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New Southwark Plan update

A new stage in the extended drafting of the New Southwark Plan (NSP) has been reached with consultation launched on the 27 August on the Proposed Changes to the Submitted New Southwark Plan.

The consultation process will last until 26 October 2020 and pushes back the Examination in Public of the NSP until early 2021, meaning that adopted and draft policy continues to be relevant to those bringing forward new development in Southwark.

Changing Southwark

The NSP is the council’s borough-wide planning and regeneration strategy up to 2033 and its gestation since 2013 has occurred during a period of change across a number of sectors. The borough has long been a location with a high level of residential and commercial development and includes some of London’s most significant areas of growth and regeneration, including Peckham, Blackfriars Road, Canada Water, Elephant & Castle and London Bridge.

Under the leadership of Cllr Peter John, Southwark has been supportive of tall buildings and large scale transformation that delivers on the council’s social agenda for its communities. However, following controversies over affordable housing and displacement of small businesses at Elephant & Castle, the LPA has sought to bring in policies within the NSP to ensure development is sensitive to local communities. With new political leadership due to be elected in Southwark in September the borough remains an important location for new development, where it pays to be up-to-speed on the twists and turns of plan-making.

The draft NSP includes a foreword from Cllr Johnson Situ, Cabinet Member for Growth, Development and Planning, and leadership contender. Though unchanged from the previous version, the foreword is a useful summary of key priorities for Southwark, including the importance of ensuring existing communities benefit from development, the pressing need for new homes of all tenure types but in particular social housing, Southwark’s declaration of a Climate Emergency, affordable workspace requirements and the needs of an ageing population.

Plan-making challenges

The new consultation on the NSP had not previously been anticipated by the council and responds to matters of soundness raised by the appointed Inspectors in relation to the plan’s submission version during the early stages of examination. The Inspectors’ initial letter in April 2020 highlighted a number of considerations, including:

  • the need for a clearer spatial strategy to bridge between London Plan targets and site-specific policies, including a key diagram and clarity on the overall quantum of growth to be delivered - this is addressed in the revised draft, through an overall spatial strategy policy;
  • the need to review the housing trajectory and deliverable housing supply;
  • greater clarity in site allocations on the scale of development proposed – which is addressed by adding an indicative housing capacity for allocated sites;
  • additional plan-wide viability work necessary – a viability background paper dated May 2020 is provided with the latest evidence base documents; and
  • the need for additional consultation and greater co-operation with neighbouring authorities.

The council has since made progress in addressing the Inspectors’ concerns and opted to continue with the examination rather than withdraw its plan altogether. Its three-pronged response includes the current extra consulation on a consolidated version of the NSP; providing the Inspectors with the required additional evidence, through updated evidence base documents; and including capacity information within the NSP site allocations.

A plan with impact

The NSP has long been an important material consideration for developers in Southwark and applicants must stay on top of its evolving content, including:

  • changing policy on residential standards, which brings requirements more up to date but is also inconsistent with the London Plan in some areas;
  • new affordable housing policy that alters the overall requirement and expected tenure split in some locations, and again differs from the London Plan on important matters like the fast-track threshold and acceptable forms of social rents;
  • additional sustainability policies that seek to make the borough carbon neutral by 2030, and will require a specific supplementary planning document;
  • an affordable workspace policy that places greater obligations on applicants to provide low-cost space for Southwark-based organisations;
  • new expectations for provision of small shops and relocation support for businesses displaced by development;
  • backing for a wider range of different types of homes including housing for older people and BTR where this meets council requirements;
  • Equalities Impact Assessment requirements placed on applicants; and
  • 16 area visions to guide development and 82 site allocations with specific requirements for proposals including, as discussed, in relation to indicative residential capacity.

The importance of expertise

Despite the significance of the NSP for delivering Southwark’s priorities and the ongoing work by those involved in the examination process,  it is not clear when the new plan will eventually be adopted. The council has been working on the document  since 2013 and had hoped to adopt in 2017; yet it will be the saved policies of the Southwark Plan (2007) and the Core Strategy (2011) that will comprise the local borough-wide component of the adopted development plan until at least 2021. The weight of the NSP within a planning assessment of an application will continue to increase the closer it gets to adoption.

The challenges of producing the NSP and progressing through examination are now likely to be exacerbated by the impact of COVID-19, the fundamental reforms envisaged in the Planning White Paper and through recent Regulatory changes, including to planning Use Classes, leaving a complex situation where policies can overlap, and where the future is unclear. The Proposed Changes version of the NSP does not refer to the new Use Classes which are effective from 1 September and we anticipate the need for further amendments in order to rectify this.

We have a successful track record of large and complex schemes in Southwark and are well-placed to advise on development prospects, planning opportunities and strategy. We will be engaging with the draft policy consultation on behalf of a number of clients. Please get in touch with Phil Jones or Oliver Jefferson if you wish to discuss specific issues in relation to current or planned projects.

28 August 2020

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