New West End Company response to the draft City Plan 2040

New West End Company has made a formal response to Westminster City Council’s draft City Plan.

Read the full response here.

Here is our Executive Summary:

New West End Company, the importance of the West End to Westminster, London and the UK and key growth factors

The West End is a vital element of the economies of Westminster, London and the UK with a GVA greater than The City [1], employing 522,000 people [2] and set to accommodate half of the 77,000 new jobs created by 2036.  The City Plan projects further job growth predicting up to 96,000 additional jobs across the wider West End from 2016-41.

It faces increasing global competition and structural changes to retailing.  Its role in attracting investment and talent to London will increase after Brexit.  It needs to accommodate 40% more visitors when the Elizabeth line opens and retain the important mix of retail, entertainment, culture, commercial and residential use.

New West End Company’s four key asks of the City Plan

New West End Company broadly welcomes the emerging City Plan and support its recognition of the importance of the West End International Centre and the need for policies that enable it to grow in ways which retain its global position.  We also support the City Council’s analysis of the amount of additional commercial space required to accommodate expected job growth.

New West End Company has identified four key asks of the Development Plan which will most support the future growth of the West End.

Key Ask One – That the City Plan provides the level of flexibility of uses in the West End to enable appropriate growth to take place through the lifetime of the plan.

Changes in global retailing and customer demand will require a more flexible range of uses in the West End.

We support policies 2C and 15I which support flexibility.  However, we are concerned to ensure that:

  • The City Council is ambitious enough to allow new global formats which may emerge throughout the lifetime of the plan.
  • Further guidance through an SPD for the Oxford Street District involves retailers and extends to the whole of the International Centre.
  • Flexibility is not restricted unnecessarily by restrictions on more than three non-A1 uses consecutively in a frontage.
  • Parts of Oxford Street are not included in the Soho Special Policy Area.

Key Ask Two – That the City Plan provides sufficient new commercial space to accommodate agreed job growth targets with supporting infrastructure.

The Plan cites scenario testing for the West End by Arup (2018) which projects potential for an uplift of 96,000 jobs by 2041 across the wider West End.

The Plan also references the London Office Policy Review estimate of a further 75,000 office based jobs in Westminster between 2016-41.  This, it says, will require as much as 850,000 square meters of additional office space.

The City Council already has ambitious jobs growth targets with 50% of the 77,000 new jobs proposed by 2036 being in the West End.  These new visitors will further support the growth of the West End.

The City Council recognises the need to create up to 2 million square meters of new commercial space to accommodate these additional job numbers.  The Elizabeth line provides a major new commuter link.

The Arup Report on West End Good Growth states that only a good growth scenario, which requires 1.3 million sqm of additional commercial space, will allow for significant net job growth of up to 96,000 additional jobs by 2041.  All other scenarios, even those including an element of growth, are forecast to result in a decline in job numbers in the West End by 2041 due to continued loss of commercial space.

We welcome Policy 1C, 1E and 1H which support the provision of sufficient new commercial space throughout Westminster and policy 2A which supports intensification in the West End.

But we are very concerned that policies insisting on commercial developments including 35% of affordable housing will freeze development.  Development will become unviable and if housing is for sale the mixed tenure will prevent future development taking place.

We also believe that it will make an already challenging additional office target (850,000 square meters) much more difficult to achieve since it will require 1,307,000 square meters of total development.

We appreciate that developments in the International Centre will be allowed to provide the 35% of affordable housing off-site within the West End Retail and Leisure SPA but we believe that it will be difficult to find sites.

We understand the City Council has undertaken an independent assessment of the likely impact of these polices on the provision of affordable housing and commercial space in Westminster.  We would like the City Council to share this information with the business community.

In addition, we believe that any additional housing within the International Centre will create difficult-to-solve amenity problems because many existing operational and servicing activities will conflict with new residents’ expectations for a peaceful home life.

Key Ask Three – That the City Plan promotes a high-quality physical environment and encourages a dynamic range of experiences.

To attract international and domestic visitors requires high-quality public real and a continually changing range of experiences.

We support policies 2D, 2E,2F and 2G which promote a diverse evening and late night economy, a more coordinated approach to freight and waste management services, an enhanced public realm and transport infrastructure and the protection of the unique character of the West End.

However, we believe that a comprehensive, world class district management plan, fully costed and with resources identified, needs to be put in place as soon as possible if the West End is to maximise the returns on the significant investment in the Elizabeth line and the Oxford Street District transformation.  This is a key recommendation of the Arup Report.

Key Asks Four – That the City Plan defines the geographical extent of the West End International Retail Centre to enable greater policy flexibility.

We welcome the clear geographic definition of the International Centre as the necessary foundation for polices specific to the Centre.  We suggest that a future SPD for the Oxford Street District should apply to the entire International Centre and that thought should be given to a range of policy measures specific to the International Centre which will support its growth and economic success.

Other Policy Areas – Connection Policies

We support policies to make Westminster a walkable city by prioritising pedestrians and reducing bus services and stands.

We support proposals to provide better cycling routes but not on Oxford Street.

We believe that Oxford Street should be removed from the Strategic Road Network.

We support policies to encourage freight and waste consolidation.

Other Policy Areas – Environment Policies

We support policies to improve air quality in the area.

We support policies to prioritise Oxford Street for air quality offset schemes.

[1] West End Partnership Delivery Plan 2015-30
[2] Arup West End Good Growth 2018

Read the full response here.

Fri 14 December 2018