The Wider South East and Beyond
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The panel asked the following: M16. (a) How, if at all, should the Plan address the matter of development and growth in the wider South East?
(b) Are policies SD2 and SD3 necessary, and would they be effective in assisting in implementation of the Plan and/or informing a future review of the Plan?
Panel’s Opening Announcements The panel of inspectors opened the session by asking that participants engage in structured discussions around the matters highlighted on the agenda. Further stating that the purpose of the sessions was to assist in the National Planning Inspectorate’s decision on whether the plan is viable.
The Inspector opened the session by stating that the Wider South East had been touched on in previous sessions, particularly Matters 4, 5 and 6 last week. The GLA’s position is that there should be no dependency on the Wider South East (WSE) region to accommodate London’s growth. London’s demands, in housing or otherwise, should be met within London. GLA representatives expanded on this by saying that the Mayor cannot govern development outside London but it is not denied that the capital does have links strong links with the WSE region, so it makes sense to collaborate with these authorities, particularly on strategic matters that go beyond London and its administrative boundaries.
a) How, if at all, should the Plan address the matter of development and growth in the Wider South East (WSE)?
The London Forum stressed that this issue isn’t just about housing but also the economy which, like many other issues, operates beyond administrative boundaries. The Home Builders Federation (HBF) added that according to the National Planning Policy Framework (NPPF) 2018 the mayor has a duty to cooperate on cross boundary planning, something which the HBF feel the mayor has refused to engage with over the last three years; the plan should reinforce this duty. The HBF further stated that neither the mayor nor the WSE governening authorities have fully engaged with the housing gap that they believe is inevitable. The HBF felt that in order for the plan to be in line with the NPPF (2018) policies SD2 and SD3 need to state that the mayor is responsible for producing statements of common ground. The House Builders Consortium concurred and added that they believe that the shortfall is inevitable and the GLA should prepare and plan for it.
The Common Futures Network, a national body of academics and practitioners, advocate for a more strategic, evidence-based approach which applies a consistent methodology. This applies to issues much broader than housing and, due to the extent of interregional commuting, London and the WSE needs to be treated as a wider city region. The Network advocated for central government departments to get involved in the planning process arguing that integration could not be achieved through bilateral discussions.
Natural England added that the natural environment is an important part of the growth and development agenda as the Good Growth Policies set out in the plan cannot be delivered without due regard to the environment. The Inspector acknowledged that there is a wide range of issues, not just housing, that needs to be considered in the discussion around London’s relationship with the WSE region.
Ian Gordon from the London School of Economics (LSE London) found the plan to be evasive when dealing with the issue of housing and argues that the GLA cannot simply transplant the demand in London to the WSE region. A mutual agreement must be reached via a collaborative and integrated approach. The London Assembly Green Group further stressed the need for integration across a host of issues such as housing, transport and natural infrastructure which is currently missing from the plan. The Assembly Green Group representative felt this had been done well within London but not between London and outside areas. The London Forum noted that exporting people to outside of London will overload already stressed transport links. The representative argued that encouraging prosperity and economic growth in the WSE in a way which is balanced would mean some people would have to commute out of London, relieving some pressure on transportation networks.
HBF called for a clear structure to be expressed in the plan explaining how strategic issues will be addressed in relation to the WSE as the current plan doesn’t live up the expectations in the NPPF. A representative from Gatwick Diamond highlighted that authorities in the WSE are already under pressure to meet their own housing needs. The London Plan lacks a realistic approach of what these extra demands will mean not only in terms of housing but the associated social infrastructure. The Inspector appreciated this summarising the representative’s point by saying that the scale of the growth they will inevitably have to accommodate is huge.
(BREAK at 11:05)
b) Are policies SD2 and SD3 necessary, and would they be effective in assisting in implementation of the Plan and/or informing a future review of the Plan? (11:25)
The GLA were asked to clarify what policies SD2 and SD3 were. The response from the Mayor’s team was that SD2 provides a procedural approach and commitment to collaboration whereas SD3 sets out a spatial approach to collaboration on growth and unlocking infrastructure opportunities in the WSE.
The representative from the county of Buckinghamshire expressed their support for the policy and the general approach but asked that there be a clearer approach for future collaborations. East of England Local Government Authorities asked that the plan be more specific about which areas London will require the WSE region’s help with.
The Common Futures Network were encouraged by the GLA’s pooling resources approach as they believe this will improve the evidence base on which spatial strategies are made. Nicky Gavron, representing the London Assembly, seconded the need for a strong evidence base as without one it is impossible to have more structured discussions and clearer actions. Gavron further suggested that there should be a technical secretariat which would work to formalise the process and create a more structured space in which to have these discussions.
Natural England support for SD2 for wider collaboration, in particular subsection E and its inclusion of biodiversity and green infrastructure.
The HBF felt that through the London Plan the Mayor is ignoring central government policy, in particular his duties under the NPPF, and not for the first time. In order for the plan to be implementable it needs to change. He adds that the willing partners matrix should be deleted from SD2 and SD3 as it doesn’t have the weight of the NPPF or the weight of statute.
In conclusion the London Borough of Bromley representative felt that policies SD2 and SD3 were vague; the London Forum recalled the statement by Jennifer Peters (GLA) that 80% of the housing built in London is only affordable to 8% of Londoners; finally, LSE stressed the Mayor and by extension the plan has a duty to cooperate in a transparent and realistic way.
notes by Emma Woodward
Just Space 