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The next London Plan will shape how London will develop over the next 23 years (2027-2050). Its early consultation document, 鈥楾owards a new London Plan鈥�, outlines the ambitions of the Next London Plan and the policy ideas proposed to achieve them.

Our research experts have examined these proposals in more detail, exploring their potential impact on housing delivery, high street, industrial land supply, workspaces, and London鈥檚 environmental future.

RECOGNISING THE CHANGING ROLE OF HIGH STREETS
The importance of town centres and high streets (and the inter-relationships between the two) is fully recognised in the 鈥楾owards a New London Plan鈥� report, most notably (but not exclusively) under Paragraph 3.3. The overriding aim is: 鈥淸鈥�] to help ensure that high streets remain a central feature of London鈥檚 economic and civil life. This must support town centre locations to adapt to a much wider range of businesses, jobs and commercial activity鈥�.

Encouraging diversity over tradition
There is full, rightful recognition of the need for high streets to evolve and a refreshing drive to embrace new thinking, rather than remain hamstrung by historic constraints. There is tacit reference that not all high streets need to necessarily be retail-led, as was maybe the case historically. Rather, the footprint needs to be diverse and encompass a wider mix of uses, and most crucially of all, reflect the needs and aspirations of the community that it serves.

Planning reform has already partially paved the way for this to become a more widespread reality. The introduction of Use Class E and permitted development rights has reduced or removed a large number of hurdles that previously stood in the way of meaningful progress and necessary change. This reform has provided a much more flexible framework to allow far greater fluidity between real estate uses, both commercial and residential.

Designating and reimagining high street spaces
Whilst supportive of the fundamental thinking and strategy, not all of the potential interventions proposed in the Plan are feasible or workable.

As proposed, there is considerable merit in reviewing those high streets that are currently undesignated and encouraging them to either become part of a wider borough framework, or released for other uses. Either way, the net result will be a far greater sense of 鈥榦wnership鈥�, in both a literal and figurative sense. Without this requisite 鈥榦wnership鈥�, there is little impetus for change and these locations will continue to drift, rather than positively evolve.

Balancing intervention with realism
Some of the more 鈥榟ands on鈥� interventions referenced are perhaps too extreme. Making moral-based judgements on the provision or restriction of 鈥渂etting shops, pay day loan shops or hot food takeaways鈥� surely exceeds the remit of a Local Plan and will draw criticism of a 鈥渘anny state鈥� mentality. A Local Plan should not be a conduit to such subjective judgements on high street provision.

Equally, proposed actions on addressing the issue of vacant properties on high streets is somewhat draconian: 鈥渆xamples include new powers for high street rental auctions that give businesses and community groups a 鈥榬ight to rent鈥� long-neglected town centre commercial properties鈥�. This line of thought is predicated on the notion that vacant properties are being wilfully withheld from the market by unscrupulous landlords. The reality is much more likely to be they remain unlet because there is no demand to occupy them in their current form. The landlord does not want them to be vacant (and generate zero income) any more than the community or local authority does. The way forward must surely be wider engagement between landlords and local authorities to work together to resolve vacancy, rather than taking a stick approach.

Embracing local identity and devolved decision-making
While intervention can be positive, underlying market forces remain a great leveller and architect of change in their own right. On this basis, it would be short-sighted to be too prescriptive as to the constitution of a 鈥榩erfect鈥� high street, by having fixed parameters (or even banded parameters) as to the optimum use mix on any given high street. So, for example, it would be overly-prescriptive to advocate that x% is allocated to retail y% to leisure/F&B and z% to other uses. Such an approach contradicts the very ethos of creating high streets that are tailored and curated to reflect local needs and aspirations, which are going to vary dramatically according to location right across the Capital.

Diversity remains one to the key cornerstones of Greater London as a whole. That diversity percolates to the town centres and high streets that form its whole. That diversity can only be embraced and nurtured by a localised, non 鈥榦ne-size-fits all鈥� plan. Central guidelines perhaps, but ultimately devolved to local authorities and Business Improvement Districts (BIDs).

RECONSIDERING THE ROLE OF RETAIL PARKS IN LONDON
Retail parks are acknowledged in the 鈥楾owards a New London Plan鈥� report, although largely in a negative context which undervalues and perhaps misunderstands the role that they play in London鈥檚 wider infrastructure.  

To highlight two examples, under Paragraph 2.7, they are singled out thus: 鈥淭here is also a range of under-used sites such as low density retail parks and car parks, which offer potential for housing / mixed uses.鈥� And under Paragraph 3.3: 鈥淭here are parts of London, particularly in outer areas, that are poorly served by local shops and services. Some locations are dominated by out-of-town retail parks which provide shopping but not a functional town centre. This increases car dependency and has a particular impact on older and disabled Londoners, expectant mothers and families with children.鈥�

鈥�Diversity remains one to the key cornerstones of Greater London as a whole. That diversity percolates to the town centres and high streets that form its whole. 鈥�

The inference from these two statements alone is that retail parks are a detrimental factor for communities and town centres across the capital and the land they occupy would be better served by other uses, commercial or residential. There is very little narrative that is supportive of retail warehousing in the Plan, which is as short-sighted as it is disappointing.

Mischaracterised as underused
To address the first of these references. To classify retail parks as 鈥渦nder-used sites鈥� is based upon a visual rather than financial or factual assessment. By their nature, retail parks have low site coverage, typically 30% - 50% (probably more towards the latter end within London). This is because car parking is fundamental to their business model. Most retail parks major in bulky comparison goods, so need large stores with ample parking. To dramatically reduce car parking provision by reallocating it to other use classes would totally undermine what is a highly successful business model.

A format consumers choose
Secondly 鈥� and to speak to both references 鈥� most consumers actually like retail parks and they are shopping there by choice rather than by default, as is inferred in some of the Plan鈥檚 narrative. It is absolutely no coincidence that retail parks are currently the best performing asset class not just in retail but of any property class in the UK. In essence, this is the product of a virtuous circle 鈥� consumers like them, retailers make money from them, landlords and investors generate a decent income and return from them. They are more a force of good rather than harm.

Underserved, not oversupplied
Retail warehousing is demonstrably under-supplied in London relative to other parts of the country. Obviously, this owes much to the unique nature of the Capital, coupled with paucity of land, high land values and strained transport infrastructure. In essence, Londoners have less access to retail warehousing than consumers do elsewhere in the country. Rather than seek to reduce this undersupply further by allocating the land to other uses, maybe the London Plan should be addressing how retail parks should be preserved and integrated more into local infrastructure.