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.

NEW DRAFT LONDON PLAN

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.

Introduction:

‘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 ( http://www.gardenofideas.org/ ) 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.

Euston

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

  1. Pingback: draft London Plan: responses | Just Space

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