It’s been a busy few weeks, and we’ve submitted two planning applications, and a pre-application submission in the last week alone. In a rare moment of calm, I’ve had a chance to reflect on the role of small sites in housing delivery, and specifically how the planning process plays into this.
London will not meet its housing needs without tackling small and complex sites. They are everywhere: awkward corners, backland plots, gap sites and underused yards that stitch our streets together. Yet too many never even make it through planning, weighed down by over-inflated land prices, onerous planning requirements or vociferous local objection.
There are positive signs. Small sites are increasingly recognised as vital to delivery, particularly as teething issues with the new gateway process for higher-risk buildings extend programmes for larger schemes. Earlier this year I attended Lewisham Council’s Small Sites Forum, where the borough outlined that small sites could account for almost a quarter of its housing pipeline. Lewisham has taken real steps, not only through its Small Sites Design Guide but via an engaged planning team. Several central London boroughs understand and reward process-led quality. Others are not yet engaging meaningfully.
Resourcing is a real constraint. Officers are stretched and the list of requirements keeps growing: Biodiversity Net Gain, affordable housing viability, noise assessments for domestic air-source heat pumps, fire statements, sustainable urban drainage strategies, flood risk assessments (even in low flood risk areas), the list goes on. In this context, checklists can dominate while design reasoning is under-weighted. Whilst some of these requirements bring demonstrable benefits, others are covered elsewhere, whether in Building Regulation submissions, or in achieving the necessary permissions from statutory service providers.
As a practice, we believe proposals should be well-researched, contextual and carefully resolved. Yet we are sometime asked by SME developer clients, who are reasonably balancing planning risk, ballooning capital outlay and tightening returns, whether a light planning submission is safer. They see low quality submissions and schemes sail through while more thoughtful, higher-quality projects are picked apart. If we value design as a disciplined process, we should recognise and reward it consistently, not just in a few leading boroughs. Innovative approaches are often needed to unlock these sites; and standard responses often under deliver on so many fronts.
Not wanting to sound too negative though, we’ve been considering a few ideas that might help to move things in the right direction.
- Firstly, we need to streamline the planning validation requirements for small sites. A better outcome would be created through fewer reports being required, and a greater focus on the matters that are relevant at the stage at which the applications are submitted.
- It would be great to see the GLA take a more proactive approach to setting out an approach to small sites, through planning guidance notes for example. In my experience on larger schemes, the GLA often provides a measured, strategic view that rises above local politics; extending that culture to small sites could really help.
- Whilst this might sound a little at odds with my earlier ranting, I do believe that there is a role for the Design Review process on smaller sites. If there is a nimble, and quickly assembled design review service available, then this could bring a greater emphasis on innovation and design quality, which can be overlooked as a benefit on small sites. As is typical with larger schemes, panels made up of suitably qualified design professionals are well placed to judge genuine design quality, assess design process, acknowledge innovation and comment accordingly.
- It seems that a more centralised approach to tackling some of the larger infrastructural and environmental issues is key, we would like to see this applied to biodiversity, nutrient neutrality, and water neutrality, where SME developers can often be saddled with site specific negotiations of these items, adding more time and cost pressure to the process.
- It would be fantastic to see the planning fees ring-fenced. This would allow for a targeted increase in the application fee if need be, these are still low within the wider cost landscape of the planning process. A focus on trying to bring back a degree of timeframe certainty to the process is absolutely vital when it comes to getting a scheme to stack up.
- Lastly, it would be great to see a reassessment of the small sites affordable housing requirements. Whilst it is recognised that they are a method through which to extract land value for public good, for the most part, these small sites represent individuals’ pensions, life-savings or elder care costs. Whilst they will likely have to sell at some point, they typically aren’t planning on giving away the land, and so sites remain unaffordable, and so aren’t able to be brought into use.
This emphasis on process-led quality is in the public interest, and it serves SME developers, and architects alike. Better inputs produce better decisions, faster. Small sites can deliver homes that provide a good quality of accommodation, enhanced environmental performance, improve their surroundings, and retain value, and this should really be encouraged.
It is great to see that the emerging Planning and Infrastructure Bill tackles some of these problems, and there seems to be a real attempt to get to grips with some of the major issues mentioned above, alongside an overhaul of the role and function of Planning Committees, which is also welcome.
https://www.workingtitlearchitects.com
James Bazeley – Founder & Director
Working Title Architects
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