Most NORA members live in urban areas outside the metropolis, but nevertheless they have a view of these proposals that merit expression.
Changes to our capital city concern us all. Nearly all visit London and have concerns about changes to the built environment as seen as a visitor and as a
temporary resident. There is also the underlying concern that what takes place in London could follow sooner or later in their urban area.
While supporting some of the proposals, there is a concern that residents' representations will be over-ruled by pressure from developers and landlords and
diminishing influence on planning decisions.
These fears are detailed in the answers given to the eighteen questions listed in the Consultation Paper.
OPTION 1: Permitted development right for additional storeys in London
Question 1: Would greater freedom to build upwards on existing premises be a viable option to increase housing supply while protecting London's open spaces?
Why do you think so?
Building high-rise apartment blocks is an obvious solution to London's housing problems, but the upward extension of existing properties by increasing Permitted
Development Rights (PDR) is highly unlikely to have even a marginal effect on housing supply. Problems of access, egress from fire, privacy and security, pressure
on water, gas and electricity services, disposal of waste water and sewage, and the inevitable damaging effect of changes to roofs are key deterrents.
Question 2: Do you agree with the proposal for a London permitted development right with prior approval, allowing the addition of new housing units where the
extension is no higher than the height of an adjoining roofline, and no more than two storeys, to support delivery of additional homes in the capital?
Prior approval alone excludes the neighbours and the community from making representations, a denial that is unacceptable in a densely populated city. The criteria
relevant in prior approval are inadequate to cover the concerns of the community.
Question 3: Do you agree that the proposed options for neighbour consultation provide adequate opportunity for comment on development proposals for upward
Neighbours may be tenants or leaseholders fearful of landlords' response to their objections. They may be in a minority in a mixed development. It is vital that
amenity groups such as resident associations and civic societies can also express their concerns.
Question 4: What other measures could a London permitted development right contain to encourage applications for upward extensions to come forward? For example,
would allowing additional physical works to provide for access, or partial or full demolition and re-build up to the height of an adjoining roofline, incentivise
building up? If so, would this raise additional considerations which should be taken into account?
To add apartments in extra storeys must require external structures for access and services, which may be harmful to the amenity of neighbours. Control over the
external appearance - design, materials, and fenestration - need assessment in order to avoid monstrous changes, which can only be ensured by a full planning
OPTION 2: Local development orders for additional storeys in specific areas
Question 5: Do you agree that local development orders would be an effective means to promote upward extensions and contribute to the delivery of additional homes
LDOs 'could' rather than 'would' be an effective means, but to design LDOs that have a universal relevance in such a varied urban environment is doubtful.
Question 6: What measures should a local development order contain to encourage proposals for upward extensions to come forward?
Appropriate LDOs covering design, materials, street-scene, amenity, space standards (sadly few LPAs have adopted the Nationally Described Space Standards) and
construction programmes might facilitate proposals but might not. Either way it is a preferred option to extending PDR.
Question 7: We would welcome the views of London boroughs on whether they consider they would introduce local development orders for upward extensions, and what
might encourage them to do so?
Not relevant to NORA.
OPTION 3: Support in the London Plan
Question 8: Do you agree that proposals for a new London Plan policy supporting upward extensions would provide certainty and incentivise the development of
additional housing in appropriate locations?
Yes, provided it includes the restraints mentioned in Q 6.
Question 9: What are your preferred option/s to support upward extensions to increase housing supply in London?
Preference is for Option 2 since LPAs are involved, and Option 3 is a second choice. Option 1 is strongly opposed, because it could be disastrous for the
community and the ambience of the built environment.
Question 10: Do you agree that premises in residential, office, retail and other high street uses would be suitable for upward extension to provide additional
Why do you think so?
Yes, provided that architectural symmetry is observed. In a residential area of similar detached and semi-detached dwellings, isolated roof extensions can
seriously damage the environment. Similarly isolated roof extensions on uniform terraces can ruin the unity of the street-scene.
Question 11: Do you agree with the locations that should be excluded from a permitted development right listed in paragraph 3.3 above, and are there other areas
where proposed upward extensions would be best managed through a planning application?
Why do you think so?
Conservation Areas also need inclusion. Changes to the roofline are key elements of the street-scene and prior approval and LDOs are inadequate to provide the
necessary protection to the amenity of an area.
Question 12: Do you agree with our proposed approach to protect conservation areas and protected views?
A full planning application is needed to assess each proposal in a Conservation Area, since prior approval and a LDO may not be adequate for a wide variety of
Question 13: Do you agree with our proposals that the property being extended upwards should share a wall with a higher property, or form part of a continuous
terrace of premises being extended that shares a wall with a higher property?
Why do you think so?
It is vital that the integrity of the site, whether a terrace or a semi-detached dwelling is preserved, and the design must be appropriate for the architectural
Question 14: Do you agree that for a permitted development right or London Plan policy a limit of two additional storeys is appropriate to manage the impact of
upward development in any area?
A London Plan policy limiting extensions to two storeys is acceptable but a Permitted Development Right is strongly opposed.
Question 15: Do you agree that a prior approval should consider the method and hours of construction?
It also applies to the London Plan proposal as it applies also to Full Planning Applications.
Question 16: Have you any views on the likely costs and benefits of these proposals to deliver additional homes in the capital?
In many areas the costs are likely to exceed the saleable value of the property, but it may be profitable in the more affluent areas. London has many terraces of
two and three storeys in shopping and residential areas, but the lack of rear access makes it highly unlikely that they would be suitable for raising the roof.
Some apartment blocks of three and four storeys might accommodate roof extension, but would the structures be safe?
As a result the proposal to facilitate roof extensions will not be significant, certainly not sufficiently so, to merit by-passing the current full planning
To extend the roof requires involvement of architects, surveyors, financial and legal advisers, so the added burden of submitting a planning application should
not be an unreasonable burden. Planning consent should mean that the proposal is acceptable, safe and sustainable.
Question 17: Have you any views on the implications of the approaches to housing supply outlined above for people with protected characteristics as defined in the
Equalities Act 2010?
What evidence do you have on this matter?
Question 18: Are there any other points that you wish to make in response to this consultation, including other key components we have not considered that would
be beneficial in taking the proposals forward, or any examples of upward extensions providing additional housing?
In London the proposals to build underground facilities have had much publicity, but there has been little or none for roof extensions. Presumably there is
little current demand. So it is difficult to believe that reducing the involvement of planners and the community in the process of development of roof extensions
will make a significant difference to the housing problems of London.
Alan B Shrank - NORA chairman