Responding to a GLA stage one report on a London scheme

A stage one report is the Mayor of London's formal view on a planning application of potential strategic importance, issued within six weeks of the borough referring it, and it tells you exactly which London Plan policies the Greater London Authority thinks your scheme fails. Getting the stage 1 report response right matters because the same officers write the stage two advice, and unresolved stage one issues are what the Mayor later uses to direct refusal or take the application over. Treat the report as a negotiating document with a deadline, not as a verdict.

The referral itself is automatic. Applications caught by Schedule 1 to the Town and Country Planning (Mayor of London) Order 2008 must go to City Hall, and the familiar triggers are 150 or more houses or flats, buildings above 30 metres outside the City of London, and development on Green Belt or Metropolitan Open Land. Check the Order rather than working from memory, because the categories are longer than most people remember and a missed referral is a validation problem for the borough rather than for you.

What a stage one report actually says

The report runs through the scheme against the London Plan policy by policy, then ends with a paragraph confirming that the application does not yet fully comply and setting out what would need to change. That closing paragraph is the operative part. Everything above it is reasoning you can argue with.

Officers write to a standard sequence: principle of development, housing and affordable housing, urban design and tall buildings, heritage, inclusive design, sustainable development, and transport. Each section either confirms compliance, asks for information, or states an objection. The distinction between the three is worth marking up in the margin on your first read, because a request for information is quick to answer and an objection on principle is not.

The report also records whether the Mayor would be minded to allow the borough to determine the application. That sentence is not a commitment. It is a statement of position as at the date of the report.

Reading the strategic issues it raises

Sort the issues into three piles. The first is arithmetic: affordable housing percentage by habitable room and by unit, play space provision against the ten square metres per child standard, carbon reduction against the Be Lean, Be Clean, Be Green hierarchy, cycle parking against the London Plan minimums. These are answerable with a revised schedule and a short note.

The second pile is design judgement. Density, massing, dual aspect ratios and the design-led approach to capacity sit here, and they are usually where the GLA and the borough disagree with each other rather than with you. If your capacity argument was built properly, the material for the response already exists in your design and access work on optimising site capacity under policy D3.

The third pile is land use principle. Loss of industrial floorspace, loss of a public house, loss of office space, development on protected open land. These rarely soften. On industrial sites the no net loss position set out in London Plan industrial land policy is applied fairly literally by GLA officers, and a scheme that cannot demonstrate reprovision or intensification is in real trouble at stage two.

Responding before the borough decides

You have whatever time remains before the borough's committee or delegated decision, which in practice is often eight to sixteen weeks. Use it.

1. Ask the GLA case officer for a meeting. Stage one reports name the officer and the GLA holds post-stage-one meetings as a matter of course for larger schemes.
2. Send a written response that answers each numbered paragraph of the report in order, using the report's own paragraph numbers as headings.
3. Submit revised drawings and revised technical documents to the borough, not only to City Hall, and tell both in writing that you have done so.
4. Where you disagree, say so plainly and give the policy reading you rely on. Officers prefer a reasoned disagreement to silence.
5. Ask the borough to record in its committee report which stage one matters have been resolved and how.

That last step is the one agents skip. The stage two report leans heavily on the borough's committee report, so a committee report that works through the stage one issues one by one does half your arguing for you.

Daylight and sunlight is the exception to the "answer everything" rule. GLA officers generally defer to the borough on neighbour amenity, so a dense-site assessment prepared on the approach described in BRE 209 guidance for dense London sites is better aimed at the borough's case officer.

Stage two and the Mayor's three options

When the borough has resolved what it intends to do, it refers the application back. The Mayor then has fourteen days to choose between three courses.

Fourteen days is short. The stage two report is drafted from the stage one report plus the borough's committee report plus anything you have sent in between, so material arriving in the second week of that fortnight is unlikely to change anything.

Direction to refuse and taking the application over

A direction to refuse is the simpler of the two interventions. The Mayor directs, the borough refuses, and the applicant can then appeal to the Secretary of State in the usual way.

A takeover is different and the threshold is higher. Article 7 requires the Mayor to be satisfied that the development would have a significant impact on implementation of the London Plan, that it has effects reaching beyond the host borough, and that there are sound planning reasons to intervene. All three have to be met. Where the Mayor does take over, he becomes the decision maker, holds a public representation hearing, and the borough's resolution falls away.

Takeovers are most often associated with schemes a borough has resolved to refuse where the Mayor supports the housing output. That is why a borough refusal is not the end of a referable application, and why the stage one report is repays reading for signs of Mayoral support as well as Mayoral objection.

What changes between the two stages

Three things usually move. The borough's position hardens into conditions and a section 106 package. The technical evidence base is complete rather than indicative. And the policy backdrop may have shifted, because the London Plan is supplemented by guidance that is updated between stages more often than people expect.

What does not change is the stage one list. If an objection in the stage one report has not been answered on paper by the time of the stage two referral, assume it survives. Fire safety is a good example of an issue that cannot be deferred: Planning Gateway One requires the fire statement to be submitted with the application, and a Fire Statement that is still described as forthcoming at stage two invites an objection the Mayor does not need to argue hard for.

Programming both stages into the timetable

Build the referral into the programme at the point you agree a validation date with the borough, not later. Allow six weeks for the stage one report from referral, then your response period, then fourteen days from the stage two referral. For a major London scheme that means the Mayor's involvement adds roughly two months of fixed procedural time on top of the thirteen-week statutory determination period, before any extension of time agreement.

An illustrative sequence for a 220-unit scheme in an outer London borough: validation in week one, referral in week two, stage one report in week eight, applicant response and revised drawings in weeks nine to fourteen, committee in week twenty, stage two referral the following week, Mayoral decision a fortnight after that. Nothing about that programme is unusual, and it is still five months from validation to decision notice.

Diary the fourteen-day stage two window as soon as the committee date is fixed. It is the only part of the process where you have almost no time to react.

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