LONDON PLAN a short summary
Boris Johnson has rewritten the London Plan
‘The Draft Replacement Plan’ sets out the direction of London’s development and growth from now until 2031. London Plan policies have a direct influence on vital matters such as housing needs, jobs, how London expands and what it will look like.
The plan will now be tested to see whether its policies are ‘sound’.
All across London development impacts on local communities who often find that their concerns are ignored. This is an opportunity to change and improve the legal policies that guide development.
The Examination in Public (EIP) of the Plan began on June 28th and the planning inspectorate is listening to detailed arguments on all the policies and issues, hearing evidence from those challenging the Plan and asking the GLA to justify their strategy.
The London Plan is important
It directly influences the local Borough plans: they must all conform with its policies and its direction. If the London Plan goes through unchallenged you will not be able to argue with the local strategy for where you live, on issues that the London Plan has fixed.
Find out about the ‘Local Development Framework Core Strategy’ on your council’s website. This is the set of Spatial Policies which will also drive your borough’s development over the next fifteen years. Many of the assumptions and targets in the Core Strategies are linked to the London Plan, for example the figures for housing growth.
The main direction of the London Plan is to plan for a predicted rise of 1.25 million people by 2031. It seeks provision of an average of 33,400 homes per year across London.
Questions being asked
Can local communities and the environment cope with increasing levels of urban development?
Will green space, small businesses and valued buildings continue to be lost?
How can health services, housing conditions and community facilities be improved for all?
How do poorer communities avoid being squeezed out by ‘regeneration’ and do the policies adequately consider the needs of vulnerable people?
Can the Plan accommodate long-term changes in the economy?
Is it too vague for real results?
What’s in the Plan?
122 policies form the basis of London’s planning regulations and cover the economy and employment, housing, open and green space, the built environment, transport, aviation, education, pollution, climate change, shops and town centres, health and infrastructure.
It divides London into planning zones: Inner London and Outer London; as well as the ‘Central Activities Zone’, ‘Opportunity Areas’, ‘Regeneration Areas’, Areas of Intensification’ and ‘Town Centres’, ‘Strategic Industrial Locations’, a strategic network of open spaces etc.
These zones have their own planning policies and redevelopment goals. For example, ‘Town Centres’ will expand in all parts of London and major development will expand into the Outer London boroughs (see how the area where you live has been classified below).
It also anticipates a change in age of the population (more younger and older people); persistent problems of poverty and polarization; a changing climate.
It intends London to continue being a ‘global city’, or business capital, while also improving Londoners’ standard of living and the places where we live.
It is a single pdf 284 pages long.
List of policies Pages 269 – 272
Housing targets for each borough Page 251 and Policy 3.3
Has your neighbourhood been classified as one of the areas below?
Opportunity areas and Regeneration Areas Page 213 and Policy 2.13
The Central Activities Zone Page 44 and Policy 2.10
Town Centre Network Page 237 and Policy 2.15, 4.7 – 4.9
See complete written versions under Just Space Submissions
There are many good things about the London Plan and we can all agree to its aspirations and many of its directions – but the small print in the policies does not always match up to these. Beneficial measures provided by development schemes are often only ‘suggested’ or are subject to a ‘flexible approach’. In effect this means that developers are not held to these measures and can sidestep them, allowing everything to continue as before.
Careful reading of the Plan is necessary. For example: The crucial issue of what proportion of new housing should be ‘affordable’ would now be left to the discretion of individual boroughs (Policy 3.12B) This means that the Plan’s aspirations for affordable housing are unlikely to be met, especially in some Outer London boroughs.
LONDON’S ECONOMY: SHOULD WE REALLY CARRY ON IN THE SAME WAY FOR ANOTHER 22 YEARS? Chapter 2, Policy 2.1
Looking forward to 2031 is as hard as looking at 2009 from the perspective of 1987. However some of the signposts are clear. There is an urgent need to alter the current way of planning for the future so that there is:
a) A value placed on the quality of life for all (both social and environmental impacts) rather than simply the economics of building and development
b) More economic diversity and less reliance on the financial and business services sector
c) Less waste and excess use of resources
d) Genuine community-led development and decision-making.
THE LONDON PLAN’S POTENTIAL
The London Plan should set the tone for an alternative vision for London, taking on a broader, fairer, more inspired set of considerations and values. The improvement of London in this way would bring a set of new benefits, new growth and new enterprise
HEALTH AND WELL-BEING Chapter 2, Policy 3.2
Health is not only affected by access to good healthcare: other factors affect health, such as low pay, social exclusion, your job or lack of a job, your housing, the environment. The London Plan should:
a) Understand how development growth affects health and well-being and prioritise health when making decisions
b) Chart the areas of deprivation to prevent further inequality. In some areas housing is a major cause of ill health through sub-standard housing and overcrowding
c) Single out crowded Inner London on housing issues – but some would argue there is inadequate housing on parts of outer London as well
d) Plan social infrastructure – schools, recreation and health facilities, community centres and so on – in parallel with new development and ensure this is sufficient to develop sustainable communities or communities that are supported.
OPEN SPACE Chapter 2, Policy 2.18 and Chapter 7 Policy 7.16 – 7.19
Open green space is strongly connected with our health and its benefits are free, therefore policy must insist on adequate open space provision and must outlaw all removal of open space. This should include courtyards and play areas provided for social housing as well as sports grounds and open spaces that are used as recreation areas. The Plan proposes a ban on building on the gardens of houses but there is no such protection for the collective gardens found on housing estates. Many of these get built over as part of “estate regeneration”.
HOUSING Chapter 3, Policies 3.3 – 3.16
Far more housing should be social housing, to meet the London Plan’s vision of an improved standard of living. The 20% reduction in affordable homes will be challenged. Boroughs must not be given the choice to set lower targets. More social housing is needed in ‘Opportunity Areas’ in outer London to balance the number of owner-occupiers. The GLA MUST impose bold social housing quotas on developers and boroughs, to meet the urgent delivery of affordable housing for those who need it most. The Plan should remove the get-out clause that allows developers to plead financial distress as a reason not to provide the housing that is needed. Boroughs should not exceed maximum housing density targets. Minimum space standards for new housing development are welcomed.
PLAY AREAS Chapter 3, Policy 3.6
The minimum space per child of 10sq m should be enshrined in policy. Provision of off-site play facilities and financial contribution should rarely replace on-site facilities. Play spaces should be sited in view of homes to create safer play areas.
EMPLOYMENT Chapter 4, Policy 4.12
There must be stronger measures to improve employment for Londoners, such as:
a) the protection and expansion of local employment
b) tackling wage inequality
c) the requirement to replace jobs lost through development / ‘regeneration’
d) the recognition of worthwhile employment
e) the obligation to provide more start-up and small business premises
f) the fostering of skills
g) protection of remaining industrial / manufacturing areas
h) recognition of the value of all jobs as a contribution to supporting the economy as against the prioritisation of certain “high value” sectors
i) support for flexible working hours. The GLA recognizes the lower job rates for women in London and must devise measures to improve their participation in employment.
j) more support for London’s community and voluntary sector enterprises as they actively provide routes to employment.
OPPORTUNITY AREAS, REGENERATION AREAS Chapter 2, Policy 2.13
The Plan continues to state that areas of deprivation or neglect need ‘regeneration’ yet it is increasingly clear that much ‘regeneration’ practiced in London produces very few benefits, and often adverse effects, for the populations living in these localities. London Plan policy should state that consent to development should be given only when it is shown that the established populations living in and around the areas will benefit and will not be subject to displacement or loss of livelihoods, facilities or community assets. The policies on local employment, green space, affordable housing and local business provision should all be tied into regeneration policy.
EXPANSION IN THE OUTER BOROUGHS Chapter 2, Policy 2.6 and 2.7
The Plan intends new expansion into the Outer Boroughs as a result of findings of the Outer London Commission. As above, the form and effects of expansion should be beneficial to the environment so that local populations are not compromised by this growth, for example the impact on local retailers and businesses caused by new large stores and offices.
There must be a more dispersed pattern of growth away from the centres, bringing lower rents, reduced travel and a higher quality of life. Local sourcing should be the norm (eg the London Food Strategy) and policy should support local procurement of services, creating stronger local economies within London. The Plan’s concept of ‘lifetime neighbourhoods’ needs to be expressed through strong policies to halt the closure of services, shops, post offices and other key services within walking distance of homes.
LIFETIME NEIGHBOURHOODS Chapter 7 Policy 7.1
The Plan’s concept of ‘Lifetime Neighbourhoods’ is positive in that it seeks to empower communities based around local shops, social and community facilities, streets, parks and open spaces, local services, decent homes and public transport and be accessible to all people of all ages. However the principle needs to be enshrined in policy to ensure these good aims are at the root of redevelopment schemes.
SMALL SHOPS Chapter 4 Policy 4.9
Provision and retention of small shop units should be a priority in London as they contribute to local employment and local economies as well as diversity and local distinctiveness. The policy should be strengthened to fully ensure that small shops are not compromised by development plans.
There is no specific policy for markets. They appear in text alongside Policy 4.8
Our street markets and covered markets must be individually recognised and supported in policy. They must be recognised not as cosmetic additions to areas, but vital as a source of healthy food, a source of cheap food, a social benefit, a source of independent business and local supply, and providing casual employment. The retail areas around markets, and their owners’ plans for development, must not be allowed to threaten the benefits and viability of the markets themselves. The present wording suggests that markets are only valuable where they draw shoppers into retail centres.
CYCLING AND WALKING Chapter 6 Policies 6.9, 6.10
Policies to encourage these are welcomed. There could be further binding policies or commitments to bring essential changes in our transport habits.
TRANSPORT Chapter 6
Public Transport: More night-time and off-hours staff on trains and stations are needed to improve safety and to encourage the all-round participation in London life. New development should be located on the public transport network that already exists or is planned and funded. The support for well-functioning neighbourhoods should reduce the general need to travel.
Cars: Traffic-generating developments should be rejected and the London Plan should clearly set out policies for reducing the volume of traffic on London’s roads. The public realm should also be more people-friendly and cars should not dominate.
Rail and Air: Rail travel should replace domestic air travel and make increased rail capacity unnecessary. The Mayor’s opposition to Heathrow expansion is welcomed but policy in favour of additional airport capacity should be abandoned. A Thames Estuary airport has no significant political support and would provoke widespread environmental and other opposition.
The aim of improving air quality by planting more trees is supported, but fewer cars are also needed: the extension of the congestion charge zone might support this aim. Developments should be required to work to sustainable best practice guidelines in their construction and demolition. (Policy 7.14)
CLIMATE CHANGE Chapter 5, Policies 5.1-5.22
Evidence suggests that we should be aiming ideally for a zero carbon economy and seek to create a demand for greener products, services and lifestyles. All new developments need to meet higher environmental targets right now. A clear, strong assessment is needed of the potentially damaging cost of the planned population expansion / increased energy consumption and major development growth. A lower concentration of growth in the centre of London would avoid creating a ‘heat island’. More interim targets between now and 2025 are needed to ensure London is on track to reducing its carbon emissions. ‘Retro-fitting’ our homes would make a significant impact on energy use and should be prioritized.
CONSERVATION, HISTORY AND LOCAL DISTINCTIVENESS Chapter 7 Policies 7.8, 7.9
The protection of historic buildings, conservation areas and locally important buildings should have stronger weight in policy. These should not be viewed as an obstacle to developers’ plans. The loss of local distinctiveness and historic fabric is a London-wide concern and should be given more policy weight in the Plan rather than appearing as an abstract concept. The re-establishment of viewing corridors, to protect historic views from being hidden by tall buildings, is welcomed. (Policy 7.11)
TALL BUILDINGS Chapter 7, Policy 7.7
The Plan states that tall buildings are permissible in a wide number of places: Opportunity Areas, Regeneration Areas, the Central Area Zone, Areas of Intensification and the new Town Centres. The negative social and economic impact of these buildings, and the environments they create around them, also need to be considered.
MINORITY ETHNIC GROUPS
The London Plan specifies problems facing black, Asian and other ethnic minority communities, especially in relation to a growing population – leading to increased housing demands, continuing poverty and unacceptable health inequalities. The policies in the plan are not enough to tackle these problems. Key issues include: 1) The Olympic Legacy – the BAMER communities in the East End have been left out 2) Improving Life Chances for All – a new definition for equality has been cited, but for what purpose? 3) No specific measures to tackle worklessness within these groups 4) No solid policy points behind the Mayor’s promise to develop high quality social infrastructure.
GYPSIES AND TRAVELLERS Chapter 3 Policy 3.9
The plan should accept the well-evidenced needs of Gypsies and Travellers, aiming to build the few pitches needed by the whole of London’s travelling community.
FUNDING AND DECISION-MAKING IN LONDON Chapter 8
For the improvement of London for all, the GLA / the London Plan must
a) identify ways to access new funds and funds that are accessible to communities
b) recognise the need for more power for local communities to make decisions
c) hold borough councils to the targets and aims set in the London Plan. Councils frequently ignore these. For example, two thirds of the developments built in 2009 had higher densities than the official maximum figure.