Imagine the outrage: you order your crispy stir fry noodles from your home delivery app of choice only to find the expected delivery time is two hours, because the nearest dark kitchen is in Watford. It’s perhaps somewhat of an over-simplification of the issue, but a fun example of why it’s so important to have a strong supply of industrial land in locations all over London. Cities don’t work if they don’t have the right balance of necessary land uses.
Yet there remains a sentiment among many in our industry, including, it seems, the Secretary of State for Levelling Up Housing and Communities, that more of London’s industrial land should be either given over or otherwise eroded in favour of housing.
London has ten times as much open space land (green belt, parks and such) as industrial land, and unlike the open space the amount of industrial land is dwindling at an alarming rate. Between 2001 and 2015, 1,300 hectares of industrial land – 16% of the overall reservoir – was released for other uses.
Yet there is no clamour to develop on the open space, because there is an inherent sympathy for its preservation. Industrial land doesn’t earn that same level of sympathy; it’s perceived as grubby and inefficient, and therefore ripe for solving the unsustainably low levels of housing delivery in the capital. I’m therefore sympathetic to those policymakers who are often perceived as blockers to development for housing or mixed-use development on industrial land. I bet they pine for the easy life writing policy to protect green spaces; it’s a much easier sell.
I preface my opinions in this way to underline that I understand the imperative to preserve industrial capacity, and to think long and hard about any development for any other land use that might jeopardise that capacity, even for the desperately needed homes London needs. But I’m still going to ask those industrial policymakers to sharpen their pencils on how industrial land can – in the right circumstances and with the right design – provide for both industry and housing.
“We’ve already done that!”, they’ll cry, directing us to London Plan policies that allow for co-location of residential and industrial land uses. And it’s true that Policy E7 (Industrial intensification, co-location and substitution) does enable the intensification of Strategic Industrial Land (SIL), Locally Significant Industrial Sites (LSIS) or other industrial land to include its consolidation to enable co-location including other uses, such as residential. But it’s a begrudging policy, as is made clear by its recently-consulted supporting guidance on Industrial Land and Uses.
I’ll reiterate that I take no issue with the Policy and its Guidance taking a firm industrial-first approach; we need our crispy stir fry noodles to be delivered pronto. But the Plan could at least provide some more encouragement to developers minded to explore the arduous task of assembling sites in industrial use for co-location and to accept the challenge of developing them in a manner that provides successfully for both industrial and residential use. The Plan and its Guidance, when read together, make this seem an unappealing task which in my experience discourages it, even though there is evidence that it can be done successfully.
The first words that leap out at me in reading the Policy approach to co-location is that it should “only be considered as part of a plan-led process”. Anyone involved in plan-making knows that the process is terribly over-wrought. According to government data, preparing a local plan takes an average of seven years. https://www.housingtoday.co.uk/news/five-yearly-local-plan-review-requirement-not-operating-effectively-says-lichfields/5127329.article. This year the Planning Inspectorate has received only 18 Local Plans for submission. PINS should be examining around 62 Plans a year to if guidance that a Local Plan should be updated every five years is to be met. I expect the seven-year average to worsen before it gets better, with Local Plans being abandoned more frequently, now even more so with the general election announced. That does not provide a prospective developer with a lot of confidence in pursuing co-location if they might need to await a Local Plan review, and then wait perhaps seven or so years for their work to yield a planning permission.
Yet there is evidence that co-location can be successfully achieved outside the plan-making process, relying on the diligence of local planning authorities and the GLA through the development management process, even where the development may amount to a Departure from a Local Plan (e.g. where Policy prohibits residential on industrial land). The London Plan denigrates this as “ad-hoc”, but it can work provided all parties are properly tuned to ensuring the industrial success of the land in question is given top priority.
