M62 Industrial land 19 March

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

Panel questions:  M62. Are policies E4, E5, E6 and E7 consistent with national policy and would they be effective in helping to ensure that sufficient suitable land and premises are available to meet the quantitative and qualitative needs for all foreseeable types of industrial15 activity over the plan period? [Reference to “industrial” or “industry” in these matters includes all types of economic activity referred to in policy E4A(1)-(9A) incorporating the Minor Suggested Changes.]
In particular: M62. Are policies E4, E5, E6 and E7 consistent with national policy and would they be effective in helping to ensure that sufficient suitable land and premises are available to meet the quantitative and qualitative needs for all foreseeable types of industrial1 activity over the plan period? In particular: (sequence changed in final agenda, as follows):

Need for industrial land

a) Are the industrial job growth projections and associated estimates of land and floorspace requirements justified?

e) Is the approach to assessing floorspace and yard space capacity set out in paragraph 6.4.5 – 6.4.5B based on existing floorspace or floorspace assuming a 65% plot ratio (whichever is greater) justified and would it be effective?

Meeting the need for industrial land

b)  Is the aim of ensuring no overall net loss of (i) industrial floorspace capacity and (ii) operational yard space capacity across London in designated Strategic Industrial Locations (SIL) and Locally Significant Industrial Sites (LSIS) justified and realistic, and would achieving that objective ensure the availability of a sufficient quantity of land and premises for industrial uses?

c)  Are the borough-level capacity categorisations (“retain”, “provide”, or “limited release”) set out in Table 6.2 justified, and would the proposed approach ensure a sufficient quantity of land and premises in different industrial property market areas?

d)  Are there parts of London where significant amounts of additional industrial land are likely to be needed in addition to that which is currently in use and/or designated?

f) Is the approach set out in Policy E7D towards “non-designated industrial sites” (36% of total amount of industrial land2) justified and consistent with national policy?

j) What evidence is there about the feasibility of delivering schemes on industrial land that would lead to the provision of net additional industrial floorspace along with the provision of significant numbers of new homes on the same site?

E7F – wider South East

i) Is Policy E7F, along with Policy SD2, likely to be effective in terms of facilitating the substitution of some of London’s industrial capacity to related property markets beyond London’s boundary, and would achieving such an objective contribute to the achievement of sustainable development?

Effect of E4-E7 on meeting housing needs

k) How would policies E4-E7 affect the implementation of Policy GG4 “delivering the homes Londoners need”?

Are E4-E7 effective, or unduly detailed, prescriptive and complicated

  1. g)  Would policies E4-E7 provide an effective strategic context for the preparation of local plans and neighbourhood plans?
  2. h)  Are policies E4-E7 clear about how they would be implemented through the determination of planning applications, particularly in terms of the role of“planning frameworks3” and “a co-ordinated masterplanning process incollaboration with the GLA”, and the relationship between policies E5D andE7B?

GLA (Gerard Burgess) opening, stressing diversity in economy, too much has been lost in past, demand will grow. No net loss of floorspace is the key policy. Plan to intensify, but release some, subject to careful planning. Complex issue.Recent minor changes deal with yard space and vulnerability of non-designated industrial land.

Starting with demand/need forecasts

Panel: Is decline of manufacturing demand reversing? A: employment-based projection doesn’t suggest growth in employment; P: shouldn’t population be the main determinant of warehouse/logistic space demand? A: We do expect econ growth to be big influence but not directly proportional. 0.4% p.a. is our best estimate. Overall need for +100 ha turns into -230 ha because of the amount of vacant land (AECOM), much in estuary.(Total 10% vacant, compared with the 5% needed for market to work.)[Lots more detailed number-work. Listen to the audio for all of it.] Table 5.25 in SHLAA shows switches to housing. [Suggest check numbers with GLA written statement.]

Panel: plot ratio 65% assumption (90% within inner London)but Panel says many recent developments have lowed plot ratios. A: further minor change introduced to allow for exceptions where more yard space really needed. P: how does urban greening factor fit? A: we did ask consultants to consider that.

Nicky Gavron (Assembly Planning Committee): 1. the plan has office growth projections for each borough; why not for industry?
2. 230 ha for release: does this take account of PD rights? Does it take acccount of new and emerging indusries? 3. New thinking about supply and demand audits: who will be responsible for them? 4. Are the non-designated sites part of the 230ha?

Peter Eversden (London Forum) About 1/3 of ind land is unprotected and we are concerned. In East London the expansion is going to have to be carefully considered. Break of bulk is land-hungry. Statement on OAs makes us worried about what the OAs are going to produce. What is the balance between building upwards and sideways? All very well for GLA to talk of ‘plan-led’ approach but boroughs are not being guided on whether or how to study/understand these things.

Ferm (Just Space): it does seem that there will be shortfall. Our comment is that evidence base broadly OK but not satisfied that firms will be able to cope.

Prologis:  How adequate is the treatment of online sales, esp for firms which don’t have physical shops (Ocado, Amazon, etc) And can the distribution system cope with the massive population growth.

Y?? More on growth of online sales. Worried that Thames gateway is miles away from where the consumption is. Transport plan not synced with LP.

FSB: affordability is the key concern for our members. Firms simply can’t afford the space on offer. They employ local people. No good telling them to move from Paddington to Dartford! And no monitoring.

Freight Transport Assn: more vans replace vast numbers of cars. Plan understates need for yard space: need won’t be met at 65%. Lots of the industrial land is in the wrong places.

Amazon: (very hard to follow speaker) …

(Barrister on behalf of) LB Bexley which is promoting a riverside site in OA. Land is SIL. 90% protected designations. They want to resist the growth in demand which is based on the rate of growth between 2000 and 2008 which was a boom period.

BRENT LB: Not enough detail in plan to support the classification of boroughs to levels of release. Thinks demand is overestimated; logistics sector needs particular types of sites which we just don’t have much of. Why can’t more of the need be met outside London?

London First: So much uncertainty. Plan needs much better and more frequent monitoring.

??Z we think intensification is going to be rare. Can’t be relied upon. Ditto co-location will be very limited. Suggests 40-45% plot ratio more approriate. There must be NO NET LOSS OF LAND. Finally how does “no net loss” actually work? no way to tell as you go along whether it is working.

GLA responds: Audits: mix of GLA and boroughs; + sometimes developers.
PD rights were considered by AECOM and boroughs would need to look in more detail.
New sectors: we do expect more data centres; e-commerce is a major growth area…
Monitoring: KPIs include annual review of “no net loss” policy.

How would the needs be met?

GLA (burgess) defending GLA adoption of floorspace and yardspace as both important and plot ratio (the ratio of the 2) a key indicator of efficiency.

“No net loss” policy. Panel seeks clarifications…  GLA Says it could be applied to individually to SIL and LSIS sites, or at a borough level where land swaps could apply.
[SIL=Strategic Industrial Land;  LSIS=Locally Significant industrial Sites.]

300 ha of Thames Gateway releases, only 50ha actually embodied in plans or permissions.

Note that boroughs can choose to designate more non-designated sites to protect it.

Panel: intensification of industrial sites: GLA: Yes. This is the main source of new supply. Panel: how confident can we really be? GLA: the GLA studies of intensification and the LP viability study have both demonstrated that it can be done ‘viably’. Jennifer Peters: if we find it isn’t working in a couple of years we’ll have to consider a review of this policy. “We’re good at reviews” – laughter all round. Burgess: our pilot projects are designed to demonstrate to developers and occupiers what can be achieved.

Bexley: we need more flex in plot coverage to reflect our special geographical situation”: bad access needs staff parking space // flood plain requires???
Notes tightened approach to industrial land contrasting with removal of numerical controls on density and replacement by “design considerations”.
We’ll be unable to meet our housing targets of industrial land is so strongly connected.

Brent: Most of our developments are 45% plot ratio.  Mixing of uses is crucial to the viability of workspace provision. Why can’t we have mezzanine floors? We’ll have t quadruple the floorspace on the sites which DO come forward to meet our industrial space target.

Enfield: we have 3rd amount, 2nd in low vacancy; and we are classified as a “provide” borough in the plan. Massive requirement if we are to do this. We try to do “no net loss” but…   London Plan viability study shows Enfield in lowest value band which is why viability is so poor. See our statement. Impossible for us to meet all our needs we need a borough-wide approach, including green belt. (A very lucid and powerful statement – ed)
Some of our green belt adjoins M25

Sutton: Table 6.2 hasn’t prevented excessive losses of industrial land. It doesn’t work. Furthermore there are silly cross-border problems where a SIL overlaps boroughs which have different classification. As yard space shrinks, staff parking will be displaced on to spine roads but that will just congest already-inadequate capacity.

H Group: No net loss will drive coach and horses through Bexley local plan. High vacancy rates should put Bexley in “limited release” category. Greenwich is supposed to provide more floorspace….  Grave doubts on feasibility.

Amazon: high plot ratio not an indicator of efficiency! Yard space can be a big contributor to efficient operation – for storage, staff parking, etc.

Ballymore: we can make co-location work, best with SMEs.  But 65% is a challenge. Combining all this with the 50% thresholds on viability fast track.

DB Cargo: (huge operator of freight trains, and in London esp for construction-related traffic. 40% of aggregates come by train; Take 70 HGVs off the road per train. Need for rail freight sites to support handing, sorting and processing of aggregates and construction wastes; many of our customers want to be on the same sites. Welcomes agent of change policy but… boroughs are very inconsistent in treatment of rail freight. DB believes specific policy support required for rail freight (as for water freight).

FSB: nothing here for micro and small business. Intensification and c0-location forces up costs and rents. Most of what gets built is unsuitable for re-making and re-working, and much is too far away.

Freight Transport Assn: Suspect that some of apparent vacancy may be land banking in hope of switch to residential use. Small pockets of land very important indeed, including a lot of non-designated land, including CAZ.  Logistics sector works antisocial hours so workers need to get to work all night and thus car parking often essential. Don’t push the big sites too far out, keep the small sites in the centre.

xx  Board..   Intensification should just be treated as a windfall.

HBF: on the supply side: interested by Panel’s parallel with small sites housing policy:  like that, this is a high risk strategy. Rather theoretical, not required by national policy. 45% of housing supply is going to come on land not specifically identified (small sites + intensification and co-location in industry). Mayor desperate to avoid strategic review of green belt and is proposing an unsound plan. This is not the right balance in terms of sustainable development. Development industry s not geared up.

London First: monitoring …. flexibility … our members concerned about the risks of co-location and they would like some financial incentives to do it, especially H6.

NNN  We think much more land needed to reach equilibrium. Doesn’t like the “exception” system for the plot ratio. Multi-level concept awaits proof of concept, even at Heathrow. Could maybe do it on green belt where land cheaper.

SEGRE: Multi-level unproven.  We have delivered (millions…) and average plot ration has averaged 45% (range 20 – 65). Lots of examples and case stories of tenant resistance to high plot ratios. Multi-storey will be only in a few places.  We are doing a co-location in Hayes, with green space, we demolished 1m sq ft factory, but couldn’t have done it with no net loss. Beside he H+H station so it worked.

Just Space, Kaymet / Just Space.  More precision needed: ancillary offices, why exclude mezzanine; operational yard ARE part of operational space. Borough benchmarks based on ALL industrial land, and no-net-loss should apply to that.  The policy must apply to all 2500 ha of non-protected industrial land. We being asked to trust the GLA that they and boroughs will become tough SOON.  In our area (Southwark) they have clearly decided that the new LP is too imprecise to prevent them from reducing … (lots of figures) This is a huge potential loss which the LP is not strong enough to resist.  LP must get clearer and stronger. No sign of City Hall showing southwark a red card.

London Forum. Precautionary Principle should apply.  – co-location should be treated as a windfall.  ALL booroughs should pursue no net loss. There should be reference to the Mayor before ANY release. Every London plan has failed on this. Need also to pre-empt Brokenshire threat to Permit redevelopment of offices as housing!  No net loss should apply also to ex-transport and ex-utility land.

Gavron: Assembly cautiously agree with no net loss.  We are cautious because of the huge losses of LSIS in recent years. Densities must be increased in industrial areas. Paris examples as well as Tokyo. Has to be an early review. Assembly aware non-designated sites are behind high streets all over London. Huge raft of innovation and local employemnt. In aggregate they are strategic AND they provide the footfall for high streets. Switch to residential damaging.  PD rights only introduced for industry in late 2018 and we don’t know the outcomes yet. Could be repeats of the wholesale evictions we had with  offices. The encouragement to switch non-designated employment space to housing should be removed, or qualified by 100% replacement.  Remove alse the ‘market signals’ passage because it’s an incentive for  owners to keep premises vacant.

GLA response:
Viability: refs to LP Viability Study and pilot studies.
on 65% SEGRO and other objections on plot ratio insists…
may not be possible in all cases. But overall aim is to increase efficiency…
Borough categorisations come from strategic studies for property market areas. Bexley comes from the supply/demand studies, as does Greenwich.
Non-designated sites: yes we agree they are cumulatively important. Boroughs can add more.
Minor changes have tried to tighten up on phoney attempts at marketing.

Relations with surrounding regions. GLA explains policy which would govern any “substitutions” in E7F with wide south east. Representative of S E authorities says some of them are worried what it would mean in practice: clarify job types / types of sites / infrastructure help / how would firms be encouraged to move? Enfield: what would the Mayor’s role be? Enfield is dominant industrial district in its market area…  lots about Broxbourne, Welwyn-Hatfield… We do not consider we’ll succeed with this: the answer is NO.

Effect of all this on housing supply. 8% of dwellings in SHLAA housing capacity is on designated industrial land. 288ha. + Mixed use (T 5.25) is more like an approx estimate. Enfield: GG4: we can’t meet our housing targets with these constraints. supply of premises for SMEs will dry us with rising rents;  there will be losses of diversity as large occupiers push out smaller and traditional firms; push out of London would lengthen trips… Less homes  or OA reduction or re-categorise us…  //  Bexley barrister again, core strategy has 50ha of industrial land for housing. No net loss would be a heavy millstone round their necks. How can we expect developers to complete employment development before even starting any housing.  Newham: we can’t meet housing targets without taking more industrial land or pushing up densities on housing sites already identified. Brent also very concerned about collision between industrial land policy and housing targets.

GLA Gerard: affordable workspaces policies deal adequately with protection of SMEs etc (ref Enfield).

Just Space (Ferm): 2 remaining key points. Policies as worded undermine NPPF “Plan-Led” approach…  we ar evry concerned by “Master Plan” as legitimating a proper plan. There needs to  be an insistence on statutory plans as a precuror of land loss. Note also the conflcit of interest between Mayor as a party to the developments and Mayor as decision make on referral cases.
Monitoring doesn’t work yet.  Try quarterly reporting?

Prologis: …..?

M63 Freight, Deliveries and Servicing

M63. Would Policy T7, along with policies E4-E7, provide an effective strategic framework to ensure that suitable sites and infrastructure are provided for all types of freight, deliveries and servicing in an integrated and sustainable manner in all parts of London? In particular:
a)  are all of the requirements of Policy T7 necessary to address the strategic priorities of London, or
b)  do they extend to detailed matters that would be more appropriately dealt with through local plans or neighbourhood plans?

GLA team
josh gibson GLA and AN Other (inaudible)
??inaudible TfL
joe boyd-wallace TfL

Panel: §10.7.2 says ‘regional consolidation…at the edge of London are needed, coupled with with micro-centres….” but then partly deleted by minor changes.??

GLA Gibson: as London grows it’s crucial to supply the growing city and its population while fostering efficient use of road space, especially by bikes, walking and buses… and so on.

Just Space (Del Brenner) Title should be freight industry. T7 omits taking traffic off the roads. Re-delivery is mentioned. But nothing on empty and half-full trucks moving round. (Inspector interrupts to say LP only concerned with land use.) Making better use of waterways is crucial and this is not dealt with. Thames and 100 miles of canal are omitted and should be reinstated. Should also emphasise coastal shipping and short-haul  traffic within London.

Sainsbury’s 2 issues. Agents of change and how it affects on-street servicing. Reading the policy suggests all servicing should be off-street. Deeply unhelpful. Not appropriate in a strategic plan. Should be in local plans and then dealt with in development management. Inhibits investment. NB also it’s too vague: does it include loading bays specially designed. Majority of our shops are in second-hand / old premises. Plan should just talk about minimising conflict. Servicing functions of established users should be protected by Agent of Change principle.

UK Warehouse association. T7 too detailed. Omit it, and cross-refer to MTS and Freight Strategy.

Road Haulage Assn. Some needs for detail. HGV traffic has dropped 4% but vans up 27%n causing more congestion on red routes. Where to park for rest breaks? Where to stop for pre-delivery? Places all gone. Seek consistency for pollution charges between cities. NIC report of dec 2018 refers to “freight blindness”.

Freight Transport Assn: T7 is too detailed. Averse to borough patchwork  of freight policy.  TfL need to play strong role.  The vast majority of vans on the road in London are servicing – mobile toolboxes – and wrong to apply policy which assumes they are all deliveries of internet orders.  Very few places where drivers can take their statutory breaks, especially securely.

FSB: T7 too detailed.

DB cargo: want yet more changes to emphasise environmental benefits of rail freight – esp for aggregates and construction waste/spoil. Word rail-head should be replaced by ‘rail-linked…” because we need vertical integration onsite  including space for DB customers. Danger of adjacent residential users inhibiting rail freight terminals. Need a specific policy on rail freight and we have drafted one.

London Forum (Andrew Bosi) crucial to shift freight to environmentally better modes. Also omitted: benefits via freight as network electrified – enabling freight to be hauled by electricity too.

2 Academics (from Southampton & Westminster Professor Tom Cherrett) support freight strategies. NOTE data missing to enable flows to be understood. Need better methods for forecasting freight and servicing trip generation. Scared that Agent of Change principle could prevent the re-opening of freight sidings where housing has been built. Need to review and update all the time restrictions. Some are archaic.  Also important to work on how delivery/sorting/storage/collection etc should be integrated into residential and non-residential buildings.

[note taker comment: is this a unique example of academics commenting on a bit of the plan spontaneously – not as representing others or as contractors to GLA. LSE London is rather different.]

John Cox Just Space: today Govt announced on last mile…  and (another topic). Don’t take anything out of T7 because it makes for consistency across London.  Seeks clarity on why the discussion is counterposing HGVs against floods of vans.   Calls for railway tracks/routes/sidings on private land should remain parts of protected railway networks.

GLA responding:

Title of policy: (waffles without answering). On whether it’s strategic: gives reasons why it’s strategic (but doesn’t discuss the level of detail – e.g. the Sainsbury’s point). TfL: Sainsbury’s point is a long-run issue. It’s only inviting developers to try to get trucks off street. [Sainsbury’s: that’s not what the Plan says!] TfL seems to be agreeing to soften it. Sainsbury’s being very tenacious about this.  Similarly DB Freight being dogged in their determination not to be constrained by new passenger proposals which are merely “planned”.

[comment by note taker:  nobody has mentioned the proposal to move Smithfield, New Covent Garden and Spitalfields markets all on a former  power station site at Barking.]


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