The purpose of the London Plan is to bring clarity and consistency, but in its tall buildings policy, the new London Plan does the reverse.
Firstly, Policy D9 had proposed that individual boroughs define ‘tall’, which seems appropriate given the varying heights that exist in the capital. But in December 2020, the housing secretary’s final direction specified the definition of tall as “not less than six storeys or 18m”.
The ramifications are numerous. On a London-wide strategic basis, can 18m really be considered ‘tall’? The Mayor of London Order retains its threshold of 30m or 25m in the Thames Policy Area, and the NLA’s Annual Tall Buildings Survey only includes buildings over 20 storeys. Even within the London Plan itself, Policy D4 retains reference to 30m.
Even more significant is the confusion about where tall buildings may be permitted. The secretary of state’s direction was designed “to ensure that there is clear policy against tall buildings outside any areas that boroughs determine are appropriate for tall buildings”.
So, tall buildings may only be approved in locations that are specifically highlighted as appropriate on maps forming part of the Local Plan; and any tall building outside such areas should be refused.
What does this mean for an authority without a definition of a tall building, or without a current Local Plan? Will we see the end of opportunistic tall buildings? Already, authorities are using Policy D9 as a reason for refusal.
The industry will be anxious to gain an informed understanding of the potential ramifications and Carter Jonas is following this closely to gain an indication of the future distribution of major schemes throughout Greater London.
Katy Davis is partner (planning) at Carter Jonas