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ADD2581: Implementation of Policy SI 6 of the London Plan

Key information

Decision type: Assistant Director

Reference code: ADD2581

Date signed:

Date published:

Decision by: Tim Steer, Executive Director, Housing and Land

Executive summary

This decision form seeks approval of expenditure of up to £50,000, for the Connected London team to procure a consultant to provide support and guidance to implement Policy SI 6 of the London Plan. The consultant will meet with key stakeholders including developers, councils, telecoms operators and government to develop technical and practical London Plan Guidance (LPG) to sit alongside Policy SI 6.

The guidance will be used by housing developers and councils to ensure compliance with the London Plan, and to play a role in supporting adoption through Local Plans.

Decision

That the Assistant Director of Transport, infrastructure and Connectivity approves the expenditure of up to £50,000 to commission an expert consultant to support with the development and implementation of planning guidance to sit alongside Policy SI 6.

Part 1: Non-confidential facts and advice

1.1. Policy SI 6 of the London Plan (see appendix 1) sets a minimum standard for full-fibre digital connectivity for all end-users in all new business and residential developments, as well as major area developments, in the capital. This means that every new building in London will be assured access to fast and reliable internet. It will also ensure that developers make provisions for mobile coverage. For the first time, London will have specific planning policy to drive full-fibre connectivity and improve mobile network coverage.

1.2. The policy addresses the Mayor’s manifesto commitments to improve digital connectivity by requiring full-fibre broadband and mobile coverage for all new builds. The Plan also helps the Mayor realise his ambition in the Smarter London Together Roadmap for London to be the smartest city in the world.

1.3. To support implementation of the policy, clear technical and practical guidance is required for developers – guidance that is relevant to submitting applications and considering their compliance with SI 6. Guidance will include contents agreed by planning and industry, and will draw from sources including legislation and Ofcom, the telecoms regulator.

1.4. Thinkbroadband reports that, during 2020, 153,555 new residential builds were built in the UK. Of these new-builds, 90 per cent received full-fibre connections. The remaining 10 per cent received copper connections, 0.6 per cent of which were below the Universal Service Obligation. This cycle of building homes with legacy infrastructure will be stopped by Policy SI 6.

1.5. In a Cluttons report, ‘The Connectivity Commercial Impact Report’, almost three-quarters (72 per cent) of commercial tenants said offices that are not well connected will become obsolete spaces in the future. This demonstrates how much more important digital connectivity has become for businesses.

1.6. LPG documents are material considerations in planning decisions. The expectation is that they will be taken into account by London Planning Authorities (LPAs) when drawing up local plans and other planning documents.

1.7. The Connected London and London Plan teams are working closely to support implementation of Policy SI 6. The GLA now requires expert advice to provide further guidance to implement the policy. A specialist consultant with experience and technical knowledge in developing infrastructure guidance is required, as this function does not currently exist within the GLA.

1.8. This consultancy will be procured in accordance with the GLA Contracts and Funding Code.

2.1. The key objectives and expected outcomes are as follows:

  • Future-proofing London’s digital connectivity requirements by ensuring that the gold standard for digital connectivity is set as a minimum standard for London’s fixed line and mobile connectivity.
  • Improving digital connectivity across the capital with a focus on capability, affordability, security and resilience.
  • Developing clear technical and practical guidance for housing developers to self-certify and ensure compliance with the Policy SI 6 of the London Plan. Equally, the guidance will support planning officers across local authorities to ensure development proposals are compliant with the Plan.
  • Guidance to include technical elements on design specification of buildings to enable full-fibre deployment with mechanisms put in place to enable further future infrastructure upgrades. Developers will be encouraged to consult with fixed-line operators to help with design specification to avoid and mitigate against risks.
  • Separate guidance to support the provision of mobile coverage, so that coverage and capacity is at the forefront of the development and should not have detrimental impacts on the digital connectivity of neighbouring buildings. Developers will be encouraged to consult with mobile operators to help identify any adverse impact on mobile or wireless connectivity, and appropriate measures to avoid/mitigate them.
  • Guidance will aim to help mobile operators benefit from their infrastructure planning applications being approved on the first attempt, to ensure London’s dismissal rates are more akin to the UK average.
  • Ensure that the guidance will have the ability to support and enable London’s local authorities to update their digital connectivity Local Plans.

3.1. Under section 149 of the Equality Act 2010, as public authorities, the Mayor and the GLA are subject to a public-sector equality duty and must have ‘due regard’ to the need to:

  • eliminate unlawful discrimination, harassment and victimisation
  • advance equality of opportunity between people who share a relevant protected characteristic and those who do not
  • foster good relations between people who share a relevant protected characteristic and those who do not.

Protected characteristics under section 149 of the Equality Act are age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex, sexual orientation, and marriage or civil partnership status.

3.2. This work will support the implementation of the London Plan and the delivery of fixed-line broadband and mobile infrastructure through the planning system. It is anticipated that this will have a positive impact on protected characteristic groups through facilitating the provision of improved digital connectivity. Research undertaken as part of the Digital Access for All mission shows that older Londoners; those with disabilities and learning difficulties; those with a minority ethnic origin, culture and language; those based in areas where connectivity is poor; and those on a low income are more likely to be digitally excluded. The 2016-17 Family Resources Survey reports that 56 per cent of adult internet non-users are disabled, even though disabled adults only make up 22 per cent of the UK population. Some 60% of internet non-users aged 16-24, according to the report, are disabled.

According to an Age UK report, ‘Mind the digital gap: older Londoners and internet use during the pandemic’, one in four of older Londoners over 65 would like to use the internet more. Digital skills, access to data and devices are cited as the primary reasons for digital exclusion.

4.1. The risks associated with this project are limited and set out below.

Risk description

Inherent score

Mitigation

Target score

The work takes longer than expected.

Likelihood: 2

Impact: 3

Total: 6

The contract for services will provide assurance that work will be carried out to the specified programme. A stakeholder list for use by the consultant as part of the work already exists and is updated regularly as required, which should reduce the likelihood of unexpected delays.

Regular project updates will be sought through the duration of the project.

Likelihood: 1

Impact: 2

Total: 2

The budget for the work is exceeded.

Likelihood: 2

Impact: 2

Total: 4

The scope of the work and fees will be agreed in the contract for services.

Likelihood: 1

Impact: 2

Total: 2

The work is of insufficient quality.

Likelihood: 2

Impact: 3

Total: 6

The scope of the work will be agreed in the contract for services.

The guidance’s produced will be reviewed internally in detail before being published.

Likelihood: 1

Impact: 2

Total: 2





Link to Mayoral strategies and priorities

4.2. The Mayor is committed to increasing full-fibre and mobile availability in London by implementing the strongest digital connectivity policies through the London Plan. Policy SI 6 over-delivers against Part R1 of the Building Regulations 2010, which requires buildings to be equipped with at least 30 MB/s ready in-building physical infrastructure.

4.3. The Digital Access for All mission is for “every Londoner to have access to good connectivity, basic digital skills and the device or support they need to be online by 2025”. Implementation of Policy SI 6 will ensure that all new builds in London will benefit from gigabit-capable speeds and mobile connectivity that Londoners need.

4.4. Mission 3 of The Smarter London Together Roadmap states: “Consider planning powers, like requiring full-fibre to the home for all new developments, to enhance connectivity in the future.”

4.5. The Economic Development Strategy states:

“The Mayor will tackle the barriers to provision of fast, reliable digital connectivity through a comprehensive programme including: appointing a dedicated team in City Hall, promoting best practice and innovation, developing guidance, advocating the use of public sector assets for digital connectivity and championing the use of standardised agreements.”

4.6. There are no conflicts of interest to note for the officers involved in the drafting or clearance of this decision form.

4.7. No issues relating to data protection, health or safeguarding arise from the initiative set out in this form.

5.1 Approval is sought for the expenditure of £50,000 on the procurement of a consultant to provide support and advice in implementing planning guidance related to the London Plan.



5.2 This expenditure will be funded by the Data and Devices programme within the approved Transport, Infrastructure and Connectivity budget allocation for 2022-23.

Activity

Timeline

Finalise specification for procurement

July 2022

Procurement

July/August 2022

Consultant start date

October 2022

Consultant completes draft guidance

January 2023

London Plan team review/sign-off guidance

February 2023

GLA publishes guidance

March 2023

Arrange training/workshop for LPAs

April 2023

Appendix 1: London Plan – The Spatial Development Strategy for Greater London, March 2021

Signed decision document

ADD2581: Implementation of Policy SI 6 of the London Plan

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