The Government has threatened to intervene to prevent London mayor Sadiq Khan imposing strict limits on car parking in new developments as part of the new London Plan.
The warning from communities and local government secretary James Brokenshire came as the Greater London Authority this week released the consultation responses to the draft plan published last December (LTT 08 Dec 17), and minor amendments to the draft plan in light of the feedback. A public examination of the plan is likely to be held this autumn.
The consultation responses reveal the anger that the mayor’s parking proposals have provoked within the development sector and among boroughs, particularly those in outer London. Concerns are also raised about the policies on electric vehicle charging and car clubs.
The Home Builders Federation’s 76-page response is highly critical, stating that the draft plan is “not a strategic spatial plan at all”. “It is a glorified local plan that neglects essential strategic issues such as London’s relationship with the Wider South East and which interferes too much in the detail of the work of local planning authorities.” Parking is one of the issues it highlights.
The parking standards for new developments are vital to supporting the mayor’s efforts to reduce car use in the capital. The mayor’s transport strategy sets the objective of 80 per cent of all trips being made by walking, cycling and public transport by 2041 (the draft London plan says this means 95 per cent of trips in central London by these modes, 90 per cent in inner London, and 75 per cent in outer London).
For residential developments the draft plan proposes that “car-free development should be the starting point for all development proposals in places that are (or are planned to be) well-connected by public transport... Car-free development has no general parking but should still provide for disabled persons.” The areas in which car-free development will apply are: the central activities zone; inner London opportunity areas; metropolitan and major town centres; all areas with Public Transport Accessibility level (PTAL) scores of 5 or 6 (the highest scores), and inner London areas with a PTAL score of 4.
Outer London boroughs wishing to adopt minimum residential parking standards (within the maximum standards) must only do so for parts of London that are PTAL 0-1 (the lowest public transport accessibility). Inner London boroughs should not adopt minimum standards at all.
The maximum parking standards for inner London are: up to 0.25 spaces per dwelling (PTAL3), up to 0.5 spaces (PTAL2) and 0.75 spaces (PTAL0-1).
For outer London they are: up to 0.5 spaces (PTAL4), up to 0.75 spaces (PTAL3), up to one space (PTAL2), and up to 1.5 spaces (PTAL 0-1).
None of the above standards have been changed by this week’s amendments.
Outer London boroughs such as Bromley, Hillingdon and Kingston have all criticised the parking policies (LTT 16 Feb & 02 Mar). Bromley said the standards could lead to “significant under-provision of car parking” in new residential developments, adding that boroughs were best-placed to determine appropriate standards.
The Home Builders Federation has told Khan: “National policy is clear that the establishment of car parking standards is a local matter. We consider that the setting of car parking standards is a matter for the local planning authority.”
Home builder Berkeley says the standards “will reduce the viability of development”.
Planning consultant Lichfields, representing DfT company London and Continental Railways, which specialises in managing and disposing of property assets in a railway context, says: “We do not consider that it is realistic, nor is it based on any sound justification, to expect that developments within all inner London opportunity areas, metropolitan and major town centres (particularly those in the outer London boroughs), areas with a PTAL of 5-6 and/or inner London sites with a PTAL of 4 will be car-free. This is particularly relevant where family housing is delivered, as is encouraged by draft London Plan policy.”
Lichfields says the plan should be revised to “promote the delivery of car-free developments where appropriate, particularly in the CAZ [central activities zone] and inner London opportunity areas; and increase the ‘maximum’ parking standards elsewhere, to allow for the necessary flexibility when delivering developments on sites which require car parking, particularly those with two or more bed units.”
In his letter to the mayor last month, James Brokenshire, the secretary of state for housing, communities and local government, says: “A number of policy areas in the draft are inconsistent with national policy, such as your policies allowing development on residential gardens and your policy on car parking.”
He says the plan also “strays considerably beyond providing a strategic framework”, echoing remarks by the Home Builders Federation and boroughs such as Kingston.
Brokenshire warns Khan: “I would remind you that I have powers to intervene before the plan is published, by giving a direction to avoid any inconsistencies with current national policy or to avoid detriment to the interests of an area outside of Greater London and I will be carefully considering whether it is appropriate to exercise any of my statutory powers.”
Brokenshire’s predecessor, Sajid Javid, wrote to Khan in March, setting out the Government’s concerns with the draft plan in detail. Javid did not mention parking specifically, but did acknowledge the concerns of boroughs and others that the plan “strays considerably beyond providing a strategic framework”. Brokenshire mentioned parking in his own consultation response as the MP for Old Bexley and Sidcup in south east London. “The zero parking target for developments around mainline stations in areas such as Bexley is likely to add to overall parking issues and displace problems into neighbouring areas,” he said. “I believe this is too rigid and should be changed.”
Some developers are equally exercised by the proposed parking standards for other types of development, notably retailing. The draft plan proposes that retail development (at any scale) in central London and areas with public transport accessibility level score of 5 and 6 (the highest scores) should be car-free. In inner London and outer London opportunity areas, the maximum standard is one space per 75 square metres, and for the rest of outer London it is one space per 50 square metres. Again, these standards have not been changed by this week’s amendments.
Says British Land: “We are extremely concerned that an instant ban on any car parking for new development in high PTAL areas will make it harder to let space and result in regeneration stalling or certain land uses not being promoted in schemes at all.”
British Land’s particular concern is how the car-free standard could impact its proposed 5.5 million square feet mixed use development at Canada Water in the London Borough of Southwark.
“For Canada Water, where a new major town centre and high street is proposed, this policy raises particular concerns,” it says. “Our proposals will see around 80 per cent of all trips to the development being made by non-car modes. As such the car-borne mode share will be low for inner London and consistent with the Mayor’s aspiration for less than 20 per cent of journeys being made by car. This will be unprecedented for a major town centre in London and poses a major challenge to British Land in attracting retailers and leisure operators to take space in an untested location.
“The lack of parking will be a barrier to attracting retail and leisure operators to invest in new town centre development given how challenging they expect retail economics to be over the short- to medium-term.
British Land says the Greater London Authority “should be doing everything within it powers to support retailers and high streets which are struggling across London”. “The GLA/TfL stance on parking is therefore extremely unhelpful in this context.”
British Land also says the maximum standards are too reliant on PTAL scores. “Whilst PTAL measures public transport accessibility in terms of proximity to bus and rail services, it does not consider the coverage of those services in terms of origins and destinations and therefore is an incomplete measure. It is not appropriate, in our view, for the car parking standards in the draft New London Plan to be articulated solely in terms of a PTAL score and the broad location bands of central, inner and outer London.”
Car club hostility
Car club operator Zipcar is another consultee irked by the draft plan – and an amendment tabled by the mayor this week may make matters worse.
Zipcar says the original document does little to support Londoners to give up car ownership in favour of car club membership. It points out that the “sole mention” of car clubs in the whole document comes in the statement: “Outside of the CAZ [central activities zone], and to cater for infrequent trips, car club spaces may be considered appropriate in lieu of private parking.”
Says Zipcar: “We believe that such weak inclusion is a key missed opportunity and risks reversing the significant progress made over the last five years of car clubs being included on new-build developments.
“Thanks to planning guidance given by boroughs Zipcar (and car sharing more broadly) has become embedded in major regeneration schemes across the city, encouraging businesses and residents to reduce vehicle ownership at over 500 developments.
“Whilst we appreciate a desire to be single-minded in your treatment of the car across both the mayor’s transport strategy and the London Plan, we believe that both have left a considerable void in how does the city want the car to be consumed in the future.
“For those trips that remain, how do we want as a city for them to be done? The current draft demonstrates no acceptance or acknowledgement that most Londoners, wherever they live and whatever the quality of public transport, will continue to have car needs and so we need to decide how best to provide these as the city regenerates.”
Zipcar says nearly a quarter of a million people live in London’s central activities zone. Noting the plan’s policy that all new residential developments in this area should be car-free, it asks: “Are we really saying they will have no car trip need? Even where public transport accessibility levels (PTALs) are strong, again, do we really think that public transport can meet all needs, getting out of the city, etc?”
Zipcar wants the plan to include a “stronger vision statement on the role of the car in London in the future and how London as a smart, modern city is going to provide for the car”.
It also wants to see “explicit mention of the role car sharing plays in meeting Londoners car trip needs in an efficient, low carbon way” and calls for “explicit direction on the inclusion of car sharing provision as a requirement on all significant new-build developments including in the CAZ and areas of highest PTAL”.
These requests appear to have fallen on deaf ears. The amendments published this week include a new statement about car clubs that may do little to quell operators’ anger. It reads: “Car clubs count towards the maximum parking permitted [in new residential developments] because they share many of the negative impacts of privately-owned cars. However, in some areas, car club spaces can help support lower parking provision and ‘car-lite’ lifestyles by enabling multiple households to make infrequent trips by car.”
Some housing developers are also unhappy with the draft plan’s proposed cycle parking standards, saying they are too generous. Says Berkeley: “Our developments currently provide considerable cycle parking, which is not fully utilised. The minimum cycle standards increase this further. We would propose that, rather than seek 1.5 spaces per one bed home, which in our experience exceeds demand, provision is made at one space per home with usage monitored and further provision made if it is demonstrated to be needed.”
British Land says: “The proposed cycle parking standards for class C3/C4 dwellings could result in the provision of almost one cycle parking space for every resident. While we understand that the availability of cycle parking underpins the potential for cycle use to increase, we are not convinced that cycling will increase to the extent that almost every resident will either own or use a bicycle.”
Here, the mayor has tabled an amendment, which appears to relax the requirement for some smaller dwellings. The standards are now: one space per one person dwelling; 1.5 spaces per two person one bedroom dwelling; and two spaces for all larger dwellings.
Another aspect of the mayor’s plan that is causing angst for developers is the proposal that 20 per cent of car parking spaces in new developments should have electric vehicle charging facilities, with passive provision for all remaining places.
“We think it is premature for the mayor to develop policy in this area,” says the Home Builders Federation. “If electric vehicles are to be encouraged by the Government, and new house-building is to be the testing ground, then, as in other areas, the implications need to be carefully investigated by Government and a national approach is needed that is implemented through the building regulations. The mayor and local authorities should not be allowed to develop their own variations and impose this through local planning policy.”
The Federation adds: “The Government’s shift in policy towards a greater reliance on electric vehicles has the potential to introduce quite serious unintended consequences for housing delivery if not given careful consideration. In terms of grid capacity, the adverse impact that any increase in electric charging could have if more than say 10 per cent of dwellings are to have a re-charge facility is potentially considerable.”
Any requirement to increase the electric loading in an area could be constrained by the size and capacity of cables that are already laid in the ground. “If re-charge demand [for EVs] suddenly becomes excessive, then investment in new, increased capacity cable and sub-station infrastructure may well be essential. Needless to say the extent, timing and who will be required to pay for the cost of network reinforcement (most probably the housebuilders themselves) could be critical considerations for all partner/stakeholder interests.
“Such policy initiatives will reduce the amount of money in a development that is available to subsidise the supply of affordable homes,” says the Federation.
Barton Willmore, representing Barratt Developments plc, concurs: “This proposed policy approach may see applicants asked to secure and reserve capacity from an already constrained electricity grid. This could see capacity on the grid ring-fenced for a change (a conversion from passive to active provision) that never happens. This would be an inefficient use of infrastructure.
“Alternatively, the proposed policy approach might see applicants asked to integrate substations within developments to deliver electricity that is never required. This would be an additional infrastructural cost. Designing in additional substations could have knock-on design effects that detract from a scheme and its wider contribution to the local area.”
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