Draft London Plan Examination: The Year of the Tall Building

It therefore felt timely for the first discussions on the GLA’s draft new policy D8 ‘Tall Buildings’ and draft new policy D6 ‘Optimising Housing Density’. A range of stakeholders were represented at the Examination in Public to discuss the methodology, modelling, deliverability and achievability of the draft new policies. 

As London’s skyline rapidly changes, the GLA was keen to reiterate that high density developments do not necessarily require tall buildings. Throughout both sessions the GLA stated that alternative forms of developments can meet housing needs, and this was supported by many stakeholders.

One of the main points of discussion was the GLA’s change in direction regarding the location of tall buildings. No longer will the GLA define the appropriate location for tall buildings. Instead this requirement will be placed on the boroughs to establish through the production of their Development Plans. This would allow the local character and prevailing building heights of a borough to inform a more context-led approach to assessing what is appropriate and what is not. 

Many stakeholders felt  that the implications of this policy would be restrictive in terms of development, as the London boroughs may only signpost a limited amount of land as being appropriate locations for tall buildings. Stakeholders also raised concern over how boroughs will work together regarding designation, particularly at borough edges.

Our view is that the policy should allow flexibility for height and density. Indeed, policy already recognises that developments of scale can define their own character. Arguably, a ‘broad-brush’ plan led assessment cannot properly access every determinant of potential height. In addition, precise and descriptive policies cannot be sufficiently well informed to allow development to optimise potential.

It was the general view that emerging policy on tall buildings focused on commercial tall buildings rather than residential tall buildings, with many stakeholders requesting further guidance in the policy on residential tall buildings in terms of amenity space, child play space and access. Indeed, the report produced by the NLA this week stated that 90% of all tall buildings proposed are substantially for residential use, indicating that the predominant use of tall buildings is for residential purposes. For instance, Savills secured planning permission for the tallest residential tower in Western Europe at 67 storeys comprising 861 residential units at a density of 4,105 habitable rooms per hectare.

With regard to density, the GLA have decided to withdraw their current density matrix and instead propose a design-led approach, to help identify the capacity for growth and determine optimal development density on a site. Many schemes already deliver densities significantly above the guidelines in the matrix and this additional flexibility is welcome.

We consider that the design led approach has merit as a vital tool for delivering the right development in the right place, but increased subjectivity will mean that those emerging schemes will need to employ appropriate experts to advise throughout the development process.

With regard to tall buildings, we believe that they still have a role to play in meeting the need for new homes in London, as stipulated in the NLA report. Boroughs have shown a desire for tall buildings with 22 out of the 33 London boroughs now containing tall buildings under construction. As boroughs develop their policies in relation to the location of tall buildings, this creates an opportunity for stakeholders to influence the chosen locations through the submission of representations during the Local Plan making process. Where boroughs designate land as being appropriate locations for tall buildings this will be significant for the future of London’s evolving skyline.