M60 Affordable workspace March 20

Warning: Just Space and UCL are trying to make available some sort of record of what happens in the EiP for the benefit of community members. Notes are being taken by students and checked/edited so far as possible by more experienced staff and others. Neither Just Space nor UCL offers any guarantee of the accuracy of these notes. If you wish to depend on what was said at the EiP you should check with the speaker or with the audio recordings being made by the GLA. If you spot mistakes in these notes please help us to correct them by emailing m.edwards at ucl.ac.uk

Low Cost and Affordable Business Space (panel questions)
M60. Are policies E2 and E3 justified and would they be effective? In particular:

a)  Are they necessary to address the strategic priorities of London, or do they extend to detailed matters that would be more appropriately dealt with through local plans or neighbourhood plans?
b)  Would they be effective in helping to ensure that the accommodation needs of all micro, small and medium sized businesses, including those wishing to start up or expand, could be met in all parts of London?
c)  Or would that objective be better achieved by market forces in the context of other policies in the Plan, including E1A, E4A, E4H, E5C and E6, as well as any relevant policies in local plans and neighbourhood plans?
d)  How would policies E2 and E3 affect the implementation of policy GG5 “growing a good economy”?

A brief note from outcomes of 20 March discussion on low cost business and affordable workspace.
1.  The arrangement of speakers around the table (anticlockwise) was :
  •  .GLA officers
  • Assembly members  (Pro affordable workspace)
  • London Property Alliance, London First, Canary Wharf Group , Workspace group (Anti)
  • FSB, London Forum, Vital OKR, JustSpace, Hear   (Pro)
2. Inspector indicated he didn’t want repeat of written submissions but additional material to address his points and to improve clarity. Policies E2 and E3 were taken in turn separated by a break.
3. Panel took input for E2 Anti clockwise.
4.   The GLA came under pressure from inspector to explain:
 a) Why use classes B2 and B8 were excluded.  GLA made it clear that their approach had been to draft policies according to use class:  E2/E3 = B1 use class, E4-E7 policies were B2 and B8.
 b)  lack of clarity on how they were meant to be implemented: Development plan documents, planning management policies or on case by case basis?


The anti group made three main points: –
 – E2 refers to local effects so need to be dealt with locally.  It’s not a strategic issue  (and they didnt buy evidence of need for policies),
–  LPA arguing it shouldn’t apply to CAZ
 – low cost business space was generally offered in old tired buildings so this was condemning developments to remain old and tired
 – policy was too prescriptive.
The pro group made a number of points:
 – The evidence points to lack of low cost business space
 –  policies were strategic (and undeveloped from NPPF), and prescriptive nature recognised differences in application at the local level, disingenious to say localised effects mean a local policy is needed
 – E2 needed to be extended to B2 and B8
– Assembly members came out strongly in favour of policy
 – redevelopment could occur and still provide affordable space: the anti group had already indicated there was a range of prices offered
Overall Inspector seemed to be leaning towards:
 –  the policy might present an additional barrier to redevelopment
 –  the policy application of : “where it can  be demonstrated that there was a shortage of low cost business space, it should apply to all types of business space i.e. not just low cost business space
 – needed to include B2 and B8.
Anti groups didn’t do well on this one and raised the prospect of restricting the application of policy in practice using viability assessments
E3  (speakers taken clockwise after GLA questioned)
GLA was under pressure to  explain how E3 A to F was meant to work (step by step assessment or simultaneously) and inspector raised concerns about clarity.
Pro groups argued that there is market failure to address – lack of access and affordability.
Anti groups argued the policy was wholly unnecessary, interference in market, anti competitive, smacked of state aid (so could be illegal) (workspace) no market failure to address and even if policy was adopted, it was too prescriptive and particularly E3 F was limiting. Workspace argued that if policy was adopted it needed to be more prescriptive (i.e. limited in its application)
Assembly members argued strongly for links to GG1 and GG5.
LPA managed to be made to backtrack by Hear and Just Space by saying of course there was a need to consider voluntary, community & third sector workspace in CAZ as part of strategic function of CAZ  (from which it follows this policy justifies providing affordable workspace in CAZ as well)
Overall it seemed that:
Inspector saw it could be implemented by S106 agreements, section F needed widening
Inspector called for more references to evidence, saw the policy as needing to be evidence driven and called for probably a re-write from GLA to improve policy wording and clarity
The anti lobby intend to look for ways to limit at the viability stage so this will be a key upcoming fight.
Michael Parmar, Just Space