-Haringey Fed of Residents Associations
42 Falmer Rd, N15 5BA – http://www.haringeyresidents.org
12th January 2010
To: The Mayor of London – Mayor@london.gov.uk
From: Dave Morris, HFRA Secretary
Replacement London Plan – response by Haringey Federation of Residents Associations
1. The Haringey Federation of Residents Associations is the umbrella organisation for Haringey’s 169 local RAs of all kinds. Haringey’s Residents Associations have a wide range of experience regarding planning issues and applications, and as Federation we have taken an active part in advising and supporting them, taking up strategic cases, responding to planning consultations at all levels (including regarding the Haringey UDP/LDF and the London Plan), and participating extensively in the most recent ‘Examination In Public’ of London Plan policies.
2. We are affiliated to the London Tenants Federation, as many of Haringey’s local RAs (around 60) are based in council and RSL housing, although the majority are street or neighbourhood based.
We have actively helped to shape the planning policies of the London Tenants Federation through a range of meetings, discussions and mini-conferences.
2a. We broadly support the well-informed and detailed LTF response to the draft Replacement London Plan, including the LTF definition of Lifetime Neighbourhoods.
2b. We also have some additional responses of our own.
2c. We are prepared to contribute relevant evidence regarding planning and development in Haringey to back up many of the points made by the LTF and by ourselves below.
3. Haringey has a wide range of planning characteristcs, applications and development. The London Plan approach thus far, and proposed here, is not effective to meet the real needs of London’s communities. Everyone now recognises that we must have environmentally and socially sustainable communities throughout London. Planning policies for local boroughs and London claim to agree – but is this only lip service? The litmus test is what is actually happening on the ground.
4. We are facing extreme pressures from private and corporate developers and town planners leading to a range of concerns & problems, and pressure on (and loss of) an already inadequate social infrastructure (schools, health facilities, parks, play areas, public transport, post offices, local pubs and community centres and other facilities and public land etc). Some policies supposedly meant to protect the interests of communities are being systematically flouted by developers, Councils & the GLA.
5. Throughout London there are an ever-growing number of objections and campaigns over proposed local developments. Residents groups and associations are forming more and more alliances to resist what’s wrong with major developments as well as smaller but equally important sites in local neighbourhoods. These include efforts to…
5a. protect heritage and conservation features & the distinctive character of neighbourhoods
5b. resist unwanted over-development imposed on communities
5c. oppose over-intense housing development – densities have risen massively in the last few years, and there is a systemic failure by Councils and the GLA to enforce maximum density limits
5d. support genuinely affordable housing – the vast majority of housing development is unaffordable to local people in need. A scandalously low 19% of new homes completed in 2006 in London were social housing (the only genuinely ‘affordable’ housing), despite housing need being used as ‘justification’ for otherwise unacceptable policies [See below for more comments regarding housing issues]
5e. protect valued ‘backlands’ sites
5f. defend open green space from development, especially undesignated sites
5g. address the widespread deficiencies of green open space of all kinds
5h. defend and expand children’s play facilities in our neighbourhoods
5i. oppose poor project design
5j. defend community facilities eg. healthcare sites, local shops, post offices, meeting places, community pubs. Publicly-owned land is continuing to be widely sold off for private development.
5k. campaign against the sell off of ever more publicly-owned land
5l. halt the loss of affordable offices & sites for voluntary groups & small businesses
5m. protect front gardens – concerns include the quality of street scene, pedestrian safety, flooding etc
5n. resist environmentally unsustainable development eg energy use, materials, design etc. A comprehensive low/zero-carbon energy programme (insultation, alternative energy generation, 100% recycling etc) is needed for every home, building and workplace throughout London
5o. criticise increasing pollution – visual, air and noise
5p. campaign against the ever more illegal advertising hoardings and billboards
5q. remove street clutter
5r. implement effective traffic calming, ‘living’ streets & affordable public transport
5s. call for greater (not less) resources for maintenance and improvement of public facilities, buildings & services
6. Faced with constant pressures for inappropriate or damaging development, residents want to ensure that we and future generations will live in strong, supportive and sustainable communities. Based on the experience and evidence of what is actually happening on the ground we dont have confidence that the draft London Plan, despite many good sentiments, protects community interests effectively. Reasons include:
6a. The policies themselves
6b. The interpretation of the policies
6c. Failure to commit to, and enforce, key policies which are supposed to protect community interests (eg social infrastructure, affordable housing targets, housing density limits, heritage etc) when contrasted with other policies (eg house-building and large scale development)
6d. Enforcement of conditions and agreements
6e. The lack of a level playing field between local residents & well-resourced developers
6f. The HFRA is concerned about the reliance on S106 payments, instead of actual planning gains. We are extremely worried that councils are becoming increasingly dependent on section 106 contributions to maintain ongoing basic services to our communities – in terms of the community facilities and amenities that are essential to sustaining communities – rather than as any actual planning gain to mitigate the effects of development. We are worried both about the lack of funding for social and community infrastructure, and that section 106 is a powerful incentive for Councils and others to accept and support otherwise unacceptable planning proposals. Further, in the curent economic climate, it is clear that even this inadequate mitigation facility is being undermined by many local Councils often agreeing to waive part or all of the s106 stipulations for a proposed development. This is unsustainable and benefits only the developers rather than the affected local communities.
6g. Objectors denied their right to appeal, unlike developers
6h. The need to listen to, genuinely consult, and empower communities instead of giving increasing power to the Mayor and central government
7. In addition the HFRA has serious concerns with the ‘consensual approach’ proposed in the Mayor’s 2008 ‘Planning for a better London’ consultation, as such an approach would simply mean a more laissez-faire approach to developers and market led development which will result in less genuinely-affordable housing being produced and further erosion of the social infrastructure and facilities all communities need and are entitled to. Policies which are protective of local community needs and interests, such as social housing percentages, protection and expansion of social infrastructure and green spaces, which are there to prevent or mitigate against climate change etc, must be binding and strengthened. Councils should have flexibility to strengthen them further from a London Plan ‘baseline’. Meanwhile, London Plan policies which allow developers and others to pursue their own agendas at the expense of the needs of London residents should be amended appropriately, and Councils given flexibility to weaken them further from a London Plan ‘maximum position’.
8. To adequate serve London’s peoples and communities the draft London Plan needs to
* strengthen all the policies which protect community interests, social infrastructure, greater percentage of social housing and family housing, protect heritage, deal with climate change, reduce density limits etc etc
* ensure that these policies are binding on development, proportionate to the range of evidenced needs of the community, rather than something to be seen as just secondary or at most just to be ‘balanced out’ with developers’ needs.
* support an ‘evidence based approach’. If this is to work we believe there must be very firm policy guidelines and targets to address evidenced need, and that such need should guide all development rather than the current laissez-faire approach favouring the whims and profits of developers
* give objectors the right of appeal against a planning decision (as currently only an applicant can appeal)
9. We need sufficient policies and guidelines to ensure that each development serves the requirements of those sections of the community with identified needs, with an appropriate balance weighted towards those in most need in order to address London’s challenges and problems. This will ensure avoidance of exclusive, profit-driven but merit-less development.
10. In addition, regarding housing issues, we outline the following questions and concerns which we believe need to be addressed by amending the proposed policies in the draft London Plan:
10i. Over-high housing densities undermine the need to ensure sustainable communities. Current social and environmental infrastructure is inadequate to deal with the needs of current population levels, let alone greater/denser population levels. People are entitled to good quality living space and access to gardens etc. Do we really want to see a return to the failed tower blocks & estates of the past?
10ii. ‘Affordable’ and social housing: what can be done to overcome the failure to reach even the very modest % targets from new housing completions. Most so-called ‘affordable’ housing is well out of the reach of the vast majority of those who need it, and should be radically redefined. Social housing is currently the only genuinely affordable, permanent housing and should be the majority of new builds (it is only 20%). The London Housing Strategy Evidence Base 2005 found that to meet need, 59% of housing constructed in London should be social rented, 7% intermediate and only 34% market. We understand that in more recent studies the evidenced need relating to social rented housing has remained consistent. Hence the Mayor’s proposal to reduce rather than increase social housing % in developments is irresponsible and unacceptable.
10iii. Do S106 agreements lead to actual planning gains? Community facilities and amenities of all kinds essential to sustainable communities (eg open spaces, childrens’ play areas, health, education, sports, leisure and meeting places, local shopping parades etc) are not only failing to be extended to address existing deficiencies, let alone the ever greater population pressures, but are under threat and being eroded on a daily basis in local neighbourhoods and town centres alike. No amount of S106 contributions can mitigate such real effects on the ground. In any case, we believe that s106 policies, already inadequate, are in the current economic climate being further undermined and siddelined by developers and Councils who are favouring the needs of developers at the expense of community needs.
10iv. What can be done about the failure to ensure that new build housing contains enough family-sized housing, especially family-sized genuinely affordable and social housing? In Haringey the recommended mix for affordable housing developments is: 26% 3-bed, and 32% 4-bed. Yet of the total housing completions in 2006/7 94% were one and two bed units. Of the affordable housing completed in 2006-7 only 11% were 3 or 4 bedrooms.’
10v. How do we halt the spread of Houses In Multiple Occupation? Homes are being divided into ever smaller units, causing not only loss of much-needed family accommodation but also unacceptable over-crowding.
10vi. How do we ensure that all new housing, including all ‘affordable’ and social housing, is designed to conform to accepted, good quality standards and to the positive character and heritage of neighbourhoods? This relates to the interior and exterior of every home, including impact on and contribution to the street scene.
10vii. How do we ensure that every substantial residential development contributes effectively to improving public open spaces and recreational facilities of all kinds? How do we also protect smaller, informal green spaces?
10viii. How can we ensure that, in boroughs with serious land stress and competition, that all available land is earmarked for community needs – rather than for what developers can grab in order to make the most profit? Existing amenity land (eg for health services, education, and community facilities and services of all kinds) is being whittled away and sold off. We believe that too much public land has been handed over to the private sector, to the detriment of existing communities, and that this land should be preserved exclusively for public benefit.
10ix. What can be done to respond to ever-increasing house prices, rents and insecurity? And could there be more effective action to prevent homes being left empty for long periods?
10x. What can be done to prevent homes being left empty? The Empty Homes Agency has suggested that whilst the number of empty homes has dropped over the 5 previous years, the drop was not significant and the figures are still high.
11. Bearing in mind the need for urgent and drastic cuts in carbon emissions to avoid dangerous climate change, what comprehensive policies and practices need to be imposed on all development (including housing, commercial and other development) eg regarding energy usage and generation, materials, design, space, greenery and green space, recycling etc? Developers are rarely paying more than lip service to these critical issues. Policies need to be very carefully appraised and strengthened regarding the prevention, mitigation and adaptation to climate change, and environmental sustainability in general. Comprehensive funding must be made available to address these serious issues effectively and immediately.
12. The HFRA feels that there has been an over-emphasis on new growth, especially of private housing, corporate malls, and industries which have failed to address sufficiently the infrastructure needs of either existing or new communities. Economic growth, which is a primary causal factor of the current climate change crisis, must be challenged rather than assumed to be some kind of unchallengeable benefit or public good. At the minimum each and every development must be considered on its merits regarding potential contribution to climate change. We argue that planning policies must be guided by the evidence and the science.