I have just submitted our response to the London Borough of Southwark to its draft Area Action Plan for the Old Kent Road Opportunity Area. This is what we said:
CONSULTATION RESPONSE TO OLD KENT ROAD DRAFT AREA ACTION PLAN
“Southwark Council’s vision for Old Kent Road Opportunity Area talks about the Old Kent Road becoming a high street with shops, cafes, restaurants, leisure, and other facilities, with residential homes above. However, there seems to be no mention of the Old Kent Road being a major road transport route into central London and how this will be dealt with in the future: there is mention of public transport and, quite rightly, its increasing importance as the area intensifies, but it ignores the private transport which will in the future continue to use the Old Kent Road as a mayor route into central London from the edge of and beyond London.
The Draft Area Action Plan talks about the Old Kent Road itself be transformed into a modern boulevard. We wish to see more details supplied about how the character of the road and its buildings will change, and how this will be obtained, in order to psychologically break up this road to those travelling along it. As a long road it should be different in character at the northern end (where it is 1 mile form London Bridge) from the southern end (where it borders Lewisham) – the character needs to show transition from being a part of central London to the edge of the inner suburbs, and there needs to be a succession of ‘landmark’ buildings to provide legibility and visual clues to provide a sense of journey for those travelling the length of the road. We need more information on how the Old Kent Road will remain a mayor road route into central London whilst improving environmental quality.
The Draft AAP mentions new links stitching together neighbourhoods on both sides of Old Kent Road, but these links must also extend into the neighbouring Action Areas and Opportunity Areas (for example, Ayslebury Action Area; Peckham and Nunhead Action Area; Lewisham, Catford, and New Cross Opportunity Area; and the Bermondsey Action Area). We would like to see these links being planned for, considered and co-ordinated at a pan-Action and Opportunity Areas level. These links are especially important for pedestrian and cycling routes in order to encourage and enable modal shift for relatively short journeys.
The Draft Area Action Plan talks about heritage buildings and parks being sensitively incorporated into new developments thus enabling the story of Old Kent Road to be better appreciated. This aim and aspiration must be taken seriously; developers must not be allowed to water-down or avoid this aim by claiming ‘viability’ issues. In addition the definition of historic buildings must not be restricted to only those which are ‘Listed’. Furthermore, good urban design depends on a range and mix of building ages so large scale demolition must not be allowed. In general, we feel this policy is too weak and allows profit maximisation to trump heritage-led regeneration and place making.
The Draft Area Action Plan talks about new Parks at Mandella Way and the gasworks, and of a green route on the alignment of former Surrey Canal. It strikes us that the route of the Surrey Canal could be reinstated to form part of an area-wide and integrated Sustainable Urban Drainage (SuDS) strategy and we would like to see the feasibility of this explored. In any event there needs to be, and we would like to see, an area-wide SuDs strategy which is integrated with green infrastructure in order to deliver a Blue-Green Grid. This Blue-Green Grid and strategic SuDs strategy should also be integrated with neighbouring Action and Opportunity Areas.
The Draft Area Action Plan talks about the need for environmental sustainability including district heating networks to reduce carbon emissions; measures to tackle poor air quality, and SuDS to reduce flood risk. As previously mentioned in this response, there needs to be an integrated, area-wide, SuDs strategy: leaving developers to respond to urban drainage on a site-by-site basis will lead to sub-optimal solutions, and opportunities for integrated land use (eg Blue-Green Grid) will be lost. Likewise, District Heating or District Energy Networks should not be left to individual developers, nor should it be assumed that this must be delivered or operated by the private sector – it could be community owned, and community ownership can help to provide ‘buy-in’ from the local community.
There are around 9,500 people working in the Opportunity Area in some 750 businesses and other organisations. There is an existing population of around 32,000 – with 43% of the population born outside of the UK. Deprivation is high, with several areas in the most 10% deprived wards in the country. There is a lower level of full-time employment than elsewhere in Southwark and higher proportion in lower skilled occupations. It strikes us that the Old Kent Road Opportunity Area is being developed without sufficient regard to the opportunities for these people and businesses, and with too much regard to the opportunities afforded to investment capital. Re-development of Old Kent Road needs to be approached so that it works for people, the environment and productive business – instead of being seen as a way of making returns for rentiers (i.e. not as a means of sucking rents, commercial and residential, out of the area and the profits being spent elsewhere). In short, the plans seem to be too focused on property development, and the needs of property developers, and not enough on the development of people. This needs to be rebalanced, and one part of this rebalancing needs a strong, integrated and ambitious education and skills system to be put in place now – in advance of the property development.
The Draft AAP talks about the need to consider affordable work-space (especially for existing businesses) but we consider that leaving this to the market (via hope and Planning Conditions) will be insufficient. Innovative solutions and approaches, such as social rented work-spaces, and opportunities for self-build owner-occupied workshops, must be considered. We would like to see exploration of owner-occupation provision regarding employment space in general. Managed space may be too expensive, and the strategies being adopted for the provision of work-space seems to repeat the faults of many high streets, with a few large-scale landlords who can dictate rental levels rather than operating in a true competitive market for rents.
Landownership in the core Opportunity Area is very fragmented and many sites are subject to long leases. Therefore Southwark Council must be prepared and resourced to use its CPO powers robustly. In addition, sites and buildings must not be left empty and unused during any land assembly process and prior to development, so there must be a temporary use strategy drawn up, put in place, and actively implemented.
The Old Kent Road area is, in some parts, characterised by retail sheds with large car parks – this suggests there is demand (or need) to use cars for shopping by the existing community, but the Draft AAP seems to be silent on how this demand will be transformed to being able to shop without cars.
The design of each neighbourhood must be done in such a way that is not seen as the sole ‘property’ of that area and everyone has the right, and expectation, to pass through and visit. Good Urban Design principals must be used to ensure there are no enclaves.
The Draft AAP talks about the need for new homes to help foster mixed communities and include a range of sizes and mix of private and affordable homes, including council homes. We believe that the scale of need for social rented homes has not be recognised in the Draft AAP, and so there needs to be a robust plan for the provision of large scale Council Housing (in the old fashioned, accepted, sense of the term). There also needs to be a proper definition of the term ‘affordable’ and one which most ordinary people would accept as ‘affordable’.
We consider it vital that OKR AAP Area is well planted with trees, especially street trees. Very tall trees (such as London Planes) can reduce the apparent scale of tall buildings and high density. Trees are also useful in controlling and mitigating the effects of climate change. The width of pavements along some of Old Kent Road is enough to allow for planting (possible as part of a rain-garden); building large buildings right up to the pavement line should be avoided – this is already being seen in new development on Old Kent Road and it doesn’t add to the attractiveness of the road and is wasting opportunities.
The Draft AAP says that residential neighbourhoods will feel like central London with high densities which benefit from improved public transport and proximity to local facilities. We wish to see much more clarity about what is meant by this – Central London has a range of densities very often in the same neighbourhood. It is also doubted whether the level of connectivity really will be comparable to central London (which varies within itself in any event).
The Draft AAP says that developments of 10 or more homes will provide a minimum of 35% affordable housing, ‘subject to viability’. Firstly, we wish to see a firm definition of ‘affordable housing’, and one which most ordinary people would recognise as affordable. Secondly, we wish to see the phrase ‘subject to viability’ removed. Southwark Council must have a policy and stick to it: with due notice of the policy there is no excuse for this requirement not to be viable – flexibility will encourage developers to over-bid for land and then claim it is not viable to deliver your policy. It should be noted that Southwark’s evidence shows that they really need half of all new homes to be affordable, so why not make this the requirement? Additionally, it is risky to depend on the private rented sector to supply some of the affordable homes without considering in the strategy what happens when the Government’s policy of reducing support for Housing Benefits is rolled out over the years.
The draft Area Action Plan talks about a Public Realm Strategy: it must be noted that the whole length of Old Kent Road must have public realm improvements – not just have ‘key public realm improvements’ as indicated in the draft AAP.
The draft AAP contradicts itself by saying that large buildings and sites are impenetrable but then says that smaller blocks constrain the need to provide higher densities or tall buildings. There is no mention of the need for good Urban Design to be based on short-blocks as well as active frontages – also ‘natural surveillance’ is just as important as activity generating functions.
We cannot see the point or legitimacy to talk about ideas to ‘potentially remove the flyover’ without a proper transport and movement plan being carried out to show what alternatives are possible and viable.
The draft AAP talks of tall buildings enabling more public realm to be provided. We maintain that this therefore means that the area must have:
i/ High quality public realm
ii/ Usable public realm;
iii/ Strong management and maintenance arrangements
iv/ Money to maintain to high standard.
This ‘theory’ (that tall buildings ‘enable’ more public realm) has been advanced in the past (in the residential high rise of the 1960s and 1970s), and too often it doesn’t work in practice because resources for management and maintenance of the public realm are not provided (or are not affordable by the residents). Before we can support a policy and strategy for tall buildings in order to provide high-density we need to be convinced that the mistakes of the past are not being repeated.
The draft AAP talks of ‘Rising land value’ because of competition for existing space or alternative land use. This rising in price for alternative land use can only crystallise through the Planning System, and Planners should not allow speculators in land to dictate land use – we have a Planning System to balance competing uses for the benefit of society as a whole, and Planners must use the Planning System for its intended purpose. It is not acceptable to argue that because someone can make more money by using any particular site for another (different) use that this is sufficient reason to do so.
The draft AAP talks about the vital importance of having High Speed Broadband infrastructure in place, but it is a mistake to assume that the market will provide it. The AAP ought to have a requirement for all developments to have Symmetrical Ultra (or even Hyper) High Speed Broadband with Fibre to the Premises in place. Developers must be made to ensure that the infrastructure is in place, and as a very minimum there must be a Fibre-strategy of having ducts in place linking sites to Points-of-Presence. Planning conditions must be used to achieve this.
We feel that Appendix 2 which talks about how to achieve mixed use, and offers a ‘design guide’, is very clunky and not clear, and therefore needs re-working.
Generally, we feel that the Old Kent Road Opportunity Area is being approached in a way to service central London rather than treated as an area with its own vision and sense of place – what is OKR’s Sense of Place, its Genius Loci? We don’t see anything in here which will make OKR Opportunity Area anything different or distinguishable from an extension of the global property development model of central London. Central London is increasingly becoming (despite the warning about cities becoming so) an international style, ‘any city’, which lacks distinctiveness. As currently proposed OKR AAP seems to extend this blandness (created for the benefit of foot-loose international investors rather than local populations and economies) from central London hot-spots into edge of the city areas. It lacks ambition for people and is overly concerned with the property development model of urbanism. Flourishing places require the mingling of high yield, middle-yield, low-yield and no-yield enterprises, but the model chosen for the development of Old Kent Road Opportunity Area seems to be aimed disproportionately at the high-yield international property development model”.