London Chamber of Commerce and Industry (LCCI) is the capital’s largest independent business representative organisation. We represent the interests of firms of all sizes, from micro-businesses and sole traders to large, multi-national corporate bodies. Our members operate across a broad range of sectors in all 33 London local authority areas, and also include businesses located outside of London with trade or business interests in the capital. The points outlined below reflect the areas highlighted by our member businesses which the next London Plan should consider.

This response is divided into three sections:

1. Ensuring London is a place for people to live, work and enjoy – focusing on routes to the housing ladder and making future housing developments suitable for home-working.
2. Making London a place for business to thrive – emphasising the need for industrial land and more supportive freight policies, improvements needed in energy infrastructure and the necessity for the Agent of Change principle to be in the next London Plan.
3. Supporting London’s economic recovery from Covid-19 – centring on measures to support the Central Activities Zone and aviation.

Ensuring London is a place for people to live, work and enjoy

Rent to own and routes to the housing ladder

The ability for businesses to recruit and retain employees is put at unnecessary risk by the cost of accommodation in London. The cost of buying a home in London has prevented many from attaining property ownership. Therefore, the next London Plan should include policy or criteria for rent to own schemes. These schemes can provide an alternative to traditional home ownership and could help get Londoners onto the housing ladder.

The next Plan should also ensure that affordable housing targets are met. This ensures that London is an attractive and affordable place to live as well as work. Moreover, future affordable housing developments should consider the need for homeworking. The pandemic has changed the world of work drastically and it is unlikely to ever return to what it was. Remote working is going to remain a part of many Londoners’ working patterns and home-working should be recognised for its contribution to post-COVID economic activity. As a forward-thinking city, London should lead in making hybrid working viable. Policy should aim to support economic activity in residential settings, facilitate home extensions and strengthen broadband infrastructure in all of London.

London’s Green Belt

London continues to face affordability issues for those who want to live and work here. LCCI recognises the importance of London’s Green Belt and its beneficial functions for the city. However, research commissioned by LCCI in 2017, published in the ‘Brown for Blue report’ identified approximately 329 hectares of ‘brownspace’ – land that is otherwise vacant, unused, derelict or has poor quality use – within the Green Belt. This land could be used for other purposes, such as new housing developments or sites for business use. Given that this study was undertaken more than four years ago, an updated mapping exercise should be conducted to map the Green Belt and identify areas of ‘brownspace’ for targeted intervention. Limited intervention into the Green Belt would be an important step in addressing the housing crisis in London.

Making London a place for businesses to thrive

Infrastructure for new businesses

The challenges to London’s status as a global hub for business come not only from the pandemic, but also from the UK’s departure from the European Union. A study from New Financial in April 2021 showed that more than 400 firms had moved / were moving parts of their business, staff, or assets out of the UK to the EU.

Therefore, it is essential that the infrastructure necessary for new businesses to start up and grow is provided in London, such as better transport design, wider high-speed broadband connections, and specific policy regarding data centres. The next London Plan should include provisions that maintain and help foster London’s status as a hub for businesses, considering their changing needs. Additionally, policy should aim to help businesses that need land and premises for hotels, shops, restaurants, and other ventures.

Land for industry, logistics and services to support London’s economic function

LCCI acknowledges that boroughs are encouraged to deliver intensified floorspace capacity, and that the number of hectares of industrial land released to other uses has been well in excess of monitoring benchmarks.

However, intensified floorspace cannot be the solution for all of the capital’s logistics and industrial needs. Instead, industrial land should be restored through reinstating the ‘no net loss’ policy of previous London Plans. This revised policy should seek to go further than simply ‘no net loss of floorspace capacity’ only. A significant number of members consider that the policy should be for no net loss of land, with priority being given to the provision of open land and vehicle storage areas. This is vital to London as a growing city; as the population becomes less reliant on personal cars, greater reliance on freight and logistics will naturally ensue. Guidance supporting intensification and co-location must identify industry’s real-world requirements.

The ‘no net loss’ policy featured in the draft of the current London Plan was directed to be removed by the Secretary of State. To prevent this occurring again in the future, early engagement by the GLA is required with the Department for Levelling Up, Housing and Communities. This engagement should emphasise that land for industry and logistics ought not to be seen as being in competition for land for housing, but complementary to new communities providing employment and essential logistics infrastructure.

London’s growing population will increase demand for deliveries and servicing activity and therefore land needs to be in place to support this. The British Property Federation’s report What Warehousing Where states that there are presently 69 sq. ft of warehouse floorspace for every home in England. This could provide a useful benchmark for the future logistics land requirements for London. In addition, ensuring sufficient logistics land is located in the right place is essential to reduce stem mileage and assist the logistics industry in achieving net zero.

Strategic Industrial Locations and Locally Significant Industrial Sites

Land for industry and logistics is being lost at three times the anticipated level of release identified in the previous London Plan. This rate is unsustainable. Moreover, as this measure only applies to designated industrial land, which accounts for just 64 percent of total industrial land, the actual loss may be far greater.

The categorisation of industrial sites is doing more harm than good when it comes to meeting London’s industrial needs. The category ‘Non-Designated Industrial Sites’ includes land that is significant to population-dense locations in central and inner London.

If these sites were designated under the category of ‘Strategic Industrial Locations’ and ‘Locally Significant Industrial Sites’, they would be afforded greater protections and recognised for the importance that they hold. In the next London Plan the ‘NonDesignated Industrial Sites’ category should no longer be used.

Agent of Change principle

The next London Plan should include the Agent of Change principle as a sensible and pragmatic approach to the issues which arise from new residential developments being constructed next to existing industrial and logistics sites. Over the years, this has resulted in many businesses being forced to restrict their activities, relocate, or close altogether (with the associated loss of employment). The onus should be on developers to ensure that new residential developments are designed to protect both the existing businesses and the new residents.

The policy should not only focus on noise but include all potential activities that could cause a statutory nuisance including vibration, traffic, parking, and odours.

Supplementary Planning Guidance should be produced to detail how the policy will be enforced in the long-term and safeguards to be put in place to ensure that it remains enforceable after the developer has sold the property. The policy also needs to protect future uses of the industrial land, such as business expansion or diversification.

Local Plans

Businesses wishing to expand or diversify face issues with contrasting requirements in Borough Local Plans. Greater consistency is needed between the ambitions of the Mayor of London and local boroughs. Boroughs’ Local Plans should ensure they are aligned with the next London Plan, so all actors are putting their efforts towards the same goals. Boroughs have an important role to play in identifying how their own land can be used by logistics companies for micro-consolidation, but the array of varying plans across London can be confusing for businesses. A clear, unified outline is needed to ensure businesses are maintaining the same practices across the city.

Energy infrastructure

There is increasing demand on the capital’s electricity infrastructure as a result of the growing population, expanding economy and the increasing uptake of electric vehicles. The Next London Plan needs to include provisions for more charging infrastructure to match the ambitions for an increased use of electric vehicles. Additionally, alternative 5 means of power are also being used for larger freight vehicles, and the appropriate refuelling infrastructure is essential for vehicles using gas instead of diesel.

Policy needs to be clear that the costs of improving this infrastructure cannot be borne solely by industry. It must consider expected rises in demand resulting from factors such as an increasing move from gas, petrol, and diesel to electric, and the introduction of smart technology solutions.

Healthy Streets

The existing policy for Healthy Streets prioritises active travel and avoiding personal car travel, which is expected to increase reliance on freight for Londoners. Therefore, the importance of freight to servicing businesses and residents must be recognised. The next London Plan should be reflective of the Mayor’s desire to work with the freight industry to find creative solutions to manage freight. The Plan should act as a guide for the fragmented and difficult to follow regulatory environment that freight currently must navigate. Without this, the industry will continue to face barriers to achieving the Mayor and TfL’s goals.

The next London Plan should also aim to align with ambitions for accessible electric vehicle charging infrastructure in line with the uptake in this mode of travel. Accessibility to charging points must be a consideration of all future adaptions to the road network, to enable those businesses that rely on vehicles to operate.

Supporting London’s economic recovery from Covid-19

The Central Activities Zone (CAZ)

The impact of the COVID-19 pandemic in the Central Activities Zone (CAZ) should be accounted for in the next London Plan, particularly in terms of policies to support its future resilience. Findings from the GLA’s The economic future of the Central Activities Zone (CAZ) report should be considered in the next London Plan. The CAZ is critical not only to London’s economy, but the UK as a whole. As the report from the GLA sets out, there must be consideration of the necessary steps to ensure the CAZ can thrive in a world of changing work patterns. The success of the CAZ will also greatly depend on the return of international tourism, highlighting the need to consider London airports’ plans when developing the next London Plan.

Aviation

The next London Plan should recognise and support the critical role that aviation plays in the capital’s global connectivity, as well as its role in supporting global connectivity across the UK. This is in addition to the vital role it plays in supporting businesses and jobs linked to the sector, such as through supply chains. London is a global city, and its aviation sector is key to linking London to the rest of the world.

Airports that serve London such as City, Heathrow, and Gatwick are developing plans that will cover the coming decades. These documents must be considered when drawing up the next London Plan.

For example, the London City Airport Master Plan is a resource that should be used and was subject to extensive consultation. Its findings will be useful for shaping aviation policy generally and has particular application to the Royal Dock Opportunity Area.

The aviation industry is also committed to strengthening existing climate change policy applicable to them and this should be reflected in the next London Plan. Gatwick Airport is committed to net zero by 2050 through the Sustainable Aviation coalition and similar international commitments are expected at the ICAO Assembly in September 2022.

Conclusion

The points made above are policy suggestions that are fundamental to businesses succeeding in the years to come. We recognise that there will be further opportunities where more detailed evidence can be provided. We look forward to being fully engaged at all stages of the review process.

Contact

Should you wish to discuss this submission or engage with the LCCI at any point during the London Plan review process, please contact the Policy Team on policy@londonchamber.co.uk.