HGH Consulting


Under the Radar – Planning’s Other Stories

There were apparently 44,000 responses to the White Paper consultation, and for months the Planning airwaves have been heavy with comment from every direction. However, Planning is constantly evolving, and often things that don’t dominate the headlines have big ramifications.

The three below are worth noting:

Carbon Collision Course?

Take as an example the GLA’s current consultation on Whole Life Cycle Carbon Assessment. This is an entirely logical next step for the planning system, which is intended to focus our minds on how much carbon is used in building buildings as well as using them. However, it is worth considering some of the implications. First, the Mayor’s guidance is proposed to apply to all “major” applications, and to be required at pre-app stage. Major applications include schemes with as few as ten homes, so a large proportion of development schemes will be caught in the net, and applicants (indeed pre-applicants) will find themselves having to commission a new piece of technical work that has never been required previously, and doing so right at the start of the planning process. That in itself will beg all sorts of technical questions which hitherto have not had to be considered until much later in the process. Second, it is going to bring about a collision between the desire to preserve embodied carbon on one hand; and on the other, the need to replace obsolescent space, concern to avoid unsympathetic alterations to heritage buildings, and the desire (and sometimes the imperative) to avoid paying the 20% VAT that perversely applies to refurbishment schemes but not to new build.

City Limits

Another example: Westminster Council’s policy of imposing a 200sqm limit on all new homes. This has had relatively little publicity as it has quietly slipped through the system over the last couple of years (see City Plan, p.54). You can’t fault someone’s logic in thinking that this could be a good way of ensuring that each scarce site is developed with more homes, and thus makes more of a contribution to meeting the Council’s targets. However, we can see trouble ahead. Westminster is the heart of the nation’s capital city. It attracts domestic and overseas investment which is important to the national economy, quite apart from generating the affordable housing, other Section 106 contributions and CIL that the city needs. Most homes historically have not been larger than 200sqm, but some have, and they often generate disproportionately more wealth. Impose a straightjacket that sits uncomfortably with what the market wants and those important contributions will disappear.

Exclusion Zone

And another: most people are well aware that Government introduced new permitted development rights in the summer – to redevelop buildings in some circumstances, and to add one or two additional storeys in others. However, these rights are hedged around by far more exclusions than the politicians chose to mention. Amongst many other things, the rights don’t apply within 3 kilometres of an aerodrome – which has had everyone poring over maps to work out what this means in practice. Since Battersea heliport qualifies as an aerodrome, an area of around 30 square kilometres is immediately excluded, stretching from Putney to Pimlico, via Hammersmith and Balham. Likewise, the exclusion zone around London City airport covers a large chunk of the Thames Gateway regeneration area, both north and south of the river.

Please forgive this blog being so London-focussed, but the best examples of insidious detail often show themselves first in the part of the UK where Planning can be at its most complex.


Image: Unsplash


Roger Hepher, Executive Director, hgh Consulting
[email protected]

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