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Welcome to the third issue of our online newsletter, London Forum Insights
We go to press in the immediate aftermath of two major announcements from the Ministry of Housing, Communities and Local Government (MHCLG). Firstly, the Secretary of State has now written to Mayor Khan authorising the publication of the latest version of the London Plan. And secondly, the Government has published for consultation a draft National Model Design Code (responding to the recommendations of the Building Better Building Beautiful Commission) and consequent changes to the National Planning Policy Framework. The consultation runs until 27thMarch – see here. We have posted some basic information about both topics to the London Forum website, and will shortly be communicating with members in greater depth.
One thing that is clear about the replacement London Plan is that small sites will play a more prominent role in the housing mix, not least because the Government has closed the door on incursions into the Greenbelt and on metropolitan scale developments in suburban centres. So the question becomes “who decides what is permitted” on any site, the Mayor, the Council, the community, the developer, or a Planning Inspector on appeal? Civic Societies should be pressing their Councils to put local communities centre stage. This issue of Insights carries a report from London Forum’s John Myers on one initiative aimed at achieving this.
Over the past two months, the Forum team has been busy responding to two major consultations: MHCLG’s Supporting Housing Delivery and Public Sector Infrastructure, and the Mayor’s Good Quality Homes for all Londoners. Insights has reports on both of these.
There is also a report from Clare Birks on December’s Zoom meeting – “Can Community Engagement Really Work?” Surely this will be an important theme throughout this year.
Thank you to Jane Maggs and Sam Dunkley for contributing a report on Civic Voice’s Green Belt webinar and a review of “London’s Mayor at 20” respectively. We also welcome new member, the South Woodford Society, adding Redbridge to the growing list of boroughs with at least one London Forum member society. Just two more to go!
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Supporting Housing Delivery and Public Service Infrastructure
Forum response to the recent MHCLG consultation
This consultation deals with three topics:
- A proposed new Permitted Development Right (PDR) to convert properties in Use Class E (Commercial, Business and Service) to Use Class C3 (Residential) in almost all circumstances and locations.
- Proposals for an accelerated planning pathway for public service infrastructure (schools, hospitals, prisons etc), both for extensions on existing sites and for major developments.
- Consolidation and simplification of all existing PDRs
The Forum objects strongly to the first proposal, on the grounds that it could lead to:
- The elimination of essential shops and facilities in towns and local centres; high streets could even be cleansed of all retail activity and local services
- A reduction in the vibrancy and attractiveness of shopping parades everywhere
- The wholesale loss of offices in town centres and elsewhere
- The creation of poor quality homes in the wrong places, and lacking social infrastructure
- Councils and communities being unable to plan high street recovery post-Covid, or to make good use of the Government’s Towns Fund and Future High Streets Fund
- Councils being unable to fulfil their place-making responsibilities, as specified in the National Planning Policy Framework
- Certainty for developers, but for no one else
- Loss of public confidence in Local Plans, and in planning in general.
We hope that the Government will re-think, and add real safeguards to this new right.
London Forum supports the Government’s ambitions with the second topic. However, this whole section treats the planning process as if it were an undesirable burden on the providers of public service infrastructure rather than a positive process that brings forward proposals for future infrastructure needs through a plan-led approach and as a means of engaging citizens in the way in which their community develops and its needs are met. London Forum rebuts this lack of recognition of the need to plan ahead.
The proposals to shorten the statutory consultation period from 21 to 14 days and the determination period from 13 to 10 weeks seem to be based on a pious hope that extensive consultation will already have taken place and that proposals can be more or less “nodded through”. If only!
The consolidation and simplification of existing PDRs (topic 3) is a necessary task. However, existing exemptions in some London locations for office to residential conversions and protections for Conservation Areas must be retained.
The consultation closed on 28th January. London Forum’s response can be seen here.
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Good Quality Homes for all Londoners
Consultation on Mayor’s housing design guidance closes
Last October, the Mayor and GLA published 5 weighty volumes of housing design guidance (see here), the consultation on which closed on 16th January. This guidance, once adopted, is intended to assist boroughs with implementing the housing policies (including “gentle densification” of the suburbs) set out in Sadiq Khan’s replacement London Plan, which should now come into force within weeks. After an introduction setting out the context, volumes 2-5 are labelled:
- Optimising Site Capacity - a Design-led Approach
- Small Housing Developments – Assessing Quality and Preparing Design Codes
- Housing Design – Quality and Standards
- Housing Design – Case Studies and Appendices
Boroughs’ Local Plans will be required to conform with the London Plan’s housing targets and policies, and should either adopt this design guidance or develop their own versions of it. Civic Societies will want to be involved in this process.
The London Forum broadly supports this approach, including the housing design guidance. Peter Eversden’s commentary on the proposals, and the Forum’s response to the consultation can be accessed via the Updates page on our website, see here. We aim to hold an Open Meeting on this topic as soon as the timetable for adoption becomes clear.
Two points to note: firstly, the Guidance introduces the notion of areas and sites for “Transformation, Enhancement or Conservation”, akin to “Growth, Renewal and Protection” in last year’s Planning White Paper – though it is unclear whether all land in a borough should be so classified. And secondly, the picture above, taken from the opening page of the consultation document, gives an indication of building characteristics that appear repeatedly in the design exemplars in the final volume of the guidance – brick cladding, full height portrait windows and deep reveals.
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Towards a more community-led planning system
London Forum’s John Myers reports
Since the Planning White Paper was published, London Forum has worked with others to push the process in the most constructive direction for local communities. The Government in recent months has moved away from its original plan to raise housing targets in the South East outside London. It has also instructed the Mayor to amend his London Plan in a way that may reduce the number of tall buildings in the future.
However, the Government still intends to impose higher housing targets on London, albeit perhaps not until the next London Plan. London Forum remains concerned that such targets might result in loss of precious local green space, or in highly inappropriate metropolitan-scale development imposed against the wishes of local communities.
To that end, we are seeking to influence the debate in a more community-led direction. One idea, recently highlighted as having potential by the Royal Town Planning Institute among others, is for residents of smaller areas, such as streets, to take the lead on selecting design codes or plans for their streets to determine what designs would be acceptable. The idea is for a simpler and less arduous process than neighbourhood planning, to allow a layer beneath neighbourhood plans that can help to fill in the detailed design codes that the Good Quality Homes guidance requires now and that the Planning White paper is likely to confirm.
That may provide a means for residents, where they consider it appropriate, to approve for example more housing suitable for older people, or improvement of backlands by replacing disused sheds with mews cottages in which family members could live - ‘gentle densification’. Residents could specify what designs of extension or other development will be acceptable.
The Prime Minister's current advisor on housing was previously at the think tank Policy Exchange, where there is now a new housing team. We engaged with them to encourage community-led approaches and were pleased that they seem open to such ideas. We hope to see a report in the near future which will advocate that town centres, high streets and suburbs should be strengthened as appropriate by community-led processes rather than by imposition from above, and that trials of such ideas as street-level design codes should be undertaken.
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What does ‘best practice community engagement’ look like?
Clare Birks reports
On 9 December, over 60 members heard from three master-practitioners: Mark Rintoul of Rogers Stirk Harbour + Partners, project lead on the Hammersmith Civic Campus project; Sarah Banham, Head of Community and Sustainability at Battersea Power Station Development Company; and Henry Peterson, Chair of a Neighbourhood Forum in North Kensington which from 2013 worked to develop a neighbourhood plan, now adopted. The key factors are:
- Shared vision and values where the clients, architects, and other leaders in the team are publicly committed to the need for community engagement;
- The broadest possible range of community inputs from the start;
- Continuity - the same community groups and individuals engage from the outset, from pre application all the way through, so that when the going gets tough and people disagree, there need be no loss of respect and engagement can continue.
The case studies highlighted the various ways in which community engagement can have an impact. Member societies will need to engage with their Council to help them recognise and adopt best practices. For a fuller report of this meeting click here.
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Do we need to talk about England's Green Belt?
Report on a Civic Voice Webinar by Jane Maggs, Southgate District Civic Voice
In December 2020, Planning Barrister Zack Simons wrote an article for the Financial Times: ‘We need to talk about England’s green belt’. This generated considerable debate and spurred Civic Voice into holding this webinar conversation. Alongside Zack Simons, the other speakers were Crispin Truman, the CEO of CPRE - The Countryside Charity and Catriona Riddell, an expert in strategic planning.
Zack felt that many people confused the Green Belt with green space. His article was intended to spark debate to determine what was worth protecting, as well as highlighting how the Green Belt acts as a girdle to many towns and cities. He argued that the Green Belt prevents the building of homes that are urgently needed and puts pressure on towns within their girdle.
Crispin Truman agreed that there is a need to have a debate, and that the CPRE is not against house building and would support appropriate community led schemes. The Green Belt had been highly successful, particularly in its aim to constrain urban sprawl and in a post COVID world, open green space is more important than ever. However, he accepted that not all Green Belt land is good quality or accessible but he felt that these negatives were outweighed by the valuable spaces worth both protecting and enhancing. Crispin also pointed out that some building does occur in the Green Belt, but over 80% of it consists of houses on large plots, which are unaffordable to the majority actually needing housing.
As a planner, Catriona argued that meeting the changing needs of society requires better planning, with a more strategic national policy. This would remove the need for local authorities to make decisions, which inevitably provoke both division and emotive arguments.
Summing up, Ian Harvey from Civic Voice echoed that there was a need to continue this debate; at the very least we need to look at how Green Belt policy will meet the challenges of the future.
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Mayor’s plans for meeting transport deficit emerge
Andrew Bosi reports
The Mayor published longer term budget proposals at the same time as the London fares increase was announced, the latter deferred from January to March to align with National Rail fares. The increase is thought to raise £60m. in the remaining ten months of 2021 and £74m. in a full year. However these estimates may prove to be wide of the mark, as the return to public transport may be sluggish even once face coverings and social distancing are no longer compulsory.
There is a limited but welcome bias in favour of shorter journeys in the way the increase is applied, although bus fares rise by 3.3% against the average of 2.6%. TfL say that this is the smallest amount possible because of a perceived need to round to the nearest 5p. However, with almost no cash fares it is difficult to understand why rounding could not be to the nearest penny. Tube fares stay rounded to 10p.
The extension to the Ultra Low Emission Zone is still planned for October 21st this year. Road pricing may follow once the election is out of the way and the House of Commons Transport Select Committee makes its report on the matter. There is also a proposal to move stations around Canary Wharf and Canada Water into zone 1. Shifting Shoreditch High Street to zone 1 was a disaster: several stations had to be moved into a boundary 2/3 zone with consequent loss of income. This proposal will need careful scrutiny.
The bus deficit is to be tackled by reducing frequency on the busiest routes in central London. This is preferable to shortening routes, as long as disruption caused by road works can be managed. The restoration of lost bus lanes, which might result from the recent court judgement against TfL, would go some way to achieving that.
There will be further charges for driving in London to ensure that fare increases do not send people scurrying to their cars. Cost is not the only factor: convenience took a knock when bus routes were shortened.
Testing commences on Northern line extension
Test trains are running between Kennington and Battersea via Nine Elms. The Northern line extension seems on course to open this Autumn, ahead of Crossrail’s central section which more than two years ago was within four months of a planned opening.
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Round the Societies - items from members' newsletters that caught our eye
Societies across London responded to the government’s Planning White Paper consultation highlighting how proposals threaten to ‘destroy local democracy’. The Highgate Society also submitted last-minute comments to a (poorly publicised) House of Commons Select Committee request for evidence on the White Paper and were one of 50 (out of 6,000), selected to give verbal evidence to a Zoom session chaired by MP Clive Betts. They noted that the majority of attendees seemed to be associated with the development industry, with few from the community sector, but the Society’s spokesperson took full advantage to articulate communities’ major concerns.
Low Traffic Neighbourhoods (LTNs), as an emergency response to the pandemic, have caused consternation in many areas, particularly where implemented at the same time as other traffic changes, (closure of Royal Parks, new London Cycleways with removal of bus lanes for example). LTNs force cars onto main roads and this has resulted in traffic jams, idling traffic and higher air pollution along those routes. There are equalities issues, not only for the physically disabled and the elderly but for those who live along these routes, who are often without a voice. The Ealing society report that a local group is now raising funds to mount a Judicial Review against six of Ealing’s LTNs and a JR Court Hearing is scheduled for 2 February.
There have been some positive impacts. The Dulwich Society report a sevenfold increase in children cycling through Dulwich Village; the Brixton Society report first results from the Railton LTN, showing vehicle traffic substantially lower and cycle traffic substantially more; Islington Society note considerable support and shops benefiting. Changes need time to bed down, but societies will need to monitor and ensure they voice concerns before changes become permanent.
Many members are dealing with major tall building developments being approved or brought forward which are at variance with Local Plans, such as the Charlton Riverside GLA Area of Opportunity, with developers ignoring the height and density provisions of the Charlton Riverside Masterplan SPD.
On a lighter note, The Barnet Society celebrates the Society’s 75th anniversary, the Blackheath Society announced the publication of Volume 3 of Blackheath Village and Environs by their President Neil Rhind and the Enfield Society report the Enfield (Council’s) Chase Restoration Project will create a new publicly accessible woodland with the planting of 100,000 trees.
For a fuller version of this article, click here.
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A warm welcome to the South Woodford Society
Located within a vibrant suburban area of Redbridge, South Woodford is a mixed area of housing, shops, and small businesses. It is connected to neighbouring areas, central London and further afield by the Central Line, the busy A406 and the M11/M25.
Set up in 2015 by a group of concerned residents who felt some ‘large’ planning issues needed a coordinated local approach, a key focus for the Society now is to work with our residents to create a Neighbourhood Plan for South Woodford. We are keen to see more affordable housing, protecting our green spaces from development and improving the variety of businesses on George Lane and our other shopping areas. We have a good relationship with our MPs, local councillors and Redbridge borough council, who provide active support for our aims.
We run regular litter picks, help co-ordinate and promote a monthly market in George lane and are setting out to re-green our environment, beginning with the creation of a community orchard to improve biodiversity and to help to lower pollution.
Other major achievements include:
- Formation of the Neighbourhood Forum for creation of South Woodford Neighbourhood Plan
- Acquiring funding for the creation of Community Orchard/Forest Garden in South Woodford
- Formation and co-ordination of the South Woodford Business Forum
- Adopted by our local Co-op for funding
- Accepted to benefit from Redbridge Local Lottery funding
We circulate a regular newsletter and use social media to communicate with our members. Reaching residents remains a key challenge and we are keen to sign-up new members. For a longer version of this article, click here
Co-Chairs: Louise Burgess & Pearl Arbenser-Simmonds
www.southwoodfordsociety.org
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London’s Mayor at 20 - Governing a Global City in the 21st Century
Edited by Jack Brown, Tony Travers and Richard Brown
Reviewed by Sam Dunkley
The book aims to reflect on the first 20 years of the mayoralty and to discuss what might come next for the capital, its people, and its governance. Contributors include inter alia Michelle Dix, Dave Hill, Stephen Glaister, Robert Gordon Clark, Kit Malthouse, Ben Rogers, Bridget Rosewell and Deyan Sudic, and the book includes full-length interviews with Ken Livingstone and Sadiq Khan (Boris Johnson declined).
London’s Mayor at 20 has attracted some heavyweight recommendations: Simon Jenkins calls it “essential reading”; David Lammy says, “vital and timely”. It will be a useful reference point for Forum members. However, readers should note that many contributors have been involved in the conception and operation of the Mayoralty and the Greater London Authority, and the publication is sponsored by well-known players in the property development ecosystem.
This book is a mine of information on the mixed scorecard of the GLA’s first 20 years, and the length and quality of contributions varies. Congestion Charging and the Overground, London2012 and Cycling are lauded as success stories. Less attention is devoted to the assault on London’s skyline and the failure to address London‘s housing crisis. All three Mayors seem to have been more interested in prestige projects than in putting in place the mechanisms that will allow London to evolve as circumstances change.
Is the current governance structure fit-for-purpose and will it survive? The concluding section points out that the Mayor has fewer powers than his (or her) counterparts in Paris, New York and most other big cities. Even these limited powers are being reined in by Whitehall, as evidenced by Robert Jenrick’s insistence on extensive changes to Sadiq Khan’s Intend to Publish version of the replacement London Plan, and the imposition of two Government appointees to the TfL Board.
The “unexpurgated version” of Sam’s review can be found here
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London Forum needs your help!
The London Forum has a good deal of expertise on its committees, but there are some gaps. One is the natural environment - green spaces; wildlife; nature conservation etc. Another is freight transport - lorries; delivery vans etc. If your society has people who could help to provide a London-wide perspective on either of these topics, please let Paul Thornton (london_forum@icloud.com) know and we will arrange a Zoom meeting to discuss ideas and possibilities.
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