RETROFIT-FIRST: FIRST GLIMPSE OF THE CITY OF LONDON’S NEW DRAFT CITY PLAN 2040

The City of London Corporation (“the Corporation”) has been working behind the scenes to prepare a new Local Plan, known as the ‘City Plan 2040‘, to guide development within the Square Mile up to 2040.

With the Square Mile feeling the effects of the pandemic more than most areas within the capital, this new City Plan promises to set a new direction, diversifying the City’s offering whilst leading the fight against climate change.

We received our first glimpse of those draft policies as part of the Corporation’s recent Local Plans Sub (Planning and Transportation) Committee.

Below are our ten key takeaways:

1. RETROFIT-FIRST

Policies now have a significantly greater emphasis on promoting retrofit, wellbeing and circular economy design approaches.

Design policies explicitly require proposals to “take a ‘retrofit first’ approach, prioritising the retention and retrofit of existing buildings, informed by an appraisal of the development options.”

All major developments must undertake an optioneering assessment, in line with the Corporation’s Carbon Options Guidance Planning Advice Note and should use this process to establish the most sustainable and suitable approach for the site.

NABERS 5* is now a requirement for major development.

2. FLEXIBILITY FOR OFFICES

The Corporation’s ‘Loss of office’ policy has been updated to provide four potential routes to facilitate the loss of office floor space.

There is no longer a need to provide viability evidence in all circumstances, with part 1 of the policy requiring proposals to demonstrate that:

• they would not lead to the loss of office floorspace or sites of a scale, type and location that are strategically important for the City;
• they would not compromise the potential for office development on sites within the vicinity;
• there is no demand in the office market, supported by marketing evidence covering a period of no less than 12 months.

Subject to meeting the criteria in part 1, the Corporation offer four routes to facilitate the loss of office floor space. These are:

• The much anticipated ‘retrofit fast track’ route, enabling change of use to hotel, cultural and/or educational use where the substantial majority of the superstructure of the existing building can be retained;
• A ‘Viability-tested route’ to demonstrate that office floorspace at the site would not be viable in the long-term;
• A ‘Residential areas route’ enabling loss of office to residential where the site is within or immediately adjacent to an identified residential area; and finally
• A ‘Ground floor uses’ route – enabling loss of office floor space at ground or below ground levels to alternative uses where they are complementary to retained office uses on upper floors.

Our latest offering, RetroFix, is tailored to guide clients through the ever-shifting office market, enabling them to adeptly address issues of obsolescence. See more here.

3. DIVERSIFYING THE CITY THROUGH ART, CULTURE AND ENTERTAINMENT

All culture-related policies have been significantly ‘bulked up’ to reflect the Corporation’s ‘Destination City’ initiative.

A new draft policy, Policy CV2, encourages the provision of arts, cultural, and leisure facilities by requiring on-site facilities from large-scale development and provision (either on-site, off-site, or through contributions) from all major developments.

We’re told that the requirements of draft Policy CV2 will be supported by a ‘new cultural planning framework’ which will set out focal areas for cultural provision across the Square Mile.

Major applications will need to be supported by a cultural plan.

4. GREATER FOCUS ON AFFORDABLE HOUSING, CO-LIVING AND BTR

Within identified residential areas, the Corporation will prioritise the delivery of affordable housing, co-living, build-to-rent, hostels, sheltered and extra-care housing, with less focus on for-sale market housing.

5. CELEBRATING THE CITY’S HERITAGE

The draft policy has been extensively altered with emphasis placed on the need to celebrate the Square Mile’s heritage and promote public enjoyment of historic spaces and buildings in ways that are inclusive and accessible. The policy encourages heritage-led placemaking, the retrofit of historic buildings and collaboration between heritage sites and other adjacent developments.

6. ACTIVE FRONTAGES

There is greater support for the retention and new ‘active frontage’ uses across the Square Mile, with the Corporation encouraging the opening of retail and other uses in the evenings and on weekends.

7. TALL BUILDINGS

The policy now seeks to fall in line with the requirements of London Plan Policy D9, with an amended approach based upon recent evidence gathered concerning character areas and tall building areas.

8. KEY AREAS OF CHANGE

Significant amendments have been made to the ‘City Cluster’ Key Area of Change. The draft policy highlights the need to transform Leadenhall Market into a vibrant leisure and retail destination, the need for new development to provide free to enter and publicly accessible elevated spaces and to respect the immediate setting of Bevis Marks Synagogue.
Minor amendments have been made to the policies guiding all other ‘Key Areas of Change’.

9. BIODIVERSITY NET GAIN

The Corporation has acknowledged that it will be very difficult for development to achieve the 10% biodiversity net gain requirement introduced as part of the Environmental Act 2021. Rather, the draft policy seeks an absolute increase in biodiversity units in lieu of a percentage uplift.

10. FUTURE TIMESCALES

The draft City Plan 2040 will now go through a process of internal review and update before the Regulation 19 consultation stage, due to take place December 2023 – February 2024, providing an opportunity for all to make comment.

We will continue to monitor the draft City Plan throughout the consultation and adoption process.