m10-13 notes 22 January 2019

M10-13 Overall Spatial Development Strategy

Warning: Just Space and UCL are trying to make available some sort of record of what happens in the EiP for the benefit of community members. Notes are being taken by postgraduate students and checked/edited so far as possible by more experienced staff and others. Neither Just Space nor UCL offers any guarantee of the accuracy of these notes. If you wish to depend on what was said at the EiP you should check with the speaker or with the audio recordings being made by the GLA. If you spot mistakes in these notes please help us to correct them by emailing m.edwards at ucl.ac.uk

The Panel questions were: M10 Should the vast majority of London’s development needs be met within London?
a)  Is the approach of seeking to accommodate the vast majority of identified development requirements between 2019 and 2041 within London justified and would so doing contribute to the objective of achieving sustainable development?
b)  Alternatively, would accommodating more of London’s development needs in the wider South East and beyond better contribute to the objective of achieving sustainable development?
c)  If so, is there a realistic prospect that such an approach in London and the wider South East could be delivered in the context of national policy and legislation?

M11. Is the strategic approach to accommodating development needs within London justified and consistent with national policy? In particular:
a)  Is the focus on the Central Activities Zone, Town Centres, Opportunity Areas and through the intensification of existing built-up areas in inner and outer London whilst protecting the Green Belt and Metropolitan Open Land justified and would it be effective in meeting identified needs and achieving sustainable development?
b)  Alternatively, should some of London’s development needs be met through reviewing Green Belt and Metropolitan Open Land in London?

M12. Is the broad spatial distribution of housing and employment development proposed in the Plan, including between inner and outer London10, justified and would it contribute to the objective of achieving sustainable development particularly in terms of minimising the need to travel and maximising the use of sustainable transport modes; building a strong, competitive economy; creating healthy, inclusive communities; and respecting the character and appearance of different parts of London?

M13. Would the Plan be effective in ensuring that adequate physical, environmental and social infrastructure is in place in a timely manner to support the amount and type of development proposed? In particular:
a)  Is the development proposed in the Plan dependent on the provision of the infrastructure identified in the London Infrastructure Plan 2050 [NLP/EC/020]?
b)  If so, is the strategy justified and would it be effective, bearing in mind that the delivery of some of the infrastructure projects is not certain and that there is an identified infrastructure funding gap of at least £3.1billion per year?
c)  What, if any, strategic infrastructure other than that identified in the London Infrastructure Plan 2050 is likely to be needed to support the development proposed in the Plan?

On Tuesday 22nd January, the Examination in Public focused on the overall Spatial Development Strategy laid out in the New London Plan (NLP). The session ran over a full day and was the occasion to question the relevance (and likelihood) of meeting London’s housing, infrastructure and jobs needs within the GLA boundaries, following the ‘compact city’ approach laid out in the NLP. Overall, the discussions set out the scene for further thematic examination of the NLP’s approach to spatial development by highlighting that the housing targets it introduces would be extremely difficult to achieve, for multiple reasons.

Firstly, there is evidence of a consistent failure in meeting housing targets set out in past London plans. Various participants including Outer Boroughs, local authorities from the East of England and South East (together called Wider South East), house building organizations and community groups expressed concerns on the feasibility and consequences (in terms of density, displacement, etc.) of the objectives set out in the NLP (66,000 homes a year). LSE London and Just Space both highlighted that London’s footprint extends beyond its administrative boundaries and this has implications for housing markets beyond the GLA border. Similarly, major infrastructure projects – and national policies – do create connexions between London and its broader functional region. As a result, growth projections and housing strategies need to account for these effects and to engage with local authorities in the Wider South East in order to realistically assess what the appropriate (and realistic) response to housing needs and population growth might be. The point was made that more engagement from the Mayor (beyond the ‘willing partners’ approach) was needed to ensure mutually beneficial strategies could be laid out in collaboration with other local authorities. The GLA team responded this was something they were pursuing and that it would take time to engage in collaboration with partners outside the GLA.

Secondly, it was noted that the NLP differs from previous plans in that Outer London Boroughs are asked to contribute to the provision of housing and jobs in a greater proportion than Inner London Boroughs. A representative from the London Borough of Enfield welcomed this ambition but doubted it could be achieved without giving greater autonomy and flexibility to Boroughs themselves so that they can achieve their targets. A representative from the London Borough of Croydon stressed that housing and job targets should be supported by an assessment of their impact on local communities. A lot of Outer Boroughs’ housing density targets will be conditioned by the delivery of major infrastructure schemes, such as Crossrail 2, which are themselves highly uncertain. Unlocking land for development and incentivising densification might be necessary to address housing needs, but the NLP should incorporate further consideration of the issues it will raise in relation to the provision of key services (schools, health) and transport infrastructures within the GLA boundaries and beyond.
Thirdly,  the mechanisms laid out in the NLP to accelerate housing delivery in Town Centres, Opportunity Areas and Small Sites were deemed problematic for various reasons including the lack of clarity on their impact on employment & services, local character (for Town Centres), the type of incentives and behavioural changes that would be needed to bring these forward (in the case of small sites), their ability to deliver affordable housing for all Londoners and to protect existing communities (in the case of Opportunity Areas).
Overall, there was a consensus that the targets set out in the NLP were likely to be unrealistic and that their delivery – particularly as they focus on unlocking opportunities for private-led developments – would raise sustainability challenges, specifically in relation to the protection of local communities – low and middle income –, the provision of affordable housing and in relation to the protection of local character and heritage.
Just Space was almost alone in challenging the spatial structure of London as it was emerging and foreseen in the draft Plan, challenging the GLA’s asssertion that the premium rents paid by firms to locate in the Central Activities Zone (CAZ) was adequate evidence to support the Plan’s continuing priority for central employment growth. JS agreed that the benefits of agglomeration do indeed accrue to businesses and to the owners of bulldings in which they operate, but that the costs of agglomeration were great too, and are borne by the population (air quality, housing costs, travel costs) or mitigated by massive state invetments in radial transport. This was partly why Just Space has called for less emphasis on CAZ growth, more on sustaining existing and growing employment in the rest of London. The spatial strategy of Just Space, of which this is an element, should have been evaluated as part of the Strategic Environmental Assessment (which we had argued under Matter 1 SEA). This community-generated spatial strategy is based in maximising local accessibility between homes and jobs, sustaining and building upon non-central local economies, focusing transport investment on orbital and bus routes as well as walking and cycling and thus reducing the need to travel.

Edited by Enora Robin from notes by Cecilia Colombo, Gabi Abadi, Sam Colchester, Alice Devenyns and Emma Woodward

Later Paul Burnham from Tottenham who spoke from the Just Space seat, presenting the Just Space case for part of the day, wrote
“The existing London Plan 2016 (Policy 3.3) advocates estate demolition both to build additional homes, and because the estates are seen as bad in themselves: supposedly mono-tenure places which entrench social exclusion, etc.  All of this is all changing in the Draft New Plan, which lists in Policy H1, six sources of new housing supply, which do NOT include the redevelopment of council estates.  Of course the GLA is still facing both ways.  But it is no longer encouraging estate demolitions as hard as before.”

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On to next blog post: Opportunity Areas M14