Architects say changes to London housing design standards are distracting

Last month, the Ministry of Housing, Communities and Local Government (MHCLG) and the Mayor of London outlined changes they said would encourage building.

These included the removal of a blanket presumption in favour of dual-aspect homes, and slashing London’s affordability target from 35 to 25 per cent, as well as new guidance on core dwellings and cycle storage.

The changes to design standards are still to go out to consultation. However, architects have already raised doubts about the proposals and whether they will reverse record low levels of house-building in London, where a third of councils failed to start work on any homes during the first quarter this year.

Jas Bhalla, principal at Jas Bhalla Works, told the AJ that while the individual policies were ‘no doubt well intentioned, little consideration appears to have been given to the amalgamated effects of disparate regulation’, including what he described as ‘increasing regulation in recent years, with changes to Parts B, L, O, and S.

‘Like many others, I suspect the announcement of these “emergency measures” won’t provide the jump start the housing industry desperately needs. In this context, focusing too heavily on the temporary removal of certain standards feels like a red herring.’

Bhalla added: ‘The challenge now should be to move beyond reactive policymaking and work collectively toward a regulatory and delivery framework that empowers architects to create lasting, inclusive, and genuinely liveable homes for all Londoners.’

Gort Scott director Fiona Scott agreed. She told the AJ that MHCLG and the mayor’s proposed changes ‘do not address the more complex over-arching issues that we should build less and refurbish more’.

She said: ‘Housing must be understood as social infrastructure, cutting across everything from public health to the economy – not real estate, and I welcome the focus on delivery of affordable homes, where almost none are currently being delivered, and having seen first-hand the real challenges of viability.

‘I would welcome a similar “crisis” level of support for low-carbon construction and refurbishment. However, I hope that by easing viability, there may be more room for innovation in these areas. These measures also do not answer the bigger systemic question about the share of house-building that is taken on by profit-driven developers, rather than the public and community sectors.’

New Works founding principal Doug Hodgson argued that other policy changes and priorities might be a better fix for the housing crisis.

‘The proposed changes to London’s housing design standards risk distracting from the real crisis: the shortage of genuinely affordable and high-quality social rent homes,’ he told the AJ. ‘Core design, daylight and ventilation are already regulated, and design justification is still required.

‘Focus has to be on social rent housing, with over 65,000 families currently living in temporary accommodation across London boroughs. Even if 60 per cent of the 20 per cent fast-tracked affordable homes were social rent, this would only contribute around 5,000 new social rent homes annually, far short of what our communities need now and in the future.’

Hodgson added: ‘The expectation that private developers can solve our housing crisis is flawed. Over the past decade, London has delivered on average under 40,000 new homes per year, with around a third classified affordable or social rent. Clearly a new way of tackling this crisis is needed to achieve the new target of 88,000 new homes per year.

‘To deliver the missing 48,000 new homes per year, we need publicly led development paid for by UK pension funds, providing 100 per cent affordable and social rent new homes, that are sustainable, high-quality and robustly designed by architects in collaboration with communities. This model should be replicated across the country to meet the local need.’

But Paul Rickard, chief executive of developer Pocket Living, took a much less critical view. He told the AJ that he was particularly ‘supportive of the change to dual aspect because it’s been a real issue to maximise dual aspect where possible, with no wriggle room, so you end up designing in complexity and cost that gives us zero benefit for the resident …’

‘Having the flexibility is absolutely welcomed through a planning process. It’s not an excuse to build something of a lower standard; it’s driving appropriate design so you get the right homes in the right places with the right features.

‘These changes will help us on some schemes. Yes, it’s a marginal gain and others will benefit much more than us, but house-building in London is so much in crisis, any marginal difference helps, and it will help.

‘Up until now, we’ve had the death by a thousand cuts. So why don’t want to reverse some of those cuts? There are a thousand levers we need to pull. The government is pulling some of them, and I’m hugely supportive of that. Let’s keep pulling more and more levers. We won’t always get it right. Some of those levers will be wrong or they won’t work, but we’ve got to pull them all. We have no choice.’

And Berkeley Group chair Rob Perrins told the AJ: ‘We commend the secretary of state and Mayor of London’s leadership in bringing forward this package, which goes a long way towards resolving London’s viability challenge. For these measures to work in practice, every organisation involved in housing delivery must now get behind them, and act with real urgency and conviction to increase homebuilding at pace.’

The changes to the London Plan were announced as part of an ‘emergency’ package of measures to revive house building in London. These also include giving the mayor, Sadiq Khan, the power to review and call in housing schemes of 50 homes or more that boroughs have indicated they will refuse. City Hall will also be able to rule on developments of more than 1,000m² that are on greenbelt land.

Khan will be able to carry out a call-in process without the need for a full hearing, potentially cutting six months from planning, according to the MHCLG.

It also confirmed an initial £322 million to establish the City Hall Developer Investment Fund, which was announced in June.

The cut to affordable housing proportions was trailed last month, with The Financial Times reporting at the time that industry insiders were pushing for an even lower target – between 10 and 15 per cent.

MHCLG said housebuilders would be able to claim ‘time-limited emergency relief’ from the Community Infrastructure Levy (CIL) ‘where this is necessary to unlock development’ and where at least 20 per cent of the housing on their scheme is affordable.

It will apply to projects starting after the new regulations come into force and before the end of  2028.

Khan said affordable housing had always been one of his top priorities, but that construction inflation, high interest rates, the pandemic and Brexit had been a ‘perfect storm’ for house-building.

‘Urgent action is required,’ he said, ‘which is why I’ve been working with the government on this package of bold measures. I grew up in a council house, so I know the importance of social and affordable homes.

‘I’m not willing to stand by while the supply of affordable housing for Londoners dries up.’

The consultation dates for the proposed changes have not yet been announced.