-Spitalfields Community Association
Spitalfields Community Association (SCA)
Submission on the Draft Replacement London Plan January 2010.
Spitalfields Community Association
6 Evershed House, Spitalfields, London E1 7NU
Introduction The Mayor’s role City Fringe Opportunity Area
City offices Tall buildings Regeneration Areas and regeneration
Planning Obligations Markets Conclusion
The Spitalfields Community Association is a residents’ association formed in 1998 to represent the wider interests of local community in Spitalfields. We have seen at first hand the change in the area since the 1980’s and the effects on the local community of the process of ‘regeneration’. This is a common theme across London and the new London Plan is an opportunity to highlight this issue once again.
The City Fringe (as it is was named about ten years ago) of all areas of London has felt particular pressure from its proximity to the City and its office expansion programme. Tower Hamlets’ previous LDF referred to the ‘pressure of development’ as a central feature of the borough. Land values have risen and development has occurred, typified by the move of the Spitalfields wholesale fruit and vegetable market to Stratford, the demolition of half the market buildings and their replacement, by owners the Corporation of London, with the 500,000 sq ft office development. Meanwhile the deprivation indices in the borough have remained the same and local business has suffered crippling rent rises and loss of premises.
Although in principle the SCA supports the Mayor’s emphasis on the quality of life we are disappointed to see that, like the Tower Hamlets Core Strategy, the new Plan does not appear to contain planning policy ideas to tackle the anomaly of high growth and earnings for some and continuing poverty and exclusion for others. We believe there must be changes to the Plan in order for it to become a viable long-term strategy.
At the outset of 2002 the SCA was optimistic that the new London Plan provided a set of broader, positive policy ideals against which the then Mayor would be able to judge the merits of refusal of the Spitalfields Market planning proposal. However the then Mayor read the Plan differently and picked out a new policy to approve the demolition: the development ‘would increase the supply of office space in this city fringe location’ and this became his habit for the rest of his term of office. It is important to note that the loss of the market buildings and their uses was condemned by a very broad range of voices from the thousands of visitors, to residents and traders, politicians, planners and critics, who recognised the issue as having more than local significance.
The Mayor’s Role
Notwithstanding that (mis)use of London Plan policy the SCA is of the opinion that the Mayor’s position as a moderator and upholder of policy is an important addition to the democracy of planning the city and provides for an over arching view of the future shape of the city for the benefit of all who live and work in London. While the Mayor advocates a ‘hands-off’ approach to local authority business, the SCA considers that it is a function of the GLA to provide certain checks and balances to the aims and aspirations of individual boroughs’ planning departments, and even, in some cases, inhibit those aims and objectives.
The London Plan is an ideal vehicle for setting out overarching and beneficial standards, ensuring they are then enforced. If the Mayor and the GLA are not prepared to enact this role, then the SCA asks what is the point of a strategic authority?
The Plan assumes that all Boroughs will conform to high planning standards as well as adhering to more detailed policies and proposals to enact the aims of the Plan yet the Boroughs often refer back to the London Plan to justify their own vague policies and low targets. The Plan should therefore contain a substantial number of targets that allow the Mayor to counteract bad local decisions and actions.
In having no explicit target in the Plan other than the reference to 13,200 affordable homes a year (and dropping the existing 50% target), the Mayor loses the right to object to any lower target set by a borough. The Plan should therefore set the amount of affordable housing to be provided by each borough.
In abandoning the 50% affordable housing target the Mayor’s position in responding to proposals for no grant schemes, or schemes with no / low affordable housing, would be weaker than at present. This is a good reason not to drop the 50% target.
In the view of the SCA, the weak wording of policy 5.1 and 5.2 – the Mayor “seeks to achieve” a 60% reduction in carbon emissions – and with no interim targets there is nothing against which the Mayor can monitor the success, or otherwise, of achieving this reduction.
City Fringe / Policy 2.13 Annexe 1
The SCA disagrees that there a strategic need to accommodate the expansion of London’s financial and business sector in the City Fringe because we have not found anything to recommend the corporate development planned or approved here: 32-42 Bethnal Green Road; ‘Bishops Place’; the Corporation of London’s plans for the ‘Nicholls and Clarke’ site; all negotiations to date over Bishopsgate Goodsyard; Aldgate. None of these plans pays any attention to the character of Shoreditch, Spitalfields, Brick Lane, Whitechapel and Bethnal Green or to the needs of its residents who live in ‘some of London’s most deprived inner city neighbourhoods’ (Annexe 1).
The SCA believes that the Corporation of London should concentrate on increasing office density within its borders, which is already occurring with the Heron Tower, while all development outside these borders needs to be of a different nature and subject to fresh ideas. The Plan alludes to this where it says there should be ‘a distinctive planning policy approach’ (para 2.37 Inner London). We discuss this further under regeneration policy.
We do not agree with Opportunity Area policy being applied to the Spitalfields / City Fringe area as it favours high density, major business centres (smaller businesses are relegated to outside the area in Tower Hamlets’ Core Strategy) with smaller, high-density housing units, less open and green space, and unsuitable for families to remain living in.
Policy 4.2 Offices
The Plan’s emphasis on building offices according to office floorspace projections is to be expected but the SCA suggests that the large-scale office-building mentality needs to change and that the continuing development of traditional corporate spaces and large-scale buildings, in the wrong place, will not contribute to the mixed, challenging, residential and small business areas adjoining the City – unless the idea is to further force the current population and businesses out. This has been a part of our experience here in Spitalfields.
The major office building agenda has been particularly driven by the Corporation of London many of whose members profit from the development and from the property speculation industries. The Corporation of London views the Isle of Dogs / Canary Wharf, where there is more room, as opposition rather than as a partner as it seeks to build more floorspace. The SCA would like to see alternative independent research to justify the need for the proposed office floorspace figure that presumes major large-scale business districts in Whitechapel and on the Bishopsgate Goodsyard. That research should factor in new alternative workspace needs, office refurbishment and home-working.
The East London office development industry should also be viewed somewhat separately from ‘London as a World City’ because London’s primary status in the league table has much more to do with lack of financial regulation and other factors (European Cities Monitor 2009). In fact the move to the West End of smaller banks and hedge funds, shows a boredom with the corporate culture of the City and Canary Wharf, as people seek more life outside this mono culture. At present the City Fringe does still provide this multi-cultural life but will not do so once the corporate blanket covers it. The industry is also subject to the swings of fortune experienced by the banks, leaving large properties empty and of no use to any economy – local or national – Dubai-style.
The Policy should:
Update office projections and justify the City Fringe office target.
Recognise the local economic effects of corporate office development.
Seek provision and protection of local businesses and business units where major office mixed-use development is proposed, ideally within the development, providing specific renumeration from developers for local small business incentives / premises and not diverting funds off-site.
(This would be a similar approach to Retail Diversity policy in the Plan. Also, see Kensington and Chelsea report ‘A Balance of Trade’ by Cllr Tim Ahern which recommends “require, through a Section 106 agreement, that developers gift a proportion of small units in a new retail development to the Council to manage as affordable retail units, in the same way that developers construct housing units for registered social landlords to house low-income residents.”)
Policy 7.7 Tall and large buildings
The policy mixes the physical design of buildings with non-design financial and economic considerations and this creates an ill-defined policy. Indeed this correlation between a policy and its economic aspects, impacts or benefits is seldom found elsewhere in the Plan where it could be.
What exactly is the inherent ‘strategic approach’ (7.7A) assumed by the development of tall buildings? It implies that a tall building represents a form of development that cannot be achieved in any other way and that these buildings possess powers beyond their physical form to ‘change or develop an area’. This needs to be explained and justified.
Tall and large buildings should ‘make a significant contribution to local regeneration’ (7.7 C (h)). As we argue, the ‘regeneration’ carried out in the last twenty years has not lead to sufficient benefits for local populations and until a new mandate for regeneration is established it is not appropriate to list ‘regeneration’ in this way.
London Plan policy should not state inherent economic benefits of tall building development when in practice it can be so detrimental to local economies and enterprise. Instead the policy should only focus on the design considerations of tall buildings.
There is much to suggest that new ways of working and sustainable approaches to building will bring about different forms of architecture. There is also much work on the achievement of density at a low-rise scale without the negative impacts of high-rise. Tall buildings use high amounts of energy to construct, power and maintain, often they are designed to have a very short life as part of the continued property development ‘churn’ discussed above. For a long-term, carbon-reducing plan, this form of development should be phased out, not singled out as inherently beneficial.
A much-repeated but valid concern about tall buildings for housing is their ‘return to the mistakes of the 1960’s’: bad designs, social dysfunction and very run-down shared space. In the housing standards policy, further conditions could be included and require specific plans for the proper management and upkeep of tower block housing.
The policy should focus solely on the subject of ‘location and design’ and should read:
7.7A(Strategic) Tall buildings should meet the highest standards of sustainable and inclusive design and should not have an unacceptably harmful impact on their surroundings. (delete Tall buildings should be part of a strategic approach to changing or developing an area)
Delete7.7C (a) sites for tall buildings
Delete 7.7 C (h) re. regeneration
Policy 8.2 states that the proper level of financial contributions is a material consideration (rather than a condition of any development) but financial considerations should not override other material considerations.
Policy 2.14 Areas for Regeneration
Regeneration is discussed here under Policy 2.14 but the subject of ‘regeneration’ is common to the whole Plan and must be considered as a fundamental issue.
Regarding the policy itself, we do not support putting regeneration areas in the hands of local authorities without a set of guidelines, or a ‘regeneration mandate’: a tool to provide improvements and benefits to the local communities in these areas to change the ‘deprivation map’ for the better. Our experience in dealing with Tower Hamlets Council is that their interest in regeneration is as a mechanism to bring money into their hands rather than a process that could deliver more subtle social effects. The council recommends for approval a high number of major developments which go against planning policies such as those for public amenity, green open space, affordable housing, housing density, community facilities, local business, local historic buildings – policies beneficial to the community.
What are the problems in the way regeneration is enacted in London?
It is a property-led, growth-driven process, which does not lend itself to a parallel consideration of what is needed on the ground; and local authorities no longer believe it is their role to mediate between these two.
It can entail the breaking up of existing communities and social capital, the replacement of existing (affordable) commercial activities and local services, increased crime, pressures on surrounding affordable areas, and community resentment and conflict – in addition to the obvious loss of affordable housing. It does not have sufficient root in the community in which it happens. (NB these effects are listed in the Tower Hamlets Core Strategy Equalities Impact Assessment.)
Regeneration agencies are parachuted into the area often without useful and deep knowledge or ownership of it. They enact their business for a five-year period then leave. This prevents long-term thinking and long-term investment.
Regeneration does not provide solutions to fundamental problems. How could this be improved?
Policy in the San Francisco Bay Area is an example of how planning can recognise and provide some solutions to this continuing issue. Their focus is the development of areas around transit systems, developed to reduce car use (exactly like town centres / transport nodes in the London Plan) but which lead to higher property prices and the displacement of local populations who in turn must travel further and be subject to fewer services and improvements in their situation, when they need it most.
‘Development Without Displacement’ is explained as follows:
“Equitable development is an approach to ensure that low income residents and communities of color participate in and benefit from regional growth and development.
Equitable Transit Oriented Development Strategies for Planners
Transit-oriented development can be a solution to regional and local inequity by reducing segregation and concentrations of poverty, improving public safety and amenities, and unlocking neighborhood development potential. If TOD, promoted to address climate change, ends up displacing low-income or minority residents, there is an environmental justice concern.
Incorporating anti-displacement goals at the beginning of a transit-oriented development planning process can help engage broader political support for planning, maintain neighborhood diversity and character, facilitate new development, and create new housing and job opportunities where they are most needed. Around the Bay Area, regional and neighborhood groups and local agencies have identified tools to make sure that transit-oriented development also improves equity. Individual developers, neighborhoods, cities, regions, states, and federal government all have a role to play in limiting TOD-related displacement.
Strategies to Prevent Displacement
Based on the existing planning and urban policy literature and current Bay Area practices, six strategies are offered to prevent displacement in areas where substantial new transit and real estate investment is forthcoming. Each of these strategies is associated with specific tools that can be used to ensure the development of complete communities for the residents who already live within them.
The strategies are as follows:
Understand neighborhood change and displacement potential.
Engage residents in creating a vision for the future.
Preserve existing units and act quickly to secure land for development of new
Protect areas sensitive to displacement from upzoning.
Retain and grow good jobs.
Plan for neighborhood activity centers (“social seams”) to support integration and secure other community benefits for current residents.”
To make a solid improvement to the London Plan the Mayor should take on the role of devising a strategic mandate for regeneration, which tackles the ‘development without displacement’ issue that is so much a focus of concern. This should apply to all the areas set out for regeneration, intensification, centralisation and opportunity. The SCA would support every one of the initiatives presented by the SFBA above, and would support the addition of a community development policy in the Plan.
Policy 8.2 Planning Obligations
The SCA feels that the Section 106 Agreement system must be more accountable to the communities in which development occurs so that money can be used in a transparently beneficial way. The Community Infrastructure Levy, or any levy that takes away from beneficial local use of such money, is not supported. Having battled very hard and through Parliament and the House of Lords to prevent Crossrail digging a tunnel in the very heart of Spitalfields, a plan without any consideration for the local community, the SCA finds it hard to support regeneration funds being diverted to Crossrail.
The SCA supports the policy put forward by the Friends of Queens Market and others – a new policy added to the London Plan for the protection and support of London’s markets. This new policy would have lasting benefit.
The LSE in a background note on the London Plan (HEIF Development Workshop 9th December 2009) discusses the social policy in the Plan, which they describe as: ‘two spatial strategies – targeting investment and job creation on/close to areas of social deprivation and promoting mixed residential neighbourhoods – plus skill development for individuals and the growing emphasis on place.’
They then go on to say: ‘One question which needs to be asked is whether there is actually an evidence base for the suggestion / belief that these elements in the Plan can have substantial social effects or whether the issues are concentrated more on other constraints on individuals’ ability to share in the benefits that a successful economy should offer. Anotheris whether, beyond the sets of Performance Indicators to be deployed in the Plan-Monitor-Manage framework, there will be provision for diagnosis and learning – about the causal connections between policies, processes and outcomes, and how better understanding of these should feed back into the Plan revision process.’
The SCA would welcome the Mayor’s closer examination of these ‘policies, processes and outcomes’ of planning policy, some of which which we have endeavored to highlight in this submission, to increase the beneficial social effects of the Plan across London.