Co-Living isn't just a trend that will phase out over time. In fact, quite the opposite; this new form of housing is beginning to entrench itself into the market, which is intended to complement the modern way of working and living. Developers have found themselves in a unique position to re-define city living and so the GLA's new large-scale purpose-built shared living (LSPBSL) London Plan Guidance (LPG) which was published on 29 February 2024, has been a welcome step forward in this space.
Whilst the guidance will only be applicable in London, we may see Co-Living developers and local planning authorities outside of the capital following suit and apply similar criteria as a model of best practice.
What does the guidance do?
LSPBSL (Co-Living) is a type of housing which is not self-contained and is generally made up of at least 50 private individual rooms and communal spaces and facilities. As set out within the LPG, it is intended to be distinguishable from traditional residential dwellings (use class C3) as well as from HMOs, hotels, residential institutions and student accommodation.
The guidance is intended to provide a benchmark for LSPBSL (Co-Living) relating to, amongst other things, shared spaces and facilities, designed to encourage communal living and social interaction. It has evolved a long way from the first draft of the LPG published in January 2022, and now is a robust framework with a much-needed degree of flexibility. It is hoped that this will allow developers to deliver co-living schemes which are carefully crafted to provide for a range of needs and importantly, schemes which integrate into the local community.
Policy H16 and planning permission
When the London Plan Policy H16 was introduced in 2021, it aimed to accommodate the emerging new ways of residential living. The policy sets out an array of requirements specific for a co-living development such as being of good quality and design, being located in areas that are well connected to local services so as to not be car dependent, the development being under single management, clarity on size for private and communal spaces, and a cash in-lieu contribution towards off-site affordable housing provision.
In addition, demonstrating that a co-living scheme will promote a diverse and inclusive contribution to the local neighbourhood, is not just a 'nice to have', but it is a must - especially now that adherence to the H16 policy can be measured.
The LPG helpfully expands upon the requirements of policy H16 and clarifies minimum requirements as well as optional communal facilities that could be provided on-site. The LPG should therefore provide a useful guide to Co-Living developers when formulating their plans for new developments as well as provide greater certainty.
The interface between Co-Living and Affordable Housing
Of note, whilst the co-living offering goes some way in providing a much needed and unique additional housing option for some people, the co-living units do not meet the minimum London Plan internal space standards for C3 housing. Consequently, it cannot be considered an affordable housing product that provides housing that is genuinely affordable or housing to support families. It is very much viewed as a 'transitional' accommodation option suited to single-person households.
The Challenges
Care has to be taken to ensure units in co-living developments are not self-contained, or not equipped with facilities that encourage self-containment, as the product is being promoted as an alternative to HMOs, hotels and student accommodation. This will be a fundamental concept in the success of co-living schemes and the LPG will need to be carefully considered, in order to demonstrate how the guidance has been adhered to.
But one must also consider going too far the other way. For example, the recommended benchmark of having 1 cooking station per 15 residents could have health and safety implications; the benchmark of having one washer and one dryer per 35 residents could easily result in disagreements, the list goes on. Although it is slightly out of the box (yet perhaps understandable) that the guidance says a management plan should be secured through a section 106 agreement, there are some unusual requirements being made from the manager in how to manage resource such as inadequate kitchen or laundry facilities, as 'avoiding conflicts' is an unusual thing for a housing manager to be doing.
The requirement to ensure a 90-day-plus tenancy agreement for all co-living units is an interesting one. Does this go against the flexible nature of opting to reside in a co-living scheme, or does it encourage enough time to form a community and therefore have a higher likelihood of residents renewing their tenancy? This will be one to watch.
Developers and local authorities will also have to be mindful that co-living schemes are not all concentrated in one area. There may be locations where demand for co-living could be particularly high, and this could potentially have a negative impact on creating mixed and inclusive neighbourhoods. If this is likely to happen, local planning authorities could introduce a local policy framework, which limits the number of developments within a specified area, or alternatively, decide this on a case-by-case basis.
There have been some concerns (likely due to the lack of understanding of this new form of residential living) amongst developers and local planning authorities, in explaining the role of co-living in meeting the housing need, and where it sits in the hierarchy of required housing. However, in this current climate, where individuals are seeking more flexibility than ever before with their living arrangements, there is an increasing demand from single person households, to have specifically designed accommodation which promotes social integration and communal living.
