M9 notes 16 January

London Plan EiP Week 1  16 January 219 M9

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M9 Good Growth

M9. (a) Are Good Growth policies GG1 to GG6 consistent with national policy and/or justified, and would they help ensure that the Plan provides an effective strategic framework to achieve sustainable development? [Bold: Questions posed by the Panel in advance.]

GLA:A few more amendments we intend to make.

–  Correct an omission of GG1 (FA), race should have been on the list.

–  GG5, to recognize importance of environmental issues shaping the economy – reconsider benefits of circular low carbon economy

–  GG1 – a new clause for engagement

Just Space: a number of these changes are very welcome. However, not having the precise wording in front of us makes it difficult to comment. Not clear whether amendments are to policy or text. Will you be able to tell us when the amendments will be published online?

London Forum: GG2 jumps immediately to a design led approach without assessing accessibility. Should start with priorities, then accessibility, and then the design led approach. No logic to current sequence. 

Footwork Architects: Such a re-ordering is needed. There is a lack of priority.

London Friends of Greenspace: GG2D is currently “protect and enhance open spaces” it should be protect, enhance and expand. Addressing deficiencies is important.

Just Space: See omissions in good growth principles:

–  GG1, issue around governance – relating to support and resourcing of community networks

–  GG2, we would like to see food growing and access to healthy food added to green infrastructure

–  GG3, healthy cities needs improvement

–  GG4, we would like to see reference to ensuring access at all income levels and specialist needs and should mention participation of London communities in housing (re Grenfell)

–  GG5, no reference to supporting local, diverse economies

–  GG6, issue around low-income households and fuel policy needs adding .


Peckham vision: We need to have a consistent policy in London in the way that the community sector is involved in planning.

Footwork:Omission in GG4 – London remains an inclusive place. Our general point is whether it translates into policies. One aspect of this is preventing displacement of existing communities (no mention of this).

London Tenants Federation: Housing that meets the needs of low-income communities should be included in GG1 and GG4 

Aitch Group: In the intro there is a reference to the housing crisis, but later on, the objective to ‘ensure that more homes are delivered’ is weak.

Just Space: It would be helpful if GG amendments are published so that we will be informed for future hearings.

GLA:They will be published as early as possible for future sessions.

London Forum: In previous plans the suggested changes were mentioned in the morning.

Aitch Group: If GGs are policies would expect them to be more specific in terms of linking to other parts of the plan.

London First: Defining policies as objectives is needed. Difficult as development management policies.

SD Commission: Rather than aspirations we want more specific language that integrates metrics and targets.

Assembly Planning Committee: effective policy would include a clear vision with a set of objectives. The GG policies have neither of these. GGs should be redefined as strategic objectives. Insufficient weight is given to social inclusivity and environmental improvement, which are the drivers to economic prosperity, not fetters of it.

Just Space: GGs are objectives. It’s not clear in chapter 1 what the vision is and what the objectives are. In foreword the mayor mentions: rebalancing development, a socially integrated and sustainable city where people have more of a say (we like these aims). But see that this is not followed through.

Neighbourhood Planners London: GGs seem to be objectives, perception across London that neighbourhood planning has not had an impact since 2012. We think they (NPs) are good at identifying small housing sites and infill sites. Think that the GLA has a bit of a blind spot when it comes to neighbourhood plans.

Just Space: ‘A city that works for all Londoners’ is mentioned by the Mayor but not defined. Would like to see this defined. There is an extremely important issue around migrants (they do not feel that they have equal rights). Would be good to have definition that includes all migrants in for ‘all Londoners’ definition.

The glossary now provides a different definition of Sustainable Development from NPPF 2012’s clear definition. The NPPF definition provides 5 guiding principles. Changes shouldn’t throw out good governance; planning within environmental limits; and using sound science responsibly. Would like to see the 5 principles restored.

Footwork:The social role is not sufficiently applied. Use the NPPF definition for being proactive about SD.

Just Space: We support the good growth approach – it’s an excellent change. What I said earlier was around the usability of the plan.

(b) Are the policies in chapters 2 to 12 of the Plan appropriately informed by and consistent with Good Growth policies GG1 to GG6?

[16:08] London First: GG1-6 cover a huge range of objectives but there is no prioritisation. Housing provision has no reference.

London Tenants Federation: Opportunity Areas are an unwelcome thread in the London Plan. Not brownfield sites often, often where people work. In contradiction with many of the good principles that we have been elaborating on. Exclusive housing developments for high end that do not meet the need of the people living there. Push out businesses that meet the needs of the people that live there, new jobs don’t meet local needs. Want the mayor to make a close examination of Opportunity Areas to see how they have impacted the people in the areas already living there.

Footwork: GG policies don’t satisfactorily translate through to the chapters.

Assembly Planning Committee: Making the link between GG and the chapters has bedevilled the plan. We are hoping that the GG policies will be reframed as strategic objectives. We feel that there are inconsistencies (H12) which pushes one-bedroom studios and lacks provision for family housing. G8 for tall buildings does not refer to the energy efficiency of constructing and maintaining tall buildings.

London Forum: If there were cross-references from the GG to the rest of the plan then that would be a checklist to see if you have policy coverage.

Peckham Vision: In the GG section local knowledge and experience in neighbourhoods is omitted. This has an impact all the way through.

Just Space: Lack of expression of strategic importance of food in GG policies. Earlier I proposed a GG7 just to focus on food. Mention of it is focused on problem of childhood obesity. Absence of in- depth appreciation of food security.

London Forum: Tendency among some of us to make this a managerial document rather than an aspirational document.

Just Space: Would like to see monitoring: is London a fair and inclusive city; equalities and development of civil society (depth and diversity of engagement); the levels of trust in authorities that people feel. What determines homes and housing in the London Plan?

Footwork:Aims are socially very ambitious but then don’t quite translate into the policy. If there is no policy to monitor and scrutinise them, then you devalue their significance.

London Forum: Has not been a cross check between key principles and monitoring.

Peckham Vision: Focus on development has been about clearing out and replacing. We have proved in Peckham that this does not need to be the case.

Just Space: Conflicts around monitoring surround the lack of clarity by what ‘Londoners’ means.

Notes made by Lyuboslav Petrov and Sam Colchester

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On to the next blog post: scope of the plan and consistency with national policy M7&8