The Impact of Design Codes
The publication of the new London Plan brings with it a clear strategic priority to increase the rate of housing delivery on small sites with the introduction of Policy H2 ‘Small Sites’. But the question is, how are London Boroughs going to begin delivering on this policy?
Small sites have, in the past, played a key and meaningful role in contributing to housing supply in London. However, in recent years, the number of new homes being built on small sites has been in decline and we now find ourselves in a housing crisis whereby the city’s housing stock no longer meets the needs of those that inhabit the capital.
The London Plan, which defines ‘small sites’ as anything a quarter of a hectare or less (just over 1/3 of the area of a standard football pitch), encourages boroughs to pro-actively support well-designed new homes on small sites through both planning decisions and plan-making.
Prior to the publication of the London Plan in March 2021, we witnessed the Secretary of State’s tempering of the Mayor’s small sites policy, through a reduction in the housing delivery targets, as a result of insufficient confidence in deliverability. The London Plan now includes a ten-year housing target of 119,250 net housing completions on small sites, with the largest targets appearing in the London Boroughs of Hackney, Croydon, and Southwark.
These housing delivery targets are considerable, and so, the question arises: how are individual London Boroughs going to begin delivering homes on small sites?
The planning challenges associated with developing small sites are well documented particularly in terms of viability and affordable housing, but small sites must also consider a long list of planning considerations such as residential amenity (both in terms of future residents and impact on existing neighbours), architecture and design, accessibility and parking. The list of planning considerations is often a similar length to that of a much larger site but with the difference being that small sites have much less flexibility in terms of layout.
At Carter Jonas, we have acted on behalf of numerous Local Authority Development Companies in the delivery of their small sites including Lampton 360 (Hounslow), BexleyCo (Bexley), Brick by Brick (Croydon) and Westminster City Council. In Westminster, we recently advised on the redevelopment of two former garage sites in Ladbroke Grove. Given the proximity to neighbouring properties, the scheme had to be carefully designed to maintain existing residential amenities, but we also had to deal with the acute need for affordable homes in the area and the requirement for improvements to the public realm around the site. Provision of affordable housing and off-site improvements are not immediately obvious considerations for small sites, but they are often required in terms of unlocking sites which may otherwise be considered unsuitable for development.
To overcome such challenges preventing the delivery of housing on small sites, one thing is clear: individual London Boroughs need to be proactive at a local level. Policy H2 of the London Plan encourages this hands-on approach through the preparation of site-specific briefs, masterplans and design codes for small sites.
Design codes are essentially design rules which govern the physical development of an area. They help to provide planning certainty for both individuals and developers but also stimulate high quality development. Typically, design codes would define aspects such as plot scales, shape, layout, urban form, style of development, and materials in a defined area. Whilst they do not prevent development that falls outside of the parameters set out in a design code, proposals that do fall outside these parameters tend to be subject to more scrutiny.
Croydon Council led the way with the adoption of their Suburban Design Guide in April 2019. The document focuses on proactively encouraging additional housing on small suburban sites such as rear gardens and back lands, and but also draws attention to area focussed intensification, where low density suburban locations have been identified as having capacity to accommodate additional housing.
We have worked closely with Brick by Brick’s architects on many small sites in Croydon (most of which are former garage sites and areas of poor quality or underutilised open space) to meet all the requirements of the Suburban Design Guide. By their very nature, these sites are usually highly constrained and close to neighbouring properties. Officers at the Council have been clear that any development on these sites will be expected to comply with their Suburban Design Guide, in particular with regards to subservience to the ‘host’ building and separation distances.
But Croydon Council are not alone. Lewisham Council are currently out for consultation on their Small Sites Supplementary Planning Document (SPD) until June 2021, and the likes of the London Borough of Harrow have commissioned the production of capacity studies and design codes.
Following in the footsteps of, and learning from, those boroughs who have already adopted, or are in the process of producing, design codes will be an important step forward in terms of unlocking small sites in boroughs where there is currently no guidance. Engagement with relevant design experts or skilled consultants that can assist with preparation of such documents will be vital, but so too will be engagement with local stakeholders including private developers, local contractors, architects and landowners to ensure the concerns and aspirations of Londoners are considered.
Clearly design codes cannot be considered the silver bullet to meeting the considerable housing targets set for small sites in London, but they certainly provide food for thought and should offer a framework to help kick start delivery in individual London Boroughs.
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