Westminster City Plan formally adopted
The Plan’s central objectives are to increase housing delivery with a focus on affordable and family homes, produce the right environment for business growth across various sectors, broaden the retail and cultural offers and significantly enhance the built and natural environment with a vision to become carbon neutral by 2040.
Some of the key policy headlines of the Plan are discussed below.
Housing targets
Westminster had originally set itself an ambitious housing target of 1,495 homes per year for the first 10 years, recognising the need to see a stepped changed in housing delivery. However, despite commending the policy’s ambition, the Inspector felt that there was not enough evidence of sufficient land supply to support this target. Accordingly, the target has been reduced in line with the London Plan (2021), which equates to 985 homes per year. A significant number of these homes are expected to come through windfall development, and the policy also recognises the role that upwards extensions could play.
Whilst the new target is an 8% reduction on the former London Plan target, the clear committal to continued optimisation of land for housing is welcomed.
Affordable housing
The Plan sets a minimum affordable housing target of 35% (50% public sector land), which is a 5% increase on the City Plan’s current target of 30%. This will apply to sites of at least 0.5ha, developments proposing 1000sqm of gross internal residential area or 10 or more units. The preference is maintained for on-site delivery, with off-site or payments only being justified in exceptional circumstances. Development that does not meet this target will need to be supported by a viability assessment and subject to early and late stage reviews to capture uplift.
Deletion of policy seeking affordable housing from commercial development
Crucially, the Inspector examining the Plan deleted Policy 10, which sought affordable housing on office and hotel development within the Central Activities Zone. The Inspector found that the policy was inconsistent with national policy despite Westminster seeking to amend it to only require payments as opposed to on-site provision. Despite recognising the potential to capture significant funding from development within the CAZ, the Inspector concluded that the policy was simply not justified.
Optimisation
The Plan includes a maximum housing size of 200sqm, which is likely to have notable implications for the prime and super-prime residential sector. The purpose of this policy is to ensure that Westminster’s scarce land supply is optimised, with new units over 200sqm seen as ineffective use of land. It is however unclear how much flexibility could be applied where there are existing units already above the threshold and a development suggests it’s like for like replacement.
The Plan also endorses innovative forms of housing, including co-living and build to rent, which are to be assessed in a manner consistent with the London Plan (2021).
Offices
New and improved office floorspace will be supported within the CAZ, town centres and certain development areas. There is also support for updating existing stock. Generally offices will be protected unless in very specific circumstances including an original residential use being restored in a residential area or the change being to a hotel after 12 months marketing for all Class E uses.
Retail and Town Centres
The Plan has changed its historic blanket protection of ‘retail’ in favour of a more pragmatic approach that seeks to support any commercial use with an ‘active frontage’ at ground floor level. The change to the policy position was triggered by the Government’s update to the Use Class Order and the introduction of the new Class E ‘Commercial, Business and Service’ use. The Plan is now consistent with the primary legislation and supports flexible uses within all centres across Westminster.
Hotels
The Plan has removed the former Core CAZ designation, which is where hotels were formerly directed to. Now, hotels will be directed to commercial areas of the CAZ and town and district centres. Commercial areas of the CAZ are defined as those “where the majority of ground floor uses comprise of a range of commercial activity.” Commercial includes all Class E uses, plus hotels, schools, halls, and many sui generis uses.
The spatial loosening of this policy should allow for more hotels to be delivered in line with the London Plan’s support for enhanced visitor infrastructure. There is likely to be some debate over what constitutes an ‘area’, as these are not specifically defined within the Plan.
Existing hotels will be protected except in predominately residential areas or where they are having a significant negative impact on residential amenity.
Land use swaps
Land use swaps have long been a way of consolidating and transferring uses within the City. This is particularly important due to the high levels of protection for almost all existing uses.
The policy includes detailed wording that stipulates the circumstances in which land use swaps may be considered appropriate. These are that the supply and donor sites are within each other’s vicinity and appropriate in each area, that there is no net loss of each protected floor space and that the quality of residential accommodation is uplifted. Applications proposing such swaps will need to come forward at the same time and provide a detailed breakdown of floorspace.
Existing mixed use credits from the old City Plan will continue to be able to be used to off-set affordable requirements where the credit floorspace is registered as affordable.
Tall buildings
The Plan now defines Tall Buildings as those that are twice the height of the prevailing context. This should allow for suitable upwards extensions of buildings and incremental intensification of densities, without unduly restricting building heights. The introduction of this definition should be welcomed as in the absence of a local definition, the London Plan’s default definition is anything above 18m.
Tall buildings will be directed to the Paddington and Victoria Opportunity Areas, Marylebone flyover / Edgware Road junction and the Housing Renewal Areas. Outside of these locations it is likely that a very stringent approach will be taken to the development of tall buildings.
Carbon neutrality
A key aim of the Plan is carbon neutrality by 2040. As such, there is a clear requirement for all major development to be zero carbon, with any remaining carbon to be off-set via a payment. There will also be a broad encouragement to retrofit existing buildings. This approach brings Westminster’s approach in line with the London Plan.
In addition, any proposal for substantial demolition will need to be justified with respect of its whole-life carbon impact, resource and energy use, when compared to the existing building.
Parking
The Plan has moved away from the previous approach in Westminster that sought to maximise on-site parking provision to reduce on-street parking stress. Now, all new development will be expected to meet the standards in the London Plan, which means car-free for much of Westminster.
This strategic shift should help in the management of air quality and carbon emissions, but Westminster will need to monitor the policy’s approach to mitigate parking stress through lifelong car club membership or increased cycle provision as opposed to restricting on-street parking permits for new dwellings, as many other boroughs do.
Summary
The adoption of the City Plan offers a clear framework for residential and commercial developers in one of London’s most spatially constrained boroughs. It will now be given full weight and is the integral policy document within the Development Plan, together with the London Plan 2021.
