Housing

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4.1 Housing Context

4.1.0 Housing is vital for the City’s future economy and its communities. A shortage of housing, particularly affordable housing, is one of the main barriers to future business and community growth in the City and across London. High quality, affordable housing is also essential to meet the housing needs of those of the City’s communities on lower incomes.

4.1.1 The 2021 Census indicated that the City’s permanent residential population was 8,600, which is small in comparison to the working population in excess of 590,000. The GLA’s 2021-based interim housing-led projections suggest that the City’s population (excluding those with main homes elsewhere) will have a modest increase to approximately 9,500 by 2040. The 2021 Census indicated that there were 1,700 second homes in the City of London.

4.1.2 The majority of the City’s housing is concentrated around the edge of the City in four estates (the Barbican, Golden Lane, Middlesex Street and Mansell Street). Other residential areas are located in Smithfield, the Temples, parts of the riverside (Queenhithe), Fleet Street (City West), Carter Lane and around Botolph Lane. Most residential units in the City are flats with one or two bedrooms, which is consistent with the need assessment of unit sizes recommended in the City of London Strategic Housing Market Assessment (SHMA) 2023.

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4.1.3 The City Corporation is the strategic housing authority for the City of London and a landlord responsible for over 1,900 social tenanted properties and over 900 leaseholder properties across London. The City Corporation provides over 1,800 social housing units on 11 estates that it owns and manages outside of the City of London in the six London boroughs of Southwark, Islington, Lewisham, Lambeth, Hackney and Tower Hamlets. This is in addition to social housing provided within the City.

4.1.4 Clustering new housing development in or near existing residential areas allows greater opportunity to protect residential amenity and deliver a high quality residential environment. Residential clustering reduces potential conflict with commercial and office uses. There may be occasional opportunities for new residential development on appropriate sites near identified residential areas, such as through the re-use of heritage assets, where the potential to meet future office needs may be limited by site-specific considerations.

4.1.5 References to housing in this Plan include market and affordable housing (comprising social rented housing, affordable rented housing and intermediate housing), hostels, sheltered and extra-care housing. It also includes Built to Rent and Co-Living accommodation which are likely to have an increasing role in meeting future housing needs, particularly for City workers at an early stage of their careers. References to housing in this Plan do not include student accommodation, as it may be appropriate in different locations to other forms of housing.

4.1.6 Co-Living accommodation will contribute towards meeting general housing need at the national ratio for non-self-contained accommodation of 1.8 bedrooms to 1 residential unit. Student accommodation contributes to meeting general housing need at the national ratio of 2.5 student rooms to 1 residential unit.

Housing requirement

4.1.7 The NPPF sets out a standardised approach to assessing housing need and requires strategic planning authorities to follow this approach in setting housing targets in Local Plans. The City of London Local Plan is required to be in general conformity with the London Plan, which sets a housing target for the City and the London boroughs.

4.1.8 The London Plan’s strategic framework includes Policy SD5 which indicates that residential development is inappropriate in the commercial core of the City of London. Within this context, the London Plan is informed by a Strategic Housing Land Availability Assessment (SHLAA) for London, providing guidance on the amount of land potentially available in the City for residential development. The 2017 SHLAA identified a potential supply of large housing sites in the City in the period 2019-2029 of 527 dwellings and an annual average of 74 dwellings on sites under 0.25 hectares, based on past trends. In line with the findings of the SHLAA, the London Plan requires the City of London to deliver 1,460 new homes during the period 2019/20 –2028/29. This includes the 740 units that the London Plan sets as a target to be provided on small sites of less than 0.25 hectares in size over the 2019/20 – 2028/29 period. Beyond 2028/29, the

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London Plan requires boroughs and the City to draw on the capacity work which underpins the London Plan’s target and any local evidence of capacity, as well as rolling forward London Plan small sites estimates, when setting longer term targets.

4.1.9 Different assessment methods provide different figures for local housing need. Using the national standard method for assessing local housing need at the time of preparing this Plan, the City’s minimum annual local housing need figure would be 102.

4.1.10 The City Corporation recognises that the wider housing needs across London support the case for a higher level of housing in the City than indicated by the national standard method. This Local Plan therefore seeks to meet the City of London’s London Plan housing target between 2025/26 and 2029/30 (an average 146 dwellings per annum) and to meet the housing requirement identified by the national standard method from 2030/31 up to 2039/40 (an average of 102 dwellings per annum). This gives a total housing requirement of 1,706 dwellings, and can be expressed over three periods of five years:

X 2025/26 to 2029/30: 686 dwellings

X 2030/31 to 2034/35: 510 dwellings

X 2035/36 to 2039/40: 510 dwellings

4.1.11 Housing delivery in the City is impacted by the volatile nature of the wider London housing market. If past volatile trends continue, new housing delivery in the City is likely to fluctuate from year to year and monitoring and delivery performance

should therefore be assessed against overall delivery both in the period up to 2028/29 for the London Plan and up to 2040 for the City’s wider housing target, rather than on an annual basis. The City Corporation’s housing pipeline shows that approved applications would result in completions for the first five year plan period (2025/26 to 2029/30) of 570 units. This would be below the housing requirement for the first five years of the Plan, which is 686; however, it is expected that sufficient windfall sites would come forward to meet the housing requirement in the City Plan.

The Office for National Statistics project that the City’s permanent residential population will rise to approximately 9,500 by 2040.

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4.1.12

4.1.13

The City Corporation’s Article 4 Direction, which removes permitted development rights for the change of use of offices to residential, the size and commercial character of the City and the priority given to commercial development through London Plan Policy SD5, all mean that new housing development in the City of London has been delivered through ‘windfall’ development rather than through the allocation of sites. City Corporation monitoring shows that in the period 2011/12 to 2022/23, completions and permissions on windfall sites will have delivered an annual average of 175 dwellings per year. It is anticipated that windfalls will continue to deliver sufficient housing to meet the housing requirement in the City Plan.

The City Corporation has committed to play a leading role in tackling the housing shortage in London with a pledge to build hundreds of new social homes and thousands of additional mixed tenure homes. The City Corporation aims to deliver at least 700 new social homes on City-owned land and housing estates with potential for renewal and expansion. Where these homes are outside of the City, the City Corporation normally seeks joint nomination rights with the host borough to ensure that the housing can meet both City of London and host borough housing need. The City Corporation as a strategic landowner across London is seeking to deliver a significant number of additional mixed tenure homes on other sites in partnership with other providers, in recognition of the need for additional housing across London to meet housing needs. The co-location of the City Corporation owned and managed wholesale markets (Smithfield Meat Market, Billingsgate Fish Market and New Spitalfields Fruit

and Vegetable Market) onto one site in Dagenham would provide an opportunity for mixed use redevelopment which could include housing.

Affordable Housing

4.1.14 The City of London can be an expensive area to live in. ONS data shows that the affordability ratio of lower quartile house prices to lower quartile residential earnings in 2021/22 was 14.25, above the London average of 13.46 and the England average of 7.28. The City of London SHMA shows that market rental prices in the City were significantly above the London-wide average or the average for inner London, indicating a significant problem of affordability. Overall, the SHMA suggests affordable dwellings should be maximised to meet affordable housing needs.

Gypsy and traveller accommodation

The London Plan indicates that, in the absence of an up-to-date local gypsy and traveller needs assessment, boroughs should use the need figure set out in Table 4.4 of the London Plan. This table indicates that there is no need for specific gypsy and traveller accommodation in the City of London. The City Corporation will work with the Mayor and London Boroughs in the preparation of a London-wide Gypsy and Traveller Accommodation Needs Assessment.

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Strategic Policy S3: Housing

The City Corporation will protect existing housing and amenity and encourage additional housing concentrated in or near the identified residential areas to meet the City’s needs by:

1. Making provision for a minimum of 1,706 net additional dwellings between 2025/26 and 2039/40:

a. Encouraging new housing development on appropriate sites in or near identified residential areas;

b. Within identified residential areas, prioritising the delivery of affordable housing, co-living, build to rent, hostels, sheltered and extra-care housing, while recognising that for sale market housing would be likely in some instances to have a role to play in making housing development viable;

c. Protecting existing housing where it is of a suitable quality and in a suitable location;

d. Exceptionally, allowing the loss of isolated residential units where there is a poor level of amenity; and

e. Refusing new housing where it would prejudice the primary business function of the City or be contrary to Policy OF2.

2. Ensuring sufficient affordable housing is provided to meet the City’s housing need and contributing to London’s wider housing needs by:

a. ensuring the delivery of a minimum of 50% affordable housing on public sector land;

b. requiring residential developments with the potential for 10 or more units to provide a minimum of 35% affordable housing on-site. Exceptionally, new affordable housing may be provided off-site, or through an equivalent cash in lieu payment, if evidence is provided to the City Corporation’s satisfaction that on-site provision cannot be satisfactorily delivered and is not viable; and

c. providing an appropriate mix of affordable tenures, addressing identified need in the City of London, including social or London affordable rented housing and intermediate housing (living rent, shared ownership or other genuinely affordable products) for rent or sale.

3. Requiring a publicly accessible viability and feasibility assessment to be submitted to justify any proposals that do not meet on-site or off-site affordable housing requirements in this policy. Where policy targets are not able to be met when an application is decided, the City Corporation will require an upwards only review mechanism to be applied to ensure that the benefits of any subsequent uplift in values or reduction in costs are reflected in affordable housing contributions.

4. Ensuring that other new land uses within identified residential areas are compatible with residential amenity.

5. Requiring at least 10% of new dwellings to meet Building Regulation requirement M4(3) ‘wheelchair user dwellings’ and all other new dwellings to meet Building Regulation requirement M4(2) ‘accessible and adaptable dwellings’.

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Reason for the policy

4.2.0 London has a severe housing shortage caused by a growing population and an inadequate supply of housing units. The lack of suitable and affordable housing has been identified by many businesses and business groups as a key constraint to further economic development and investment. The scale of housing proposed will contribute towards meeting local and wider London housing needs whilst still ensuring that the City remains predominantly a commercial office centre of national importance.

4.2.1 New housing in the City may be suitable for people that need to live near their workplace, especially key workers. Suitably located housing in the City can address local housing need (in 2023 there were 977 people on the City Corporation’s housing waiting list) and make a modest contribution to alleviating the housing shortage in London and relieving pressure on the transport system.

4.2.2 The London Plan detailed Policy H11 supports Build to Rent developments. Build to Rent accommodation is specifically designed for renting, is typically owned by institutional investors, offers the potential for longer term returns for investors and importantly, longer lease terms and security for tenants. The City Corporation will support Build to Rent in or near the City’s residential areas and where it meets the detailed requirements in the London Plan.

4.2.3 The City Corporation considers that there is potential within or near the identified residential areas for co-living accommodation

and will encourage such provision on appropriate sites. Co-living accommodation will typically provide private ensuite bedrooms, shared social and kitchen spaces and co-working spaces. They are often suitable for people at early stages of their career.

4.2.4 Where appropriate, the City Corporation will support the appropriate regeneration of residential estates in the City where it will deliver improved living conditions for existing tenants and provide additional housing to meet housing needs.

4.2.5 Many households in London already require accessible or adapted housing to lead dignified and independent lives. More Londoners are living longer and with the incidence of disability increasing with age, older people should have the choice of remaining in their own homes rather than moving to alternative accommodation.

How the policy works

4.2.6 To ensure that permissions for new housing are built out in a timely fashion, developers should provide information on the expected completion date for new residential development. The City Corporation will keep this under review and expect developers to liaise with the Corporation where it becomes apparent that anticipated completion dates cannot be achieved.

4.2.7 There is a presumption in national policy and the London Plan that new affordable housing associated with housing development should be provided on-site. The City Corporation will expect developers to deliver on-site affordable housing in new housing development above the affordable housing threshold

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unless it can be demonstrated through robust assessments that on-site provision is not feasible or viable and that off-site provision would better deliver mixed and inclusive communities than on-site provision.

4.2.8 The City Corporation requires commercial development to make a financial contribution towards off-site affordable housing delivery instead of delivering mixed use development including housing on commercial sites. These contributions are used to deliver new affordable housing principally on City Corporation housing estates within and outside the City of London.

4.2.9 Land within the City is an expensive and limited resource and there is a policy priority to deliver new office floorspace to strengthen its strategically important business role. The City Corporation therefore also works with housing partners to deliver new affordable housing on sites in the City fringe and in neighbouring boroughs, principally on City Corporation-owned housing estates, utilising commuted sums from commercial and housing developments within the City. This approach has been supported by the GLA and has provided affordable housing in locations in or near the City that meet local housing need, whilst making the best use of scarce City land for strategically important commercial activity. Although some affordable housing provision outside the City will continue to be funded by contributions from commercial development in the City, the presumption in this Plan is that new housing development in the City should provide affordable housing on-site.

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4.2.10 The London Plan and the Mayor’s Affordable Housing and Viability Supplementary Planning Guidance (SPG) set a strategic target for 50% of all new homes across London to be affordable, with a minimum threshold of 35% affordable housing on all developments comprising more than 10 units or which have a combined floorspace greater than 1,000m2. The Mayor has adopted a threshold approach to the consideration of applications for housing. Schemes which meet or exceed 35% affordable housing, or 50% on public sector land, are not required to submit viability information. Where an application does not meet these requirements, a viability assessment is required and the development will be subject to viability review as development progresses.

4.2.11 In light of the Mayor’s approach and the shortage of available affordable housing to meet the needs of London’s workforce, a minimum of 35% affordable housing will be required on residential schemes in the City, with an ambition to deliver higher levels of affordable housing where this is viable. On public sector owned land, the higher 50% target will be applied as set out in the London Plan. The presumption is that affordable housing provision should be made on-site and all sites will be expected to deliver at least the minimum required level of affordable housing. Off-site provision or cash in lieu contributions will only be accepted in exceptional cases. In these cases where offsite provision or cash in lieu contributions are considered to be acceptable in principle, agreements for this should provide no financial benefit to the applicant relative to on-site provision and should include review mechanisms in line with the Viability

Tested Route, as set out in the London Plan. This means that the off-site provision, or the financial contribution, will be set at a level which captures the full uplift in value when delivering 100% market housing. This will ensure that the development is not more viable when the affordable housing obligation is satisfied through off-site provision or a cash in lieu payment in comparison to on-site delivery. The level of off-site provision, or the amount of the cash in lieu payment, must be sufficient to deliver at least the same number, size and type of affordable homes that would be required on-site. Further guidance on affordable housing requirements, including the methodology for calculating the level of cash in lieu or off-site contributions required is set out in the City Corporation’s Planning Obligations SPD. This guidance will be kept under review and amended as required to ensure financial contributions keep pace with the cost of delivering affordable housing and will continue to be sufficient to meet the full affordable housing requirements set out in this Plan.

4.2.12 Developments that propose lower levels of affordable housing, or where a developer considers particular circumstances exist that make a policy compliant scheme unviable, will need to be supported by robust viability assessments. These assessments will be published alongside other publicly accessible planning application information on the City Corporation’s website. The City Corporation will commission an independent review of submitted assessments, with the cost being met by the applicant. Consideration of viability and overall levels of affordable housing should take place at pre-application stage to avoid unnecessary delays in the determination of submitted planning applications.

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4.2.13 The requirement for on-site affordable housing in this Plan must be reflected in the price paid for land for residential development in the City. Overpaying for a site is not an appropriate justification for failing to meet the affordable housing target.

4.2.14 Where a viability assessment for a development demonstrates that the Plan’s affordable housing targets cannot be met, the level of contribution should be determined based on the maximum amount of affordable housing at the relevant tenure split that could be provided on-site, as assessed through viability assessments. The detailed wording and timing of these review mechanisms will be determined on a case-by-case basis, having regard to the City Corporation’s SPD and London Plan Guidance prepared by the Mayor of London.

4.2.15 Various types of affordable housing are included within the national definition of affordable housing. The London Plan indicates that a minimum of 30% should be low cost rented homes, including social rent and London affordable rent, and a minimum of 30% should be intermediate products, such as shared ownership. The remaining 40% should be determined by the relevant borough based on identified need. The City’s SHMA found that the need for intermediate housing products was relatively low and that social rented units would most successfully address the City’s affordable housing needs. However, different and innovative forms of affordable housing are being developed and the viability and suitability of particular tenures is likely to change over the Plan period. The tenure of affordable housing will therefore need to be determined on a site-by-site basis, having regard to evidence of need in the City and London Plan

requirements. Developers should liaise with the City Corporation’s Department of Community and Children’s Services to determine an appropriate mix for proposed schemes.

4.2.16 The term ‘intermediate’ housing covers a range of different housing types, including shared ownership products, other lowcost homes for sale and intermediate rent. The City Corporation will take a flexible approach towards intermediate housing, based on the circumstances of each site, and will encourage provision that meets the needs of essential local workers where possible.

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Policy HS1: Location of New Housing

1. New housing will be encouraged on suitable sites in or near identified residential areas. Within these areas a mix of residential, commercial, community, cultural and other uses will be permitted.

2. New housing must not:

a. Prejudice the primary business function of the City. Where proposed development would result in the loss of office floorspace it must meet the requirements of Policy OF2;

b. Inhibit the development potential or business activity in neighbouring commercial buildings and sites; or

c. Result in poor residential amenity within existing and proposed development, including excessive noise or disturbance.

3. Where existing residential estates are being redeveloped, an increased number of residential units will be expected, and the existing affordable housing on-site must be re-provided with at least the equivalent floorspace and tenure of affordable housing. Affordable housing which is re-provided must be offered to existing tenants at rents and service charges equivalent to those in the properties being replaced.

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Reason for the policy

4.3.0 The City is a busy and sometimes noisy place, with a high density of development and business activity at all times during the day and evening, seven days a week which has the potential to cause disturbance to residents. Large parts of the City are unsuitable for new housing because it could have an adverse impact on the City’s primary business role and would be likely to have poor residential amenity. The London Plan indicates that residential development is inappropriate in identified parts of the City to ensure that the current and future potential to assemble sites and deliver office development is not compromised by residential development. Elsewhere in the City, the London Plan indicates that offices and other strategic functions of the Central Activities Zone (CAZ) should be given greater weight in planning terms than residential development, except in wholly residential streets or predominantly residential neighbourhoods.

4.3.1 The City’s policy approach is therefore to encourage new housing to be located within or near the identified residential areas shown in Figure 3, where reasonable residential amenity consistent with a central London location can be achieved. This approach helps to minimise disturbance to residents within the areas, while reducing potential conflict with the development and operation of commercial uses and providing a suitable framework for delivery of additional housing in the City.

4.3.2 Due to the size and unique character of the City, all new housing has previously come forward on ‘windfall’ brownfield sites through the redevelopment or conversion of existing buildings as opportunities arise, within a similar policy framework to the one

in this City Plan. This pattern of housing delivery is projected to continue throughout the life of this new Plan, delivering sufficient new housing over the Plan period to meet London Plan targets and projected local housing need. There is no need to allocate sites in the Local Plan to meet housing targets.

How the policy works

4.3.3 The policy sets out those parts of the City that are suitable for housing, specifically in and around established identified housing areas. In reality, the majority of proposals for new housing in and around these areas would be likely to be on sites occupied by office uses. It is therefore important to read this policy in conjunction with Policy OF2.

4.3.4 Residential development will not normally be permitted along streets which have high levels of noise and air pollution unless robust evidence is submitted which demonstrates how the development will mitigate the impact of that noise and pollution.

4.3.5 Regeneration of housing estates will often involve the redevelopment of existing homes. Regeneration schemes should deliver an increased number of dwellings, where this is compatible with the delivery of a high quality living environment for existing tenants. Existing affordable housing must be replaced at an equivalent tenure and offered to existing tenants at rents and service charges levels equivalent to those in the properties being replaced. Tenants should be involved at all stages of the process and have the opportunity to shape the proposals. Regeneration schemes should seek opportunities to improve social infrastructure and open spaces within the estate. This will help protect established local communities.

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Policy HS2: Loss of housing

The net loss of existing housing units, including the amalgamation of residential units, will not be permitted except where:

1. They provide poor amenity to residents which cannot be improved; or

2. They do not have a separate entrance; or

3. Exceptionally, they are located outside identified residential areas and their loss would enable beneficial development for the business City.

Reason for the policy

4.4.0 The net loss of existing housing units will be resisted because of the limited opportunities to replace it in the City. This policy will also be applied to proposals for the amalgamation of adjoining residential units unless the existing accommodation is of such poor quality that it cannot provide a reasonable standard of amenity, or the proposed amalgamation of no more than two units would meet a clearly identified need for larger family accommodation or for retirement purposes. Exceptionally the net loss of existing housing may be acceptable outside residential areas where the development of offices will have a significant beneficial impact for the City. Isolated residential units outside identified residential areas can suffer poor amenity, such as noise nuisance and other disturbance due to non-residential uses in close proximity, including clubs and pubs, and can be adversely affected by the operation of the business City.

4.4.1 Development sites that have received planning permission for residential units, and which demonstrate that there is a deliverable housing element, will be refused permission for change of use to non-residential use.

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Policy HS3: Residential environment

The amenity of existing residents will be protected by resisting uses that would cause unacceptable disturbance from noise, fumes and smells and vehicle or pedestrian movements.

1. New noise-generating uses should be sited away from residential uses where possible. Where residential and other uses are located within the same development or area, adequate noise mitigation measures must be provided within the new development and, where required, planning conditions will be imposed to protect residential amenity;

2. All development proposals should be designed to minimise overlooking and seek to protect the privacy, daylighting and sunlighting levels to adjacent residential accommodation. Light spill from development that could affect residential areas should be minimised, in line with policy DE8;

3. The cumulative impact of planning applications for individual developments on the amenity of existing residents will be considered.

Reason for the policy

4.5.0 The City is predominately a centre of business, with activity taking place at all times during the day and evenings, 7 days a week. This sometimes results in noise and disturbance to residents from new commercial development and commercial activities nearby. While the City Corporation will endeavour to minimise noise and other disturbance to residents it is inevitable that living in such a densely built-up area will result in some disturbance from a variety of sources, particularly outside the identified residential areas.

4.5.1 The need to minimise overlooking and overshadowing of residential accommodation and minimise light spill where it impacts on residential accommodation, is a consideration in the design and layout of both new residential buildings and other development. However due to the density of development in the City it may not always be possible to entirely avoid any impacts on amenity.

How the policy works

4.5.2 The ‘Agent of Change’ principle makes developers responsible for addressing at the design stage the environmental and other impacts of development on existing neighbouring occupiers. Applicants for development near to existing residential properties should identify potential impacts on residential amenity and set out measures to mitigate those impacts within their Design and Access Statements or other supporting application documents. Where required, planning conditions will be imposed to limit hours of operation and servicing within predominantly residential areas.

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Policy HS4: Housing quality standards

All new housing must be of a high quality design and of a standard that facilitates the health and wellbeing of occupants and neighbouring occupants, and:

1. Meets London Plan housing space standards, including outdoor space standards and amenity space for individual units;

2. Meets standards for Secured by Design or similar certification;

3. Maximises opportunities for providing communal open and leisure space for residents;

Reason for the policy

4.6.0 All new housing, including changes of use to housing from other uses, will be expected to provide well designed, high quality living environments, both internally and externally, incorporating principles of inclusive, secure and sustainable design.

How the policy works

4.6.1 Housing development should comply with the requirements in the London Plan. The layout should incorporate sufficient space and facilities for waste, recycling bins and disabled and cycle parking.

4.6.2 Private outdoor space should be provided in line with London Plan standards. Amenity space for residents could include gardens, roof top gardens/terraces, private balconies and the provision of new sports and recreational facilities. Play space should also be included in line with the requirements in Policy HL8. There should be no distinction between amenity spaces and play areas for private and affordable housing residents. Proposals which seek to restrict access to such areas by affordable housing tenants will be refused.

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Policy HS5: Short term residential letting

1. Short-term letting of permanent residential premises for over 90 days in a calendar year will not normally be permitted as it would reduce the stock of permanent housing in the City and may adversely impact the amenity of existing residents.

2. Short term letting to provide residential accommodation for commercial purposes will not be permitted unless the units are contained within a separate building and will not be permitted if mixed with permanent residential accommodation.

3. Where short term residential letting is permitted for commercial purposes, conditions will be imposed to prevent any later changes to permanent residential use in unsuitable accommodation or locations.

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Reason for the policy

4.7.0 The City of London is primarily a commercial office centre. There is a small stock of permanent residential properties, and this stock needs to be maintained and increased to ensure that the City can continue to meet its assessed housing need. Loss of residential accommodation to short-term letting would reduce the overall stock of permanent housing and the City’s ability to meet its housing need. At the same time, there is some demand for residential accommodation that can be let on a short-term basis to provide for the needs of the City’s business community, particularly for visiting workers. Such short-term accommodation has a role to play but should not be mixed with permanent residential accommodation as it can impact the amenity of neighbours.

How the policy works

4.7.1 Under the Deregulation Act 2015, short-term letting for less than 90 days in a calendar year of domestic premises liable for council tax does not require planning permission. Letting for periods of more than 90 days in a calendar year would require permission.

4.7.2 Short term residential lets of more than 90 days in a calendar year within domestic premises will not normally be permitted as they would reduce the stock of permanent housing in the City, possibly jeopardise housing delivery targets, and adversely impacting on the amenity of existing residents.

4.7.3 Change of use of short term residential letting accommodation to permanent dwellings will normally be permitted where housing and amenity standards are met and the location accords with Policy HS1.

4.7.4 Where short term lets are proposed, the units should be contained in a separate block that is designed and managed for this purpose rather than forming part of a mixed block of short term and permanent residential units or short term residential lets and commercial activities.

4.7.5 The requirement for the provision of affordable housing in Policy S3 applies to the commercial provision of self-contained short let residential accommodation.

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Policy HS6: Student accommodation and hostels

1. Proposals for new Purpose-Built Student Accommodation (PBSA) and hostels should support the City of London’s primary business function and the vibrancy of the Square Mile. They will only be permitted where:

a. They would meet high standards of design and amenity for occupants;

b. There are appropriate amenities for occupants in the local area;

c. They are well connected to relevant further or higher education institutions;

d. They would not prejudice the primary business function of the City, or result in the loss of suitably located and viable office floorspace, contrary to Policy OF2;

e. They would not have an adverse impact on the residential amenity of the area; and

f. They would not involve the loss of permanent residential accommodation.

2. Proposals for PBSA should be supported by identified further or higher educational institutions operating in the City of London or the CAZ.

3. 35% of student accommodation on a site should be secured as affordable student accommodation as defined through the London Plan and associated guidance.

4. The loss of existing student accommodation and hostels to other suitable uses which are in accordance with Local Plan policies will be permitted where there is no longer a need to provide accommodation for CAZ based universities or there is evidence that student accommodation is impacting on residential or business amenity.

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Reason for the policy

4.8.0 The demand for student accommodation in London continues to grow. Higher education provision is a key part of London’s attractiveness as a World City and supports the City of London’s commercial role. However, opportunities for residential development in the City are limited and student accommodation may represent an opportunity lost to meet other housing needs in residential areas.

How the policy works

4.8.1 PBSA should be supported by an identified further or higher educational institution for the housing of its own students. To reduce the need to travel between student accommodation and educational institutions, PBSA providers should seek support from institutions within the City or the CAZ through nomination agreements in line with London Plan requirements. Nomination agreements, secured by s106 agreements, will be required for all affordable student accommodation.

4.8.2 The Housing Delivery Test establishes a national ratio that every 2.5 student bedrooms in PBSA meet the same housing need as one conventional housing unit and contribute to meeting the City’s housing target at this ratio.

4.8.3 Student accommodation, like all development in the Square Mile, should meet the highest standards of accessibility and inclusive design. To help achieve this, the appropriate proportions of accessible rooms should be provided, in line with guidance

issued by the Greater London Authority, which advises that the relevant part of London Plan Policy E10 Part H applies to development proposals for new non-self-contained student accommodation.

4.8.4 Student accommodation should be built to a high standard, including appropriate sunlight and daylight levels.

4.8.5 New student accommodation must not impact adversely on the amenity of existing residents or occupiers, either individually or cumulatively with other student accommodation developments. Developers will be expected to proactively liaise with local residents and businesses to manage the impacts of the development and offer mitigation solutions. Applicants will be required to submit Management Statements detailing how amenity issues will be addressed.

4.8.6 Hostels can contribute to providing accommodation for homeless people. The City Corporation’s Homelessness Strategy outlines how the Corporation will seek to reduce the incidence of rough sleeping in the City through collaborative working with outreach services, health services, the City of London Police, businesses and others. The Strategy seeks to provide appropriate accommodation options for homeless people, including through the use of s106 contributions to deliver new affordable housing or hostels. Hostels may be acceptable within or near identified residential areas, where the amenity of existing occupiers is protected.

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Policy HS7: Older persons housing

1. The City Corporation will aim to ensure there is a sufficient supply of appropriate housing available for older people by:

2. Seeking to provide a minimum of 86 net additional dwellings for older persons between 2023 and 2040 supporting development that meets the specific needs of older people;

3. Supporting development that replaces existing provision for older people with better provision that addresses care needs or fosters independent living;

4. Ensuring new development is inclusive and accessible to all to allow people to continue living in their own homes; and

5. Resisting development that involves the net loss of housing for older people.

Reason for the policy

4.9.0 The City of London has an ageing resident population profile, in line with national demographic trends. Some people will wish to remain in their own homes, with suitable adaptations, or may choose to move into specialist housing which caters for the needs of older people, with varying degrees of support. The City of London SHMA identifies a need for 86 specialist older person units over the life of the Plan, however this figure does not take into account older people who choose to stay in their own homes and access personalised care. The London Plan has an indicative figure of 10 units per year.

How the policy works

4.9.1 The City Corporation will work with developers to encourage the provision of sufficient accommodation suitable for older people, including provision of specialist older persons accommodation, where feasible, to meet identified needs. Housing suitable for older persons, including sheltered housing, is provided by the City Corporation on its land and estates, inside and outside of the City. Provision outside the City may assist in meeting the need for older persons housing for City residents through nomination rights. Specialist older persons housing should deliver affordable housing in line with Policy S3.

Housing 4

Policy HS8: Self and custom housebuilding

The City Corporation will encourage the provision of self and custom build units within large residential schemes.

Reason for the policy

4.10.0 The Self Build and Custom Housing Building Act 2015 requires councils to create a public register of individuals and groups who are interested in acquiring a plot to use for a self-build or custom build home. The City Corporation launched its own register for prospective self-build and custom housebuilding in 2016.

How the policy works

4.10.1 There are no large areas of unused land in the City of London that would provide an opportunity to create serviced building plots. Furthermore, self-build and custom-build are likely to involve lower density development, which would conflict with policies in the Plan which seek to maximise housing supply. Given these constraints, the City Corporation considers that the best prospect for bringing forward suitable land will be in conjunction with large housing developments.