Last week saw the Examination in Public (EiP) of the Partial Review of the City Plan, with the following policy topics reviewed within the City Plan: Affordable housing, site allocations and the introduction of a new retrofit first policy. The Newmark team representing WPA at EiP (James Wickham – Partner, Newmark, Suzanne Thurtle – Associate – Knowledge and Policy Lead, Newmark and Hannah Davies – Senior Planning Consultant, Newmark) shared their reflections on the week below.
The EiP ran between 29 April and 01 May 2025 and was split into three parts: Day one covered scope of the examination, legal compliance and the updates to the affordable housing policy, day two covered the emerging retrofit first policy and half of the site allocations, and day three covered the remaining site allocations and a wrap up by the Inspector.
The WPA has continuously engaged with Westminster City Council on the emerging policies from Regulation 18 stage and the collaboration between WPA and WCC was praised by the Inspector.
Day one: Scope of the examination, legal compliance and updates to the affordable housing policy
Day one was kicked off by an opening statement provided by Cllr Geoff Barraclough, Cabinet Member for Planning and Economic Development, where he thanked the Westminster City Council policy team and stakeholders for their collaboration. He outlined the strategic objectives behind the Partial Review, citing housing, climate and growth crises which the Partial Review seeks to address in part.
The session then moved to consider the scope of the Partial Review and legal compliance matters, where only the City Council participated. Bar a few minor matters, the Inspector was largely happy with the scope and legal matters did not appear to raise much concern. We expect that the Inspector’s main considerations will be focused on soundness.
The afternoon’s topic was affordable housing, with discussion about the change in approach to tenure mix (70% social and 30 intermediate). The Inspector was interested to understand other boroughs’ approaches and how this would affect the Fast-Track/Viability Tested routes as per the London Plan. In terms of small site affordable housing contributions, the Inspector considered that the Council had applied “a degree of pragmatism” in seeking for 20% provision when the evidence pointed towards 35% being justified. There was a lengthy discussion around the approach regarding portfolio sites, which the Inspector will further consider.
Westminster City Council officers referred to the adoption of the Affordable Housing and Planning Obligations SPD after the Partial Review, possibly by the end of the year.
Day two: Policy 43 (Retrofit First) and site allocations
This session focussed principally on emerging Policy 43 (Retrofit First). WPA was represented on day two of the EiP by Roy Pinnock (Partner, Dentons) and James Wickham (Partner, Newmark), who put forward WPA’s main concern that the requirement to optimise site capacity through a design-led approach (especially in the CAZ), as a key policy mandate, had been relegated to a balancing exercise of public benefits in Test 4 of the proposed Sequential Test. They explained this to be an area of inconsistency with national and London policy, which goes to the effectiveness of the policy.
Discussions were held on how best to measure ‘substantial demolition’ and ‘retrofit’ i.e., through GIA floorspace figures (as suggested by WCC) or through carbon volume studies (as suggested by WPA). Whilst the Inspector recognised that GIA floorspace may only be a proxy for carbon volume, he noted that using floorspace figures would prevent an additional burden being placed on applicants, may be more easily communicated to residents and politicians and may still support reductions in carbon emissions as floor slabs are one of the most carbon intensive elements of a building.
Overall, the Inspector recognised that emerging Policy 43 is “an ambitious policy [which has] undergone a lot of change – the most detailed I’ve seen among London boroughs” and that WCC is “at the head of pushing the boundaries of this aspect of planning.” The Inspector confirmed he understood the concerns raised by the WPA – particularly in respect of Test 2 of the Sequential Test – and agreed that he needed to reflect further on this point.
The rest of the day focussed on site allocations for a new, state-of-the-art hospital at St Mary’s Hospital and the redevelopment of Westbourne Park Bus Garage.
Day three: Remaining site allocations and conclusion by the Inspector
Day three commenced with the remaining site allocations at the land adjacent to Royal Oak, and Grosvenor Sidings, followed by a wrap up session where the Inspector set out his initial position. The Inspector confirmed he was largely happy with the Partial Review of the City Plan in respect of scope and legal compliance. In respect of soundness, there were two elements he confirmed he would take away to consider further: 1. Portfolio sites and 2. The functioning of the Sequential Test in emerging Policy 43 (as raised by WPA).
Cllr Geoff Barraclough closed the EiP with his closing statement stating that the City Council considered the proposed policy changes are essential to deliver the Fairer Westminster mandate that Labour was elected on. Cllr Barraclough reiterated that, in respect of the environment, the emerging policy is ‘retrofit first, not retrofit only’ and acknowledged in order to do what is best for the City of Westminster, in some cases this will mean full redevelopment.
Next steps
The Inspector will now write to Westminster City Council on the portfolio sites and the Sequential Test in emerging Policy 43 by the end of May, with Main Modifications to be prepared and consulted on over the summer, before the Inspector issues his final report. This is expected to land in October (although the City Council has requested this is issued earlier where possible).
Read the latest information on the Westminster Draft City Plan (Partial Review)
