Recently the London Borough of Bexley published its Draft Growth Strategy for consultation. This is what I think and what I said.
“In general, the Draft Bexley Growth Strategy is an impressive document, as at a high level (which is what would be expected in a strategy document) in contains much of what would be expected in a strategy which is based on good urban design and place making theory and practice. Therefore most of our individual comments highlight specific areas where we wish to stress our support and flag-up where special attention is required in order to deliver the vision behind the strategy and the strategy itself.
The extent of Bexley’s future growth and the way in which it is to grow (for example densities) is already a given; based on policies which have and will come out of the GLA and The Mayor of London. However, for this be be fully accepted and embraced by the residents of Bexley, what actually materialises in Bexley must be of high quality; and the vision behind Bexley’s Growth Strategy, as well as the detail in the strategy which articulates this vision, must actually be delivered.
The Draft Strategy is ambitious and says many of the right things, but actual delivery at the standards outlined will require:
a strong and knowledgeable Planning Committee and Planning Department, and full Council, who are all prepared to be robust with developers and say where necessary ‘your proposals are not good enough and we will therefore refuse to give you planning permission or our support’;
in some circumstances direct intervention and delivery by Bexley Council, rather than hoping that outside developers and/or investors, and their ‘needs’, will coincide with what Bexley needs and what Bexley Council and its Growth Strategy requires.
We like and support much of the thinking behind the vision and strategy which is backed up by much research (internal and external), much of which we are familiar with: however, we feel that it is vital that others (such as Councillors and Developers) are made aware and understand that the Bexley Growth Strategy is based on this research and that is why certain things are being insisted on and must be delivered (for example how good urban design leads to good health outcomes). Therefore, we would like to see some sort of education programme developed and established so that Councillors; members of the Planning Committee; all of the Planning Department (especially the development control side which takes over once the strategic planners have done their work); developers and their agents, and the wider community, understand why we are insisting on what the strategy sets out.
However, having visions, strategies and policies is not enough: the resources and ability to manage and enforce these policies are vital.
We note that in a number of places mention is made to the strategy having to take regard to the ‘tough financial setting’. This is quite surprising: we are dealing with a document looking forward and covering 30 years – surely it is not being accepted that the UK’s economy will be facing a tough financial setting for 30 years?
What follows is mainly comments and responses to specific issues and points which are mentioned in the Draft Growth Strategy.
The draft growth strategy makes it clear that the presumption of high growth is premised on securing a major uplift in supporting infrastructure, particularity with regard to improved connectivity through better public transport.
We support this approach. However, this improved connectivity must not be focused solely on central London. For example, improvements to connectivity in the opposite direction, such as to Ebbsfleet; to the Medway Towns, to other parts of the Thames Gateway area, etc are also important to add flexibility and more options for Bexley residents in taking up employment. Likewise the local connectivity within the Borough and to neighbouring Boroughs is vital. It needs to be remembered that not everyone will work (or wants to work) in London’s Central Activity Zone. Therefore, we are pleased to see that the importance of these considerations is also recognised and highlighted in the Draft Growth Strategy.
The draft strategy says that Bexley’s schools are popular and Bexley is a net importer of children living in other areas particularly to secondary schools. We would like to see the London Borough of Bexley lobby central government to change schools admission and place allocation policies so that catchments are truly local so that most children can walk to their school. It is strange to talk about removing the need to travel yet school admission policy allows children to travel unnecessarily to school.
Flood Protection and Drainage
Much of the future development is focused in the north of the borough. Many of these locations are within the defended flood plain of The River Thames, protected by flood walls on the Thames. A study from The Environment Agency said that the existing Thames flood defences are ‘good’ for quite a few years yet but will eventually need to be strengthened.
We feel that the draft Growth Strategy needs to say more about tidal flood risk in these at risk areas. Although The Environmental Agency says that the existing defences are good for many years yet, beyond the end date of the growth dealt within the Growth Strategy, this is a probability based assessment and it is thus not impossible that the existing defences (and indeed future strengthened defences) are breached . The sort of things we think need to be included in the Growth Strategy are:
the need to protect critical infrastructure should flooding occur;
the splitting of the areas into zones so that successive defences have to be breached should the main defences be over-topped.
It is not our place here to suggest detailed proposals but the strategy needs to give this more thought.
Although the need for Sustainable Urban Drainage Systems (SuDs) is covered in the Draft Growth Strategy we feel that the requirement and expectation for these needs to be strengthened. We feel that saying things such as there is ‘an expectation’, or ‘were possible’, is not strong enough; instead it needs to be said that each of the growth locations and sites ‘must’ have a SuDs strategy. As Area Action Plans (or similar) are drawn up for each area these must include details of the strategic SuDs strategy into which individual development sites’ SuDs can plug into.
The words about SuDS need to be put into practice. As an example, and at a smaller scale, it is disappointing that no SuDs systems or features have been incorporated into any of the recent highways and public realm works in the centre of Bexleyheath.
Core Industrial Areas
This is one of our greatest areas of concern because one of the most difficult things to do is to predict and plan for how the future of work and employment will actually play out in practice.
We note that ‘core industrial areas retained for employment uses will be improved and intensified, fostering the Makers Movement’. We think the ‘Makers Movement’ is very interesting and ought to be incorporated into the strategy but there is no certainty that it will work as a major part of the employment and industrial strategy. We support the policy, and wish to encourage it, but all of Bexley’s employment eggs shouldn’t be put into this basket.
Furthermore, we think that the Makers Movement cannot be left to the market alone, and requires the active support of the public sector, with The London Borough of Bexley playing an active role in setting up such things as Fab-Labs and seeing them into maturity. However, this will require an entrepreneurial approach and not a bureaucratic one and also not a property development approach. There is also a role for the third sector in the Makers Movement.
We note that the growth strategy wishes to see new engineering and manufacturing business established in Bexley. However, at least a proportion of these businesses require cheap and affordable premises which can be at odds with the property investors and developers who are looking for high rents and high land values for their completed developments. We would like to see some of the employment areas owned and run as Cooperatives, or owned by the business located there, and not to automatically expect property developers and institutional or other investors to be in charge. Too often change is built around the standard model of property development where money is made through property trading and being rentiers rather than long term entrepreneurial activity on the part of the landowner.
All employment areas must be fully integrated into the wider and local areas, not cut off physically or psychologically. They must be visible to surrounding areas, permeable, and have some form of mixed-use. The model of isolated business parks and industrial estates is less and less acceptable to modern businesses and those who work in them. Likewise a high level of environmental quality is now required. We are pleased to see all of this reflected in the draft strategy but it is vital that the words are actually translated into action on the ground. A good quality environment in employment areas need not be expensive, and should be expected as normal.
We are pleased to see the encouragement of co-living and co-working environments, and of ‘fab-labs’. We would point out that fab-labs do not necessarily have to be in employment areas, and at least some should be elsewhere such as in town-centres (perhaps in those parts which need ‘consolidating’) where ‘normal’ people can see and discover them.
There seems to be a conflict between the Mayor of London’s policies and those in the draft strategy. On page 53 the draft strategy says ‘the London Plan identifies Bexley to be a strategic outer London development centre with strategic functions including logistics’. However, this doesn’t match Bexley’s strategy of high density employment developments: logistics uses are of low employment density. We prefer Bexley’s strategy of high-wage high-density employment uses.
The Regeneration and Development of People as well as Places.
Much of the growth, change and development in the Draft Growth Strategy is located in the north of the Borough of Bexley, which is usually thought of as being the poorer part of the borough.
Therefore we would wish to see action to ensure that change, growth and development happens with the existing population and not done to them. It is imperative that the existing population see (and have) a place and role for them in the existing places regenerated and the new places created. In this way it will make it easier to welcome and integrate the new population which is expected to be attracted to Bexley. This actually applies to all existing communities in all parts of the Borough, but is particularly important in the north where many already feel that the south of the borough is off-limits to change and intensification.
Housing and Housing Tenure
We are very disappointment that we didn’t find any mention of increasing the provision of social rent. ‘Affordable’ has become increasingly unaffordable for many people. The shortage of social renting is mentioned in the draft strategy, but there seems to be no requirement to increase the supply of social housing. It must be recognised that for some people social tenure, at social rent, is the only viable tenure and it needs to be planned for as part of a strategy. We would also like to see it acknowledged that security of tenure (in all tenures) helps to create secure and sustainable communities which is a declared aim of the growth strategy.
It is mentioned that half of all tenants in the private rented sector are in receipt of housing benefit. We would like to see a strategy to reduce this public subsidy to the private sector.
We are pleased to see it specified that ‘new homes must be high quality, attractive and accessible, designed to meet residents’ needs now and as their needs change over time’. However, we would like the strategy and policy to be explicit that new homes must be designed in a way that allows for future change, adaption and extension.
The need for digital infrastructure is mentioned, as it is in many other Local Planning Authorities’ vision, strategy and planning documents. However, we wish to see more information and detail about what this really means and how its delivery will be ensured.
We note that dark fibre is mentioned but who is going to fund and deliver it; who is going to light it up, who will it be owned and operated by?
We believe that it is not enough to plan for what today is called high-speed broadband (with speed and capacity unspecified in the strategy as to what counts as ‘high-speed’). Instead at least one generation needs to be skipped with ultra-high speed broadband being required as minimum, with the capacity and capability to be symmetrical.
We would like to see digital infrastructure based around an OPLAN (Open Public Local Area Network) approach rather than depend on the investment priorities of the usual utilities.
Consolidation and Comprehensive redevelopment
The words ‘consolidation’ and ‘ comprehensive redevelopment’ are used in the Draft Strategy.
This raises a number of issues with which we are concerned.
Consolidation of Uses: (for example within employment areas, and within town centres):
It is vital that during or because of such consolidation existing and viable business are not lost; so we would like to see a properly thought through retention and relocation policy and strategy. We wish to see it recognised that existing businesses may be viable and useful but become unviable and be lost if the only premises available in areas to be relocated to are too expensive. It may be argued that in the long-run it is better than low value businesses, which can only afford cheap premises, are lost; but in the short-term this is someone’s job or livelihood no matter how ‘marginal’ it may be. People and businesses need to be helped to move from the short-term into the long-term.
Comprehensive redevelopment: (for example, ‘there are existing residential areas with the potential to deliver higher density housing through comprehensive redevelopment’). We must be very careful to not mention comprehensive redevelopment as if there is no-one currently living, and making a life, in these places. It is imperative that a detailed, genuine, and meaningful community engagement process is undertaken in these areas from the earliest stages; before any sort of plan has been made. It must be recognised that Public Consultation is very different than Public Engagement, and to comply with Government guidance and policy there must be proper Public Engagement.
Transition, Flexibility and Temporary Uses
We are pleased to see the draft strategy talking about the need for temporary uses for sites as they change and are developed and re-developed over the years. We would like to see there being a requirement for each site to have a temporary use strategy covering the transition period as it moves from ‘now’ to its potential ‘end state’ in say 30 years time. Derelict, empty and poorly maintained sites and buildings which blight neighbouring areas should not be acceptable as part of the development process. We also support the related policy of densities of sites and areas changing over the years as new infrastructure comes on stream to support these higher densities.
Green and Blue Infrastructure
We are pleased to see the importance of green and blue infrastructure mentioned in the draft strategy, and the importance of them being multifunctional, and integrated, through the whole of the borough and the wider environment.
However, it must be recognised and accepted that the best organisation to own and manage most open space is the Local Authority. So called innovative funding solutions are actually the most expensive way of funding things and so, in the main, must be resisted.
We are pleased to see that the draft strategy requires the protection and enhancement of the natural environment and stresses the importance of enhancement of biodiversity and the natural environment in all development proposals.
Too much is reliant on developers, and inward investors, investing in land and property in the borough. Land must be seen as a means to an end and not an end in itself. Bexley needs to attract productive investment not the investment of rentiers who like to take largely unearned income.
We are very concerned to read the following in the draft strategy ‘…balancing the need for quality with the need to ensure development is financially viable’. We must be very careful not to fall into the viability trap – the end use of a site or building determines land values, and land value must be the residual in any viability calculation not what can be spent on infrastructure or affordable housing.
We are glad to see that the draft strategy accepts that there may be a place for Bexley Council to exercise its CPO powers in order to assemble land. When this is done the Council must ensure that it takes a share of the profits from the development as a reward for taking part of the risk and enabling development.
Bexley Council must make it clear, through policy and actions, that they are not willing to let footloose investors buy-up development sites and then leave them empty for prolonged periods of time.
To deliver the vision and strategy set out the London Borough of Bexley must not cave in to developers and development which fail to meet the required standards and policies. They must be prepared to say “no” at times.
We are surprised that there is no mention for the requirement to incorporate and use artists into the developments. We think there should a ‘percent for art’ policy incorporated into the strategy.
The ‘potential to develop a decentralsied energy network’ is mentioned. This needs to be stated in stronger terms than this – a decentralised energy network is an imperative if zero carbon requirement are to be met. There must be a Borough low-carbon energy plan.
We are pleased to see the importance to which the strategy attaches to culture and leisure facilities. However, we would point out that the more cultural and leisure facilities are to be provided via private and third sectors (thus ‘paid for’), the more vital it is that informal leisure and cultural facilities are made available for those who can’t pay for their leisure and culture.
On page 45 of the draft strategy it says ‘Innovative approaches will be pursued to identify potential funding including fiscal devolution to enable the capture of local land value uplift’. This worries us: ‘innovative’ funding; is usually more-expensive funding, so we would like to see the use of traditional but cheaper funding models lobbied for instead.
We would like to understand in greater detail what is exactly meant by ‘capture of local land value uplift’. We are in favour of capturing the uplift in value of development sites but not the general uplift in value for sites not being developed, especially when they are existing residences. Stability of communities is vital and some means of land value capture can potentially force out long-term residents. We would also like to see the financial modeling which proves that Bexley can be fiscally self-sustaining before such fiscal devolution is lobbied for.
In general, the words we have read in the draft strategy are good words, what we would expect to see in a strategy based on good urban design and place making principles, but are they believable and will the words be followed through into delivery?”