Recommendation 1: Strategic and Plan Making – Review of Strategic Industrial Land
1.1 There should be a London-wide review of existing allocated Strategic Industrial Land and Policy 2.17 (Strategic Industrial Locations) of the London Plan. This would ensure that planning does not take place in a piecemeal fashion. It would consider the needs of the industrial and logistics sector, review current locations and identify potentially inappropriate locations and sites for today’s urban logistics providers, which may be better suited for alternative uses.
1.2 The review should consider:
- The quantum of industrial land that is available
- Whether sites are in the right locations
- The quality of space and land available
- The rate at which industrial land is being lost to other uses, particularly high quality larger sites and those in key industrial locations
- Whether the right sites are being retained
- Where new locations are needed; and
- Land ownership
1.3 The review would result in a robust supply of protected Strategic Industrial Land with the ability to meet the needs of the sector. At the same time it would also identify sites that would be better used to deliver for London’s other needs.
1.4 As well as a London-wide piece to identify strategic need and locations, London boroughs should be required to assess local industrial sites in a similar way.
Recommendation 2: Production of a Full and Comprehensive Demand Assessment
2.1 It is important that supply is not considered in isolation, but that a full and comprehensive review of the quantum of future demand is undertaken. This should inform the above exercise and London Plan policies relating to supply of industrial land and its release, as well as targets for release set out in associated Supplementary Planning Guidance.
2.2 The assessment should be carried out in accordance with NPPF guidance on the production of employment land assessments. However, in some regards the NPPF falls short of ensuring a holistic approach to industrial land supply, and further refinement of this should be considered such as:
- The space requirements (ha) of urban logistics and industrial operators, including consideration of appropriate employment densities as well as plot ratios to account for parking for delivery vans and shift work.
- How the urban logistics market will grow in size (employees, businesses) over the next 10-20 years, including consideration of the relationship to population size and other businesses.
- Locational requirements of urban logistics firms. This should include consultation with urban logistics firms and related stakeholders to understand the full range of requirements; there is not a one-size-fits-all solution, with larger logistics operators and local businesses having differing needs.
- Regular updates (such as every 2 years) to ensure the demand assessment remains up to date and reflects market changes.
2.3 London Boroughs should be also be required to undertake an analysis for local industrial needs, alongside a more strategic review at the London level.
Recommendation 3: Review of Policy Designation
3.1 Strategic Industrial Locations across Opportunity Areas should be reviewed. Where these are retained they should be afforded strong policy protection. Opportunities for new designations should be considered. These should be in locations which are fit for purpose and reflect the most meaningful locations for urban logistics operators and industrial occupiers, taking into account the locational requirements of the sector. Proximity to housing development should not be a negating factor; mixed-use schemes are demonstrating that combined land use solutions are possible. The GLA could also consider designation of new Industrial Opportunity Areas in appropriate locations, either in their own right or as part of wider existing Opportunity Areas. The first such classification could be Park Royal, given its existing prominence as an industrial area and its location within the Old Oak Park Royal Opportunity Area.
3.2 The industrial sector has changed considerably over the last decade, which has seen a significant growth in the urban logistics sector. Urban logistics operators have specific requirements which should be acknowledged within policy wording and supporting text to promote urban logistics in Strategic Industrial Locations across London.
3.3 To ensure sufficient supply, a policy approach which seeks to protect the right land in the right locations for industrial and logistics uses should be employed by the GLA and London Boroughs with opportunities to consider land assembly, for example through compulsory purchase, where land ownerships are piecemeal”.
Recommendation 4: Acknowledging and responding to last mile requirements
4.1 As well as specific locations for industrial and logistics businesses, there must be consideration of the needs of last mile operators. Small scale distribution centres, consolidation centres and customer pick up points (such as Doddle) are a vital component in the final stage of delivery. A review of those boroughs with significant population growth (for example, over 80,000 in 2011-2031) should be undertaken to ensure suitable logistics space is provided to serve businesses and residents. Further to this, ensuring effective delivery points within new build developments such as residential, commercial and leisure/retail is fundamental in ensuring that deliveries can reach the door or desk in accordance with demand.
Recommendation 5: Recognise the locational imperative of urban logistics operators in establishing industrial locations
5.1 In allocating industrial locations it is not appropriate to simply designate locations outside of London. This will create challenges for urban logistics companies due to their reliance on proximity to their customer market. They will be less efficiently able to respond to the demands placed on their services. Further to this, many local authorities neighbouring London are already in challenging situations trying to identify sufficient land for their own employment and housing needs.
5.2 In identifying new locations for industrial land the following must be considered:
- Locations of population growth
- Locations of business growth
- The locational requirements of urban logistics companies including distance to market and access to good transport routes
- The site specification requirements of urban logistics companies
- The demands for employment and housing land from within local authorities neighbouring London.
Recommendation 6: Planning Decisions and Development Control
6.1 Development control has a vital role to play in ensuring the best use is made of the space or land available. This will be critical to the success of the sector due to the practical nature of development control as an enabler for development. Policy should seek to allow sufficient flexibility for alterations, and local authorities should be flexible enough in their approach to development control, supporting changes to planning permission (Section 96a and Section 73) and intensification of uses where these are needed to support occupier requirements.
6.2 Occupiers’ technical and operational needs may require flexibility in policy and/or planning permissions. This should be ensured for:
- Parking – to allow for shift changeovers, increased staff numbers and visitors
- Operations – need for 24/7 access and servicing
- Lorry/van parking (inside and outside buildings) – this is particularly important where HGVs and LGVs are required to carry out logistics operations. These are separate from requirements for staff parking
- Floorspace – flexibility regarding subdivision and amalgamation of units, as well as the installation of mezzanines
- Uses – need for flexibility across B1/B2/B8 uses. This may include, for example, the ability to deliver to a small pickup point (such as a Doddle) in a high street location which may be designated for B1/A1 uses
- Innovation and workshop (maker space) units – support for start-up units alongside more established users
- Supporting uses and enabling development – both ancillary within buildings and within estates e.g. hotels. This is often important to ensure that developments can be brought forward as well as delivering appropriate amenity provision to businesses and their employees
- Supporting infrastructure – such as power and broadband/fire connectivity
- Delivery bays – new commercial buildings, including retail, hotels and offices, should include sufficient loading bays for deliveries.
- Offices – up to 50% of the floorspace for flexible uses such as R&D or to support businesses that want to consolidate their office/HQ and industrial operations.
Recommendation 7: Implementing a requirement for replacement of losses above target
7.1 The rate of industrial land release in recent years above the targeted rate indicates that appropriate measures need to be brought in to keep the rate of release in check and to hold local authorities to account.
7.2 There should be a clear requirement for local authorities to ensure replacement of industrial land lost where this exceeds their annual target. This should be in locations suited to such uses and should reflect the specific function of urban logistics operators and industrial occupiers.
7.3 This approach would help to ensure that local authorities took ownership of the industrial land policies set at both borough level and through the London Plan to ensure that local policies are not only fit for purpose but are implemented and adhered to.
Recommendation 8: Refining policy to enable intensification of industrial uses more readily
8.1 In some, though not all, instances there will be the potential to intensify industrial uses through inclusion of mezzanines, mixed-use and stacking. Flexibility should be included within London Plan policy and encouraged where considered practical by operators. This will enable the industrial land available to be developed to its full potential.
Recommendation 9: Providing a Long Term Voice for the Industry within London Policy Making
9.1 A GLA Logistics and Industrial Sounding Board should be established to give a more prominent voice to the industry in London and ensure the needs of urban logistics and industrial businesses are taken into consideration in the planning of Opportunity Areas and other activities which affect industrial land provision across the capital. This should include key urban logistics operators as well as some more local providers.
Recommendation 10: Ensuring that London’s infrastructure supports the industry’s adoption of environmental technologies
10.1 This should also examine environmental considerations and support the industry with investigation into solutions such as consolidation centres. The GLA also needs to facilitate consistency in approach from local authorities into areas that may require policy updates such as retiming of deliveries.