-London 21 draft
The new London Plan:
Towards ‘convergence in quality of life’
Comments from London 21; January 2010
The London 21 sustainability network is a registered charity working across London with some 2700 supporting organisations and individuals. It “supports grassroots and disadvantaged communities in acting to create a sustainable London. London 21 shares information and promotes good practice, raises awareness and recognises that sustainable development is a shared responsibility strengthened by collective action.”
A critical time for London and the planet
The new London Plan comes at a critical time. The widely-agreed need to deliver 60% cuts in CO2 emissions by 2025 and 80%+ cuts beyond that means that significant change is needed and is needed now. Every month of delay in action on mitigation means that the pace of change will have to be that much more rapid in later years. Business as usual, albeit with moves towards efficiency, is no longer a valid response to the challenges we face.
Climate Change is of course not the only challenge: there is the challenge of creating and maintaining a city, already the most diverse on Earth, where people can live safe and fulfilling lives and where there is clear and increasing ‘convergence in quality of life’ (para 2.19) across all boroughs and all communities, and not just those ‘Olympic boroughs’ referred to in the Plan in this context. The challenge here is to minimise inequalities in terms of environment just as much as health, social and economic inequalities.
With climate change there are other global challenges. There is ample evidence that we are over-reaching environmental limits both globally and within the UK. In that context there is a need to address the idea of continued ‘economic growth’ that forms one of the key justifications for this plan. “A city that meets the challenge of economic and population growth” does not have to mean a city that meekly accepts the current model of economic growth or development.
The Mayor envisions a city full of “relaxed and good-humoured people” who are “surrounded by things of beauty” and clearly no-one would disagree with such sentiments. The question must be how far this Plan is likely to deliver this vision.
There are of course limitations on any planning process and this is a plan that is at its core about spatial development. But this is a key-stone for much future development, and with that in mind we would comment on some of the key issues as well as a limited number of specific points.
In 2006, when the London Plan was last reviewed, our specific concerns were with regard to:
- The continued focus on economic growth
- Waste minimisation
- Climate Change
- The lack of clear approach to tackling environmental inequalities within London
- Community Engagement
We still see these as areas where the London Plan needs improvements. We are now focusing on
- Economic growth and prosperity
- Environmental inequalities within London
- Climate Change
- The River Thames
- Community Engagement
We make these comments in the light of some core principles and priorities:
- Cutting waste – of land, of underused housing, of resources and energy, and of people’s voluntary inputs into work for a better future;
- Maximising the sustainable and efficient use of the resources we have in our city;
- Recognising the need for systemic change to transform London’s operational systems in order to achieve the agreed CO2 cuts, and that cuts in waste and increases in efficiency will not in themselves deliver that transformation;
- Recognising that London is the most diverse city there has ever been and that our global influence brings with it a responsibility now more than ever to take a lead in showing how cities can be transformed;
- Tackling the inequalities currently endemic in our city as a central gaol for any long-term strategy for sustainability.
A London Plan in 2010 should be a starting point for a new vision, not just of a low-carbon London, and not just a London where inequalities are not just tackled about but are progressively minimised (important as both these targets are). A London Plan should be setting out a vision and a way forward to a future that does not rely on failed economic dogma but on creative thinking and action for a genuinely sustainable future. As yet, this is not that Plan.
1. Economic growth and prosperity
The common experience of implementing sustainable development strategies since the 1992 UN World Summit is that attempting to ‘balance’ economic growth with improvements in the environment has been of failure to achieve this end. The pressures exerted by those seeking unfettered economic development in comparison to those focusing on environmental improvements are so different that achieving any realistic balance simply has not happened. Moves towards environmental improvement have occurred but the underlying trends remain focused on continued over-consumption and unsustainable growth.
Theses current proposals for the new London Plan seem to imply that different strands of the plan can exist side-by-side but will not necessarily affect one another. While we welcome the development of the IIA process this does not seem to have explored options in enough detail. There are still too many areas where long-term goals clash.
In 2006 London 21 we raised the need to question the over-simplistic notion that continued ‘economic growth’, measured as it is now, will somehow minimise inequalities and lead to a sustainable future. The recent economic downturn has put questions about the current economic growth model firmly in the public arena. It ahs also made clear the dangers in assuming that conventional models can help us reach the point where all Londoners can indeed can live safe and fulfilling lives and where there is clear and increasing ‘convergence in quality of life’. In France President Sarkozy has pointed out that “The crisis doesn’t only make us free to imagine other models, another future, another world. It obliges us to do so.”
We recognise that some growth in London’s economy and population is inevitable. But the idea that we should uncritically “welcome growth” fails to offer any scope for other routes to prosperity. The recent publication ‘Prosperity without growth’ by Professor Tim Jackson highlights the fact that other ways forward are certainly possible.
If London is indeed to be the ‘best big city on earth’, then London needs to innovate, and that innovation must start at this fundamental level.
Policy 1.1 starts with the word ‘Growth’ and subsequent sections accept this belief that growth can be managed indefinitely into the future and that growth is a goal in itself.
A simple and fundamental change would be to consider the use of the word ‘growth’ in this document and to consider where in these policies Londoners and the future of London will be better served by focusing not on growth, but on progress or development or long-term prosperity that can genuinely be sustained.
2. Environmental inequalities within London
There is also now ample evidence of the serious environmental inequalities within London, and the detrimental effect of these inequalities on people’s health and social capital and on overall quality of life.
Issues of inequality and deprivation are central to the long-term and truly sustainable development for London. We are pleased to see various references to this but we are very concerned that there is no mention of deprivation or exclusion in the six key objectives. Further more the only reference to inequality is in objective one, where there is the suggestion that economic growth can help ‘tackle’ inequality.
The underlying patterns of deprivation are set out in sections 1.24 and following, but there is little in here that does more than acknowledge inequalities.
The Plan refers extensively to the Outer London Commission and the problems that this body was set up to tackle. But the perception that outer London is somehow ‘losing out’ on many key issues does not appear to stand up beyond the issues of economic development.
Many of the UK’s poorest communities are in Inner London, and they suffer the added burdens of having a much poorer environment (in terms of numerous indicators) than outer London. Serious deficiencies around issues such as access to good quality green space do not just mean that many inner Londoners not “surrounded by things of beauty”, it means that their children are likely to be less healthy and are certainly much more at risk of traffic accidents.
Para 2.40 accepts the need for change, but the policies referred to are inadequate to tackle this problem. Policy 7.18, for instance, sets out proposals for work through LDFs and for work to identify areas of deficiency, but exhortations to ‘plan for’ future needs are no substitute for work to specifically target, on a regional basis, those areas that suyfefr these and other inequalities.
Ideas about moving towards inclusive environments (Policy 7.2) refer primarily to new developments. Relying on these ideas and on exhortations for ‘inclusive design’ are inadequate to tackle these inequalities and will have no impact in inequalities around other environmental issues such as noise, air pollution etc.
Action to tackle these underlying inequalities should not wait for new developers to somehow solve the problems. The plan should directly address the need for that ‘convergence in quality of life’ by including strategic targets in Policies 7.5 (public realm), 7.14 (Air quality), 7.15 (Noise) and 7.17 (open land) to assess existing inequalities of provision and develop an integrated programme to progressively minimise these inequalities, with suitable indicators to track that progress.
Energy-related matters also raise major inequalities issues. We refer to these in the next section.
With this in mind we would emphasise our previous recommendation made in 2006, that the London Plan should be supported by out a regional ‘environmental justice code’ for London which would work to ensure that no one group suffers disproportionate environmental impacts of policy, acts, or omissions associated with developments in London.
Such a code would the first of its kind in the UK and Europe. The code would act as guidance for policy makers and practitioners in all sectors and could provide a framework for an environmental justice impact assessment. It should be a requirement that all other plans including Borough LDFs explicitly incorporate these principles.
3. Climate Change
While we welcome the retention in Chapter 5 of the target for reducing London’s carbon dioxide emissions by 60% (below 1990 levels) by 2025 (Policy 5.1) we are concerned that the ways set out in this Plan will not be adequate to achieve that goal.
If London is genuinely be a world leader and not merely an example of actions failing to meet words, then there is without doubt a need for more specific targets around renewable energy for London, along with clear guidance within the Plan as to how these new developments can be supported and implemented by London Boroughs and developers.
The general targets for new energy sources (Table 5.1) are welcome but there is little but optimistic talk in this plan on their achievement,
Decentralised Energy and Heat
It is of course that case that Londoners do not need electricity or energy in itself; they need heat, light and other services. At the moment there are huge differences (and inequalities) in the ways that Londoners access and pay for heating, light etc. This plan sets out two key areas, 5.4 (Retrofitting) and 5.5 (Decentralised Energy Networks) where there is huge potential to improve energy use in poorer communities.
To that end the policy on Retrofitting should explicitly link to deprivation goals within the Plan and ensure that the hardest-to-heat homes where fuel poverty is often highest are clearly tackled, and identify ways in which all parts of the private rented sector can be included in this work.
Decentralised Energy and Heat networks also have a huge part to play in tackling these social problems. The idea that such Networks should be ‘prioritised’ ‘where feasible’ (policy 5.5) in insufficient; clear targets, especially in high density areas, can and should be set.
A Low-Carbon Economy
We welcome the references in this Plan to low carbon economy and examples of green industries. Para 4.6 talks of a ‘fundamental shift’ towards a low-carbon future and Policy 4.1b talks about driving towards ‘London’s transition to a low-carbon economy’. But the only specific references and targets (poorly set out as they area) are around energy in Chapter 5 It is hard to find any further reference in the various sections and policies within Chapter 4 (apart from talk of a Green Enterprise zone in 4.10) about how this transition is to be driven forward. If this Plan is to see a serious focus on this growing facet of the economy than a specific policy would be appropriate, along with an assessment of the current size of the sector and some clearer guidance on how the Plan and associated agencies will lead and / or support this work.
4. The Thames
5. Community Engagement
We note that the Plan talks in 8.1 of “commitment to engagement with all groups and individuals concerned with planning for London” including “Voluntary and Community Sector Groups”
We obviously welcome this. But we note Table 8.2 – Indicative Actions. There are many areas where Third Sector / VCS engagement will be important in delivering these but there is no reference to any role for the sector.
Further work on the Plan also needs to involve the development of mechanisms for greater community engagement in the detailed implementation of its policies in order to secure developments that meet the aspirations of both existing local residents, and incoming residents and businesses. There is reason to think that important proposals on issues such as renewable energy may be jeopardised by public opposition because of inadequate public engagement.
Recommendation: The London Plan should make it clear where community involvement in delivering targets is looked for or essential. There should be adequate resourcing of the capacity-building needed for this to happen and there should be no undue expectation of any groups’ readiness to get involved in an external agenda.