Industrial Capacity

Industrial Capacity
The London Plan

(Spatial Development Strategy for Greater London)
Draft Supplementary Planning Guidance
September 2003
Industrial Capacity
The London Plan

(Spatial Development Strategy for Greater London)
Draft Supplementary Planning Guidance
September 2003
copyright
Greater London Authority
September 2003
Published by:
City Hall
The Queen’s Walk
London SE1 2AA
internet: www.london.gov.uk
enquiries: 020 7983 4100
minicom: 020 7983 4458
ISBN: 1 85261 501X
Cover photograph: Adam Hinton
This publication is printed on recycled paper
Copies of this draft Supplementary Planning Guidance are available from
www.london.gov.uk or by calling 020 7983 4100.
How to give your views

The Mayor’s draft Supplementary Planning Guidance on Industrial Capacity
is published for consultation and your comments are invited. Please reference your
comments to the relevant paragraphs in the draft SPG. Responses must be received
by 5pm 2 January 2004. They should be sent to:
Ken Livingstone
Mayor of London
(Industrial Capacity)
FREEPOST 15799
London
SE1 2BR
Or by email to mayor@london.gov.uk
with ‘Industrial Capacity’ as the subject.
The Mayor’s Supplementary Planning Guidance Industrial Capacity
Contents
SUMMARY......................................................................................................................2
1 INTRODUCTION............................................................................................................... 4
2 BACKGROUND................................................................................................................. 4
3 POLICY CONTEXT............................................................................................................ 6
4 SPG OBJECTIVES ............................................................................................................. 8
5 CHANGING INDUSTRIAL DEMAND AND THE PLAN, MONITOR AND MANAGE
APPROACH .................................................................................................................... 10
6 THE STRATEGIC EMPLOYMENT LOCATIONS FRAMEWORK AND OTHER INDUSTRIAL
PROVISION .................................................................................................................... 13
7 INDUSTRIAL CAPACITY AND MIXED USE DEVELOPMENT........................................... 18
8 QUALITY AND VARIETY OF INDUSTRIAL CAPACITY .................................................... 19
9 SMALL INDUSTRIAL ENTERPRISES............................................................................... 21
10 STORAGE AND DISTRIBUTION...................................................................................... 23
ANNEXES......................................................................................................................24
Annex 1: INDUSTRIAL LAND DEMAND AND SUPPLY TRENDS ........................................... 24
Annex 2: STRATEGIC EMPLOYMENT LOCATIONS FRAMEWORK ........................................ 29
Annex 3: REFERENCES.......................................................................................................... 32
Index of Draft SPG Implementation Points

Policy 3B.6 of the DLP sets out the general approach to provision for industry:.....................6
SPG 1 – Industrial Capacity and Demand: the Plan, Monitor and Manage Approach ............12
SPG 2 – Strategic Employment Locations Framework ...........................................................13
SPG 3 – Locally Significant Industrial Sites............................................................................14
SPG 4 – Other Industrial Sites ...............................................................................................15
SPG 5 – Industrial Capacity and Mixed Use Development .....................................................19
SPG 6 – Quality and Variety of Industrial Capacity................................................................21
SPG 7 – Small Industrial Enterprises ......................................................................................22
SPG 8 – Storage and distribution ..........................................................................................23
1
Industrial Capacity The Mayor’s Supplementary Planning Guidance
SUMMARY
The long term decline in London’s manufacturing industries is abating, falling from an annual
average of –24,000 jobs over the last 30 years to an expected –5,000 jobs pa to 2016. A
modest resurgence in warehousing employment is anticipated, reversing the historic –1,500
jobs pa decline to an increase of nearly 1,000 pa. While the Standard Industrial Classes for
manufacturing and wholesale distribution employment do not cover all potential occupiers of
industrial land, used with other indicators they provide a reasonable proxy for industrial
demand. On past trends, these together suggest that there could be ‘churning’ annual
demand for 55 ha of industrial land pa set in the context of a long term reduction in demand
approximating to 30 – 50 ha pa.
In line with PPG 12 this Supplementary Planning Guidance (SPG) does not propose new
policies but supplements those of the draft London Plan (DLP) to:
• ensure that there is an adequate stock of industrial employment capacity to meet

the future needs of different types of industry in different parts of London,
including that for good quality and affordable space.
• plan, monitor and manage the release of genuinely surplus industrial land so that
it can better contribute to strategic and local planning objectives, especially
those to provide more housing and particularly affordable housing. In
appropriate locations where it can contribute to town centre renewal, offices,
leisure and retailing as well as high density housing will be appropriate. However,
out- of- centre retail and leisure uses will continue to be strongly resisted.
There are some 7,000 ha of industrial land in London. Subject to regular review of changing
demand and supply, this SPG and the DLP reaffirm the effective historic policy to sustain the
strategic reservoir of industrial capacity (4,400 ha) in designated Strategic Employment
Locations (SELs). More than two thirds of this will be protected as Preferred Industrial
Locations (PILs) to meet the needs of industries which, to be competitive, do not place a
high premium on an attractive environment, though they may need infrastructure and other
sorts of improvements. The remainder will be protected in Industrial Business Parks (IBPs)
offering a higher quality environment.
Drawing on a range of DLP and national policies, the SPG encourages owners and occupiers
of industrial land, as well as the LDA, boroughs and other relevant agencies, to manage and
invest in this capacity to meet the changing needs of different types of industry. To support
this, mixed use, higher density re-development of some Strategic Employment Locations
close to town centres and public transport nodes is encouraged providing it does not
compromise DLP policy 3B.6 and capacity to meet London’s future industrial needs. To
ensure that proposed alterations to national policy on industrial land use change are
effectively coordinated in London, the SPG also provides guidance to Boroughs on
identifying in Sub Regional Development Frameworks those SELs, or parts of SELs, which
could be consolidated through the first review of the London Plan. Neither intensification
nor consolidation should lead to a net loss of capacity to accommodate industrial
employment or compromise strategic and local housing policies. Such development must
fulfil stringent design criteria to secure a harmonious mix of activities and a safe, attractive
environment for all uses.
The SPG supports boroughs in identifying and protecting locally important industrial areas
outside the SEL framework providing their UDPs demonstrate that this is justified by
demand. Most of the change in the industrial stock will therefore take place among the
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remaining sites outside the SEL and UDP frameworks. The SPG recognises that cumulatively
these will still be strategically as well as locally important for industry. It therefore provides
geographically sensitive, strategic, local and market based guidelines to be refined by
boroughs to manage the supply of these sites in the light of local circumstances and
demands. The SPG also provides guidance on enhancing the quality and variety of industrial
provision and to meet the specific needs of small firms and warehousing.
3
1 INTRODUCTION
1.1 The draft London Plan (DLP) recognises that though manufacturing industry and
wholesale distribution are relatively small sectors, they have a significant role in the
London economy. They are also experiencing considerable change. The DLP outlines
the contribution these sectors can make to achieve its wider objectives. In Policy 3B.6
it promotes Strategic Employment Locations (SELs) as London’s strategic reservoir of
industrial development capacity to accommodate industry and other activities with
similar land use needs and requires boroughs to manage the protection, release or
enhancement of sites outside the SELs.
1.2 Drawing on the procedures and substantive issues addressed by national guidance,
this SPG details the broad policies and principles in the DLP which bear on provision
for industry but does not propose new policy. The national procedural context for
the SPG is set by PPG12 and the more substantive, national policy context by
PPGs 1, 3, 4, 11, RPG 9 and Circular 1/2000 as well as the wider urban renaissance
agenda outlined in ‘Our Towns and Cities: the Future’ and the ‘Sustainable
Communities – Delivering Through Planning’. An SPG is a material planning
consideration. It will inform the Mayor’s planning decisions and should be taken into
account by boroughs and other agencies concerned with the use and enhancement of
London’s industrial land.
2 BACKGROUND
2.1 Historically, industrial capacity was used mainly to accommodate the manufacturing
and wholesale distribution sectors. In the last 30 years manufacturing has changed
from providing over a fifth of London’s employment to the point where it accounts
now for only 7%. This loss of nearly three quarters of a million jobs was the single
most important reason why, until relatively recently, overall employment in London
declined. However, by the mid 1990s the decline in manufacturing employment had
abated. While long term growth is not expected in the future, neither is it anticipated
that the historic rate of decline will resume. Consultants Volterra forecast a loss of
82,000 jobs from the 2000 total of 328,0001. The anticipated rate of decline in
manufacturing is due not so much to an expected renaissance in the sector as a
reflection of there now being so fewer jobs to be lost.
2.2 The reasons for the historic decline reflect macro economic factors exacerbated in
London by higher costs and competing land uses. However, the process of change
also entailed some restructuring among the industries which still find London a
competitive location. This is partly because of accessibility to a regional market which
is uniquely large, wealthy and compact. It also reflects innovation, changing
techniques and specialisation as industries move towards the production of higher
value goods or become more closely associated with services e.g. through an
emphasis on research, catering or the leisure market.
2.3 Traditional distinctions between production, assembly, distribution and office-based

activities in the manufacturing sector are breaking down. ‘Only about six in ten of
those employed in London’s manufacturing sector work at establishments whose
main function is manufacturing activity’2. The flexibility in the Use Classes and
General Development Orders supports this. In the past such flexibility gave rise to
concern that land would change from low value industrial to high value office uses to
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the extent that industrial capacity in London would be compromised. However, while
this was once the case in some areas, more sustained sources of loss have been to
retailing and housing.
2.4 Productivity in manufacturing is now above that in some service industries, its
contribution to London’s GDP is disproportionately high (11% of the total, though
this is partly a reflection of the way in which statistics are recorded) and it is the
second most important source of exports from the capital3. The Economic
Development Strategy highlights a range of sub-sectors with particular growth
potential and needs (see paragraph 8.2 of this SPG).
2.5 Although a smaller employer than manufacturing, wholesale distribution has been less
susceptible to decline. Employment increased slightly from the mid 1990s to 275,000
in 2000 and is forecast to expand by 14,000 by 2016. The nature of wholesale
distribution has changed considerably over the last 30 years as logistics have become
more sophisticated in response to global trends and to meet the needs of the large
and complex London market. The industry is particularly affected by customer
concerns for ‘just in time delivery’ and those of the wider public for the
environmental impact of freight distribution.
2.6 Historic policy approaches to warehouse provision have been coloured by its
employment densities. However, some wholesale distribution employment densities
can approach those of some manufacturing industries, especially when associated
with related assembly, packaging or office employment. More importantly,
distribution serving a city region of over seven million people performs a vital
economic function as well as providing modern, economically sustainable
employment opportunities. In the right location and especially when associated with
appropriate transport management and inter-modal transfer arrangements, it can also
contribute to broader sustainability objectives. Guidelines on the relationship
between transport and freight are set out in the Transport Strategy as well as the
DLP. Supplementary Planning Guidance, complementary to this SPG and informing
DLP Policy 3.C3 will be produced to address the land use and environmental
implications of new and improved transport provision. This SPG will also complement
the Mayor’s proposals to safeguard wharves on the River Thames4.
2.7 Definitional issues are raised in addressing both the demand and supply of industrial
land. On the land supply side, the B1(b), B1(c), B2 and B8 Use Classes do not include
all potential users of industrial land. Conversely, some of these classes can
accommodate what are essentially office based rather than production activities.
Moreover, the General Development Order allows changes between these uses and
‘pure offices’ (B1(a)). The Strategic Employment Locations framework outlined in
Annex 2 and Figure 1 seeks to accommodate industries of different types,
recognizing that they will have different spatial and environmental requirements. On
the demand side, the manufacturing and wholesale distribution Standard Industrial
Categories (SICs) exclude activities which occupy industrial land. Conversely, they
include others which are highly unlikely to occupy such land e.g. larger firms in
central London classified as manufacturing but which are probably headquarters
offices. The consensus among the demand side studies cited in paragraph 2.6 of
Annex 1 suggests that these SICs are reasonable, pragmatic proxies for overall
industrial demand.
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2.8 Background justification for this SPG, including some material which updates that
which informed preparation of the draft London Plan, is set out in Annex 1.
3 POLICY CONTEXT
3.1 Dated, national guidance (PPG 4) has been refined over time to address the unique
issues facing provision for industry in London5. The DLP builds on these refinements.
It too recognises that long term industrial decline has left London with both an
overall surplus of industrial development capacity and, in some places, a shortage of
affordable provision of different types for firms which still find London a competitive
industrial location. Even more than in the country as a whole, small businesses
dominate the industrial sector in London. Improving quality of provision remains a
key concern but there is also a need for ‘yard and shed’ based, lower order activities.
The DLP refines the established policy distinction between local and strategic
industrial capacity. More generally, the DLP underscores the importance to London of
national policy (PPG 1, 3, 11, 12 and RPG 9) to review non-housing allocations and
consider whether some might be better used for housing or mixed use development,
to intensify development in appropriate locations, to coordinate economic
development and planning activities and to foster mixed-use development.
3.2 This SPG is supported by recent statements by the Chancellor and the Office of the
Deputy Prime Minister. In general terms, government ‘will propose that local
authorities should allow land allocated for industrial or commercial use in their
development plans, and redundant buildings, to be used for housing or mixed use
development unless a convincing case for retention can be made6’. More specifically,
it will seek ‘expeditious and sympathetic handling of planning proposals which
concern land allocated for industrial or commercial use but which is no longer needed
for such use7’. Government proposes that boroughs ‘should consider such planning
applications favourably unless’ they compromise PPG 3, RPG or up to-date
development plan policies. There is particular concern that such proposals should not
lead to over supply of housing (very unlikely in London) and that they should not
undermine demonstrable, realistic prospects of land being taken up for
industry/commerce or regional and local strategies for economic development and
regeneration.
Policy 3B.6 of the DLP sets out the general approach to provision
for industry:
• ‘With the LDA, boroughs and other relevant partners the Mayor will
promote and manage the varied industrial offer of the Strategic
Employment Locations (SEL) set out in Map 3B.1 and the Strategic
Employment Locations Annex as London’s strategic reservoir of
industrial capacity’
• ‘Boroughs should identify SELs in UDPs, and develop local criteria to
manage the protection, release or enhancement of industrial sites
outside the SELs, taking account of the strategic criteria set out in
Supplementary Guidance’.
3.3 The DLP notes the links between manufacturing and other sectors, the relative
dynamics between manufacturing and wholesale distribution employment and
highlights the scope for growth in high value added and design led manufacturing. It
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outlines the scale of industrial capacity in London (6,900 ha), cites the estimate of
industrial land release expected at the time the DLP was prepared (32 ha pa) and
notes that ‘because of constraints on the quality, availability and nature of current
supply, there may be local shortfalls in quality modern floorspace and readily available
development land, particularly in parts of West and South London. This puts a
premium on integrated action by the LDA and other relevant agencies to bring
forward the most attractive sites at a time when the planning process must manage
selective release of strategically surplus capacity to other uses’ paragraph 3B.31. ‘To
protect land for industry, the Mayor will promote the Strategic Employment Locations
framework to reconcile demand and supply and take account of industry’s needs in
terms of clustering, capacity, environment, accessibility and cost requirements
through two basic types of location Industrial Business Parks and Preferred Industrial
Locations’.
3.4 This SPG refines these industry specific and, where relevant, more general DLP policy
themes for application to industrial provision in London. It reflects not just industrial
objectives but also the broader concerns of the DLP. Of particular relevance is the
need to foster more sustainable forms of development (especially DLP Policies 3C.1,
4A.14, 4B.1, 4B.3, 4 B.7, BR16 – 18) and to meet the challenges of economic and
population growth, especially the need for additional housing (DLP Policies 3A.1, 2,
5). Thus, industrial land policy seeks a closer relationship between public transport
accessibility and the need to secure more efficient use of development capacity and
greater diversity of land uses. This does not mean that the sequential test can be
waived for out of centre leisure and retail facilities proposed on industrial areas
(DLP Policy 3D.2). However, it can mean that redevelopment of industrial sites in
appropriate locations can accommodate work space, housing and some other
activities providing that an attractive and safe environment can be created for all,
that there is no net loss in industrial employment capacity (DLP Policies 3B.6, 4B.1)
and that the thrust of the key industrial policy (3B.6) is not compromised.
3.5 The SPG acknowledges that strategic policy cannot and should not cover isolated
small sites specifically – this must be a borough matter. Strategic policy guidance can,
however, provide criteria for refinement at local level to guide their development in
the light of local circumstances. The main thrust of strategic policy must be
concerned for the overall relationship between industrial demand and supply and with
the main concentrations of industrial development capacity.
Figure 1 Strategic Employment Locations (London Plan Map 3B.1)
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3.6 The larger concentrations, called Strategic Employment Locations (SEL) in the DLP,
are mostly over 20 ha in size. However, in some areas, especially parts of West and
South London (see paragraph 6.11), where there is particular pressure on industrial
land, smaller sites e.g. of 10 ha, can be of strategic importance. To meet the needs of
different types of industries, the SELs are divided into two groups:
• Preferred Industrial Locations (PILs), which are suitable for firms which do
not place a high premium on environmental quality. These usually fall within the
B1 (c), B2 and B 8 Use Classes. PILs will not normally be suitable for B1(a) and
B1(b) uses, although some ancillary B1(a) use is acceptable and some transfer
between these classes may be inevitable under the General Development Order.
PILs will not normally be suitable locations for large scale B1(a) office
development. Nevertheless, they may be appropriate for other uses of an
industrial nature, including some of those classified as sui generis e.g. car
breaking, metal re-cycling, aggregate processing, bus garages, iron and steel
pre-fabrication. However, this cannot be taken as a general policy position, not
least because, by their nature, sui generis uses must be treated on their merits.
• Industrial Business Parks (IBPs) are for firms which need better quality
surroundings. These are usually B1 (b), B1 (c) and high value added B2 activities,
require significantly less heavy goods access and are able to relate more
harmoniously with neighbouring uses than those in PILs. IBPs are not intended
for primarily B1(a) office development. Where B1(a) office development is
proposed on an Industrial Business Park, this should not jeopardise local
provision for B1(b) and B1(c) accommodation, where there is demand for these
uses. Any B1(a) proposal, including redevelopment of existing offices, should
comply with the DLP’s office policies, particularly in terms of location and public
transport access. Proposals for science and technology parks are addressed by
DLP policy 3B.4
3.7 The management regimes, regeneration needs, branding and offer of each category
differ and there are usually differences in road access, public transport and
infrastructure requirements, especially for locations with a strong wholesale
distribution function.
3.8 Historic strategic planning policy has been concerned primarily to protect all
designated SEL from pressures for change to other uses. In this it has been largely
successful8. Though the revised SEL framework in the DLP represents a slight
contraction (3%) on the original to reflect changing market conditions, most of the
historic change from industrial to other uses has been among smaller sites outside the
SEL framework. Historically, these were subject to relatively crude, criteria based,
strategic policies, which were supposed to be refined for local application. Through
the DLP this SPG introduces more sensitive criteria and the Mayor’s UDP
conformance powers enables them to be implemented more consistently.
4 SPG OBJECTIVES
4.1 The objectives of this SPG are to supplement and to provide detailed guidance as to
how the broad policies of the DLP should manage industrial development capacity. In
particular, the SPG seeks to:
8
• ensure that sufficient land is available to meet future industrial needs, including
those of existing firms, and
• bring genuinely surplus industrial land back into more active uses to meet the
wider objectives of the DLP, especially those to meet housing and other needs.
4.2 To do this the SPG refines the DLP’s policies and national guidance to:
• provide a geographical framework for the LDA and other partners to identify and
promote the supply of sites of appropriate quality needed by different occupiers,
as well as guiding the release of surplus land for other uses. In general, and
subject to local refinements, this will entail retaining much of the capacity in
West and parts of Central and South London and carefully managing the release
of surplus capacity elsewhere, especially in East London;
• support partnership working, to provide choice and flexibility to meet the
requirements of different types of developer and occupier, including small and
medium sized enterprises (SMEs) and to provide strategic support through the
planning system for protection of the best industrial land sufficient to meet
demand;
• manage pressures for changes from industrial to other land uses in different
types of location, including protection of small, locally viable industrial sites;
• more closely reconcile the relationship between demand and supply of industrial
land. In the longer term, this will entail bringing the rate of change in industrial
capacity closer to that of employment – possibly reducing the rate of industrial
land loss to half to two thirds of that recorded during the early 1990s.
• promote realistic, balanced land-use policies including release of land for other
purposes where there is no demonstrable demand for continued industrial use.
• promote a sub-regional approach to industrial land policy, with boroughs co-
ordinating policy and economic development initiatives;
• apply national and London-wide urban renaissance principles to encourage more
sustainable use of industrial land by fostering higher density and, where
appropriate, a wider mix of uses where these are mutually compatible and can
produce a good quality environment and sustain or enhance provision for
business.
• encourage planning and design to achieve better integration of industrial areas
into the fabric of the city, resolving tensions between uses and enhancing the
security and permeability of industrial areas for walkers and cyclists as well as
business.
• promote active management of the stock of industrial land and monitoring of
industrial demand and supply to inform strategic and local policy;
• contribute to an ongoing review of the overall geographical framework for
strategic and local planning policy across London in the light of changing market
trends.
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5 CHANGING INDUSTRIAL DEMAND AND THE PLAN, MONITOR AND

MANAGE APPROACH
5.1 This SPG has been designed around government and the draft London Plan’s
approach to ‘planning, monitoring and managing’ development.
5.2 ‘Plan’: The ‘planning’ element of this trinity has three main components:
• the strategic reservoir of industrial land – a resource which must be sustained for
the short to medium term but nevertheless must itself be subject to periodic
review to reconcile demand and supply in the longer term.
• locally significant reserves of land, protection of which needs to be justified on a
sub-regional basis.
• smaller sites which historically have been particularly susceptible to change. In
some circumstances they can better meet the DLP’s objectives in new uses but in
others will have a continuing local and strategic role as industry. They will
continue to be the areas of greatest change.
5.3 The SPG also contains specific guidance on mixed development, the quality and
variety of industrial development and specific provision for small and medium sized
enterprises and storage and distribution.
5.4 ‘Monitor’: Sensitive and authoritative monitoring has a crucial role to play in a
situation where overall land supply in London is finite, competing demands on it are
strong and policy has to help sustain a sector which historically faced long term
structural decline but which now appears to be consolidating and for which there is
still strategic over-provision. In such dynamic circumstances, timely information is
essential to inform the management of land and keep policy responsive to changes in
the relationships between these factors.
5.5 To understand the balance between the three main components of the SPG outlined
in paragraph 5.2, their differing susceptibilities to change and the geographical
variations in these differences requires data on different temporal and spatial scales.
At the broadest geographical scale, it is necessary to know that for the medium to
long term industrial demand across London is continuing to decline sufficiently to
justify release of 30 – 50 ha pa (Annex 2 2.6-2.8). Indicative sub regional
distributions of these figures are shown in Annex 1, Table 2. Similarly, it will be
essential to check that within this trend, there is continuing ‘churning’ demand for
55 ha pa for new development. These will be key monitoring benchmarks. To test
them locally and strategically will require a robust understanding of both demand and
supply, particularly outside the SELs where, according to policy, most of the change
should be taking place.
5.6 For the SPG to be robust in the face of challenge, borough and strategic monitoring
systems must demonstrate that policy is working as anticipated. This is likely to entail
pooling monitoring resources and information on a sub-regional basis.
5.7 Appropriate sub-regional and borough-level benchmarks to inform policy for

industrial land could include:
• Overall stock of industrial land and premises
10
• Gross new industrial completions;

• Gross take-up of industrial land and premises;
• Industrial property changes of use and demolitions;
• Supply of vacant industrial land and premises;
• Industrial rental values, land values, yields and market perceptions
• Businesses’ demands.
5.8 Just as the most recent review led to a 3% reduction in overall area covered by the
SEL framework and informed boroughs in the approach to be taken to future
provision, cumulative assessment of the changes suggested by these monitoring
indicators will inform longer term reviews of the core SEL and local industrial
capacity. Preparation of Sub Regional Development Frameworks will provide an
opportunity to identify strategically important changes to the SEL so that they can be
addressed in the review of the London Plan (see paragraph 5.12-5.14). Informed by
the criteria in paragraphs 6.9 – 6.15, Boroughs will be expected to follow a similar
course in their UDP reviews.
5.9 ‘Manage’: Research into industrial land demand has stressed the need for active
management in order to improve quality, meet the continually changing needs of
occupiers, and deal with excessive industrial vacancy. The following guidelines are
intended to move towards a strategic framework for the active management of
industrial land in London. Guidance on interpretation of the DLP’s approach to
managing the transfer of surplus industrial land to other uses, mixed-use
development, the quality of development and provision for smaller firms is set out in
paragraphs 6.1 – 10.2.
5.10 Land should be managed to support national and GLA group objectives for business.
In line with PPGs 11 and 12 and the White Paper ‘Our Competitive Future’, the DLP
is integrated with the Mayor’s Economic Development, Transport and other
Strategies and relevant GLA initiatives such as that to secure efficient e-
infrastructure. Both the DLP and this SPG complement the Economic Development
Strategy (EDS) through support for clusters of related activities by protecting
strategically important business locations and ensuring that clustering is a key factor
to be taken into account when managing release of surplus industrial land outside
these locations. The EDS seeks to respond to the needs of businesses, including
SMEs, through business support, training, innovation and through specific
regeneration initiatives which have both spatial and sectoral priorities e.g. for creative
industries. They will complement the DLP’s intention to secure mixed-use
development, including affordable business space, through planning agreements. The
EDS also details the principles of the DLP by recognising and addressing the
relationship between SMEs and Black and Minority Ethnic and local community
enterprise opportunities.
5.11 The DLP and Transport Strategy address the parking and other transport needs of
SMEs within the context of those of London as a whole. This includes working
towards implementation of a coordinated ‘level playing field’ for parking provision
with local authorities adjacent to London.
5.12 In managing and reviewing industrial capacity, including SELs, account should be
taken of the scope for consolidating industrial capacity at particularly appropriate
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locations. Consolidation of SELs, or parts of SELs, is not a policy requirement of the

DLP and this SPG does not seek to introduce new policy. However, in light of
government’s recent proposals9 to stimulate a more active approach to releasing
surplus industrial land, especially for housing, this SPG flags the need to begin work
which will lead to a review of the SEL framework when the London Plan is revised.
SELs and parts of SELs which can be consolidated to support national policy should
be first suggested in Sub Regional Development Frameworks. This exercise must be
coordinated strategically (and structured to minimise ‘hope value’) taking account of
transport and regeneration as well as planning objectives to ensure that London’s
overall future industrial needs are addressed. It is part of the management
requirement set out in the DLP (paragraph 3B.30).
5.13 Consolidation must be informed by an authoritative appreciation of short and longer

term market and policy requirements (see paragraphs 6.9 – 15). It must also be cast
in the context of robust and sensitive relocation arrangements, which ensure that
London jobs, and Londoners’ access to them, are not compromised. Land released as
a result of such consolidation exercises, like that which may be released as a result of
the proposed industrial expansion of London Riverside to serve the Gateway area,
must be re-cycled to meet strategic as well as local priorities. Re-use for housing and
ancillary activities will be the key priority. Borough experience has shown that with
proper planning and management procedures and ‘given the link between population
and employment, new housing is not necessarily the enemy of jobs’10. In exceptional
circumstances, strategically coordinated, earlier releases of land from a SEL
designation may be acceptable for strategic proposals of essential benefit for London
which cannot be planned for or delivered on any other site in Greater London eg
provision for the 2012 Olympic games in line with DLP Policy 3D.6.
5.14 This proposal to begin the process of investigating the scope for industrial
consolidation in the context of Sub Regional Development Frameworks and the
review of the London in no way weakens the objective of DLP policy 3B.6 to secure
an adequate supply of industrial employment capacity. Boroughs, developers and
land owners must take this as a clear statement of principle. Attempts to realise ‘hope
value’ through proposals for unacceptable alternative development of SELs will be
strongly resisted.
SPG 1 – Industrial Capacity and Demand: the Plan, Monitor and

Manage Approach
In implementing Draft London Plan policy, the Mayor will and the LDA,
TfL, boroughs and other partners should:
• adopt a positive ‘plan-monitor-manage’ approach to planning for

industrial land in London to bring demand and supply into closer
harmony;
• use the Sub Regional Development Frameworks to identify and justify
changes to the SELs so that these can be addressed in the review of the
London Plan.
• co-ordinate monitoring of industrial land and policy development on a
sub-regional basis;
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• manage the stock of industrial premises so that it provides a competitive

offer for different types of occupier. This will entail both improving the
quality of provision to meet users’ different needs, including those of
SMEs and clusters of related activities and maintaining lower cost
capacity or making provision for those requiring affordable business
premises.
• initiate a review of the potential to consolidate industry in appropriate
locations and establish effective re-location arrangements in the context
of national and regional policy, especially that to secure capacity to
meet London’s future industrial needs. The GLA group will coordinate
this process as it affects SELs.
6 THE STRATEGIC EMPLOYMENT LOCATIONS FRAMEWORK AND OTHER

INDUSTRIAL PROVISION
6.1 Strategic Employment Locations: As an evolving policy construct, the Strategic
Employment Locations Framework has proved a valuable tool in achieving one of the
objectives of this SPG - protecting London’s principal industrial locations. Very little
industrial land within the SEL Framework has transferred to other land uses since
1994. In being so successful, the Framework could run the risk of fossilising land as
‘industrial’ when there is no longer demand for this use. However, the requirement to
monitor closely demand and supply relationships outlined above and to review the
framework in light of these will keep the framework in tune with market requirements
and broader planning objectives.
6.2 Historic policy towards the SEL Framework was not very successful at improving the
quality of industrial sites in these areas. The scope for much more closely integrated
planning, regeneration and transport activity now provided by the GLA group as a
whole, coupled with a strong commitment to partnership working will address this
historic shortcoming.
6.3 If the pan London approach to industrial capacity is to be effective, it must be

implemented and sustained by boroughs consistently. Departures from it will send
confused messages to developers and tend to increase the ‘hope value’ of land
making it uncompetitive for industry or even lead to it being kept vacant and out of
productive, industrial use. Changes to the SEL framework shown in Figure 1 and in
Annex 2 should therefore only be undertaken in the light of a strategic review of
industrial demand and supply.
SPG 2 – Strategic Employment Locations Framework

In implementing Draft London Plan policy, the Mayor will and the LDA,
TfL, boroughs and others partners should:
• where relevant in their strategies, Unitary Development and other plans,

identify the components of the SEL Framework shown in Figure 1 and
Annex 2 of this SPG.
• promote the SELs as the prime locations for industrial activity in
London.
13
• through co-ordinated investment, regeneration initiatives, transport and

environmental improvements and the use of planning agreements,
manage the differing offers of PILs and IBPs and provide local planning
guidelines to meet the needs of different types of industry appropriate
to each as indicated in paragraph 3.6.
• other than as part of a strategically coordinated process o mixed use
intensification (paragraphs 7.1 –7.7) development of non-business uses
within the SEL should be resisted except where they provide local, small
scale, ‘walk to’ services for industrial occupiers e.g. workplace crèches.
6.4 In many areas of London smaller industrial sites, which lie outside the SEL
Framework, can be important in providing local employment and economic diversity.
This SPG seeks to protect such sites for industrial activity where they continue to
meet industrial requirements. However, it also recognises that historic policy was
unrealistic in seeking to prevent the transfer to other uses of all industrial land across
whole sub-regions of London. This applies even to parts of South and West London
and of the fringe of Central London where market reports suggest that there is
general but not universal shortage of useable industrial land.
6.5 This SPG recognises that demand and supply of industrial land remains unevenly
distributed throughout London. Following DLP paragraph 3B. 30 it provides guidance
on redressing these imbalances, recognising that outside the SEL some industrial land
will still be transferred to other uses in areas of general shortage, e.g. in parts of West
and South London and of the Central London fringe, though most transfers will take
place elsewhere. This requires a more flexible, criteria-based approach to industrial
capacity than was provided by historic policy and one which is more rigorously
attuned to changes in market relationships. Paragraphs 5.4-5.6 underscore the need
for regular, strategically coordinated reviews of demand and supply of industrial
capacity.
6.6 Locally Significant Industrial Sites: Outside the SEL Framework, boroughs should
designate on UDP Proposals Maps those sites of particular local importance which
they wish to protect for industrial users. Where these sites are identified on Proposals
Maps and are afforded the same policy protection in the UDP as those sites within
the SEL Framework, there will be strategic support for boroughs to resist their
development for non-industrial uses. However, to ensure that land so protected will
be used efficiently, UDPs should draw on the criteria outlined in paragraphs 6.9 –
6.15 and must demonstrate that there is local demand for them in industrial use.
Particular attention should be paid to retaining adequate capacity to meet the
requirements of firms servicing Central London which require sites within or close to
its fringe.
SPG 3 – Locally Significant Industrial Sites

In implementing Draft London plan policy boroughs when reviewing UDPs,
should:
• protect locally important, viable industrial sites, which lie outside the
SEL Framework after testing them in the light of evidence of local and
strategic demand (paragraphs 6.9 – 6.11) and against the criteria in
14
paragraphs 6.12 – 6.15. These sites should be identified on UDP

proposals maps.
6.7 Other Industrial Sites: Informed by guidelines in this SPG (paragraphs 6.9 – 6.15),
boroughs should use flexible, criteria based policies to address any remaining
industrial sites not shown on Proposals Maps and lying outside the SEL Framework.
These policies will guide management of the sites for industrial and other purposes
taking into account strategic and local planning concerns as well as market
conditions. To inform application of DLP policy 3B.6 this SPG seeks to retain in
industrial use higher quality industrial sites and those of poorer quality which meet a
demonstrable need for low cost accommodation. To support the wider environmental
and land use objectives the DLP (DLP paragraphs 23 – 32) it also seeks the managed
transfer of sites which are genuinely redundant for industrial purposes, and where an
alternative land use is more suitable in planning terms. It is anticipated that these will
be mainly for housing including affordable housing (DLP Policies 3A. 1-2, 6 – 13) or,
if they can be integrated with town centres, also for office, retail, leisure, civic and
other town centre related uses (DLP Policy 3D.1 - 2). Boroughs, in UDPs, should
identify the characteristics of locally valuable industrial sites (including those
providing low cost accommodation), taking account of the nature of the overall
industrial offer within the locality and likely demand from industrial users over the
plan period.
6.8 In view of the cumulative economic importance of small scale industrial sites and the
strategic significance of the after-use of those which are genuinely surplus to
industrial needs, the criteria guidelines to manage ‘Other Industrial Sites’ are a
strategic as well as a local concern. In line with DLP Policy 3B.6 the criteria to be
included in UDPs should be developed by boroughs in the light of local
circumstances, local and strategic industrial market assessments and strategic
coordination guidelines set out in paragraphs 6. 9 – 6.15. As part of this process,
boroughs should co-ordinate monitoring and policy development with neighbouring
boroughs on a sub-regional basis.
SPG 4 – Other Industrial Sites

In implementing Draft London Plan policy, Boroughs when reviewing UDPs,
should:
• develop criteria-based policies to manage the release from or retention

in industrial use of those industrial sites outside the SEL Framework and
not designated on Proposals Maps in the terms of SPG 3 above. Such
policies should take account of demand (paragraphs 6.9 – 6.11) and
the criteria set out in paragraphs 6. 12 – 6.15 below.
• ensure that sites released from industrial use through this policy meet
strategic as well as local needs. The first priority should be to meet the
need for housing including affordable housing. Increasing capacity for
town centre related development will also be important in appropriate
locations.
6.9 In developing policy criteria for industrial sites outside the SEL Framework and not
shown on Proposals Maps, boroughs should take account of the sub-regional
demand and supply of industrial land. In this, they should be informed by groupings
of boroughs to be identified in the published SPG which will provide a broad
indication of borough level industrial demand and the broad policy response to this.
15
The published SPG will recognise that within boroughs (and the general level of
demand indicated for them) there can be marked local differences in demand and
supply of industrial space. It will be for boroughs to justify and address these local
departures from general market conditions prevailing in their areas.
6.10 The groupings set out below were identified by consultants11 in 1999 to reflect the
sub regional balance between industrial land demand and supply suggested by
market experience as well as broader economic indicators. In the short term they will
be reviewed through this consultation process and through research commissioned to
inform it. In the longer term they will be reviewed as part of the monitoring process
proposed above.
6.11 Those boroughs within the ‘ Restrictive Transfer’ category are encouraged to adopt a
particularly restrictive approach to the transfer of industrial sites to other uses. Those
boroughs in the ‘Managed Transfer’ category generally have a greater supply of
vacant industrial sites relative to demand and should generally take a more permissive
approach to transfer. The ‘Limited Transfer’ category is intermediate between the
two. Borough level policies should reflect these local differences in supply and
demand of industrial sites. The City of London is excluded as no significant industrial
land remains there.
Restricted transfer of industrial sites

South Bromley, Croydon, Kingston, Merton, Richmond, Sutton
West Hammersmith & Fulham
Central Westminster, Camden, Kensington & Chelsea, Wandsworth
Limited transfer of poorer industrial sites

West Brent, Harrow, Hillingdon, Hounslow, Ealing
North Barnet, Enfield, Haringey, Waltham Forest
East Hackney, Lewisham, Tower Hamlets
Central Islington, Lambeth, Southwark
Managed transfer of poorer industrial sites

East Barking & Dagenham, Bexley, Havering, Greenwich, Newham, Redbridge
6.12 In developing criteria-based policies, boroughs should seek to retain those sites in
industrial use which the borough considers to be most important for industrial users.
These will generally include the better quality industrial sites, but may also include
poorer quality sites which provide scope for low cost industrial accommodation for
which there is demand. Boroughs should consider the criteria set out below for
inclusion within such policies.
6.13 Strategic Factors, including whether a site:
• meets demonstrable short term demand for industrial development, and / or

strategic long term demand;
16
• is part of a larger area of existing industrial activity, or area designated for

industrial protection;
• offers potential for the in-situ expansion of existing industrial businesses;
• supports local or strategically important clusters of industrial activity;
• meets demand and addresses the particular needs of new or emerging industry
especially those identified in DLP policies 3B.7, 9, 10 and 12 and 4A.3 and 10 eg
waste, energy and recycling, taking account of the proximity principle where
relevant.
• is well located to take advantage of existing or proposed infrastructure or
economic development / regeneration funding;
• offers potential for the provision of small industrial units serving local residential
and commercial areas, particularly where there is little alternative provision in the
local area;
• is needed to accommodate provision for transport in terms of forthcoming
Mayoral guidance on provision for transport and safeguarding river related uses
eg bus garages, boat yards.
• contributes to local employment objectives and local economic diversity.
6.14 Site Characteristics, including whether a site:
• is well located in relation to the strategic highway network or local highway

network, in particular causing minimal traffic impact in residential areas;
• offers potential for transport of goods by rail and/or water transport;
• is located within or adjacent to a town centre, recognising that PPG6 and PPG13
promote high trip generating uses at such locations;
• is well located in relation to public transport facilities, recognising that many
industrial activities have relatively low trip generation and that other land uses
(such as offices, leisure and retail) may be more appropriate in locations with
high public transport accessibility;
• offers potential for 24-hour working, or provides facilities for ‘bad neighbour
uses’ with detriment to residential amenity, being well screened from
neighbouring uses, particularly residential areas;
• offers potential for space intensive activities which do not fall within the ambit of
this SPG and would not, in this location, compromise wider planning objectives.
• provides lower cost industrial accommodation suitable for small, start-up, or
lower-value industrial uses or other businesses important to the local economy;
• provides sufficient space for adequate operational parking and turning space for
goods vehicles.
6.15 Industrial Demand Factors, including whether a site:
• has been adequately marketed at realistic prices for a reasonable period

(normally at least two years) and with potential for industrial redevelopment
where this is required to meet the needs of industrial users;
17
• has been vacant for a considerable period (normally at least two years, and up to
five years in areas of generally strong demand), without realistic prospect of
industrial re-use.
7 INDUSTRIAL CAPACITY AND MIXED USE DEVELOPMENT

7.1 Historic industrial land policy resisted inclusion of non-industrial uses within SEL. This
was partly because of blanket, environmental concerns that industry and other uses
did not mix. It was also because, as higher value activities, other uses in conventional
formats were thought likely to drive out industry and so erode capacity to
accommodate it competitively.
7.2 Despite moves towards ‘cleaner’ industry, geographical separation of uses will still be
required by many of London’s industrial firms if they are to remain competitive. Many
do not need and cannot afford a high quality environment and would not benefit
from being mixed with other activities. Lower density, single use areas with adequate
vehicle access offer these activities the greatest scope for viability in London.
Preferred Industrial Locations and some appropriately located sites outside the SEL
framework will continue to provide the most sustainable home for such activities.
7.3 The external, environmental costs of other types of industrial firm can be less onerous
on potential neighbours. With careful design and branding backed by clear planning
briefs and agreements, provision for these firms can offer greater scope for mixed and
more intensive forms of development. Good public transport access is an essential
pre-requisite for such intensification. TfL can advise on existing and future public
transport accessibility of different locations, including PTAL scores. While vehicular
access will still be needed, this does not have to be as intrusive or exclusive as that
associated with more traditional types of industry. Those activities that place a higher
premium on added value rather than volume are particularly likely to fall into this
category. Those with higher employment densities may get greater benefit from
better public transport provision, which itself can only be viable in higher density
areas.
7.4 Government research and advice12 suggests that industrial uses will usually be
accommodated on the lower floors of mixed developments with other uses above,
though if access issues can be resolved, vertical rather than horizontal separation of
activities may be possible. Most appropriate will be locations where such
developments can be closely integrated with a wider mix of surrounding uses, such as
on the edge of town centres. Though the higher environmental quality of Industrial
Business Parks would seem to make them inherently more suitable for such
development, there may be scope to redevelop and upgrade parts of some Preferred
Industrial Locations in appropriate locations, e.g. on the periphery of PILs near
stations or town centres, especially where there is a barrier separating the area from
the rest of the PIL. These could enable consolidation of more environmentally
sensitive, existing PIL tenants while maintaining the integrity of a local business
cluster. Complementary, sensitive relocation arrangements are likely to be necessary
to avoid loss of industrial employment of different types through the re-development
process.
7.5 The design of industrially led, mixed, higher density re-development should also
ensure that overall there is no net loss of industrial employment capacity within SELs
18
and Locally Significant Industrial Sites (see SPG 3 above). In view of the particular
need to increase housing provision, especially of affordable housing, housing will be
the key other priority on permissible mixed use re-developments. Leisure, retail, civic
and other town centre uses will also be appropriate if the mixed use development can
be integrated with broader proposals for town centre renewal. However, other than to
provide small scale, local convenience services, such uses will not be appropriate
outside town centres.
7.6 Re-development, intensification and selective support for higher density, mixed uses
in these locations must not compromise their offer as the main strategic and local
reservoirs of industrial capacity. Inappropriate re-development of even parts of
industrial sites can compromise the industrial offer of wider areas. This is particularly
important in areas where industrial capacity is in short supply (see paragraph 6.11).
This SPG therefore supports the thrust of the Draft London Plan 3B.6 in underscoring
the prime purpose of SELs which is to ensure an adequate stock of industrial
employment capacity. Mixed-use development should only be permitted where it will
support this central policy objective and support the DLP’s broader objective to
encourage better use of land such as that which can be brought about by mixed use
re-development.
7.7 Without compromising policy to resist inappropriately located retail and leisure
development, provision should be made for small scale, walk to facilities, particularly
A1 and A3 uses and specialist services like crèches, which serve the needs of people
working within industrial areas. Such provision is likely to be particularly important in
larger industrial areas, including SELs.
SPG 5 – Industrial Capacity and Mixed Use Development

In implementing Draft London Plan policy the Mayor will and the LDA, TfL,
boroughs and other partners should:
• identify strategically recognised industrial sites or parts of sites which

have good public transport accessibility, especially those within or on
the edge of town centres, for industry led, higher density, mixed re-
development. This re-development should not incur a significant net loss
of industrial employment capacity or compromise the offer of wider
areas as competitive industrial locations.
• establish robust and sensitive industrial relocation arrangements to
support re-development where necessary.
• where necessary improve provision of small scale, ‘walk to’ amenities
and services including crèches, which serve the needs of people working
within industrial areas.
8 QUALITY AND VARIETY OF INDUSTRIAL CAPACITY

8.1 The poor quality of sites allocated for industrial development is a major concern in
many parts of London. Much of the vacant industrial land in London is unavailable
for development because of various forms of constraint, or because it is unsuitable
for modern industrial purposes. In 1998 it was found that at least 40% of vacant
industrial land had constraints preventing immediate development13.
19
8.2 Improving the quality of industrial sites will require co-ordinated planning,
regeneration and transport actions, with co-operation between boroughs and the
GLA group, especially TfL and the LDA. The short term geographical priority for these
actions is set out in the LDA’s Corporate Plan. That for 2003 – 2006 focuses on Park
Royal/Wembley, London Riverside, the City Fringe, Lower and Upper Lea Valley,
London South Central, Woolwich and North Bexley, Kings Cross/Finsbury Park and
Southhall/Hayes. The LDA also has a broader remit to address the needs of industry
through its business led Production Industries Advisory Commission. In addition it will
target the needs of life science, environmental, ICT and ‘emerging’ sub-sectors. The
Agency will also seek to acquire sites, including compulsorily, which it considers are
key to delivery of its programmes and priorities.
8.3 Innovative approaches may be needed to improve industrial areas and meet the
varied needs of key sub-sectors as well as new forms of production and working,
including, in appropriate locations, genuine live work units. Paragraphs 7.1 –
7.7provide examples of how this may be achieved as part of mixed use
re-development. A pro-active approach to enabling development through planning
agreements both within and outside the SEL framework is likely to be important. The
DLP provides the strategic context for planning agreements in London (Policies 5.3,
5.4 and paragraphs 5.39 – 5.42). Depending on the circumstances of individual
developments they can be used, inter alia, to secure affordable works space as well as
adequate e-infrastructure, transport provision including ‘car clubs’, contributions
towards site assembly and de-contamination and provision for emerging industries
highlighted in the DLP and Economic Development Strategy. Planning agreements
will also be required to secure the balances of uses required to meet the mixed use
requirements of SPG 5, the relocation arrangements and consolidation processes
indicated in SPG 1 and paragraphs 5.12-5.13.
8.4 With some notable exceptions, industrial development has been little affected by
wider objectives to enhance the quality of the urban environment. While exacerbating
development costs must be a concern for industries which find London to be only a
marginally competitive business location, good design does not have to incur these,
especially if it is incorporated from the outset of the development process. The LDA
and the GLA’s Architecture and Urbanism and Planning Decisions Units have some
capacity to advise on this. Design factors which could usefully be taken into account
in this process include:
• sustainable design and construction - further guidance will be provided in the

forthcoming sustainable design and construction SPG
• landscaping – traditionally not a significant concern in industrial development
but modest investment can have a major impact on enhancing the environment
• elevation treatment – imaginative use of new industrial cladding materials can
have significant and cost effective environmental benefits
• site layout – buildings should be integrated into their context.
• designing out crime – draw on police design advisers to address lighting,
circulation and security issues
20
• intensification – maximise site attractiveness and uplifts in land values generated

by proximity to transport infrastructure through higher density, higher quality re-
development
• settings - maximise site attractiveness and uplifts in land values generated by
nearby, higher value or more attractive uses/surroundings through re-
development
• surroundings - design should complement and enhance the surrounding uses
8.5 In improving the quality of industrial provision account should also be taken of the
needs of firms which make important contributions to the London economy but have
negative environmental impacts. Boroughs should therefore ensure that there is
adequate capacity for ‘difficult neighbour’ industrial uses in locations where they will
not detract from the environment of other activities. These will usually be in PILs.
Many of the difficulties which such industries have traditionally caused, can be
avoided through careful design of facilities and their relationship with surrounding
areas.
SPG 6 – Quality and Variety of Industrial Capacity

In implementing Draft London Plan policy the Mayor will and boroughs,
the LDA, TfL and other partners should:
• seek to enhance the operating environment within and around all viable
industrial areas.
• subject to securing low cost premises to meet local needs, encourage the
re-development of London’s industrial areas to enhance their offer as
competitive locations attractive to modern industry.
• seek imaginative, sensitive design and investment solutions which do
not entail a net loss of industrial employment capacity, which make
more efficient use of space and which enhance the environment within
and around industrial areas.
• depending on local circumstances planning agreements are likely to be
necessary to secure the DLP objectives detailed in this SPG including
premises for different types of industrial occupier, transport, e-related
and other infrastructure, contributions towards site assembly and
decontamination and meeting the needs of specialist industries.
• make provision for demand for ‘difficult neighbour’ industrial uses in
environmentally acceptable locations, normally within PILs, and through
good design ensure that they do not compromise the viability of other
activities or the regeneration potential of the area. Proposals for waste
facilities should accord with the policies of the Mayor’s London Plan and
Waste Strategy.
9 SMALL INDUSTRIAL ENTERPRISES

9.1 The Mayor’s DLP and Economic Development Strategy recognise that most industrial
firms in London are small and many may suffer from inadequate or inappropriate
accommodation. This SPG seeks to protect viable industrial sites which can
accommodate small industrial units suitable for start-ups and small industrial
21
businesses. Where large, higher value schemes are proposed and there is
demonstrable need for smaller or affordable industrial premises, boroughs should
draw on national and metropolitan mixed use policy to seek planning agreements to
secure provision of these as part of mixed use schemes.
SPG 7 – Small Industrial Enterprises

In implementing Draft London Plan policy the Mayor will and boroughs,
the LDA, TfL and other partners should:
• protect industrial sites which meet demonstrable demand for lower cost
industrial accommodation.
• promote the provision of small industrial units suitable for small
businesses and start-up companies.
• secure provision of small and affordable industrial units in appropriate
locations as part of larger mixed use schemes, including commercial
developments and residential schemes where careful siting, design and
access arrangements can satisfactorily overcome environmental
concerns.
22
10 STORAGE AND DISTRIBUTION

10.1 In the past there has been a view that warehouse development in general industrial
areas should be resisted on the grounds that employment opportunities are fewer and
inferior to those provided by manufacturing firms. However, distribution functions
comprise a significant element of much general industrial activity in London and are
expected to become more important. This is diminishing traditional differences in
employment density between production and distribution. More specifically wholesale
distribution facilities, such as large warehouses, also provide a key economic service
for the capital, even though they usually have low employment densities.
10.2 Planning policy must therefore take a positive approach to provision for distribution
in the context of the overall objectives of the DLP. Heavy traffic generators should be
steered away from environmentally sensitive locations to those where their impacts
can be minimized, usually in Preferred Industrial Locations with easy access to the
strategic road network. In line with sustainable transport policy set out in the DLP,
boroughs should promote facilities at locations which allow the movement of goods
by rail or water. Where boroughs do seek to restrict the development of warehousing
facilities within industrial areas they should provide reasoned justification for this
restriction, particularly where these restrictions apply within PILs. At a more strategic
level, the review of potential to consolidate SELs proposed in paragraphs 5.12 – 5.14
will provide an opportunity to coordinate warehousing provision to more effectively
meet wholesale distribution needs across London.
SPG 8 – Storage and distribution

In implementing London Plan policy the Mayor will and boroughs, the LDA,
TfL and other partners should:
• encourage distribution facilities which will promote the movement of

goods by rail or water.
• in light of local and strategic assessments of demand, ensure that
provision is made for large scale distribution activities in environmentally
acceptable Preferred Industrial Locations with good access to the
strategic road network, and generally resist it elsewhere.
• generally accommodate smaller warehouse facilities and mixed
industrial / warehouse units within the SEL in line with strategic road
capacity. Such provision on industrial sites outside the SEL should not
compromise the local environment, access or road capacity or broader
concerns to secure intensification at appropriate locations.
23
ANNEXES
Annex 1:
INDUSTRIAL LAND DEMAND AND SUPPLY TRENDS
1 INDUSTRIAL LAND SUPPLY
1.1 Comparable information on trends in the overall stock of industrial land is not
available. The most up to date stock data14 shows that London contains 12.1 mll sq m
of industrial floorspace and 15.6 mll sq m of warehousing space, both concentrated
in outer London (Figures 2 and 3).
1.2 A partial data time series shows availability of industrial land over the decade to
199815. This suggests that available land increased from 1,300 ha in 1987 to 1,600 ha
in 1991 before declining to 1,200 ha in 1995 and 900 ha in 1998. LPAC estimated
that between 1991 and 1998 releases to non-industrial uses averaged 75 ha pa. It
calculated that only 2% of this loss was from sites within the Strategic Employment
Locations. Much of the loss was concentrated in Inner East London. Considerable
areas stood vacant for long periods: 45% of that recorded vacant in 1995 was still
vacant in 1998. Of the sites becoming vacant between 1995 and 1998, 30% had
some constraints on their re-development and 6% had major constraints. Overall,
more than 40% of available land was recorded as having some form of constraint on
development in 1998. The GLA and boroughs are currently updating this data series
as part of the London Plan monitoring process.
Figure 2 Borough Distribution of Industrial Floorspace 2002
Source: ODPM. Commercial and Industrial Floorspace and Rateable Value Statistics, 2002. ODPM 2003
24
Figure 3 Borough Distribution of Warehouse Floorspace 2002
Source: ODPM. Commercial and Industrial Floorspace and Rateable Value Statistics 2002. ODPM 2003.
1.3 Consultants Roger Tym & Partners and GVA Grimley16 estimated that in total, London
contained some 6,900 ha of industrial land in 1999. This figure is broadly consistent
with that estimated by LPAC. LPAC concluded that two thirds (4,600 ha) of the total
lay within defined Strategic Employment Locations (SELs). Of this, 70% was
designated purely as Preferred Industrial Locations (PILs), 12% as Industrial Business
Parks (IBPs), nearly 16% as joint IBP/PILs and 1% as Technology Parks. The policy
approach to the latter is outlined separately within the DLP under ‘Offices’. The sub
regional breakdown of the different categories is shown in Table 1 and their
indicative location is set out in Fig 1 (DLP Map 3B.1). Coupled with geographical
variations in demand (paragraphs 6.9 – 6.12), this range in the distribution of the
supply of industrial capacity underscores the need for local refinement of pan-
London SPG through Sub Regional Development Frameworks.
Table 1 Industrial Land within Strategic Employment Locations 1998 (ha)

Sub-region PIL PIL/IBP IBP Total
Central 179 - - 179
East 1,558 72 241 1,871
West 654 652 155 1,460
North 406 - 98 504
South 482 - 58 540
Total 3,279 723 551 4,553
Derived from: LPAC Report 14/2000, Strategic Employment Sites: Revised Framework and Policy
Advice, 1 Feb 2000
25
1.4 This table does not show Other Employment Areas (OEAs), which lie, outside the
Strategic Employment Locations. LPAC estimated that those that could be identified,
including some proposed for mixed uses, cover about 2,200 ha. In addition, there
were smaller, scattered sites which were not identified by LPAC.
2 INDUSTRIAL LAND DEMAND

2.1 On average, over the 30 years to 2001, London annually lost 24,100 manufacturing
jobs (-2.3% pa) and 1,500 from wholesale distribution (-0.5% pa)17. In the late
1990s, Roger Tym & Partners18 found that the consensus among forecasters was that
while total London employment was expected to grow, that in industry was expected
to decline and more steeply than for the UK as a whole, though less steeply than in
the past in London. Rates of forecast loss ranged from –1.7% to - 2.6% pa for the
period 1996 – 2015. Their own forecast indicated a slightly slower decline (-1.1%, -
2,900 workers pa) for manufacturing and slight growth (0.3%, 600 workers pa) for
distribution. They suggested that this was because ‘London is gradually losing its
comparative disadvantage because much of the activity for which the capital is not a
competitive location has already left, and there are a number of actual and planned
improvements which should make London a more attractive environment for
industry’.
2.2 The GLA’s more recent review of independent forecasts confirms these general
trends19 . Its own independent projection20 suggests that manufacturing employment
is likely to decline by1.6% or 5,100 workers pa and wholesale distribution to increase
by 0.3% or 900 workers pa.
2.3 Recent government estimates suggest that the vacancy rate of floorspace (as
opposed to the overall amount of vacant industrial land) peaked in the mid 1990s at
15% before declining to 9% in 2000/01. Vacancy rates in London, especially inner
London, have been consistently and significantly above those of other English
regions. Within London, some boroughs e.g. Hackney 24%, Ealing 18%, Brent 15%,
Newham 14% were substantially above the relevant Inner/Outer averages21.
2.4 London industry is dominated by two sectors – distribution which accounts for 40%
of industrial employment and paper, printing and publishing with 20% (though 60%
of this sub sector works in publishing rather than printing or paper manufacture).
RTP/Grimley’s suggest that industries which are likely to find London a competitive
location are those which:
• serve London markets
• are near the end of the physical production process, producing final
commodities rather than capital equipment or intermediate goods
• produce time sensitive goods and services
• are high productivity and high value added but not necessarily high
technology
• are at the borderline of industry and services, with a high ‘tertiary’ content
26
2.5 Those which ‘typically do not find London a good location and over time are likely to
decline relatively probably include heavy manufacturing plants serving geographically
large markets’. In between these two extremes, mainstream activities are those for
which London will often be a reasonably competitive location. They are likely to
include activities which serve very localised markets and are comparatively low-skill
and low-value added, but closely tied to London, such as low level distribution, motor
repairs, some construction and a host of small scale services22.
2.6 To translate these employment forecasts into demand for land, RTP/Grimley’s
reviewed the relationship between industrial workers, floorspace and land in different
parts of London. On the basis of their own, particularly modest forecast of decline in
industrial employment, they suggested that in net terms London was likely to lose 32
ha pa to 2015. This was much lower than the 400 ha pa loss implied by government’s
floorspace statistics for 1984 – 9423 (RTP/Grimley), the 32 - 97 ha pa loss suggested
in an independent study by Halcrow Fox24, the 75 ha pa recorded by LPAC25 as being
released from industrial use 1991 – 98 and the 51 ha pa implied by the GLA’s
independent projections26
2.7 In light of the scale of decline in demand for industrial land indicated by these
different sources, the 32 ha pa net loss figure reported in the DLP is very prudent and
provides for a generous vacancy rate of approximately 14%. Moreover, it is based
only on vacant land, not vacant land and premises. RTP/Grimley suggest that ‘even
on the most cautious assumptions, there are about 500 ha of industrial land that will
be available for other uses over the next fifteen years, and there could be as much as
800 ha’.
2.8 More recent, independent re-working of the RTP data for the LDA27 indicates that,
under some scenarios, the 32 ha pa figure could be increased to 80 or even 120 ha pa
when greater weight is given to vacant premises as well as vacant land. This strongly
underscores the robustness of the Volterra based28 51 ha pa figure put before the
Examination in Public into the DLP.
2.9 Industrial land policy cannot simply be predicated on a quantitative, ‘macro’ view of
the overall relationship between demand and supply. Account must also be taken of
qualitative and geographical mismatches in supply and demand, especially in view of
the extensive physical and other constraints that affect industrial land. This calls for
action which will address these constraints rather than simply seeking to sustain the
overall stock of land in its present condition. Though the most recent, purely
quantitative assessment suggests that there is surplus industrial capacity in all
boroughs29, the consultants did not consider that this invalidated the conclusion of
their earlier, more market sensitive appraisal - that in parts of South and West London
the supply of useable and attractive industrial land may not be equal to requirements.
This will be tested in a new market demand assessment (paragraph 6.9 – 6.11.
2.10 This SPG provides the context for Sub Regional Development Frameworks to take
account of these variations in demand and supply. Table 2 below illustrates, on the
basis of different assumptions, how surplus industrial land might be released in
London’s different sub-regions. The first of these assumptions reflects a pro rata
release of between 30 and 50 ha pa based on the distribution of vacant industrial
land in 1998. The second and third maintain the same London-wide scale of release
but assumes that there will be 25% or 33% less release in South and West London
and that the balance is re-distributed to East, North and Central London. Revised in
27
the light of consultation on this SPG and the currently on-going 2003 Industrial Land
Availability Survey, these illustrations will inform sensitivity tests in the final SPG to
help monitor release of surplus industrial land through Sub Regional Development
Frameworks.
Table 2 Draft Sensitivity Benchmarks to Monitor Sub Regional Distribution

of Surplus Industrial Land Release (hectares pa)
London Central East West North South
Scenario 1: pro rata 30 1.3 16.6 5.7 4.8 1.7
distribution on
40 1.7 22.1 7.6 6.4 2.2
basis of vacant
industrial land 1998 50 2.1 27.7 9.5 8.0 2.8
Scenario 2: as 30 1.4 18.0 4.3 5.2 1.3

Scenario 1 but with
25% less loss in W 40 1.8 23.9 5.7 6.9 1.7
& S and the balance
redistributed to the 50 2.3 30.0 7.1 8.7 2.1
E, N & C
Scenario 3: as 30 1.4 18.4 3.8 5.3 1.1

Scenario 1 but with
33% less loss in W 40 1.9 24.5 5.1 7.1 1.5
& S and the balance
redistributed to the 50 2.3 30.7 6.4 8.9 1.9
E, N & C
2.11 Qualitative assessment of industrial land demand and supply relationships also
underscored the need for policy to recognize that while there will be a net reduction
in overall demand during the term of the Plan, at any one time there is likely still to
be substantial demand for usable industrial land. On the basis of development trends
it was estimated that ‘the long term average gross take up may be up to 55 ha per
year’30. This points to the importance of concerted LDA, borough and private sector
initiatives to meet the needs of the market, especially in terms of bringing forward
‘oven ready’ land and premises in locations attractive to industry.
28
Annex 2:
STRATEGIC EMPLOYMENT LOCATIONS FRAMEWORK
(Draft London Plan Annex 8)
Table 3 Preferred industrial locations
Number Borough Preferred industrial location name
1 Barking & Dagenham River Road Employment Area
2 Barking & Dagenham Rippleside
3 Barking & Dagenham, Dagenham Dock (part)
Havering
4 Bexley Belvedere Industrial Area (part)
5 Bexley Erith Riverside (part)
6 Brent, Ealing, Park Royal
Hammersmith &
Fulham
7 Brent Wembley Stadium (part)
8 Brent Staples Corner
9 Croydon Marlpit Lane
10 Croydon, Sutton Purley Way Area
11 Ealing Great Western Road (part)
12 Ealing Northolt, Greenford, Perivale (parts)
13 Enfield Brimsdown
14 Enfield, Haringey, Central Leaside Business Area, including Deephams,
Waltham Forest Garman Road, Leeside Road, Willoughby La. etc
15 Enfield Freezywater
16 Greenwich North Charlton Employment Area
17 Greenwich Greenwich Peninsula West
18 Greenwich Plumstead Industrial Area
19 Hackney Hackney Wick (part)
20 Harrow Wealdstone Industrial Area
21 Havering Harold Hill Industrial Estate
22 Havering Coldharbour Lane Employment Area
23 Hillingdon Uxbridge Industrial Estate
24 Hillingdon Stonefield Way/Victoria Road
25 Hillingdon Hayes Industrial Area
26 Hounslow North Feltham Trading Estate
27 Hounslow Brentford (part), including Transport Avenue
Industrial Area, Commerce Road
28 Kingston Chessington Industrial Estate
29 Lewisham, Southwark Surrey Canal Area (part)
30 Lewisham Bromley Road
31 Merton Willow Lane, Beddington
32 Merton Morden Road Factory Estate
29
Number Borough Preferred industrial location name

33 Merton North Wimbledon (part)
34 Merton Beverley Way Industrial Area
35 Newham, Tower Lower Lee Valley (part)
Hamlets
36 Newham London Industrial Park
37 Newham Marshgate Lane Area
38 Newham Thameside West
39 Newham Thameside East
40 Redbridge Southend Road Business Area
41 Redbridge Hainault Industrial Estate
42 Southwark Bermondsey South East
43 Sutton Kimpton Industrial Area
44 Waltham Forest Lea Bridge Gateway
45 Waltham Forest Blackhorse Lane
46 Wandsworth Nine Elms
30
Table 4 Industrial business parks

Number Borough Industrial business park name
1 Barnet Northern Telecom, Brunswick Park
2 Bexley Thames Road, including Crayford Industrial Area
3 Bexley, Bromley Foots Cray Business Area
4 Brent, Ealing, Park Royal
Hammersmith &
Fulham
5 Brent East Lane
6 Bromley St Mary’s Cray
7 Enfield Great Cambridge Road (part)
8 Hammersmith & Wood Lane (part), including Freston Road
Fulham, Kensington &
Chelsea
9 Haringey Tottenham Hale
10 Haringey Wood Green (part)
11 Harrow Stanmore (part)
12 Hillingdon North Uxbridge Industrial Estate
13 Hounslow Great Western Road (part)
14 Kingston Barwell Business Park
15 Newham British Gas Site
16 Newham Beckton Gateway
31
Annex 3:
REFERENCES
1
Mayor of London. Planning for London’s Growth. GLA, 2002
2
(TEC London Employers Survey 1996/97 cited in Roger Tym & Partners, GVA Grimley. Industrial Land
Demand in London. LPAC, 1999
3
CEBR. London’s Contribution to the UK Economy. Corporation of City of London, 2002,
4
GLA. Safeguarded Wharves on the River Thames, Consultation Draft. GLA, 2003
5
LPAC. Strategic Planning Advice for London. LPAC, 1994.
GOL. Strategic Planning Guidance for London Planning Authorities, RPG 3. HMSO, 1996
LPAC. Strategic Employment Sites: Revised Advice on Planning for Industry in London. LPAC Report
14/2000, LPAC, 2000.
6
HM Treasury. 2003 Budget Statement. HM Treasury 2003
7
ODPM. PPG3 Housing Review Consultation Papers - Supporting Delivery of New Housing, proposed new
paragraphs 42a. ODPM, 2003
8
LPAC. Report 14/2000, Annex 1. LPAC, 2000
9
HM Treasury, op cit
ODPM. PPG3 Housing Review Consultation papers – Supporting the Delivery of New Housing, proposed
new paragraph 42a. ODPM, 2003.
10
GLA Economics. Spreading Success. How London Is Changing. GLA, 2003
11
Roger Tym & Partners, GVA Grimley. 1999 op cit
12
DoE. Planning Policy Guidance. General Policy and Principles. PPG1. HMSO, 1997
DTLR. Mixed Use Development: Practice and Potential. HMSO, 2002
London Residential Research. Developing Additional Housing Above and On Non-Residential Sites.
DTLR, 2002.
13
LPAC. Report 14/2000. LPAC, 2000
14
DTLR. Commercial and Industrial Floorspace and Rateable Value Statistics 2002. DTLR, 2003
15
16
Roger Tym & Partners, GVA Grimley. 1999 op cit.
17
Mayor of London, 2002 op cit
18
Roger Tym & Partners, GVA Grimley, 1999 op cit
19
GLA. London’s Economy Today, II, 15 October 2002. GLA, 2002
20
Volterra Consulting. The Future of Employment in Greater London. SDS Technical Report 8. GLA, 2002
21
ODPM Commercial and Industrial Property Vacancy Statistics England 1991/92 to 2000/01. ODPM, 2003.
22
Roger Tym & Partners, GVA Grimley 1999 op cit
23
Roger Tym & Partners, GVA Grimley 1999 op cit
32
24
Halcrow Fox, Future Sources of Large Housing Sites. LPAC 1998
25
26
Roger Tym & Partners. Demand and Supply of Business Space in London. SDS Technical Report 21. GLA,
2002
27
URS Economic Development & Planning. London Thames Gateway Industrial Land Study (unpublished).
LDA, 2003
28
Volterra Consulting, 2002 op cit
29
Roger Tym & Partners, 2002 op cit
30
Roger Tym & Partners, 2002 op cit
33
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Industrial Capacity

The London Plan

The London Plan

How to give your views

Index of Draft SPG Implementation Points

• ensure that there is an adequate stock of industrial employment capacity to meet

2.3 Traditional distinctions between production, assembly, distribution and office-based

Figure 1 Strategic Employment Locations (London Plan Map 3B.1)

5 CHANGING INDUSTRIAL DEMAND AND THE PLAN, MONITOR AND

5.7 Appropriate sub-regional and borough-level benchmarks to inform policy for

• Overall stock of industrial land and premises

• Gross new industrial completions;

locations. Consolidation of SELs, or parts of SELs, is not a policy requirement of the

5.13 Consolidation must be informed by an authoritative appreciation of short and longer

SPG 1 – Industrial Capacity and Demand: the Plan, Monitor and

• adopt a positive ‘plan-monitor-manage’ approach to planning for

• manage the stock of industrial premises so that it provides a competitive

6 THE STRATEGIC EMPLOYMENT LOCATIONS FRAMEWORK AND OTHER

6.3 If the pan London approach to industrial capacity is to be effective, it must be

SPG 2 – Strategic Employment Locations Framework

• where relevant in their strategies, Unitary Development and other plans,

• through co-ordinated investment, regeneration initiatives, transport and

SPG 3 – Locally Significant Industrial Sites

paragraphs 6.12 – 6.15. These sites should be identified on UDP

SPG 4 – Other Industrial Sites

• develop criteria-based policies to manage the release from or retention

Restricted transfer of industrial sites

Limited transfer of poorer industrial sites

Managed transfer of poorer industrial sites

6.13 Strategic Factors, including whether a site:

• meets demonstrable short term demand for industrial development, and / or

• is part of a larger area of existing industrial activity, or area designated for

• is well located in relation to the strategic highway network or local highway

• has been adequately marketed at realistic prices for a reasonable period

7 INDUSTRIAL CAPACITY AND MIXED USE DEVELOPMENT

SPG 5 – Industrial Capacity and Mixed Use Development

• identify strategically recognised industrial sites or parts of sites which

8 QUALITY AND VARIETY OF INDUSTRIAL CAPACITY

• sustainable design and construction - further guidance will be provided in the

• intensification – maximise site attractiveness and uplifts in land values generated

SPG 6 – Quality and Variety of Industrial Capacity

9 SMALL INDUSTRIAL ENTERPRISES

SPG 7 – Small Industrial Enterprises

10 STORAGE AND DISTRIBUTION

SPG 8 – Storage and distribution

• encourage distribution facilities which will promote the movement of

Figure 2 Borough Distribution of Industrial Floorspace 2002

Figure 3 Borough Distribution of Warehouse Floorspace 2002

Table 1 Industrial Land within Strategic Employment Locations 1998 (ha)

2 INDUSTRIAL LAND DEMAND

• serve London markets

• produce time sensitive goods and services

Table 2 Draft Sensitivity Benchmarks to Monitor Sub Regional Distribution

Scenario 2: as 30 1.4 18.0 4.3 5.2 1.3

Scenario 3: as 30 1.4 18.4 3.8 5.3 1.1

Number Borough Preferred industrial location name

Table 4 Industrial business parks

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