A summary of the submissions

Here is a tabulation of the 23 Just Space groups and the issues they have raised in their responses to the Draft London Plan . Summary Matrix

Below are summaries, one by one, of the submissions. Both the table and the summaries have been prepared by Julienne Chen.

Draft London Plan Representations
Summary of Just Space Submissions
12 February 2010

Age Concern London (ACL)
ACL is concerned with promoting the interests of older people. Their representation highlights an omission of the older people’s contribution as workers, volunteers, grandparents, carers and in many other roles, particularly in the section on economic opportunity. There is also a need to strengthen policies for Outer London, which have higher proportions of older people than in Inner London, and which is particularly relevant when considering people aged 50+ who are employed or would like to be employed (this is a significant number that requires more targeted employment programmes) are often looking for employment close to where they live. Issues of accessibility are paramount, including step-free access for the Underground and wheelchair accessibility in housing. Social infrastructure should include social care provision, community meeting facilities, recreation facilities and premises for voluntary/community organizations; and supported housing should also be tailored to BAME and LGBT groups who may face exclusion. ACL also requests that policies should provide support to the voluntary and community sector. Finally, the concept of lifetime neighbourhoods should make reference to the criteria regarding transport, facilities and design as can be found in “Lifetime Homes, Lifetime Neighbourhoods.”

Chapters Referenced: 1, 2, 3, 4, 6

Black Neighbourhood Renewal and Regeneration Network (BNRRN)
The BNRRN has stated concern about the ability of the draft London Plan to effectively tackle issues of deprivation, worklessness, and affordable housing shortages, particularly in relation to BAMER communities. They have requested greater emphasis on the consultation process with BAMER groups for the Olympic legacy; strengthened policies to provide affordable housing (including concern about the 50:50 split and the need for investment in building council homes instead of relying on the market-led approach); a more integrative approach towards tackling deprivation, including social infrastructure provision, extensive community consultation and support for third sector and voluntary organizations, and strategies for places of deprivation that have no planned opportunities; and opening opportunities for employment.

Chapters Referenced: 1, 2, 3, 4, 7

Camden Tenants
Camden Tenants represent council tenant and leaseholders in Camden. They advocate focusing on creating a more diversified economy that places a higher value on quality of life (incl. social and environmental), is more environmentally responsible, and allows for meaningful community involvement in redevelopment decisions. They ask for binding targets for affordable housing (per borough), oppose the 20% reduction proposed and more enforcement to secure s106 housing from developers. They also focus on development quality, such as regulation of density and tall buildings. They also challenge the call for mixed-tenure development, which threatens the supply of affordable housing and is condescending and lacks an evidence base – publicly subsidized development should benefit particularly those originally living and working in the area. Finally, all new developments should meet higher environmental targets, with more interim targets between now and 2025 and a priority on supporting retro-fitting homes.

Chapters Referenced: TBD

Campaign for Better Transport
The Campaign for Better Transport has focused its representation on securing an implementable commitment in the London Plan to reducing car usage and specifically, the need to travel. They are concerned that there are contradictory policies that on one hand support public transport, walking and cycling, but at the same time make provisions that encourage personal vehicle usage (e.g., relaxed parking and road [environmental] standards, removal of traffic reduction targets, an absence of policies to tackle traffic volumes and speed, and support for increases in road capacity). They further request a greater focus on implementation measures to reduce the need to travel through spatial planning (such as the support of accessible and dense centres with a diversity of land uses); the inclusion of transport in the CO2 reduction target; and more ambitious cycling targets.

Chapters Referenced: 2, 4, 5, 6, 7, 8

Capital Transport Campaign (CTC)
CTC has focused most of their response to the Mayor’s Transport Strategy. Specifically in regards to the draft London Plan, they request further definition of ‘smoothing traffic flow,’ and its effects on other policies such as encouraging walking. They also support more refinement in how Public Transport Accessibility Levels (PTALs) are calculated that in particular incorporate physical constraints in access.

Chapter Referenced: 6

David Fell

Mr. Fell’s representation focuses on 1) the need for the Plan to explore alternative futures for London outside of economic growth, taking into account the contradiction between endless economic growth with quality of life and environmental sustainability; 2) the need for the third sector and community-owned and social enterprises to be recognized – an supported – in the plan; 3) an inconsistency and mismatch throughout the Plan between rhetoric and supporting policies, targets and interventions. On the third point, he points out the examples of: creating job opportunities for Londoners, a low carbon economy, access to quality and healthy food, energy provision, innovation and enterprise (as illustrated by the lack of support for micro, third sector, ethnically-led or ‘alternative’ enterprises). Mr. Fells also takes the example of supporting affordable units for small retail shops, and requests extending that protection to other categories, such as small offices or voluntary/community owned enterprises. He also has a number of specific policy changes within Chapter 4 (Economy).

Chapters Referenced: 1, 4

Development Trusts Association (DTA)
The DTA represents social and community enterprises that are part of the wider third sector and involve a business model of community-based income-generating activities that simultaneously address issues of inequality, poverty and worklessness. Their representation requests more explicit support and recognition in the London Plan for community-based solutions and a commitment to support social enterprise innovations, such as through pilot funds/projects, that in turn can play a powerful role in the creation and maintenance of social infrastructure. They would also like social and community enterprises eligible as potential beneficiaries of planning obligations.

Chapters Referenced: 3, 4

Friends of the Earth

Friends of the Earth ask that the London Plan incorporate social and environmental requirements into all of its objectives, including those on the economy. The plan should build a just society, reduce inequality and promote sustainability, and the economy needs to be diversified (geographically and sector-wise) to reflect a low-carbon commitment. This principle applies also to all development and regeneration, taking into account impacts on environmental targets and impacts on existing communities. Outer London must also play its part, creating opportunities to live/work in the same place and reducing the need to travel. Car dependence should be addressed e.g., through congestion charging, more stringent road building and parking standards, refusing new large roads & vehicular river crossings. Climate change/air quality should be regulated through opposing increases in airport runway capacity/flight increases, incl. at City Airport. Sustainability must also be achieved through housing, including via retrofitting programmes and through ensuring affordability.

Reduction in CO2 emissions should incorporate interim targets, and specify reductions to be achieved by all sectors (e.g., transport only set at 10%). More proven measures are also needed to reach required air quality EU targets. Friends of the Earth also advocates a 20% policy for renewable energy; reinstating self-sufficiency targets for waste; increasing recycling; and provision and protection of natural habitat and open space.

Chapters Referenced: 1, 2, 3, 4, 5, 6, 7

Friends of Queens Market
Friends of Queens Market have requested a specific policy that protects and supports street markets. They object to the statement in the draft Plan that markets are only valuable where they draw shoppers into retail centres, and ask for recognition of the importance of markets in their own right for their contribution to health, enterprise, local economies and their social value. Furthermore, they ask that future planning developments adjacent to markets provide a more thorough level of consultation that includes all groups (incl. those whose first language is not English.

Chapter Referenced: 4

Haringey Federation of Residents Associations (HFRA)
The HFRA are a subset of the London Tenants Federation. In addition to the LTF submission, the HFRA adds their particular concerns that they have been faced with, particularly borne out of the interaction between developers and the local community. They are focused on protecting community interests and object to an over-emphasis on new growth. Instead, effort should be concentrated on empowering communities; providing more – not less – affordable housing, especially family-sized housing and the appropriate social infrastructure for it; retaining affordable offices for small businesses and voluntary groups; maintaining local community character and heritage; providing overall aesthetic improvements; promoting traffic calming and affordable public transport; protesting overly-dense developments that undermine sustainable communities; ensuring that s106 agreements lead to actual planning gain; and providing implementable policies imposed on all development to reduce carbon emissions.

Chapters Referenced: No specific policies referenced, but have subbed in 2, 3, 5, 7

Inclusion London
Inclusion London represents deaf and disabled people. They find that the draft London Plan does not adequately meet the needs of disabled people, and call for the following: funding for local groups of disabled people to be able to monitor and work around access issues; an increase (not decrease) in the target for affordable homes and for social housing for rent; a stop to ‘shared surfaces’ plans that exclude many disabled people – and action to agree to a universal and inclusive concept of shared streets; step-free access at tube stations; and active and collaborative implementation of lifetime neighbourhoods. They also ask for the Social Model of Disability to be explicitly and centrally present in all strategies, particularly to be reinstated in the equality strategy, with the core principle of ‘nothing about us, without us’.

Chapters Referenced: 3, 6, 7

Just Space

The Just Space representation is a comprehensive document that covers all sections of the draft London Plan save the implementation section. There are a few fundamental underlying currents: that the London Plan should support a more diversified economy that helps to meet sustainability goals, meets and supports the needs of local communities and opens up opportunities for women, the elderly, the disabled and BAME communities. The role of the voluntary sector and different enterprise and ownership models should equally be recognized in this effort. Inequality and deprivation needs to be addressed specifically and through more equitable housing policies that do not decrease the affordable and social housing supply, but instead actively seeks to increase them through targets applied to boroughs (scrap the viability clauses), social housing building and support of innovative new models of affordable housing delivery, support for housing sized adequately for families and built in accessible, neighbourhoods that are not overly dense and have adequate social infrastructure e.g., open space and play facilities, places of worship and even burial spaces. Furthermore, there is an immediate need to provide for and protect the housing needs of the elderly (sheltered housing, care homes and extra care housing), as well as for gypsies and travellers (extra pitches).

In a similar vein, the Just Space representation is opposed to policies on ‘mixed and balanced’ communities, the Olympics Legacy and similarly the definition of regeneration that do not specifically direct that local communities and their supporting social infrastructure be positively affected and not displaced. Reference to (and a precise definition for) lifetime neighbourhoods is preferred. This include a local needs index of the shops, social and community facilities and open spaces which need to be accessible to everyone within easy walking distance. Furthermore, policies should be in place to support and protect street markets and small shops. Tall buildings should be exemplary in sustainable and inclusive design and not have a negative impact on their surroundings. A separate section on community development is supported.

Climate change is a big topic, and there is inadequate guidance in the Plan to get us to the 60% reduction target, as well as no reference to environmental justice and reducing environmental inequalities. Interim emissions targets should be set, and focus should be on committing to a green, low carbon economy, retrofitting existing buildings, improving London’s biodiversity areas, and reducing the need to travel. This final point can be tackled in many ways, from more support for bicycling, walking, and sustainable public transport; the prioritization of rail expansion over air travel expansion; using the Blue Ribbon Network (BRN) for freight travel; the creation of neighbourhood centres in Outer London that allow live, work and play needs to be met locally; and more – not less – stringent guidelines for personal vehicle use including speed and parking standards and road user charging.

Finally, there should be more attention paid to land for food growing, the Blue Ribbon Network and the protection of wharves, boatyards, and the River Thames, which is under threat of increasing privatization and relaxed development control. Overall, Just Space also notes a general lack of targets in the Plan that can counter poor local decisions.

Chapters Referenced: 1, 2, 3, 4, 5, 6, 7

King’s Cross Railway Lands Group (KCRLG)

The KCRLG represents local resident and business needs in the King’s Cross area. They have taken objection to policies within the sections on Housing, Economy, Opportunity Areas and Regeneration and Walking/Cycling. On regeneration, KCRLG asks for the protection of all residential neighbourhoods from development (not just those in designated areas); that opportunity areas take into account local needs and impacts; that the housing and employment targets for opportunity areas be subject to full consultation (specific to King’s Cross – why have the housing targets been reduced by 325 units?). Furthermore, KCRLG questions the fundamental use of regeneration, arguing it should only be applied when it benefits – and does not displace – the local population and public/private services. They also reject the Plan’s support of mixed-tenure development as threatening the affordable housing supply and as being condescending and without backing evidence of its benefits. Regarding housing, KCRLG asks for investment in social housing (incl. quotas on developers and targets not determined by boroughs) and new funding and delivery models for affordable housing.

On the economy, the plan should explore alternative economic models of growth and development (e.g., development trusts, community land trusts). The concept of lifetime neighbourhoods are strongly supported, but they should also be implemented in Inner London. They advocate effective citizen engagement, particularly for areas facing railway expansion. Finally, they request that policies on walking and cycling be strengthened to insist upon good permeability through large development projects.

Chapters Referenced: 2, 3, 4, 6, 7

London 21
London 21 supports grassroots and disadvantaged communities in promoting sustainability, and has a driving goal also to minimize inequalities – environment, health, social and economic. They have the following areas of concern: that the six key objectives do not mention deprivation or exclusion (although Objective 1 prescribes ‘economic growth’ as a remedy). However, the Plan should not focus on economic growth, but a more sustainable model that focuses on progress and allows for long-term prosperity. Environmental inequalities should be addressed via targets for the public realm, air quality, noise and open land and a framework for an environmental justice impact set. Specific policy to achieve the 60% reduction in CO2 emissions and implementable measures, such as guidance on renewable energy and heating and retrofitting should be provided. Furthermore, The London Plan should make it clear where community involvement is looked for in delivering targets is looked for, and provide mechanisms for engagement in the detailed implementation of its policies.

Chapters Referenced: 1, 4, 5, 7, 8

London Forum of Amenity and Civic Societies (Summary of their summary)
London Forum has provided an extensive representation, covering Chapters 2 through 7 of the draft Plan. They have made comments on the need in the Plan to: provide a more adequate policy framework for Inner London; discourage large-scale office development; identify disaggregated preferred locations for office space with re-evaluated need projections; address whether affordable housing targets can be met; provide guidance on how the density matrix should fit into LDF; provide housing support for key workers, students and elderly; provide accessible health care within social infrastructure (which further needs to be linked to neighbourhoods); support reducing need to travel through tightening standards on parking, strategic development location, and transport access & capacity; promote the creation of walkable communities; address the contradiction between the objectives of the climate change strategy and transport strategy; preserve and protect heritage, views, open space and the Blue Ribbon Network; and ensure that architecture & tall buildings make a positive contribution to the townscape.

Chapters Referenced: 2, 3, 4, 5, 6, 7

London Gypsy and Traveller Unit
The London Gypsy and Traveller Unit has made representation regarding pitches to house gypsies and travellers, for the support of “inclusive communities where Gypsies and Travellers have fair access to suitable accommodation, education, health and welfare provision.” They request recognition of the immediate need for pitch provision; designating clear leadership to stakeholders in working towards such provision; an increase in the target for new pitches; promotion of pitches within the Olympic Legacy and other large development schemes; inclusion of Gypsy and Traveller sites in s106 social housing provisions; and more accurate counting of the gypsy and traveler population and monitoring of pitches to better evaluate set targets.

Chapters Referenced: 1, 3

London Play
London Play aims for every child in London to have quality, accessible and inclusive play opportunities, near to their home. They comment specifically on Policy 3.6 (Children and Young People’s Play and Informal Recreation Facilities), asking the word “should” to be replaced by “must” or “will.” They also ask to incorporate recent documents and guidance on standards (e.g., DoH’s Guidance on Joint Strategic Needs Assessment), and to cross reference the policy with other parts of the London Plan, such as Chapter 7, to better safeguard open spaces and playgrounds.

Chapter Referenced: 3

London Tenant’s Federation
All Londoners should have the opportunity to enjoy a good quality environment in an active and supportive local community. Ensuring this means planning for lifetime neighbourhoods in which communities are empowered and in which local shops, social and community facilities, streets, parks and open spaces, local services, decent homes and public transport are affordable and accessible to everyone now and for future generations. Within their representation, the London Tenants Federation has expressed a need for more focus on addressing the issues of poverty, inequality, polarization and worklessness; development of community engagement strategies; ameliorating the adverse effects of dense developer-led (vs. bottom up) regeneration on existing communities (including health and local character), including for the Olympic Legacy; bottom up economic growth that supports lifetime neighbourhoods and sustainable communities; supporting industrial locations; higher targets for social rented housing; support for youth recreational facilities; and questioning of the effectiveness and objectives of mixed-tenure communities vs. sustainable communities that do not rely on a strategy to “import wealth and export disadvantage.” The London Tenant Federation also has put forth an alternative definition of “lifetime neighbourhoods.”

Chapters Referenced: 1, 2, 3, 4, 7

London Voluntary Service Council (LVSC) – this representation refers to the Economic Development Strategy
The LVSC’s position is that the third sector (7% of London’s employment) should be more explicitly acknowledged and supported within the Strategy. The role of the third sector includes innovative models in fields as diverse as developing international links to affordable housing provision to green industries; community engagement and empowerment and social entrepreneurship. To support the third sector requires more tailored business support and services; provision of office space and premises in mixed use developments; and a move away from economic dependence on the financial sector.

This response also makes reference to the section on the low carbon economy, but believes that there is a fundamental contradiction between economic growth and sustainability that has not been resolved/prioritized within the document, and further requires more support for private and third sectors to reduce emissions. Some further actions to support: promoting equality – e.g., through reducing the costs of childcare, helping young people to volunteer, general improvement and skills development in low wage industries, development of community asset-based regeneration (such as for 2012), investing in local suppliers, and the use of wider impact measurements than monetary figures to determine success (e.g., social return, environmental impact).

Michael Edwards

Michael Edwards has made his representation on four main points: concerns about the growth objective and growth assumptions; diversification and sectoral emphasis; land/property markets; and a balance between local services and centres. He takes issue with the objective to pursue growth of GDP/GVA, which overvalues ‘high-value’ work at the expense of ‘low-value’ work and is contrary to improving quality of life and creating a low-carbon economy. The economic growth assumptions inherent within the draft Plan also are considered to be overly optimistic given the current state of the economy, and should provide alternative (more pessimistic) scenarios that also enable policies that support diversifying the economy through raising productivity (and wages) in the ‘non-high value’ sectors. Mr. Edwards has also stated a need to rein in the expectation of land value growth via strictly enforcing the density matrix with no exceptions. Finally, there is a need for the Plan to focus more on decentralising services, shopping and employment (as opposed to concentrating activities in centres) to reduce the need to travel and make areas better served locally. In support of this, he advocates higher priority in policies for street management and taxing parking spaces on private land.

Chapters Referenced: 1, 2, 3, 4

Planning Aid for London
Planning Aid for London is primarily concerned with community involvement and stakeholder partnership in all phases of regeneration (community-based and –led regeneration initiatives, including post-development management and maintenance), and with the implementation of the various policies of the London Plan. They favour the retention and improvement of existing housing stock and the disadvantaged communities that occupy it, rather than total demolition and redevelopment, and call for the involvement of the community and the third sector to mitigate the effects of higher property/rental values as a result of regeneration. 

Within the implementation chapter, they are concerned with the reduction of affordable housing targets and the split between social rented and intermediate housing, calling for the return of a 50% target and a 70/30 split and ‘teeth’ to limit the latitude that boroughs have in determining their affordable housing allocation. There is concern that the growth figures cited are overly optimistic and will have an impact on the delivery of affordable housing and social infrastructure.

They also ask for the following: to minimize the privatization of public spaces and the protection of garden and open spaces for food growing and commercial opportunities; recognition of the voluntary sector; more tailored policies for Inner London; a broad interpretation of quality of life; the need for ‘genuine religious literacy’ in interfacing with faith groups; coordination between boroughs and the regional Children and Young People’s Strategy; recognition of the disproportionate impacts of a decrease in affordable housing on people with disabilities; and concern about location, quality and the nearly 30% reduction in pitch targets for gypsies and travelers.

Race on the Agenda (ROTA)
ROTA’s representation is primarily focused on strengthening sections of the draft Plan to better tackle (and, ultimately, eliminate) issues of BAME inequalities – in health, education, representation in local structures and processes, social infrastructure, economic opportunity and housing. They suggest a separate section on equalities in Chapter 1, and an explicit objective to address the substantive inequality faced by BAME communities and other equality groups in London. They ask for support for BAME communities to participate in the emerging, cultural and socially diverse economy to compensate for the focus on the financial sectors, which certain communities do not have access to. ROTA is also concerned with the implementation of the Plan, requesting an outline of how to assess equality impacts and a cross referenced Key Performer Indicators that gauge how distinct communities are faring. They also favour a distinction between the third sector and the BAME third sector because of the specialized role that BAME organizations can play in tackling inequality and assisting in social infrastructure provision.

Chapters Referenced: 1, 3, 4, 8

The Regent’s Network
The Regent’s Network is an organization concerned with London’s waterways, and specifically the omission of considerable text and policies regarding the waterways from the 2004 London Plan to the current draft iteration. They advocate re-incorporating [redrafted] key segments from the 2004 London Plan’s section on the Blue Ribbon Network, including the principles, introduction, and the 24 policies that have been removed or incorporated elsewhere in the Plan. Subsequently there is a need to incorporate directives that address: balancing productive use and leisure use; private use and public use; towpath access for cyclists vs. pedestrians; access and safety; provisions for support facilities/boatyards; objections to business barges; need for design guidelines; protection of waterway infrastructure and wharves; support for commercial waterway transport; cooperation with the Crossrail project and the Olympic Legacy; discharge of sewerage into the waterways; regulation of light pollution; lack of visitor mooring; and provision of public toilets.

Chapters Referenced: 2, 6

Spitalfields Community Association (SCA)
The SCA is primarily concerned with the conflict outlined by the draft Plan’s focus on economic growth, development and regeneration, without taking due concern about the subsequent effects of displacement, loss of community character, and increasing polarization/deprivation. They object to assumptions that East London should accommodate the expansion of the financial and business sector, and specifically that the Opportunity Area policy be applied to the Spitalfields/City Fringe area, and request that office development take into account updated need projections, recognition of its local economic effects and the need for protection of local businesses. In addition, the detrimental effects of tall building development on local economies, character and enterprise should be considered in its policy, and SCA argues in favour of more sustainable approaches to building and the achievement of density at a low-rise scale. Furthermore, ‘regeneration’ should be accompanied by a mandate that provides tools for improvements and benefits to local communities and strategies to prevent displacement; with s106 agreements used in a more transparent way and accountable to the local communities.

Chapters Referenced: 2, 4, 5, 7, 8

Women’s Design Service
The Women’s Design Service focuses on strengthening the draft London Plan to better address deepening inequalities of women, who are generally poorer and are likely to be disproportionately affected by a failure to address poverty and deprivation. They have essentially submitted the Just Space representation with a few additions that focus on the needs of women: the need for mixed use/public transport accessible developments that allow for “trip chaining” (which also needs to be supported by transport fare structure that allows such chaining); affordable child care; access to affordable housing; removing barriers to women’s employment (part-time, flexible work opportunities; local employment and flexible business spaces; support for homeworkers); safe, accessible and cross-London transport (incl. bicycles, buses); and focus on creating safe open spaces and public realms.

Chapters Referenced: 1, 2, 3, 4, 6 (only those where WDS made additions to the Just Space representation)


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