My Response to the New Draft London Plan – I’m worried

Back in February 2018 I responded to the consultation on the New Draft London Plan. I thought I’d repeat it here.


This response to the consultation of the above planning document is written on behalf of a group of residents from the London Borough of Bexley.


‘Good Growth’ is not about supporting growth at any cost’. This is a nice little statement but it isn’t believable that the boroughs or The Mayor (or The Government via ministerial interventions) will say ‘no’ to bad growth – London will get the numbers in this document but not the quality. The approach should be turned around – if we don’t get the things which make growth good there will be no growth.

Central to the plan is how we can help Boroughs better co-ordinate growth across London – it includes strong new measures and sets ambitious targets for every London Borough for building the London we need. Who is the ‘we’ mentioned here? Who is this London growth for – the people who live and work in London or those who invest in London? Is London for people or international finance and investors? How the benefits of London’s growth are distributed are just as, if not more, important than growth itself. It seems to be accepted as a given that London can and will just grow and grow in order to suit the needs of investors. Studies and evidence show that cities can get too big, and beyond a certain level the size of a city negates the benefits of size and agglomeration. London is already at this size – where its size begins to bring dis-benefits; so it is very disappointing that this evidence has been ignored and not referred to.

It is very disappointing that there are no targets for employment space and buildings for jobs for each borough. There seems to be no employment plan or strategy. Too much is focused on the CAZ and its international focus – not everyone in London works in (or even wants to work in) the CAZ. Many London residents’ travel-to-work-area ignores the CAZ and involves travel across London Borough boundaries rather than into the CAZ. In the outer boroughs many residents’ travel to work area is away from London and is into the surrounding counties. None of this seems to be acknowledged or recognised in the draft London Plan. Too much of the draft Plan is focused on London as an international city and too little on the proportion of the economic and social activity which is ‘domestic’ (both intra-London activity and London’s relationship with the rest of the UK) other than these areas being a supplier of labour to London.

The Mayor says “I want a city that works for all Londoners”. In which case is he willing to accept that this may mean that those who live in London take precedence over those who invest in London – that London is for Londoners, not globalised capital and investors? If he isn’t this is just window dressing and empty words.

The document says that the Mayor has ambition for ‘a city where people can spend less time commuting’. This is nonsense – how does this fit with CR2 and HS2 which will encourage more commuting?

It is disappointing that The Mayor doesn’t mention the relationship London has with the rest of the UK and how it can increasingly help these places thrive rather than suck life and jobs from them. There is talk of coordination but this talk goes nowhere far enough and doesn’t recognise the harm London actually does to the rest of the UK.

0.0.14 footnote – the draft plan is underpinned by housing and economic projections. The projections are based on past trends. Surely we should be looking at likely or possible future events and scenarios, and decide whether we passive accept these or try to affect them. What guarantee is there that the future will follow the past. In short, this is too passive: we should not, and we must not, passively accept the future which is ‘given’ to London and Londoner’s – we must positively plan to deliver the future we want.

Chapter 1 Good Growth Policies

1.1.1 ‘Every individual decision to make a new development car free helps Londoners to depend less on cars and live healthier lives’. Firstly this is a fallacy: it has been well known for years that Germany has more cars per head of population than the UK but the Germans use them less. It is not access to cars which stops people walking or using public transport, it is lack of walk-ability, lack of high quality public transport, and lack of local leisure and work opportunities. All ‘lack of car parking’ will do is: trap people where they live if there aren’t good alternatives; and create problem parking. Secondly, this statement and policy is written in a very central-London centric way and ignores the way in which the outer boroughs of London work and, even with intensification, will work in the future. Outer London is not like inner London: their travel and working patterns are different.

1.0.5 ‘London’s global economy is the envy of other world cities – it is the engine of the national economies’. Is this ‘engine of the national economies’ a symbiotic relationship or is it harming other parts of the UK (or even other parts of the world)?

‘It will be important to think about what the purpose of economic growth actually is‘. This is a very good point, and we support it, but it doesn’t go far enough. The London Plan ought to be looking at how economic growth, and the benefits of economic activity, are distributed. The London Plan ought to be about a fair distribution of London’s benefits – but it doesn’t do this.

1.0.6 ‘A focus on large multi-national businesses in the centre of London has not been matched by economic development in other parts of the city. A failure to consider the wider implications of London’s growth has increased car dependency’. The lessons here are not being considered yet alone learnt – could it be that the focus on multinational businesses is what is harming the rest of London? The London Plan must see, and set out, that central London is not, and will not, be solely for big and multinational businesses. In the same way in which the draft plan talks about mixed-use it must set out that central London is for small and micro-businesses as well as big businesses and multi-nationals – indeed the balance needs to be reset as it has already gone too far.

1.0.8 Planning for mixed use development in all parts of London will spread the success of London’s economy and create stronger communities. We support the creation of mixed use developments but on its own this will not bring success to all parts of London. In addition, it must be understood that mixed use is more than having, say, a retail unit at the base of a residential block – it is localities which must be of mixed use, with a place having more than one function and having multiple uses spread and varying over different parts of the day. These uses must work together and must not harm nor conflict with each other.

1.0.9 6 Good Growth Policies

1.1.5 Early engagement with local people leads to better planning proposals with Neighbourhood Plans providing a particularly good opportunity for communities to shape growth in their areas. This is an important point, but this seems to be an empty statement. Without resources communities cannot get involved in a meaningful way; in practice communities are almost never engaged at an early stage, and their views are almost never taken into account. It is misleading to say that communities can shape the growth in their areas – they are being given a fait accompli and will continue to get what they are given, unless something changes.

Policy GG1 Building Strong and Inclusive Communities

These are all good points, but under section C and E we would like to see the vital importance of Urban Design made very clear. The places and spaces must be designed before the buildings, and urban design must lead. But to do this requires resources, and the policy of place making must be followed through from planing policy into development control and then delivery – too often good planning policy is let down by the planning control process. It is partly this failure to deliver what was promised that leads to communities objecting to, and fighting off, development proposals.

Page 32 Making the Best Use of Land

To grow whilst protecting Green Belt the Plan proposes more efficient uses of the cities land.

      1. The key to achieving this will be taking a rounded approach…. will mean creating places of higher density in appropriate locations……ensuring a mix of land uses and co-locating different uses. We are concerned that the definition of appropriate locations seems to be town centres and at train stations without any analyses of whether these are really appropriate locations. Some of London’s Town Centres are not actually near to train stations; many of London’s Train Stations do not have capacity on their lines to take more commuters, and this policy seems to be taken without regard to the actual practicability and therefore the deliverability of this intensification.

1.2.4 Making the best use of land means directing growth towards the most accessible and well-connected places. Having a place well-connected doesn’t mean that the people living there can afford to access the transport. What is the point of intensification of land use around train stations if too many of the people living there cannot afford to use the service? There is no guarantee that public transport will continue to be affordable and so we are in danger of locking ourselves into a poor quality living environment for the sake of an unaffordable transport system.

1.2.5 Mentions the intensification of outer London. Do those making the London Plan understand how outer London actually works? Have communities in outer London been engaged in agreeing to this policy? It appears that they do not and have not (in any meaningful way) and this will lead to communities fighting and resisting developments (even if technically these developments are in accordance with the New London Plan); in turn this makes the proposed plan undeliverable.

Is a walking, cycling and public transport orientated London suitable for an ageing population? Sure many older people can do all of this (some of the time), but as our population gets increasingly older and more infirm they will not be able to depend on these methods to get around.

Policy GG3 Creating a Healthy City

F – : There are potential problems with over-heating with new buildings – a vital issue to consider and address.

1.4.3 2017 SHMA identified a significant overall need for housing and for affordable housing particularly. London needs 66,000 new homes per year for 20 years and evidence suggests that 43,000 of these should be genuinely affordable. This supports Mayors strategic target of 50% of new homes being genuinely affordable.

66,000 per year with 43,000 being affordable = an actual need for 65% affordable, so the Mayors target of 50% (which seems to be later watered down to 35% in some places) doesn’t match or meet his strategy. There needs to be a return to social housing at social rents (for general needs, at secure tenancies) if we are to solve the housing crisis.

    1. The London Plan is able to look across the city to plan for the housing needs of all Londoners, treating London as a single housing market. What! London is not a single housing market! Not even for international investors – they are not ambivalent over which part of London they invest in; they invest in a limited number of locations. Most Londoners are not ‘free’ to live in any part of London. Most people in South London do not look to locate in North London. Most people moving to London from outside of London tend to locate in central London (Zones 1 and 2) and not the outer London Suburbs. This is a silly and simplistic statement and this will lead to a London Plan which will not work. In short this statement has been written by someone who doesn’t understand how housing markets work.

1.4.5 Talks of brown field sites and town centres being important in the provision of new homes. If existing homes and their surroundings are being defined as brownfield sites, the London Plan is storing up a whole lot of trouble for itself. Those that live in homes do not see themselves as living on brownfield sites.

1.4.6 Build to Rent model can deliver homes for rent quickly. But Build to Rent is more expensive than social housing. As such they must be resisted not encouraged. Going down the private sector Build to Rent model will store up a whole lot of problems for London and Londoners, as well as the country’s tax-payers who will be expected to subsidise the rents. The Mayor needs to put down a marker that the failed housing model of the last 40 years is at an end in London, and Build to Rent is part of this failed model.

1.4.8 The draft plan talks of London and the wider South East being engines of the UK economy and the wealth it generates is essential to keeping the whole country functioning, but the benefits of economic success are not shared evenly within London itself. There is no mention of the harm London does to the economy of the rest of the UK, nor are there any policies for how this can be mitigated and the position changed in the short, medium and long terms.

1.4.10 Projected growth towards 6.9 million jobs by 2041 provides opportunity to strengthen London’s economy for the future and doing so will depend on increasing diversification. The CAZ and Northern Isle of Dogs will remain vital ……but growth in town centres across London will be equally important, supporting local regeneration. Reasonably priced, good quality employment spaces will be needed across London to make this happen. Regeneration is very different from property development, and it is not clear in the draft Plan if the Mayor and his policies understand this. Transport patterns and, therefore, the needs to make London’s town centres function are very different to those needed to make Central London and its CAZs work – there seems to be no recognition of this. It is not ‘reasonably priced’ employment premises that are required but cheap premises and ‘appropriate’ quality along with a range of qualities. Extreme care must be taken not to lose premises which existing businesses rely on. In the same way that the Mayor’s and the UK’s housing policies are not delivering housing for everyone who needs it, but is only working for the rentiers, business premises are going the same way, and this must be avoided.

1.4.11 Talks about the right infrastructure which is required. Although Environmental Infrastructure is mentioned elsewhere in the draft Plan we would like to see it specifically mentioned here. The multiple benefits of green infrastructure must be recognised and delivered.

Policy GG5 talks about public transport and cycling networks as well as its network of town centres, to support agglomeration and economic growth. It must be understood that London’s town centres function in very different ways to central London’s CAZ (and much of the CAZ is actually different from the core of the CAZ). The draft Plan doesn’t seem to understand this.

Policy GG6 says that London will becoming zero carbon by 2050 and that we must ensure that buildings and infrastructure are designed to adapt to a changing climate. Words are not enough. Planners must resist development which does not or is not designed to do this.

Chapter 2 Spatial Development Patterns

The map on page 26 has no meaningful legend and its purpose is unclear. It is also trying to do too much in a small space and is thus not clear. It appears to us that whoever drew up this map and designations within it doesn’t understand how South East London functions.

2.0.2 Talks about green and open spaces but only Green Belt and Metropolitan Space are actually mentioned. It is not only strategically important open spaces which are important to Londoner’s and London’s environment.

2.0.3 Talks about outer London, ‘where the suburban pattern of development has significant potential for appropriate intensification over time, particularly for additional housing’. There seems to be no thought given to what the implications are of the suburbs not being suburban in nature. As this affects those living and working in the suburbs there should be special efforts to consult with these people to ensure that they have been fully involved with the process of drawing up the London Plan and that they support it – but this has not been the case. Hardly anyone in outer London knows what is being planned for them. The ‘Principals of Public Consultation’ (as confirmed by The Supreme Court) have not been met in the drawing up of The London Plan, so it should be rejected. In addition, the focus in the suburbs should not be solely on housing – jobs must be planned for and provided to go with housing in the suburbs, otherwise there will be an unsustainable need and demand for transport to and from the CAZ.

2.0.4 Talks about the infrastructure for Opportunity Areas being planned for well in advance. This does not go far enough – it is insufficient to plan for infrastructure; it has to be delivered in advance not just planed in advance. We very much doubt whether the infrastructure which is mentioned as being a prerequisite to the housing being build will be funded and built, so we believed that the London Plan as set out is actually undeliverable.

2.0.5 ‘Many town centres and the surrounding areas have potential to accommodate significant quantities of new housing’. If this also requires significant demolition of existing homes this must be made clear – to not do so is misleading. We believe the Mayor and his Planning Team, in drawing up the London Plan, has not taken any account of the resistance there will be to intensifying the suburbs from those who already live there, and this makes the London Plan undeliverable.

2.0.7 Mentions that in the past too many Londoner have been priced out of the area they call home. The Mayor, his strategy, and The London Plan must make clear that private sector developers and private rentals will not stop this pricing out of Londoners from where they have been brought up. There must be a return to larger scale social housing with low rents, and secure tenancies, if this pricing out is to be prevented. The large scale adoption of Build-to-Rent must be resisted as this is crowding out low-cost owner occupation. Shared-ownership must also be resisted as all it does is keep prices high.

Policy SD1 Opportunity Areas

The Mayor will provide support and leadership for collaborative preparation and implementation of planning frameworks. The Mayor must ensure that the Planning Departments of Borough Councils are fully and adequately resourced so that they can truly work in partnership with The Mayor’s Planners, otherwise it will be clear that these frameworks are being pushed from the centre and have no local support or legitimacy.

SD1 Regeneration is mentioned. This requires a definition of regeneration that is not synonymous with Property Development. Property Development and Regeneration are two very different things.

SD1 mentions affordable housing. Affordable Housing has become a devalued term because of its misleading nature in usage. The public do not understand what is meant by affordable housing and such ‘code words’, with meanings other than a common or garden dictionary definition, should not be used.

SD1 also says that Boroughs should support and sustain Strategic Industrial Locations (SILs). It must be ensured that it is not possible for only a few land owners of SILs (and other employment land) can dictate rents. Employers and businesses require cheap premises and this must be the focus, not the opportunity for value extraction by a few land owners. A successful UK industrial strategy requires the focus to be on those who create value by running productive businesses not on extractive business who takes rents from those that create value. It must also be recognised that many jobs are not in SILs but tucked away in, around, behind and on the edge of town centres and these are important suppliers of cheap work space.

SD5: The policy of Local Authorities to plan for the intensification of industrial land assumes a high level of competence from the Local Authorities in order to do this successfully. This is a doubtful supposition.

There is also talk of ensuring Planning Frameworks are subject to public consultation. This is not strong enough; there must be engagement with communities (under the Gunning Principles of Public Consultation) before any planning work is undertaken and not consultation after a lot of work has already been undertaken. Too often communities are being presented with, what seems to them, a set of proposals over which they have no real say or influence.

2.1.2 ‘Many Opportunity Areas overlap with Strategic Areas for Regeneration’. This seems to be an admission that Opportunity Areas are about property development and not regeneration. This is unacceptable; all sites in London must be about regeneration and not be only seen as opportunities for property development.

2.1.9 Talks about the 4 Principal Approaches from the Housing Strategy. The London Plan needs to explain how the Mayor’s actions and funding will not be used to just, or mainly, subsidise the profit of the private sector developers and landlords and how his policies and funding will lead to additional delivery above and beyond what would happen anyway.

2.1.11 says that the development value in Opportunity Areas could contribute to the funding of the schemes. But this will only be the case if policy requirements are incorporated into the developers’ proposals and priced accordingly in their development appraisals and thus the price paid for the sites. Developers must not be allowed to use ‘viability’ arguments to get out of meeting policy requirements.

Old Kent Road Opportunity Area

2.1.14 Says that the Area Action Plan for Old Kent Road should plan for no net loss of industrial floorspace’, and ‘Areas that are released from SIL should seek to co-locate’. These statements are far too weak. The policy must be changed to say ‘must’ and say that sites will not be released for housing until done so. Already existing and viable businesses are being forced out of the Old Kent Road Opportunity Area, and it is vital that new sites accommodate the needs of existing businesses so that these businesses can continue and grow and are not forced out by new developments.

2.1.18 Phrases such as ‘large-scale redevelopment of 5 key sites including Catford Shopping Centre’, are banded about seemingly without regard to the fact that people actually live here. However, it is good that the term Redevelopment is used rather than the false use of the word Regeneration. Nevertheless, there seems to be no assessment of whether Milford Tower needs re-development or does it really need renovating. There is no mention of how much social housing there is now and how much there will be once re-developed.

Cross Rail 2

2.1.19 CR2 appears to be a Ponzi Scheme. It is ‘required’ for London to grow and the business plan for it requires London to grow even more to fund CR2. To deliver the increased density development along the CR2 corridor, and at its transport hubs, requires such a high standard and sensitivity of design that is unbelievable that this will be achieved. Some of the development unlocked by CR2 can only be delivered once CR2 is operational but it is very unclear how and if CR2 will be financed in order to do this. Too much of CR2 is predicated on shipping more and more people into Central London for work. The ambition to have some outer London Hubs as sites for major office speculation and jobs is fanciful – too many people prefer to take inner London’s higher salaries, and these areas are too secondary for speculative developers.

Likewise the proposals to relieve congestion at Clapham Junction by increasing development around and above the station is fanciful thinking. This is likely, over the long term, to lead to more congestion.

2.1.31 Talks about Lee Valley and that there should be no net loss of industrial floorspace capacity and intensification of industrial land and co-location, but is totally silent on the type of provision which is required, nor the cost of rents which are required (that is, which are affordable) to the type of business and firms which the area requires. Too much of the draft London Plan seems designed for the benefit of rent takers, rentiers, and international investment, rather than productive, value-creating enterprises.

A strong presumption in favour of 1 to 25 homes. This is the danger in the suburbs. Will we have developers slowly buying up semis, leaving them empty or let as HMOs until they own enough to start developing? This, and other policies to intensify the suburbs is a formula for blight.

2.1.37 Thames Estuary North and South

Talks about 250,000 new jobs. Where do these numbers (and other job figures) come from? Are they based on estimated demand for workers; the number of people who will need jobs, or they based on the area available for development multiplied by employment density figures?

2.1.39 The Mayor has set out a vision to transform the Thames Estuary into a hub for large-scale state of the art production facilities with an initial focus on creative and cultural industries. This focus on production facilities is only looking at one side of the equation. There needs to be, and must be, places in London for major users of these facilities. The production facilities are the supply, but we must also plan for and provide the demand. High quality users of the supply are required to provide the ‘domestic’ base for the supply and for the producers to show credibility when trying to ‘export’ the supply. For example, The Garden of Ideas ( ) or a project of similar sale and impact, should be specifically mentioned in The London Plan for the Thames Estuary North and South (and indeed for the London Stansted Cambridge Corridor) . Just looking at supply without planning for domestic demand, and specifically a (or a number) of anchor institutions to act as an outlet for the supply is only looking at one side of the coin, and puts too much dependence on producers winning contracts from footloose overseas sales which can be very variable.

2.1.40 What is the Thames Gateway Strategic Group and why is there also a Thames Estuary 2050 Growth Commission? Why is there this duplication of effort?

2.1.41 Proposed Thames Crossings do not seem to look beyond the mile or so either side of the Thames. Planning for these crossings must extend to the wider East Thames Gateway hinterland and be totally integrated into plans for housing and employment growth.

2.1.42 Says that The Mayor (and the London Plan) will support the extension of The Elizabeth Line (Cross Rail 1) to North Kent. This is a very vague statement and we wish to see which parts of North Kent the Mayor is talking about (i.e which towns). We are also very concerned by many of the Transport Plans which are and have been brought forward: it must not be the case that longer distance commuting (eg from Kent) is provided to the detriment of shorter distance commuters (eg from outer London). It appears that the proposed new South East Train Franchise is making life worse for those in outer London Boroughs in order to make it easier to commute from longer distances: this is unacceptable and embeds inequality.

2.1.48 We cannot understand why major sites in inner London (for example the Royal Docks) need the incentive of being made into Enterprise Zones. London is a world city, and sites in inner London do not need the tax incentives of an EZ to attract investment that would be coming anyway. We do not support the creation of Enterprise Zones anywhere in London.

We are also concerned that the plan talks about ensuring that industrial capacity is managed in ways that reduce overall vacancy rates; unless this means that the Mayor will insist on rents and prices of vacant industrial land falling until there is demand for its use for employment. In a plan over a long period such as the London Plan we do not know what will happen and what sort and type of work there will be, so we must not be afraid of industrial land being vacant as long as it is not left abandoned or derelict. A certain level of vacancy is required to enable new business creation, business growth (or new and existing firms), and movement of firms. There must also be a temporary use strategy for each major industrial area.

Thamesmead and Abbeywood Opportunity Area

2.1.51 Talks about ‘no net loss of industrial floorspace capacity’, but the plan is silent on the types of floorspace and its costs (rental levels). We must avoid this theoretical ‘rationalisation’ leading to empty sites which can’t be taken up by real businesses because the rents demanded are too high for the work available. There must be a temporary use strategy and a strategy for the retention of existing jobs and firms and for the transformation to Industry 4.0.

The Plan talks about the need for new infrastructure to support the intensification of these (and other) areas. But we must avoid what originally happened with Thamesmead – it was built in anticipation of transport and other infrastructure which didn’t actually materialise. We are very concerned that the infrastructure which is required for London to grow will not be provided but the growth will happen anyway – therefore we will get poor growth. The lessons of the past are there and must be learnt.

The Plan talks about the need for new utility infrastructure (water, electrical, broadband, and flood management) without saying how this will be delivered, funded and financed. It strikes us that The London Plan has just said that people want to come to London so let’s let it happen without thinking whether it is good for London, or good for the rest of the UK.

Bexley Riverside Opportunity Area

2.1.53 The London Plan talks about the extension of The Elizabeth Line (Cross Rail 1) to Slade Green and beyond. This is a very brave assumption and it gives a false impression of how much growth can be delivered in the area. It is better to be upfront and only plan for what can be supported by what infrastructure will actually be delivered. The need for improved bus services to support the growth of this area is mentioned: this is welcomed but it must be remembered that this is outer London and buses can only help with some journeys – many people in outer London travel away from London for work and will continue to be car dependent; many people from the surrounding counties travel into the outer London Boroughs for work but not by using public transport so they are, and will remain, car dependent. This car dependence in outer London must be accepted and addressed but as currently proposed The London Plan seems to have been written by those who only know central London.


2.1.66 Talks about the comprehensive transformation of the area, but does so as if no-one already lives there, making a life and a living. There is no debate about who the ‘transformation’ of Euston is supposed to benefit: the existing community or international and institutional finance and developers for who this could be anywhere. Why was the term ‘transformation’ used as what appears to be a euphemism? The Plan should be upfront and call it demolition and redevelopment

In addition why is a development partner being sought? The benefits should be accrued to the public and driven by the public. Will the benefits be privatised but the risks and losses socialised?

We note that the London Plan says nothing about the intensification of Mayfair.

Policy SD2 Collaboration

E – Talks about ‘scope for the substitution of business and industrial capacity where mutual benefits can be achieved’. What does this actually mean? Is it pushing low value work outside of London – work which still needs London for its market? This doesn’t seem socially or environmentally sustainable.

2.2.1 ‘London and wider South East comprises the most productive region in the UK accounting for nearly half its output’. This totally ignores the disparities within London and the South East. There are huge inequalities hidden in this average. All of the bits which make up this average must be considered and addressed. How wealth is created is just as important as the quantum. Would London still be considered a success if 99% of the wealth (or income) was owned by 1 person?

2.3.1 The Mayor’s Plan aims to accommodate all of London’s growth within its boundaries without intruding on its Green Belt and other protected open spaces. This statement doesn’t fit with The Elizabeth Line or the proposed Cross Rail 2 moving in people from outside of London to work in London.

2.3.3 Says that the SHMA shows a need for 66,000 additional homes per year and the SHLAA shows there is room for 65,000 additional homes per year and this is in The Plan. Do these figures cover need or demand? What will prevent demand for homes to invest in and to shelter wealth in diluting the need for homes to live in being met? Does the SHMA include the need for homes to live in plus the demand for homes to act as stores of value?

2.3.4 The Mayor wants to work with Local Authorities outside of London to accommodate more growth outside London in ‘sustainable’ locations, and talks abut linking these by transport to London and New Garden Cities to London. This contradicts the Mayor’s aim of wanting to accommodate London’s growth within London’s boundaries. Again, this is too focused on London – it is better to make these places better places to work for all of their population so there is not a great need to work in London.

Fig 2.15 Map of Wider South East Strategic Infrastructure

This map seems to ignore road freight from Dover (and the Channel Tunnel) and its effect on outer London Boroughs and its population. Dover should only be used for freight which doesn’t have to cross the Thames Estuary, with freight which does made to use England’s east coast ports which are north of the Thames Estuary.

Policy SD4 The CAZ

A– ‘The London for locals’ is not stressed sufficiently. London working for Londoners must come first and not as an afterthought after the International and National role of London. It is the London for locals that is London’s unique feature.

B – The same applies for the office function. The need for office space for local businesses must be addressed and delivered.

D – The dense nature of the CAZ is not uniform and must not be allowed to become so. London has low density next to and intermixed with high density. This must not be lost.

K – The attractions of predominately residential neighbourhoods, where more local uses predominate, must be conserved. This must equally apply to ‘Council Estates’ and not just private sector residential areas.

M – Says that capacity protection for ‘last mile’ distribution should be protected. But this is already being ignored. See the Old Kent Road Opportunity Area where firms which supply the CAZ are being forced out.

2.4.6 Talks about a wide range of business space requirements, and that quality and range of rental values is essential to enable these sectors to flourish and for SMEs to fulfill their economic potential. This will not happen if London is seen as an investment opportunity for international capital. Thought must be given to how SMEs can actually own their premises, or be community or co-owned, and not be reliant on institutional landlords.

2.4.8 We don’t see the logic of imposing charges on the most polluting vehicles. Why should you be allowed to pollute if you can pay for the privilege. It something is bad just ban it.

2.4.10 Night-time and cultural attractions must not only be focussed on tourists. Locals need access to these, as do those who can’t afford high ticket, food and drink prices. There must be a wide range of offers – formal and informal; low cost and no cost. The Plan seems to ignore the problems which can arise if locals feel that tourism harms their quality of life (see what is happening in Barcelona where there is a backlash against mass tourism).

CAZ has over the years lost its family owned and run businesses, especially retail and food (cafes, small newsagents and grocery shops etc). These family run and owned businesses must not be allowed to become extinct. London (including in the CAZ) must be a London for SMEs and not just national and international chains.

2.4.17 Talks about diverse communities including affordable housing. Affordable Housing is now a misused and devalued term. Social Housing must be specifically mentioned and specified as a requirement to be delivered.

2.4.18 “in the high-value land market within the CAZ there is very limited industry and logistics capacity”. This statement in the draft Plan totally ignores the point of, and the use of, the Town Planning System. It is land use which determines the value of the land – if a site is only allowed to be used for industrial use that use will determine the value of the site. The Planning System must be used to deliver what is required to benefit the community and society as a whole. We must not allow speculation and hope value to dictate how land in London is used or not used. It is not sufficient to talk about supply and demand of such uses. Demand can be choked-off by land owners asking high rental prices. We must consider the need of these land uses not the just the ‘demand’ (which can be choked-off). In the Old Kent Road existing logistics and industrial use is being forced out because the land owners want to force these businesses out and turn the sites into higher value residential use.

Policy SD6 Town Centres

The draft London Plan talks about the intensification of town centres especially for residential development. It says that tourist infrastructure, attractions and hotels in town centre locations, especially in outer London, should be enhanced and promoted. But there is no real detail on how this will be funded and delivered, especially the supporting infrastructure, the open spaces etc. Why is the Mayor and the Plan obsessed with the Night-time economy? There is plenty of evidence that the night-time economy is harmful to health, so why is it being pushed? The negative effects of the night-time economy are totally ignored.

2.9.5 Talks about the intensification of town centres for residential development. We are very concerned that TIF has been mentioned as a means of funding delivery with no consideration of its risks. There is no mention of social housing. We do not believe that the blanket policy of intensification of town centres and around transport hubs is deliverable. It seems to have been written by people who do not understand how outer London works, and its does not have public support.

Policy SD10 Strategic and Local Regeneration

There is no definition of what Regeneration is and how it differs from development and-redevelopment.

2.10.3 Talks about Regeneration being done in collaboration with local communities. This collaboration must be real and any scheme not done in this way (in conformation with the Gunning Principles of Public Consultation) must be rejected.

Policy D2 Delivering Good Design

A ‘To identify an area’s capacity for growth and understand how to deliver it in a way which strengthens what is valued’. But the draft London Plan has/is already identifying how much growth each London Borough is to take!

The ambitions for high quality design are all well and good when set out in a policy document, but the policy needs to be delivered and experience shows that developers too easily opt out of these requirements. The intensification of London and London’s suburbs, and outer London’s town centres, requires very high quality urban design, followed through by high quality management and maintenance We know from experience that this will not happen. The London Plan is specifying a highly ‘engineered’ urbanism which we know will not be delivered. What is really required is a more loose fit, flexible, urbanism.

Generally, the draft London Plan seems to just assume that London grows and London responds to this rather than pro-actively managing the UK’s economy and growth. Conversely there seems to be no conception of what happens if and when London stops attracting the UK’s and world’s population.

Policy D6 Optimising Housing Density

B1) ‘The density of development proposals should be based on, and linked to, the provision of future planned levels of infrastructure rather than existing levels’

But we have an economic system which is cutting back on the provision of infrastructure, especially social infrastructure, (or is at least restricting the funding of the infrastructure which is really required). We have no confidence that funding the provision of infrastructure (CapEx and OpEx) will be delivered. Therefore this means that the whole of the London Plan is undeliverable.

3) says that in exceptional circumstances development is contingent on the provision of infrastructure. This is not strong enough. It implies that in most cases development can go ahead even if the supporting and enabling infrastructure is not in place. We must therefore object to this section – development can only be sustainable if the infrastructure in place – there must be no exceptions to this principle.

3.6.1 ‘This means developing at densities above those of the surrounding area on most sites’. This seems to be forgetting that high densities requires high quality design and high-quality maintenance and management for such densities to work. Experience tells us that in the main (especially for mainstream housing) this doesn’t happen. We have no confidence that the high costs of managing and maintaining flats will be met over the long term. We have seen this happen in the recent past and this is not something we should repeat. Therefore there is great risk that the London Plan will not improve London for those who live and work here. Also, where are the weekend homes and leisure gardens which enables the delivery of high densities in many continental cities and which makes them liveable?

3.6.5 It seems to be assumed that town centres are close to stations. In the suburbs this is often not the case and is therefore an incorrect assumption. This leads to the assumption that the Plan has been written by people who do not understand how outer London works.

3.7.11 Talks about free water fountains, and elsewhere there is talk about public toilets in large commercial developments. This does not go far enough – there must be provision of public toilets in public places. London has never been richer and it is unacceptable not to provide and manage public toilets in public places. There is a greater need for public toilets than free water foundations.

3.7.12 We support the temporary use policy.

Policy D8 Tall Buildings

f) ‘Buildings near the River Thames should not contribute to a canyon effect’. This policy must be extended to cover areas and places other (in addition to) than near the River Thames. Tall buildings must not be allowed to create a canyon effect anywhere.

Policy H1 Housing

We object to the definition of brownfield being extended to existing housing areas and their gardens. This is the effect of the housing policy as proposed.

We also object to the presumption in favour of development on small housing sites (1 – 25 units), and on the intensification within and close to town centres and stations. The emphasis on development of existing housing sites in and around town centres and stations especially in outer London is not supported in outer London and to have this policy in the London Plan is inviting community friction.

The proposals to intensify the suburbs are dangerous. What will prevent developers slowly buying up semis and terraced homes, leaving them empty or letting them out as HMOs until they own enough to start developing? What will be done to prevent the very real danger of development blight?

4.1.2 ‘For the purpose of the Plan London is considered as single housing market area.’ This statement shows that whoever has written the policy does not understand London. London is not a single housing market area. Most people already living in London are not ambivalent as to where they live in London – local connections means that on the whole people living in, say, south east London do not move to north west London. On the whole people moving into London from the rest of the UK or from overseas tend to settle in Zones 1 or 2; they rarely look to outer London. This lack of understanding of how London works means that the whole plan is invalid and not workable.

We object to the focus on Build-to-Rent – this is dependent on continuing rent subsidies and is thus not sustainable.

4.1.6 Encouraging new homes to be marketed to Londoners before they are marketed overseas is meaningless. The purchase of homes in London by anyone based overseas should be banned. London’s homes should be for Londoners to live in and not be as stores of value for overseas investors. We expect the Mayor to take a very strong stand on this.

The Plan depends on local Boroughs having good quality design guides and design codes if the growth is going to be sustainable and acceptable to those already living in London. We all know that the Borough do not have, and will not have, the resources to produce these high-quality design guides and codes. We therefore submit that The Plan is undeliverable.

We also object to the idea that developments should be allowed even when they harm the existing population or environment.

The housing section of the draft London Plan seems to be been written without any regard to the public’s responses to the draft Housing Strategy.

General Points in Summary

Many people, and community groups, believe (and the evidence seems to support this view) that London is being rapidly transformed to meet the needs of ‘elites’ in the world with too much focus on London being a ‘global city’ and doing so at the expense of the diversity and community which we (and the Mayor claims to) value so much and at the expense of the real economy. The new London Plan (and the Housing Strategy) needs to confront and re-balance these power relationships if London is to retain all that makes it a success.

We are concerned about the references to the intensification and densification of development in outer London – to do this in an acceptable way implies heroic assumptions about the quality of design and place making which will be delivered in practice as opposed to in theory (or required by policy). In short, we do not believe that the high quality design and place making required to make high density work will actually be delivered. This also applies to inner London and its planned for densification. Therefore we cannot and do not support these policies.

This London Plan seems to be based on two incorrect assumptions:

  1. that neoliberal economics has not recently been seriously challenged and that the next 30 years will be based on the economic philosophy and assumptions of the last 40 years;

  2. that leaving the EU will not make any difference to the rate at which London grows over the next 30 years: in short there is no recognition that the UK’s and London’s economy may not follow the pattern of the recent past.

In closing we would say that ‘we’ (the public, central government, the London Mayor, the GLA, The London Assembly etc) really need to debate and decide who London is for – those who live and work in London (not ignoring London’s affect on the rest of the UK and the wider world), or is it for the rest of the world to treat as just an investment opportunity and a safe place to store their wealth?

We cannot support the London Plan as proposed.

Yours faithfully,

Steven Boxall, MSc, BSc (Hons)

Principal Consultant

Regeneration X

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The London Plan – doomed to fail because it’s impossible to deliver?

In the New London Plan the Mayor, and his advisors, have come up with a high density London including the intensification of suburban outer London.

This intensified, high density, London is a ‘highly engineered’ concept where everything has to work in the way the plan has envisaged in order for the thing to work.

Everything has to be high-quality design:

  • the buildings,

  • the urban design,

  • the employment land and

  • the transport and movement systems.

There is no redundancy (which adds robustness) to account for things not being delivered, or working, as the High Priests have defined; or even for things changing over the years.

We have proved over the years that we can’t build highly engineered systems in the built environment that always perform as designed.

To perform as designed needs the best engineers and designers (for which read architects, urban designers, town planners, developers and clients).

But we know that most plans will not be designed by the best engineers and designers.

The developments and buildings will be occupied by people who require flexibility but there will be no flexibility built in.

We have tried to deliver highly engineered buildings in the past but they don’t get built as designed (see the schools falling down in Scotland and possibly Grenfell Tower).

We must accept this with buildings and build robustly with redundancy built in – and we need to do the same with our places, cities, town centres and suburbs.

We don’t have to be geniuses to foresee this – in the 1960s and 1970s we built residential tower blocks – who’s success depended on high-quality design; high-quality materials; high-quality workmanship; high-quality open space; high-quality management and maintenance, and high-quality public transport to get people to and from work and the town centre shops.

Many of these places failed because this high-quality was cut in the times of ‘budgetary constraint’.

These places were not robust – they were incapable of adsorbing change by not being done, or maintained and managed, to the highest quality.

It strikes me that the new London Plan is repeating the same mistakes – all will be fine if we have the best quality everything and that the money to keep everything at high quality continues to be available.

Experience tells us that this is unlikely.

So, we need a London Plan which is robust – a bit like Georgian Buildings: many were built with poor quality materials, by workman who weren’t that skilled – but they have so much redundancy built in ( they were over engineered, by which I mean of course that they are flexible), that this doesn’t matter – they were robust enough to forgive mistakes and to react to change over the centuries. I very much doubt that the places and building that we develop under the current or new London Plan will be so robust and so flexible.

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For who is the Government trying to save the UK’s high streets?

Yesterday’s Budget from the Chancellor of the Exchequer, Philip Hammond, contained some announcements about helping the ‘bricks and mortar’ retailers, and ‘saving the high street’: including some tinkering with Business Rates and changes to Permitted Development Rights to make it easier to turn shops into homes.

But who is the Government saving the UK’s shops for?

Currently one of the UK’s major owners of retail shopping centres and shopping malls, INTU Properties, is being courted with a view to being taken over by a consortium of investors. This consortium consists of The Peel Group (which is owned by INTU’s deputy chairman); a Saudi Arabian investor Olayan, and a Canadian company called Brookfield.

This looks like the continuation and enlargement of the UK’s cash-generating land and infrastructure being owned by overseas companies, with the money earned in the UK by UK residents being shovelled abroad via rents and dividends.

‘Does this matter?’ many will ask. Well it does, because this is money lost to the UK economy and therefore for UK citizens.

If only a few shops and centres were owned by overseas investors it wouldn’t matter that much, but when so much is owned by overseas companies it does – it means that a lot of money is leaving the UK.

Also the rest of the world using the UK’s major shopping areas as an asset class bids up property prices and creates, and keeps stoked, an asset price bubble.

In addition if these overseas (and domestic) owners of shopping centres see the opportunity to extend their businesses into creating, owning, and renting out homes in the areas they own this will be more money leaving the UK (especially as some of the rents will be subsidised by the UK taxpayers via Housing Benefits), and the further bidding up of asset prices.

So, it looks like the UK Government is trying to save the UK’s bricks and mortar retailers for the overseas owners of many of our high streets and shopping centres, and this doesn’t help the UK’s economy in the long term.

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Empty Shops – how to force landlords to find new users

One of my collaborators, Gibbs and Partners @TheGestalter pointed out to me a blog by Seth Godwin @ThisIsSethsBlog .

In this blog Seth Godwin points out that commercial landlords tend to be in the market for the long run, and are unwilling to unjust the rents they ask for in a downwards direction in order to ensure that an empty shop finds a tenant. They are, says Seth, willing to sit with an empty store-front for months at a time. We have all seen shops which have been empty for years yet alone months.

Although this might make sense for the landlord (and the reasons behind this was explored in my MSc about Empty Historic Buildings), it’s bad for the places where these buildings are located. These empty shops deny services to residents and visitors, they make an area look run down and reduce its vibrancy (and its viability).

In order to avoid these empty shops and all of the problems this brings to town centres, highs streets and neighbourhoods, Seth suggests a means of ‘forcing’ the landlords to reduce rents until they find a new tenant.

He proposes a ‘Vacancy Tax’ where, say, for any premises which are empty after two months of vacancy, the landlord has to pay a tax of 20% of the average rent they’d be receiving. He thinks that this would make landlords reduce rents so that some new business decides to try something and by doing so help to create more interactions and more vibrant neighbourhoods.

Seth’s full thinking and blog can be found here –

This is interesting, but I think it could lead to unintended consequences and isn’t flexible in order to take account of differing local circumstances or the different phases of an economic cycle. In any event, in the UK at least, vacant business premises still have to pay Business Rates (payable by the property owner if no one else is still around) on empty premises after an initial vacancy period, but we still have many vacant units in some places.

Therefore I prefer my idea where each local authority has a policy, which could vary from place to place (and even from time-to-time), of not being willing to allow any shop to remain empty for more than, say, one year (the period can vary from place to place); and if it is the local authority will Compulsory Purchase it at a price which reflects the rent they can let it for or re-sell it for. Of course, this depends on each local authority having a strategy and plan for finding tenants and users for the empty premises, but this can be done and my MSc Dissertation outlined how this could work. Knowing that local authorities are willing to do this could encourage landlords to reduce rents until a user is found, even if this is only a temporary or experimental use.

But whatever mechanism is used, I agree that we must not allow property owners to leave their properties empty and unused for any prolonged length of time.

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Do Local Councils really understand their local economy? They need to.

A question (well, a series of them) to Chief Executives, Leaders, Chief Planning Officers and Economic Development Officers of Local Councils:

Do you know:

  • Which company employs the most people in your area (apart from your own council – most often the largest employer is likely to be you)?

  • Who the big employers are and what companies employ the majority of your citizens?

  • Which company is the largest Business Rates payer, and what companies pay the majority of your Business Rates (increasingly important from April 2020)?

  • Which company has the largest turnover; which makes the most profit, and which is the most profitable?

  • What companies are recognised as being leaders in their fields of activity?

  • What companies export their products or services?

  • What companies import their goods, supplies and services?

  • Do you know who the owners and managers of these business are?

  • Do you regularly meet these business owners and managers, and especially those who are the most critical to your area and to you?

  • Do you know what their problems and issues are?

  • Do you know who owns (and manages) the premises which these business work from?

  • Do you know who owns and manages the premises in your town centres and high streets; who owns the main shopping centre or mall; who owns (and manages) the older shopping parades from which the smaller and independent shops tend to operate from?

  • Do you regularly meet with these people?

  • Do you know who owns and manages the empty premises in your town centres, and what their intentions are?

  • Do you know who the large land (and property) owners are in your area, and do you meet them regularly?

  • Do you know who the large housing providers (and developers) are in your area, and do you meet them regularly?

  • Do you know what the further and higher education providers in you area specialise in and do you meet their leaders regularly?

  • Do you know how many students graduate each year and what employment they are seeking?

  • Do you know what research these education providers are undertaking, and do you know what their spin-out plans are to create businesses from their research, and what help they need?

  • Do you know where you citizens work (and who for) and what their travel patterns are?

These, and others, are questions which you must be asking and ought to have answers to.

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Thames Estuary 2050 Vision – some thoughts

In July 2018 The Thames Estuary 2050 Commission published its 2050 Vision Report.

You can find the report here but I will set out here a few of my thoughts on it and on thoughts sparked by it.

The Thames Gateway (previously called the East Thames Corridor) seems, with the establishment of The Thames Estuary 2050 Commission to be now called in official circles The Thames Estuary Corridor.

Since 2008 (that is, since the Great Bank Crash), The Thames Estuary area, outside of London itself, has grown more slowly than any of the other London Growth Corridors: for example, The Thames Valley; Cambridge-Stansted-London Corridor. The Kent and Essex parts of the Thames Estuary/Thames Gateway have not kept pace with growth in east London:

  • between 2009 + 2016 East London employment grew by 27%;

  • the Thames Estuary average was 19%,

  • and the London average was 21%.

It seems to me that The Thames Gateway growing more slowing than other parts of London is to be expected. If we are growing London by importing people from the rest of the UK and the rest of the world, it is likely that growth will be from the centre out. Why would strangers to London choose the wider Thames Estuary area when the jobs are, and the ‘vibe’ is, in central London and the growing east end? As these areas close to central London become more expensive incomers may move out into the Thames Estuary, but only if the cost and effort of travel into London is worth the cost and effort.

We need to get the Thames Estuary growing more organically but this will be slow growth.

We need to plan for and deliver the things which will make people want to come to Thames Estuary area: good, cheap homes of all sorts for the full demographic; good schools, education and training; good culture, arts and entertainment; good environment; good and available jobs (at all levels); good transport and communication (at all scales); good social and community infrastructure, etc. In short, high quality places which can serve people across their whole life-span.

I said back in August 2014 that perhaps we should accept that the River Thames to the east of London is a barrier, and will always be a barrier even with new crossings, and so we should explore if the option of turning the areas north and south of the Thames to the east of London into 2 parallel(ish), separate, but equally high quality locations for homes and jobs etc, with top quality radial routes is a better way to spend Billions of £ rather than on new Thames crossings. Or at least agreeing that new crossings will not be enough, and will never be, to provide sufficient capacity.

So, I am pleased to see the Thames Estuary 2050 Commission accepting that the Thames Gateway is not a single economic or travel to work area. They have said that the Thames Estuary will not be successful if the area is considered as a single place or community – ‘because it does not function as a single place or community’ but is really a tapestry of interconnected but different economies, places and people; so what is required is a different structure of 5 connected productive places based on existing areas and their assets with a clear vision for each area.

The 2050 Vision Report contains a big and important finding: “without a coherent and integrated vision and associated priorities, this important part of the country will not deliver ‘business as usual’, let alone more ambitious ones”.

So, it appears that 30 years after the Thames Gateway was first identified as an area for development there is no coherent vision. But this doesn’t come as a shock to me – I have always said that we will not get sensible and high quality vision and delivery in The Thames Gateway without a well funded and resourced body to either be responsible for it all, or to coordinate, help and drive all of the various partners and stakeholders.

The Commission says that there needs to be a strong streamlined governance arrangement and recommends that the area needs to be represented by a South East Regional or sub-regional Government, but it is not clear if they are talking about this being elected or not. They go on to say that there needs to be a review of governance within 6 months and this should start at local level to see if agreement can be obtained – but if no programme is produced within 6 months a more top-down approach should be taken. They also say there needs to be a single Thames Gateway Strategic Group which requires capacity funding and to speak to government with a single voice.

I have always said that little will be done without central funding and resources to coordinate and drive visions, strategies and delivery; and to fund projects. But how do we do this whilst maintaining democratic input and control – the lack of which has often been a criticism of how mega projects and programmes are run, for example London Docklands?

Perhaps we could approach this by:

  • all Local Planning Authorities maintaining their Planning role;

  • setting up a Thames Gateway Body, with sufficient resources and staff, in order to coordinate and assist all LPAs;

  • this Thames Gateway Group to be responsible for planning (and Planning) and delivery of cross area strategic infrastructure such as strategic roads and rail (such as Cross Rail extensions and Thames Crossings);

  • this Thames Gateway Group working with all LPAs to ensure that policy and projects are coordinated and do not cut cross each-other, and to ensure that a beggar-they-neighbour approach is not taken.

The Commission calls for ‘people-led projects’ in part delivered through The Thames Estuary Fund. How the Thames Gateway development is funded and financed is vital: in my view the worse thing which can happen to The Thames Estuary is it being a location or target for massive inward overseas investment. We need the area to be for value creation; not for value extraction over the long-term nor for rentiers.

When considering transport and communications it is not good enough to only deal with transport into London from the periphery. All places, and local economies, need good intra-connectivity as well as connections to other places: in fact for many economies it is the infra-connectivity which is more important than mega projects (although connections with the wider world cannot be ignored).

It is good to read in the report the call for infrastructure investment to be integrated and multifunctional maximising the benefits to people, places and ecology. I have talked before about the vital importance of infrastructure being designed to deliver multiple benefits (see my blog ), and this is now a standard approach to good urban design (although that isn’t to say that it isn’t often ignored).

The Report talks about the ‘City Ribbon’ area (the London Boroughs along the Thames) building on their core strengths including the growing cultural and creative industries sectors supported by the Mayor of London’s Production Corridor. However, although the cultural and creative industries are an important part of the UK’s economy, and there is already a concentration in the City Ribbon, we mustn’t take this too far. The cultural industries have a reputation for being low paid and precarious, with a few mega-earners. I would like to have seen some analysis on the wage or income distribution within these sectors. Are 1% on a lot of money and 99% on low, precarious, incomes?

The report calls for the City Ribbon to be a hub for production spaces created for start-ups and grow-on space for SMEs. I hope this means next generation manufacturing (including bio-medicine and life-sciences) and not only cultural production.

I am very worried that the report mentions ‘Estate Regeneration’ which now has a very bad reputation with those currently living in these places.

The Commission said very clearly that The Thames Estuary vision will not be delivered if a ‘Business as usual’ approach is taken. However, in a survey of all projects and programmes being planned and developed they found that everything is ‘Business as usual’. This is a very worrying finding and needs to be changed immediately (but I can’t see it being done).

In my view this will only be done if the Public Sector acts as the Masterplanner and as the master-developer. This isn’t so unusual – it happens in Holland. So, it is interesting to see the Commission calling for exactly this. This can address both quality and timing of delivery -but only if the Public Sector is given the resources and power to do this.

The report says that one of the big issues for the Inner Estuary area (the South Essex and North Kent boroughs) is poor education and skills attainment. However it fails to say why this is the case. Is it anything to do with all of Kent having a selective education system and parts of Essex also having one? Selective education is not working for the population as a whole nor the employers; this needs to be acknowledged and challenged and changed: we must not ignore something just because it is political – if it is causing probables we must say so. When I worked with educationalists in Kent they were quite clear that this was the case. This may be a political issue but we will get nowhere if we ignore political issues which have a detrimental effect.

It is interesting that the report says that at Ebbsfleet Garden City the delivery of 15,000 planned homes has slowed – is this really true? A Development Corporation has been set up, has been operational for some years now, and delivery has slowed! I find this hard to believe, but shocking if true.

The Commission also points out the lack of job creation in Ebbsfleet Garden City. A new Medical Campus at Ebbsfleet is mentioned, so hopefully this should help with job creation. I said years ago that we should extend the Cambridge-Stansted-London Corridor (in concept rather than administratively), and its high-tech medical research corridor, into North Kent via the boroughs of Bexley, Dartford, and Gravesend onto Medway. The Cambridge-Stansted-London Corridor has the research facilities but lacks the space to grow high-tech medical and life-sciences manufacturing. North Kent has the space to do this, and the transport links to the Francis Crick Institute at Kings Cross and to the Cambridge-Stansted-London Corridor are good.

The Vision talks about the sub-region needing to address its river frontage and its relationship with the River Thames; but in my view the Ebbsfleet masterplan fails to do this to anything like the extent it should do.

The Commission said that the Swanscombe Peninsular needs resolving urgently – if London Resort Holdings do not submit a Development Consent Order for its proposed Themed Resort by the end of 2018, the Government should consider all options for resolving the uncertainty this scheme is creating.

I said from the beginning that I do not support this scheme, and that a ‘Resort’ is a poor use for this site and this area (unless it is truly unique and groundbreaking such as The Garden of Ideas – see – declaration of interest: I’m working with them). This site and area should be used for modern high-tech manufacturing, including high-tech medical manufacturing and life-sciences, set in a landscaped setting which reflects its riverside and marshland environment.

The Report calls for Cross Rail 1 to be extended to Ebbsfleet by 2030 and for the Government to provide the funding (expected to be £20bn). But I can’t see why they have stopped at Ebbsfleet: why not extend it to at least Gravesend and possible to the Medway Towns? Or has there been a strategic decision taken to not do so as this would undermine Medway and Gravesend as employment growth points? If it is too easy to get into London from North Kent this would just encourage London to grow – perhaps by too much. I can see an argument for both points of view (extend/not to extend) but it would be good to see if the Government is actually thinking things through.

The Report talks of an emerging medical research corridor connecting to the Francis Crick Institute through to Chatham to Canterbury. Yes, we need fast, cheap, Public Transport to the Francis Crick Institute. HS1 sort of does part of this but it needs to be better and cheaper. I can see why perhaps we do not want cheap commuter fares into central London (this isn’t going to happen anyway) as this would lead to lots of people commuting from East Kent to central London on a daily basis. We can have good transport for those from North Kent who need to go to Francis Institute other than daily for business, but cheap transport from so far out doesn’t help the mass of people live a balanced life. We need to have plenty of good jobs locally so having to work in London is not, or doesn’t have to be, the norm.

It was interesting to see the Report suggesting a very long term project – a new Thames Crossing east of the (yet to be built) Lower Thames Crossing, combined with a new Thames Barrier or Barrage, linking Basildon and the Medway Towns. This would be part of the Environment Agency’s new and upgraded Thames flood protection plans.

The Commission says that The Thames Estuary Corridor is seen as vital to delivering London’s growth. This thinking and argument does worry me. We really need to set up and grow the area with its own nodes to counter-balance London. We must challenge an ever growing and dominant London. The UK as a whole lacks enough second tier cities of sufficient size and clout; and Kent itself lacks a big city. I would like to see a Space Syntax like study commissioned which identifies the most appropriate location for a Kentish city of true city size and reach.

The River Thames itself is mentioned in the Report but I find it strange that the River Medway, a major Thames tributary in the area under study, is totally ignored. This needs to be rectified.

The Commission says that to deliver the Thames Estuary vision, development and growth, the area needs revenue raising powers, and to have tax and other, incentives to growth.

I worry about this:

1/. There isn’t sufficient tax base in these areas; the money ought to come from, and must come from, central Government;

2/. It is well known, and proven, that tax incentives such as Enterprise Zones displace activity and do not create it – we know this. There may be a case to displace existing and dispersed firms and activity to make them more efficient and to gain productivity and to make infrastructure viable; but we must be upfront that this is why we are setting up an Enterprise Zone, to rationalise locations, not to create new jobs. Some places will lose firms in order to grow productivity.

To close: in my view, in many ways The Thames Gateway hasn’t delivered its potential because of politics and its reliance on neo-liberal economics and ways of working. To overcome this we must be upfront about it, but the Thames Estuary 2050 Vision Report is silent about politics and political economic choices.

Without challenging the current political and economic orthodoxy (and all that goes with it, like Planning and Housing Policy) The Thames Estuary Corridor will not deliver its potential in either quantity or quality. A massive opportunity to make a step change in the quality of place making and economic vibrancy will be wasted and therefore people’s lives diminished.

This is much more than a shame.

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‘No amount of wishful thinking will allow private financing to replace public funds for critical types of infrastructure’.

I have long been a critic of the Public Finance Initiative and Public Private Partnerships, saying that these have turned into the most expensive way of providing buildings, infrastructure and services.

I have mentioned on numerous occasions that I am fed up with hearing the call for ‘Innovative Funding and Financing Solutions’, and have said that ‘Innovative’ usually means ‘the most expensive way of doing something’; and its use usually indicates that those calling for innovation can’t think of any solution because they are ‘banned’ by neo-liberal economic ‘orthodoxy’ from using the obvious and cheapest methods – government funding and financing via taxes, borrowing, or even money creation.

An example of my call to abandon the innovative funding guff can be found here with reference to the funding of public parks and open spaces –

So I was pleased to see an article from Maria Jose Romero of Eurodad which said that “Infrastructure cannot – and should not – be turned into an ‘asset class’ ”, and called on the G20 to abandon their intention and plans to develop an ‘infrastructure asset class’ for investors to invest in.

See here for Maria’s full article and her arguments –

In summary:

  • To attract private investment the risk is invariable transferred to the public sector (i.e. governments and their citizens) via guarantees and subsidies; so the public ends up paying more whilst taking the risk;


  • It must be recognised that the ‘infrastructure financing gap’ is in fact a public financing gap, and that no amount of wishful thinking will allow private financing to replace public funds for critical types of infrastructure.

In my view this applies to developed countries as well as to countries which still have plenty of development to do.

Anyway, I recommend that you read the whole article and follow the work of Eurodad and Maria on twitter @ma_jose-romero and @eurodad

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