the very high density category of 18-30m. These areas should be subject to strategic zoning in the London plan.

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