EiP 15 May Notes
Draft London Plan Examination in Public (EiP):
Town Centres, High Streets and retail policy
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 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
Admin announcement from GLA: Won’t be individual responses from GLA on comments made in the EiP. There will be a vresion of the draft plan consolidating ALL the suggested minor amendments, but no date announced.
Panel questions: M88. Is the town centre network set out in the Plan justified and would it be effective in ensuring that identified needs for main town centre use developments are met in appropriate locations in accordance with national policy? In particular:
a) Is the existing town centre network classification of (i) international, (ii) metropolitan, (iii) major and (iv) district centres illustrated on Figure 2.17 and set out in Table A1.1 justified?
b) Given the definitions of the classifications of town centres set out in Annex1 and Figure 2.18, is the identification of centres other than “international” and “metropolitan” in the Plan justified and consistent with national policyrelating to town centres and compliant with legislation relating to the purpose of a spatial development strategy?
c) Are the future potential changes to the town centre network illustrated on Figure A1.1 and set out in Table A1.1 justified?
d) Are the classifications, as set out in Table A1.1 and described in Annex 1, for (i) night-time economy functions, (ii) commercial growth potential, and (iii) residential growth potential justified?
Matter M88 town centre network.GLA opens: Longstanding approach to have this hierarchy in the Plan. District town centres allows more comprehensive evidence base. Goes through potential reclassification of Stratford and Shepherds Bush. Shift towards the polarisation of retail.
Sometimes high streets have no ‘town centre’ designation. Boroughs should look closely at high streets and consider their designation. Could also designate them as business areas or local parades.
Panel: “Consider the protection of out-of-centre high streets” is not very clear, make a note to change it.
London Forum: Strongly support the whole approach to town centre hierarchy. Most robust set of policies in the whole spatial framework.
A local detail on Night Time NT labels: South Ken NT1 designation is incorrect. Should be NT3.
Just Space: Pleased to see inclusion of high streets in th policy. Key concern is the protection of workspace and local services to reduce the need to travel. Particularly in smaller town centres. Many high streets are not captured or protected in the Plan. Employment space is under threat from residential.
In some instances classification lacks complexity and ignores the diverse rnage of centres we have. Green Street in Southall, for example, provides for many Asians from far and wide, and should be classified as international.
Policy needs to be flexible to allow more specialist centres to emerge in London.
Historic England: Would be helpful to have more clarification on high streets from GLA.
Merton: Colliers Wood centre designation is unjustified because it is based on inaccurate evidence. Town centre classification only measured two sites, only measured two sheds. Should classify it as a district centre.
GLA: Night time economy classification for South Ken is due to Royal Albert Hall.
To Just Space, keen to encourage protection of workspace. SD7 does this. Policy E1 too. Interested to hear more about the town centres that we may have overlooked but would expect Boroughs to do this better, health check can only go so far.
London Forum: Classification will encourage an even greater move to A3 uses. Needs all the support possible to support retail functions.
Just Space: On specialisms, would like to see recognition of diversity of ethnicity. Queens Market East Ham and Ridley Road market are other examples.
Chair:Moving on to M89-90.
Panel questions: M89. Would policies SD6, SD7, SD8, SD9 and E9B provide an effective strategic framework for the preparation of local plans and neighbourhood plans relating to town centres and all types of main town centre use development (including bulky goods retailing), that is consistent with national policy?
M90. Is the approach to development management set out in policies SD6, SD7, SD8, SD9 and E9BA justified and consistent with national policy and would it be effective in terms of:
a) ensuring that identified needs for all forms of main town centre uses, including bulky goods, are accommodated in appropriate locations in accordance with national policy;
b) requiring large scale commercial development (over 2,500sqm of A Use Class floorspace) to support the provision of small shops and othercommercial units (including “affordable units” where there is evidence oflocal need); and
c) supporting Policy GG4 “delivering the homes Londoners need”?
GLA: About 400k m2 of comparison goods floorspace in the pipeline. We don’t look at these too closely because there are many uncertainties.
Retail is a main town centres use and should dominate there.
Could have gone further on out-of-centre conversion to residential use.
No definition of affordable commercial workspace in plan. Un-affordability tends to be concentrated in inner London.
Smaller units inspired by High Streets for All publication.
Further suggested change from last week under policy SD7 welcomed by Just Space but might have further comment after study.[ 2.7.3A It is important that boroughs plan positively to meet the needs of their communities. Being able to access convenience retail, specialist shops and services is important for supporting the daily lives of Londoners and for creating and sustaining strong and inclusive communities. Many town centres and high streets and marketsserve specific communities, for example they may provide specialist food or clothing that meet the cultural or religious needs of one or more particular group often drawn from wide geographic areas. Boroughs should use their evaluation of the area and engagement with local communities and stakeholders to draw up local development plan policies, designations and site allocations, and develop town centre strategies that seek to meet the needs of their communities. ] The words in red in the above are insertions which Just Space suggested in an email at the time. They may or may not be accepted.
Sainbury’s: Presumption against out-of-centre retail development. Inconsistent with national policy. Currently looking to redevelop Hendon centre on Edgeware Road. ‘Discourages’ should be removed from the policy.
Accessible Retailing: Plan is not supportive enough of out-of-town retail. Rise of online is making retail parks more attractive to chain traders who are trying to compete. This means that out-of-town should not be considered as soft targets for change of use. Out-of-town and retail park retailing provide roughly a third of retail employment.
Just Space: Our position is from the standpoint of reducing the need to travel and meeting more employment needs locally. Extremely glad to see the inclusion of high streets. Experian report indicates a range of floorspace demand, GLA takes the top of the range. Parts of centres which are lost in ‘consolidation’ are often the secondary and tertiary areas where ethic minority, small and innovative businesses flourish. Concern that there will become just primary cores of town centres remaining.
JS comment To Accessible Retailing, retailers have no need for the airspace above out-of-town retailing centres, which could be turned to housing or other uses.
Just Space Lucy: market policy is not effective (E9) or justified. Evidence that is available has not been used. Markets Board report on markets not reflected in the policy. Referring back to the document is not sufficient. No mention of traders. Preserving markets like Ridley Road not possible with current paragraph in the Plan.
‘Support’ is the only word used. Strategic role needs to be elaborated on, only role mentioned is a tourist strategic role. Searchable list of markets should be referred to in the plan, instead of just naming a few. Wording for the protection of markets should be included.
Markets are being threatened; emphasis should be on keeping the existing ones. Key is protection and understanding of the role of markets within town centres and elsewhere.
London Forum: Clean up the policy.
Assembly Planning Committee: Comments on SD6 and SD9. We support the need to promote residential development in town centres but policy needs to provide adequate social infrastructure where this happens. And mayor should include support for community engagement. Just Space mentioned 47% employment within or near high streets, we have concerns that this type of use needs to be protected in policy. SD9 should be strengthened, to require re-provision of non-designated employment sites.
GLA: Contracting demand for retail from Just Space, the GLA is closer to Just Space than it appears on this, we do talk about the demand issues in London. For retail, we think that the comparison goods will continue to decline. We’re careful to state ‘declining demand’. We’ll support town centres through diversification (although unclear what type of diversification).
On markets, we take a similar approach to the Markets Board.
On London Forum: we do recognise the importance of social infrastructure in town centres, SD9 includes wording around community engagement.
M91, hot food takeaways: Panel questions
M91. Are policies E9C and E9D relating to proposals containing hot food takeaways justified and consistent with national policy and guidance about healthy communities and limiting the proliferation of certain use classes in identified areas22. In particular:
a) Is the development of hot food takeaways and associated planning conditions a matter of strategic importance to London, or a detailed matter that would be more appropriately dealt with through local plans or neighbourhood plans?
b) What evidence is there indicating high levels of obesity, deprivation and general poor health in London?
c) What evidence is there of over-concentration and clustering of hot food takeaways in London?
d) Would restricting development of hot food takeaways within 400 metres walking distance from the entrances and exits of existing and proposed primary and secondary schools positively support the delivery of policyGG3 “creating a healthy city”?
GLA: Only four London boroughs have obesity levels below the rest of England. Strategic approach is needed – not at the individual level. Concentration of takeaways around schools is worst in London.
Only 5% of the meals on offer from the main 6 fast-food outlets are below recommended meal calorie level. Children less likely to go to full restaurants than hot-food takeaways.
Boroughs don’t all have the resources to conduct their own research on this. This is why they’ve asked the mayor for help on this.
Evidence that if there are lots of takeaway outlets that are further away they are less likely to be used by schoolchildren. Where the balance is mixed and not just fast-food there is likely to be a healthier diet.
Waltham Forest have not published any data on changes on behaviour with regards to their fast food policy. Childhood obesity has increased there, but might have increased more without.
Policy could potentially have an impact on minority ethnic businesses, and in some areas would have a disproportionate impact. Won’t result in closing down vendors.
Street markets are beyond what can be controlled with this policy.
Proliferation of takeaways outside school zones is a potential unintended consequence. But local authorities have policies that can control clustering under E9BA9 and also E9D.
A1 uses provide a broader range. If we see a significant impact and they change their use type we’d have to address that in a future London Plan.
London First: E9C is a blunt policy tool, takes an overly simplistic approach to a complex problem. Unhealthy options are available from A1, A3 and A4. Ban targeting just A5 will not address the root cause. Prevents the healthier hot food takeaways coming forward, which is a growing sector. Plan is overly detailed and prescriptive. It sets an unwelcome policy precedent. More nuanced geographically specific approach needed, set by Boroughs.
British Retail Consortium: Support the statements of London First. In effect this is a London-wide ban. It’s anti-competitive, locks in place existing A5 uses and makes them more viable. Much better to have a locally focused approach. Croydon found similar policies unsound. Support the healthier catering commitment (HCC), more targeted and effective direction to take.
KFC: Would like first two sentence of E9C to be deleted. Perceived unhealthy foods are also available from A3 and A1 outlets. Unintended consequences would impose a blanket ban, would prevent healthy hot food vendors. Not consistent with national policy, which is to promote competition and town centre uses. Best approach is to add A1 and A3 to apply to the HCC. Include the HCC to the appendix so that it can be scrutinised. A1 and A3 suppliers constitute 80% of children’s out-of-home calories.
McDonalds: E9 a blunt instrument. Oxford Study did not find any strong evidence for proximity limitations. Support the HCC going forward.
Accessible Retail: Causal link has not been established.
London Councils: Support GLA’s position. Welcome profile raising of HCC across food businesses in London.
SHA London: Consider this to be a strategic issue for the London Plan. Obesity emergency is deep in London. Higher than in other wealthier countries. Sutton Council prides itself but has childhood obesity of 32%. One of the proposals is to put more weight on the HCC. One problem is that not enough research is done into this. Three supplies for all the independent takeaways. Hard to get independent outlets to follow HCC – can’t rely on HCC.
Research from SE London, parents saw fast food outlets as a problem. Mayor has to understand how to incorporate grass roots voices.
Just Space: Welcome the attention to concept of deprivation that has been associated with childhood obesity; need for systematic approaches to food and health. Wonder if it is mainly a symptom of deprivation and whether targeting a symptom will solve it. Independents from a range of ethnic communities (Caribbean, Moroccan etc.) not much attention to relationship between these and their neighbourhoods.
Want a more nuanced approach to hot food takeaways, think it should be strategic at London level. But need to go back to the drawing board to see how it relates to deprivation and inequality.
Hot food outlets do provide jobs. If you do restrict them, you’ll take-away employment options for people. International centres are underpinned by hot food outlets (eg McDonalds, Westfield). With children spending their leisure time in these types of centres they are likely to consume these foods – there is a contradiction from the GLA here by supporting larger centres.
Guy’s and St Thomas’ Charity: Supportive of the policy. Deprivation gap in obesity is significant. Causative associations will always be limited. Important to look at lived experience in these cases, in our study issues around money and time availability influence families to choose less healthy options. Often on journey from school to home that visits are made.
London Forum: NPPF talks about restaurants without making the distinction. Most of the main representatives here operate with A3s, not A5. At what point of the decision making do you add the HCC? Can only make it when the planning decision is being made.
British Retail Consortium: Problem with the policy, it is not about being near schools but across most of London. London has a high density of everything.
KFC: New policy will impact smaller independents – this is why it should be an annex to the plan so that others can make comments. GLAs evidence, although good, does not link together to support the policy direction.
McDonalds: Our locational strategy is directed by high footfall and high population, not by schools. Many of our restaurants have mixed A3/A5 designations.
London Forum: Thinks that the policy is tractable.
Just Space: No overall vision for food in Good Growth, there should be. Also, what is intended to replace the hot food businesses?
KFC: A lack of causation evidence is not unavoidable, the GLA could conduct longitudinal studies.
Guy’s and St Thomas’ Charity: Don’t forget the urgency of this issue.
GLA: The government has supported our approach. More deprived areas have higher densities of hot food takeaways. KFC and McDonald’s – you’re looking for gold-plated evidence, this is unrealistic.
Notes by Sam Colchester, mainly.
Back to EiP main page: https://justspace.org.uk/hearings-eip-2019/#M88