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Policy E7 Intensification, co-location and substitution of land for industry, logistics and services to support London's economic function

E7

  1. Development Plans and development proposals should be proactive and encourage the intensification of business uses in Use Classes B1c, B2 and B8 occupying all categories of industrial land through:
    1. development of mezzanines
    2. introduction of small units
    3. development of multi-storey schemes
    4. addition of basements
    5. more efficient use of land through higher plot ratios having regard to operational requirements (including servicing) and mitigating impacts on the transport network where necessary.
  2. Development Plans and planning frameworks should be proactive and consider, in collaboration with the Mayor, whether certain logistics, industrial and related functions in selected parts of SILs could be intensified. Intensification should facilitate the consolidation of the identified SIL to support the delivery of residential and other uses, such as social infrastructure, or to contribute to town centre renewal. This process must meet the criteria set out in part E below and ensure that it does not undermine or compromise the integrity or effectiveness of the SIL in accommodating the industrial-type activities identified in part C of Policy E5 Strategic Industrial Locations (SIL). This approach should only be considered as part of a plan-led process of SIL intensification and consolidation (and the areas affected clearly defined in Development Plan policies maps) or as part of a co-ordinated masterplanning process in collaboration with the GLA and relevant borough, and not through ad hoc planning applications.
  3. Development Plans and planning frameworks should be proactive and consider whether certain logistics, industrial and related functions in selected parts of LSIS could be intensified and/or co-located with residential and other uses, such as social infrastructure, or to contribute to town centre renewal. This process should meet the criteria set out in part E below. This approach should only be considered as part of a plan-led process of LSIS intensification and consolidation (and clearly defined in Development Plan policies maps) or as part of a co-ordinated masterplanning process in collaboration with the GLA and relevant borough, and not through ad hoc planning applications.
  4. Mixed-use or residential development proposals on Non-Designated Industrial Sites will be supported where:
    1. there is no reasonable prospect of the site being used for the industrial and related purposes set out in part A of Policy E4 Land for industry, logistics and services to support London’s economic function; or
    2. it has been allocated in a Development Plan for residential or mixed-use development on the basis of part D.1; or
    3. industrial, storage or distribution floorspace is provided as part of mixed-use intensification where this is feasible; or
    4. suitable alternative accommodation (in terms of type, specification, use and size) is available in reasonable proximity to the development proposal and subject to relocation support arrangements for existing businesses before the commencement of new development. Mixed-use development proposals on Non-Designated Industrial Sites which co-locate industrial, storage or distribution floorspace with residential and/or other uses should also meet the criteria set out in parts E.2 to E.4 below.
  5. The processes set out in Parts B, C and D above must ensure that:
    1. the industrial uses within the SIL or LSIS are intensified to deliver an increase (or at least no overall net loss) of capacity in terms of industrial, storage and warehousing floorspace with appropriate provision of yard space for servicing
    2. the industrial and related activities on-site and in surrounding parts of the SIL, LSIS or Non-Designated Industrial Site are not compromised in terms of their continued efficient function, access, service arrangements and days/hours of operation noting that many businesses have 7-day/24-hour access and operational requirements
    3. the intensified industrial, storage and distribution uses are completed and operational in advance of any residential component being occupied
    4. appropriate design mitigation is provided in any residential element to ensure compliance with 1 and 2 above with particular consideration given to:
      1. safety and security (see Policy D10 Safety, security and resilience to emergency and Policy D11 Fire safety)
      2. the layout, orientation, access, servicing and delivery arrangements of the uses in order to minimise conflict (see Policy T4 Assessing and mitigating transport impacts)
      3. design quality, public realm, visual impact and amenity for residents (see Policy D1 London’s form and characteristics, Policy D2 Delivering good design, Policy D3 Inclusive design, Policy D4 Housing quality and standards, Policy D5 Accessible housing, Policy D6 Optimising housing density, Policy D7 Public realm and Policy D8 Tall buildings)
      4. vibration and noise (see Policy D13 Noise)
      5. air quality, including dust, odour and emissions (see Policy SI1 Improving air quality and Policy SI2 Minimising greenhouse gas emissions).
  6. Development Plans and planning frameworks should consider, in collaboration with neighbouring authorities within and outside London, the scope to facilitate the substitution of some of London’s industrial capacity to related property markets elsewhere in London and beyond London’s boundary where:
    1. this results in mutual advantage to collaboration partners inside and outside London and supports a more efficient use of land
    2. full regard is given to both the positive and negative impacts of substitution including impacts on servicing the economy inside and outside London, businesses and customers, labour markets and commuting, supply-chains and logistics, congestion, pollution and vehicle miles
    3. a clearly-defined strategy for the substitution of future demand capacity and/or relocation arrangements where relevant, is in place to support this process.
  7. This approach should only be considered as part of a plan-led process of consolidation and intensification (and clearly defined in Development Plan policies maps) and not through ad hoc planning applications.

In collaboration with the Mayor, boroughs are encouraged to explore the potential to intensify industrial activities[85] on industrial land and consider whether some types of industrial activities (particularly light industrial) could be co-located or mixed with residential. Through Local Plans, boroughs should also take a proactive approach to the management of vacancy rates to reach a level appropriate to the efficient functioning of the industrial market (considered to be five per cent for land and eight per cent for floorspace)[86].

[85] Industrial Intensification Primer, GLA 2017; CAG Consulting, 2017 op cit

[86 CAG Consulting, 2017 op cit. Mayor of London. Land for Industry and Transport SPG, GLA, 2012

Whilst the majority of land in SILs should be retained and intensified for the industrial-type functions set out in part C of Policy E5 Strategic Industrial Locations (SIL), there may be scope for selected parts of SILs or LSISs to be consolidated. This should be done through a carefully co-ordinated plan-led approach (in accordance with parts B, C and E of Policy E7 Intensification, co-location and substitution of land for industry, logistics and services to support London’s economic function) to deliver an intensification of industrial and related uses in the consolidated SIL or LSIS and facilitate the transfer of some land for a mix of uses including residential. Local Plan policies’ maps and/or OAPFs should indicate clearly: (i) the area to be retained and intensified as SIL or LSIS (and to provide future capacity for the uses set out in Policy E5 Strategic Industrial Locations (SIL) and Policy E6 Locally Significant Industrial Sites) and (ii) the area to be removed from SIL or LSIS (see illustrative examples in Figure 6.3). To ensure that such development works effectively, there should be a development agreement in place between a residential and industrial developer to support this process. In order to follow the Fast Track Route (see Policy H4 Meanwhile use), industrial sites will need to meet the 50 per cent threshold for affordable housing.

Outside of areas designated as SIL or LSIS there may be opportunities to deliver a mix of industrial and residential on the same site either side-by-side or through vertical stacking. Mixed-use and residential development proposals on existing Non-Designated Industrial Sites should ensure either that there is no reasonable prospect of the site being used for logistics/ industrial purposes, or incorporate light/general industrial or storage/distribution uses or put in place suitable relocation arrangements for any businesses/operations affected.

Evidence to demonstrate ‘no reasonable prospect’ should include:

  • strategic and local assessments of demand
  • the site should have been marketed with appropriate lease terms, and where the premises are derelict or obsolete, offered with the potential for redevelopment to meet the needs of modern industrial users
  • evidence that the scope for mixed-use intensification with industrial uses has been explored fully.

There is a significant amount of industrial and logistics capacity serving London that is located outside of the capital[87]. There may be scope for some substitution[88] of London’s industrial capacity to locations in the wider region where this results in mutual advantage, such as complementary business opportunities and transport infrastructure improvements. This will require close collaboration between planning authorities inside and outside London and must ensure that any substitution does not give rise to cumulative negative impacts including, for example, on business supply chains, labour markets, pollution and congestion[89].

[87] AECOM 2016 op cit

[88] The term ‘substitution’ refers here to making provision of land and floorspace to accommodate business uses in alternative locations outside London to meet projected future demand.

[89] CAG Consulting, 2017 op cit. Peter Brett Associates. Industrial Land and Transport Study, TfL, 2017

Collaborative working between the Mayor, boroughs and other stakeholders on Development Plan reviews, planning frameworks and masterplans provide useful mechanisms to co-ordinate these processes. This should ensure that the need to maintain sufficient capacity for industry to service London’s economy and residents is considered alongside other planning objectives including delivery of strategic infrastructure, housing, social infrastructure and other uses.