-Friends of the Earth (FOE)

January 2010 (minor correction April 2010)

Thank you for this opportunity to feed into the revisions of the London Plan (LP), together with the Mayor’s Transport Strategy (MTS) and the Economic Development Strategy (EDS).

While there is much to be welcomed in the new drafts, we set out below some of our main concerns on some key points, and also refer you to our submissions to “Planning for a better London” and to “Way to Go!”.

We respond to the draft LP primarily but this response also makes reference to the MTS and EDS drafts, and the same response will be submitted to all three consultations.

Executive Summary

Chapter 1:

– the Government context of the need to pursue sustainable development should be set out, particularly the guiding principle that “achieving a sustainable economy” must be met together with other guiding principles including “ensuring a strong, healthy and just society” and “living within environmental limits” in an integrated way (Sustainable Development Strategy 2005) – and this overarching imperative to develop sustainably needs to be put into practice and be the basis for the Plan as required in PPS1.

– the ongoing difficulty in reducing inequalities and reaching environmental targets needs to inform plans for how the economy is developed – including whether the assumptions made and predictions on growth in jobs (and the economic sectors these would take place in), population and housing are sustainable.

– London must develop a sustainable economy – not pursue growth at any cost, but rather only develop the economy in ways that build a just society and reduce inequality, and so that we live within our environmental limits including on climate change and air quality.

– the objectives need to be revised in light of the above, bringing social and environmental requirements into all objectives. For instance the development of a low-carbon economy should apply to the economic objectives rather than just part of objective 5 (it is the whole economy that needs to be low-carbon). They should also reflect the need to deliver on the social and environmental aims and targets, not just move towards achieving them.

Chapter 2 – London’s Places

– Development and regeneration must take place in a way that actually delivers on key social aims (including particularly impacts on existing communities) and so that environmental targets are met – these must determine whether, and if so how, proposals are taken forward.

– Outer London must contribute to the sustainable development of London, encouraging people to live and work there, with a focus from the most local level upwards, thus also maximising access to jobs and services through walking and cycling. Car dependence needs to be addressed and not exacerbated through relaxed car parking standards or new vehicle river crossings.

Chapter 3 – London’s People

– As well as meeting the needs of all Londoners (including for adequate low-cost rented homes), housing must play its part in delivering a sustainable London – and retrofitting programmes will need to be mainstreamed to achieve environmental targets.

Chapter 4 – London’s Economy

– London must develop a sustainable economy that delivers on social and environmental aims – and the measurements of success will need to encompass these other factors. To this end London will need to do more than envisioned to diversify its economy both in terms of the sectors and geographical location, and must become a low-carbon economy overall, not just have a few low-carbon businesses and a Green Enterprise District in the Thames Gateway – the latter should be replicated elsewhere.

– the EDS’s objective 2 is to “ensure that it has the most competitive business environment in the world” but acknowledges pollution and quality of life problems work against this, and must be addressed, as should high staff and office costs which are also a deterrent to investment.

Chapter 5 – London’s response to Climate change

-mitigating the worst effects of climate change as well as adapting to it’s expected effects must underpin, and need to be integrated across, the whole London Plan and associated documents.

– The Integrated Impact Assessment (IIA), page 105, shows an increase in CO2 from 44 million tonnes in 2003 to 47.5 million tonnes more recently (the latter figure is taken to be the 2006 LEGGI figure), and Chapter 5 states that CO2 is expected “to increase with London’s expected growth by 15 per cent … by 2025, if no action is taken” (paragraph 5.13).

-it is welcome to see the Mayor’s current target of a 60% cut in CO2 by 2025 from 1990 levels included in London Plan policy, and that “The GLA will monitor progress towards its achievement annually”, but interim targets are needed to help check progress, and the 4% annual target from the previous Climate Change Action Plan, or an updated one, need to be adopted. There needs to be commitment in the London Plan to keeping targets up to date based on latest science and Government advice.

– it needs to be set out whether all sectors will play their part and meet the target of a 60% cut or whether some will do more or less – transport is currently only on track to deliver a 10% cut.

– reference to the need for boroughs to produce policies consistent with the 60% cut target is welcome, and will be needed.

– the statutory Climate Change Mitigation and Energy Strategy (CCM&ES) is not available yet, but measure proposed in its precursor such as building retrofitting, and also low-carbon zones, are likely to be needed to be mainstreamed in order to meet targets.

– the figure of 20% of energy from renewable sources that new developments should reach must be put in the relevant policy, not just the text.

– adaptation to climate change is a key issue the Mayor and GLA need to engage the public, to help give them the mandate to take adequate action to mitigate climate change.

-on waste, self-sufficiency targets must be reinstated, and recycling rates increased with only real residual waste being used for other treatments. Anaerobic Digestion is strongly preferred as a treatment treatment as opposed to thermal ones.

Chapter 6 – London’s Transport

-transport is only set to achieve a 10% cut rather than the 60% needed if it is to play its full role, and it is admitted that “a gap remains”.

-to fill the gap the possibility of road user charging has been kept open, but the Mayor proposes to scrap the existing western extension to the congestion charge (WEZ) which has clear benefits and should be kept – while congestion is due to rise by 14% despite planned measures and public transport improvements. The WEZ also provides revenue which would be lost, at a time when public transport fares have gone up.

-the Mayor should also reconsider introducing the CO2-related congestion charge.

– in light of difficulty meeting air quality targets the 3rd phase of the Low Emission Zone (LEZ) should not be delayed.

-the inclusion of reducing the need to travel is welcome, but road traffic reduction targets must be brought back into the main documents (they are only in the key performance indicators now) and made stronger, and parking standards in outer London must not be allowed to be relaxed.

-road building criteria must not be relaxed as is proposed and no new large roads or vehicle river crossings allowed – these would add to traffic and associated problems in the area, as the Thames Gateway bridge showed, including increased congestion. In light of climate and air quality targets, as well as for local people who already suffer disproportionately, problems must not be unnecessarily made worse. New vehicle crossings were not a manifesto commitment and instead public transport improvements should be pursued for any further capacity needed.

-on aviation, further runway capacity or flight increases must not be allowed – London’s competitive position should not overide the negative impacts especially in view of the difficulty in meeting climate and air quality targets, and pollution has been shown to decrease competitiveness anyway.

-opposition to growth at Heathrow is welcome, but should apply to City Airport too where local people already suffer a poor environment.

Chapter 7 London’s Living Places and Spaces

-on air quality there has been insufficient certainty on measures to reach required EU targets, and proven measures are proposed to be replaced by uncertain ones. Further measures that would make matters worse such as vehicle river crossings and more flights at City airport should not be progressed.

-the benefits of provision and protection of natural habitat and adequate open space needs to be made clear in the London Plan.

Integrated Impact Assessment

– we have strong concerns over the IIA assessment being inadequate including on not considering alternatives and on the equalities assessment.

Mayor’s foreword

While there are some welcome words in what the Mayor says, the Assembly draft foreword had a stronger statement: “Throughout these three key strategies we have sought to place environmental sustainability at the heart of our approach because job security, energy security and climate security are all interlinked and must inform our policies on housing, transport and quality of life”. This was a good recognition of the overriding importance of sustainable development and how it should underpin the policies of the London Plan.

We have commented before, and set out again that we consider the London Plan must set out the national policy context for the LP, not just of the GLA Act and Government circular, but of Planning Policy Statement 1 (PPS1) which states that “sustainable development is the core principle underpinning planning” (page 2, objectives for the planning system, No 3). PPS1 also empowers the contents of the Government’s Sustainable Development Strategy of 2005, the SDS 2005 (through paragraph 13, part (i)). The LP should also refer to this, which in turn emphasises that the guiding principle of “Achieving a sustainable economy” must be met together with other guiding principles including “ensuring a strong, healthy and just society” and “living within environmental limits” in an integrated way (chapter 1).

Chapter 1 – Context and Strategy

The overarching imperative to develop sustainably, as set out above, needs to be put into practice and be the basis for the Plan. There is welcome reference to sustainable development at the end of the conclusion to this chapter, but the concept does not underpin all aspects and areas of the LP.

This chapter seems to set out a not dissimilar philosophy to previous iterations of the LP with assumptions and predictions about population and economic growth and the dominant sectors of the economy, including that the prevailing forces are expected to continue and cannot be effectively influenced. However this LP draft has perhaps more caveats about whether these assumptions and predictions are so, which is welcome, but these need to lead to radical and ongoing reassessment. The Mayor has given welcome attention particularly to whether the potential for outer London can be better fulfilled, but there is still not sufficient follow through. Yet several factors could actually change – for instance migration patterns (and indeed there have been recent moves to decentralise Government personnel), but the case for national spatial planning that could influence population in London has not been set out.

The sections “persistent problems of poverty and disadvantage” (page 19) and “A changing climate” (page 21) for instance show that the existing plans have not been delivering a just society and that we are not living within environmental limits. The LP needs to show how its proposals will deliver on these aims and targets or should prompt reconsideration of the current assumptions and predictions on population and economic growth and the sectoral and geographical nature of the London economy.

The admitted “persistent problems of poverty and disadvantage” continue despite being recognised and supposedly being addressed over a number of years – indeed it is admitted that “London is an increasingly polarised city” (1.25) – and the LDA’s economic snapshot has shown ongoing problems with disadvantaged areas and groups. The way the economy is being developed is not delivering a “healthy and just society” but it must do so, and the LP needs to set out how this will be achieved and whether more of the same approach is going to bring the changes needed, when it has not up to now, or whether a change of approach is needed.

Equally with reference to “A changing climate” more robust policies and new solutions are essential for achieving the Mayor’s current target of a 60% cut in CO2 by 2025 on 1990 levels, and for adapting to climate change. It is clear however that we are not “living within environmental limits” as the SDS requires – the Integrated Impact Assessment (IIA) page 105 shows an increase in CO2 from 2007, and indeed Chapter 5 states that CO2 is expected “to increase with London’s expected growth by 15 per cent … by 2025, if no action is taken”. The LP will need to set out how targets can be met in these circumstances, or whether more fundamental adjustments and reconsideration are needed. London will inevitably need to develop overall as a low-carbon economy however to deliver on the reduction target.

With regard to “Ensuring the infrastructure to support growth” (LP page 22) this will need to contribute to the delivery of the just society and that we live within environmental limits (there is no place for infrastructure that unnecessarily worsens problems) and the LP must set out how this will be achieved. Transport is not currently on track to deliver its part in meeting climate change and air quality targets, but must do so or other sectors will need to cut deeper.

Figure 63 of the MTS makes clear that there is “increased congestion by 2031 as a result of growth in employment and population” and that it is only partly offset by crossrail, investment in the tube etc and increased cycling – still resulting in a 14% increase in congestion. This increased congestion in turn is a problem for, and a deterrent to, business. This issue should also prompt a reconsideration of assumptions and predictions.

With regard to “a new focus on quality of life” (LP page 23), the LP will need to set out how it will deliver on reducing health inequalities and on meeting air quality targets, or whether more fundamental changes are needed.

Conclusion:

The “Conclusion: planning for growth” (paragraph 1.45) states that “for the most part it is not a question of choosing growth”, which implies there is an extent to which it is a question of choosing growth – but this should only take place if it can be sustainable.

London must develop a sustainable economy – not pursue growth at any cost, but rather only develop the economy in ways that build a just society and reduce inequality, and so that we live within our environmental limits including on climate change and air quality.

The Mayor’s objectives (page 27)

We welcome the positive intentions expressed, we are concerned that the objectives as currently set out will not deliver sustainable development. For instance Objective 1 unnecessarily refers to economic growth (“a city that meets the challenges of economic and population growth”), and only states that this should be in ways that “helps tackle the huge issue of inequality among Londoners…” whereas this needs to be delivered on, not just worked towards. On objective 5, the environmental objective should be that London is on track to deliver on science based targets, not just moving towards them.

In respect of the above, we refer you to the paper by David Fell “A Sustainable Economy for London” which we fed in to, and endorse, and which critiques present weaknesses in the London economy and sets out the kinds of changes that might be needed. The paper asserts that the nature and extent of the recession, the scale of the climate change challenge and the deep-rooted inequalities mean there is both the opportunity and requirement for “a break with the past” and that de-coupling economic growth from the negative environmental impacts is unlikely to produce the low-carbon future needed.

Chapter 2 – London’s Places

Development and regeneration must take place in a way that actually delivers on the key needs to reduce inequality and other social aims, and meet environmental targets – these must determine whether and if so how, proposals are taken forward. This applies to large mixed schemes, to housing development, to whether and what transport infrastructure is developed to deliver the accessibility needed etc. The impact on existing communities (in terms of how unemployment is aleviated, housing, amenities etc) is of particular importance.

Outer London (page 35) must contribute to the sustainable development of London, enabling as many people as possible who live there to also work there (thereby reducing pressure on commuting routes to central London and reducing environmental impacts). Further, Outer London needs to be developed in ways that access to jobs and key services can be achieved by walking or cycling as much as possible, to be supplemented with public transport for longer journeys. A dispersed model of economic development rather than concentrating on a few centres will produce more sustainable results, and attention should focus from the most local level up to larger centres.

To complement the above, and for Outer London to play its part in transport’s contribution to the sustainable development of London, dependence on the car will need to be addressed. Further facilitation and encouragement of car use will make targets harder to achieve. Parking standards should not be relaxed (see below on Chapter 6), and no new large road building must be allowed, particularly any vehicle river crossings – policy 2.8 on outer London transport, point ‘g’ should make it clear that “road improvements to address local congestion” does not include any new vehicle river crossing development.

Chapter 3 – London’s People

As well as meeting the needs of all Londoners (including for adequate low-cost rented homes – through more council-built housing if needed), housing must play its part in delivering a sustainable London. Without the CCM&ES it is hard to tell how close the sector is expected to get towards achieving the targets needed. Measures outlined in “Leading to a greener London” eg on retrofitting (which have started to be rolled out), must need to be mainstreamed to ensure that the sector contributes fully to the required levels of emission cuts.

Chapter 4 – London’s Economy

We refer to our comments on Chapter 1 above and the David Fell paper mentioned, which relate to the economy. London must develop a sustainable economy that delivers a just society and reduces inequality, as well as one that meets environmental limits – and the measurements of success will need to encompass these other factors, not just GDP or GVA. To this end London will need to do more than envisioned to diversify its economy both in terms of the sectors and geographical location. London must become a low-carbon economy overall, not just have a few low-carbon businesses and a Green Enterprise District in the Thames Gateway (as policy 4.10 on New and emerging economic sectors indicates). Such a Green Enterprise District could be one of more developed around the capital, and environmental criteria for investors and tenants could deliver impacts in the local area.

Unsustainable infrastructure to support the economy has no place in a low-carbon London – transport infrastructure must contribute to meeting environmental objectives, rather than add to the environmental burden as any vehicle river crossing would.

The EDS has some good aims and policies, but there are some concerns.

For instance Objective 2 of the EDS to “ensure that it has the most competitive business environment in the world”, does not seem to establish (or caveat) whether this is compatible with social and environmental aims, and delivering a sustainable economy. However Table 2A (page 41 within the section on objective 2) on the attractiveness of London to businesses shows that London falls badly behind other cities worldwide on “freedom from pollution” and also on “quality of life”, and indeed it is acknowledged in the section on weaknesses, under “quality of life” (page 28) that improvements are needed to London’s quality of life to improve London’s competitiveness. Health and inequalities are separately covered in cross cutting themes, but this example shows clearly how economic development that does not pay adequate attention to social and environmental issues, as has been the case in the past, can work work against economic interests and cause problems for all. Further, London also ranks poorly on the “cost of staff” and “office space – value for money” from Table 2 – these issues act as a deterrent to businesses but are at least to some extent the product of business and financial service sectors’ dominance in London’s economy, with their accompanying ability to pay high rents and high wages, which in turn drive them up further.

Objective 3 of the EDS refers to a low-carbon economy and the “showcase” Green Enterprise District, as well as low-carbon zones, but these should be mainstreamed, as mentioned above in this section.

Chapter 5 – London’s response to climate change

The issues of mitigating the worst effects of climate change as well as adapting to its expected effects must underpin, and need to be integrated across, the whole London Plan and associated documents.

The Integrated Impact Assessment (IIA), page 105, shows an increase in CO2 from 44 million tonnes in 2003 to 47.5 million tonnes more recently (the latter figure is taken to be the 2006 LEGGI figure), and Chapter 5 states that CO2 is expected “to increase with London’s expected growth by 15 per cent … by 2025, if no action is taken” (paragraph 5.13).

Clearly action needs to be taken, and it is welcome to see the Mayor’s current target of a 60% cut in CO2 by 2025 from 1990 levels included in London Plan policy (policy 5.1), but whereas the LP “seeks to achieve” the target, policies must be shown to be adequate to ensure the target is achieved.

We welcome the statement in Policy 5.1 that “The GLA will monitor progress towards its achievement annually”. It is important that the chosen method of monitoring allows regular and frequent checks on how London is on track to meet the 60% target (probably at least annually) with scope and mechanism to adjust policies if needed (and indeed paragraph 5.15 states that “Progress will be kept under review to ensure that policies and programmes are on track”). From this it is clear that interim targets are needed, and the Climate Change Action Plan (CCAP) of 2007 had, in addition to the 60% target adopted from it by the Mayor, also a 4% annual target to deliver the 2025 target. This, or an updated, annual target should also be adopted and incorporated into the London Plan and forthcoming Climate Change Mitigation and Energy Strategy (CCM&ES).

The 60% by 2025 target and any interim targets should be referred to as current targets, and clear commitment made to keep the targets under review, so as to keep them in line with the current scientific consensus and advice from the Government and the Committee on Climate Change. In his response to the Planning for a better London consultation responses the Mayor said “We will continue to ensure that our policies on climate change are innovative and evidence-based…” and Leading to a greener London (LTAGL), the precursor the the CCM&ES states “… for London to play its full role, based on the latest science on climate change…” (page 11). This reference to reviewing and science-based targets needs to be brought into the London Plan which refers to a situation at a given time, but needs to be kept up to date.

It needs to be clear that all sectors will need to play their part, and whether each sector is expected to make cuts of 60%, or whether sectors will have different targets. The transport sector is currently expected, according to TfL in the Assembly and GLA draft MTS (see section on Chapter 6 below), to only achieve about a 10% cut in CO2 by 2025, which will need to be improved on considerably, or other sectors will have to make deeper cuts to compensate.

Each London borough has a key role in helping London become a low-carbon society and economy and we welcome the inclusion in policy 5.1, of section B that states that boroughs should “develop detailed policies and proposals that are consistent with the achievement of the Mayor’s strategic carbon dioxide emissions reduction target for London” which is the 60% cut by 2025 from 1990 levels. The Mayor will indeed need the boroughs to develop in a low-carbon way in order to meet the London targets needed.

As London is not yet on track to meet its target, it is likely that measures such as low-carbon zones and those proposed in LTAGL (some of which have begun to be rolled out), will need to be introduced as quickly as possible, and to be mainstreamed as fast as possible, rather than just being pilot projects. A key measure for London is retrofitting of existing buildings, and the importance of this is rightly recognised (eg with policy 5.4). However until we see a MMC&ES it is not clear whether these measures proposed or those on renewable energy for instance are adequate to meet targets.

Policy 5.5 in support of the Mayor’s decentralised energy target must also relate to the waste section of chapter 5, and the energy sources must be the most sustainable (see below on waste).

Policy 5.7 on renewable energy should include the 20% figure for reduction of CO2 by the production of on-site renewable energy. Currently this appears only in the text (paragraph 5.43), but it should be prominent as a policy.

Adaptation to climate change is of key importance in London which is set to suffer serious consequences from the impact of climate change. The Mayor and GLA must engage in more public information dissemination on this issue, which will also help give the Mayor the mandate to take the necessary measures to mitigate the worst effects of climate change and meet science-based targets, and be prepared for what is already inevitable.

Waste

We are concerned that self-sufficiency targets have been dropped and replaced only with weak words in policy 5.16, and they should be re-instated. It is likely anyway that neighboring regions will want to see London’s commitment to end the exporting of waste. The aim in policy 5.16 of having zero waste to landfill by 2031 is not the same as not exporting waste to other regions.

Recycling rates are only in line with previous targets, but these should be increased to reflect best practice elsewhere, and to avoid exporting waste. We are concerned that any waste treatments genuinely only use non-recyclable waste that cannot be recycled or composted. Our preference is for Anaerobic Digestion (AD) as opposed to any thermal treatments to treat non-recyclable material.

Chapter 6 – Transport

The chapter states that “the main source of policy on transport is the Mayor’s Transport Strategy” and goes on to say that reducing transport’s contribution to climate change is one of the key themes, however this climate imperative is not set out and used as a key theme in this chapter.

Transport’s contribution to meeting the current Mayoral climate change target of a 60% cut in CO2 by 2025 was set out in the MTS Statement of Intent document (Assembly and GLA draft MTS) and made clear how far transport is from meeting its share of that target. Section 4.3 set out the “reference case” (paragraph 109) as what is assumed to be in place in 2026, taking account of funded transport policies and programes, and is the basis of the section on page 53 on tackling climate change stating that “a 2026 outcome of around 10 per cent reduction in ground-based transport CO2 emissions, from 1990 levels..”

The MTS sets out the climate change issues in 4.6 and in particular 4.6.2 on reducing CO2 emissions, and it is welcome that policy 2.4 in that section states that “the Mayor … London boroughs … will take the necessary steps to deliver the required contribution from ground-based transport to achieve a 60 per cent reduction in London’s CO2 emissions by 2025 from a 1990 base…”. However under the section on “Proposals to reduce transport’s contribution to climate change and improve its resilience” (section 5.20), it is stated that “A gap remains between a mid-range assessment of the impact of the proposals contained within the strategy and the Mayor’s target. Achieving the Mayor’s target will require further strong incentivisation…” (paragraph 624).

It is also clear from figure 58 of the MTS that road user charging (RUC) has the greatest potential to fill the 2025 policy gap, along with road vehicle efficiency, and options for RUC are kept open in proposal 108 (both in section 5.20). Possible application of wider RUC is further set out in section 5.25, specifically 5.25.6 and proposal 129, but these are not specific proposals.

Figure 63 shows how a 14% increase in congestion is expected on 2006 levels, despite Crossrail and tube improvements and increased cycling – this is of serious concern and needs to be addressed, and not exacerbated.

However section 5.25 also refers to the Western Extension to the congestion charge (WEZ) which the Mayor is seeking to remove “after putting in place such measures in mitigation of negative impacts” (proposal 127). The WEZ has had proven beneficial impacts on traffic and climate emissions and also air pollution (see section on Chapter 7 below referring to the AQS). With congestion forecast to rise unless other issues are addressed, and in light of the difficulty of reaching climate change and air quality targets, we consider that the WEZ must not be scrapped.

The WEZ also provides an important revenue resource which would be lost – at a time when the Mayor has put fares up on public transport – a move that will force some to drive rather than use public transport, taking London in the wrong direction.

The Mayor should reconsider the benefits of introducing a CO2-related congestion charge as proposed by the previous administration. Again revenue could help boost alternatives to car use such as walking and cycling, acting as a multiplyer effect, or used to keep public transport fares down. There are low-carbon output family vehicles – this scheme should not be opposed on grounds of concern for family options.

The MTS also sets out the difficulties in meeting EU air quality targets (in section 5.19), yet proposes to delay the introduction of phase 3 of the key current policy to address it, namely the LEZ. In light of the difficulty meeting air quality targets, the LEZ must be introduced as planned, as addressing a health issue must not fall foul of economic considerations being prioritized. (see also section on Chapter 7 below referring to the AQS).

We welcome the Mayor’s inclusion in the London Plan of “reducing the need to travel, especially by car” (policy 6.1) and the need to “make it easier for people to access jobs, shopping, leisure facilities and services by public transport, walking and cycling” (paragraph 6.7).

Despite transport’s problem with the shortfall in meeting its share of the 60% cut in CO2 by 2025 needed and the difficulties in meeting air quality legal limits, the opportunity for road traffic reduction targets has been missed from the London Plan and MTS – they are only there as a Key Performance Indicator (KPI)- see LP table 8.1, KPI 15. The importance of reducing overall levels of traffic needs to be made clear to Londoners and strengthened targets should be in the main documents.

In light of the pressing CO2 and air quality problems traffic must not be allowed to grow, and to that end parking standards in outer London areas must not be allowed to be relaxed as is proposed to supposedly help them compete with centres beyond London (policy 6.13 and table 6.1).

Road building and vehicle river crossings

London Plan paragraph 6.10 states “Future transport policies, proposals and projects should be developed and implemented in order to support the spatial priorities set out in this Plan…in particular to support: London’s world city status by maintaining and improving its links with the rest of the world, including through taking a balanced and sustainable approach to …road links between London, neighbouring regions …”. This is not aligning the economic and world city status ambitions with the reality of climate change imperatives and other environmental and social aims, and there is no place for the generation of more traffic through the provision of any further large road building or vehicle river crossings should be avoided.

The 6.12 Policy in the London Plan (and the equivalent in the MTS) for road building is a weakening of the criteria to allow roadbuilding and follows the successful use of the previous policy 3.C.15 (later 3.C.16) to show at Public Inquiry that the Thames Gateway road bridge would not bring the regeneration benefits claimed while bringing multiple environmental and social problems to the area, and leading to the scheme rightly being recommended for refusal and then scrapped by the Mayor. The criteria must not be weakened – if anything strengthened – as any vehicle crossing must not be foisted on local people without being the best solution to their needs, and of the environment.

Possible new river crossings are referred to in the London Plan and MTS. The London Plan policy 6.4 (in a section on public transport) refers in ‘k’ to “providing new river crossings” at this point not saying if that would also include vehicle crossing provision, but not excluding them. Paragraph 6.37 of the London Plan also states that “The Mayor is investigating the possibility of additional river crossings in East London” again not specifying, but not ruling out, vehicle crossings. However the MTS spells them out in proposal 39 in section 5.8 on river crossings. “The Mayor, through TfL, and working with the London boroughs and other stakeholders, will progress a package of river crossings in east London including…”. The list includes a Silvertown link (a 3rd road crossing at Blackwall) and a vehicle ferry at the site of the rejected Thames Gateway bridge (TGB), and what would effectively be a slightly smaller TGB.

All of these vehicle crossings are unacceptable and must not be included. There are no further public transport crossings proposed and the development of these options is not adequate as they have not been shown to be the best options to achieve the outcomes needed including social and environmental aims. Solutions need to address not exacerbate the problems of the local area, which already suffers disproportionately, and environmental aims.

Climate change imperatives and targets, which London is not on track to meet (as set out above), should mean that at least TfL must not make things unnecessarily worse by building new road/vehicle crossings.

Also on air quality, London is not on track to meet EU targets, and this should be reason not to further add to the problem with more vehicle capacity. Traffic fumes from the TGB would have added to breaches of EU air quality limits, TfL admitted. One air quality monitoring receptor would have breached an EU legal limit, when this would not have happened if the scheme were not built, according to TfL modelling. Several areas would have had “significant” increases in air pollution according to Association of London Government criteria, as shown by TfL in its evidence.

Allowing any further vehicle capacity will just increase traffic and associated problems – if driving becomes more convenient people choose to drive when they did not before, or switch to that route etc – filling up space available and meaning more overall traffic and pollution in the area (references can be provided). This in turn would be expected to only worsen, not help, congestion in the area with any sort-term relief soon eroded with generated traffic. As congestion is already expected to worsen (as set out above), this again is reason to avoid making matters unnecessarily worse.

Transport for London (TfL) said in the TGB case that existing traffic congestion would be hardly – if at all – relieved if the TGB were built, with flows at the Blackwall Tunnel remaining about the same, TfL admitted. TfL later revised their case and showed that there would not even be reduced queuing at the Blackwall Tunnel in the AM peak hour if the bridge were built. TfL’s original case had expected that there would be some less queuing. The Government had also done studies on the area which showed similar results (a 2003 ODPM report “relationship between transport and development in the Thames Gateway” found at 3.4 that congestion at existing crossings east of Tower Bridge would be “not significantly alleviated by the additional capacity provided by the Thames Gateway bridge and Silvertown Link” – that is with both new roads the Government admitted that congestion would not really be helped).

Businesses and the public had cited expected reduction of existing congestion in the area as one of the key reasons they supported the TGB scheme (in response to market research and consultation) – so if congestion were not relieved, their support would be in question. The Inspector for the TGB public inquiry concluded it would “likely to cause increased congestion” if the bridge were built.

This release from when the Mayor scrapped the TGB gives some more info on the problems of road building:

http://www.foe.co.uk/resource/press_releases/thames_gateway_road_bridge_06112008.html

The Mayor’s manifesto did not include any commitment to new vehicle river crossings – only to some river crossing. This should be public transport for any additional cross- river capacity needed, which would in turn help free up space on existing vehicle crossings for those journeys that have to be done by vehicle.

Aviation

London Plan policy 6.6 states “Airport capacity serving the capital and wider south east of England must be sufficient to sustain London’s competitive position”. London Plan paragraph 6.10 states “Future transport policies, proposals and projects should be developed and implemented in order to support the spatial priorities set out in this Plan…in particular to support: London’s world city status by maintaining and improving its links with the rest of the world, including through taking a balanced and sustainable approach to additional airport capacity in south-east England”.

The MTS proposal 4.7 (in section 5.11) also gives precedence to the economy “the Mayor recognises that adequate airport runway capacity is critical to the competitive position of London in a global economy…” The MTS in section 5.20.5 on “reducing CO2 emissions from aviation” states “the international connectivity that aviation provides is crucial to the competitiveness of London’s economy in the era of globalisation. Therefore strict limits on aviation growth are not tenable”.

The drive to improve London’s competitive position needs to be seen in a wider context, where economic development must be delivered together with social and environmental outcomes, not take precedence over them. World city status ambitions cannot be at odds with the reality of climate change and air quality imperatives and targets and social aims (we refer you to our comments on Chapter 1). And it has been set out above (on Chapter 4) how pollution for instance is bad for London’s competitive position, as well as for local people.

London Plan paragraph 6.24 is specific – it says of the Mayor that “he does recognise the need for additional runway capacity in the south-east of England”. Friends of the Earth considers that there must be a stop to further runway and airport provision in the face of national and regional climate change and air quality targets, and other local environmental impacts.

The MTS proposal 4.7 (in section 5.11) states that “the Mayor…opposes any further increases in capacity at Heathrow” but London Plan 6.25 says “to ensure that existing aviation infrastructure is used to its fullest extent before more expensive and damaging courses are pursued”. We welcome the opposition on Heathrow, but think the same should apply to City airport. Paragraph 6.25 would indicate support for maximising use of City Airport, and the Mayor supported Newham’s approval for an increase in flights by 50% there (the increase is mentioned in paragraph 446 of section 5.11, although this is currently being contested). However support for this expansion should be withdrawn, as well as any further growth opposed, in light of the impacts on the local community on air quality and noise grounds, particularly as these communities are already some of the most deprived and adversely affected by environmental problems, and on climate change grounds, as targets for air quality and climate are not on track to be met. Biggin Hill should also not be allowed to increase, or change from the current operating system – it should not be allowed to become a general fare-paying airport.

Chapter 7 – London’s Living Places and Spaces

Air quality and the current failure of London to meet EU legal limits is of the utmost importance. Government agreed figures are that at least 3,000 premature deaths occurred in 2005 due to particulate matter pollution, and the figure could be considerably higher. The recent Mayor’s Air Quality Strategy (AQS) revised draft for the GLA and Assembly did not constitute an adequate plan to be certain to bring the whole of London within the legal limits. Particularly there was insufficient detail and certainty, and some measures that currently exist or are planned in which have clear benefits (Western Extension to the congestion charge zone, and the Low Emission Zone phase 3) are being proposed to be replaced with uncertain and unspecified and unfunded measures which should not take place. No new large road building or vehicle river crossings should be allowed to make the situation worse (as above in the section on Chapter 6). Aviation is referred to in the AQS but only Heathrow is mentioned and not City Airport in respect of reducing pollution from existing operations – it should be for both, and City Airport should not be allowed to increase flights by 50% while air quality legal limits are not being met (as above in the section on Chapter 6).

On the natural environment the Mayor has some strong policy protection for open space including for back gardens. We refer to our comments to “Planning for a better London” stating that there is good synergy between policies to tackle climate change and to adapt to it, helping achieve health benefits, and in protecting and enhancing biodiversity. The value of protecting and extending natural resources needs to be set out in the London Plan.

Integrated Impact Assessment

The Integrated Impact Assessment (IIA) has an objective on Climate Change Mitigation and Energy (number 9) which only states that “To ensure London contributes to global climate change mitigation…”. The assessment of chapter 5 of the London Plan (London’s response to Climate Change) is that policies are indeed ” likely to contributes positively” to the objective. However this does not give any indication of whether it contributes adequately or not. The assessment of objective 9 on Chapter 6 on transport does not set out that transport is only expected to reach a 10% cut in CO2 and falls far short of playing its full part, and the relaxing of road-building criteria and proposed vehicle river crossings are not apparently mentioned despite expected negative CO2 impacts. The objective 16 on air quality only states “to improve London’s air quality” and the assessment of Chapter 6 does not set out the gaps in reaching EU legal targets.

The IIA is intended to fulfill all the requirements of the SEA Directive and implementing regulations. But no explanation is given for the very limited alternatives selected for the assessment, which relate only to chapters 1 and 3. For the remaining chapters, including Chapters 5 on climate change and 6 on transport, no alternative policy approaches are identified for comparative assessment at all. This is deeply inadequate – reasonable alternatives should be identified and assessed to allow the impacts of the chosen policies to be properly compared.

There are also very serious concerns regarding the Equalities Impact Assessment section of the IIA, and we refer you to the separate letter sent by our Rights and Justice Centre.

We understand that there are also concerns others have expressed over the Health Impact Assessment and Habitats Regulations Assessment which we urge you to consider.

ENDS

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