Photo/image: David Howard LCF Publication No.68 guidance tools. LCF/Just Space Response to Planning for a Better London. London Civic Forum

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1 Photo/image: David Howard LCF Publication No.68 guidance tools LCF/Just Space Response to Planning for a Better London London Civic Forum

2 JUST SPACE RESPONSE TO PLANNING FOR A BETTER LONDON Environment and Climate Change issues Adaptation and mitigation We agree there is a need to both adapt our infrastructure and mitigate these environmental disasters from occurring in the first place. It is not too late to try and mitigate the worst environmental disasters. Carbon emission targets We are pleased that the Mayor has adopted the target of 60% reduction in carbon emissions by It is important that we achieve these targets through regular annual decreases in carbon emissions, rather than waiting until the last few years to do anything. A steady decrease in emission levels over the next 17 years will drastically reduce the amount of carbon the environment must deal with. Thus, it is important that the Mayor adopts yearly emission targets and revises targets according to new science. Walkable communities/ lifetime neighbourhoods One of the key ways in which planning can promote environmental awareness is by promoting walkable communities. Communities or towns should be built in such a way in which everything a person needs schools, hospitals, community centres, shops, etc - are in walking distance. This would greatly reduce the need for personal transportation (cars), but would also significantly decrease the amount people need to rely on public transportation. We encourage the Mayor to develop this concept. Outer London employment We support the policy aim of reducing the need to travel and the explicit linkage with promoting outer London areas as employment centres, rather than making everyone travel to central London for work. We would propose that this be taken forward by having employment agreements for each Outer London borough; at the present time it appears that some Outer London boroughs have zero jobs allocated. 20mph zone in all residential areas 20 mph home zones should be included in the London Plan. Many local authorities are under the impression that this will be a very costly thing to implement, when in fact, expensive equipment is not necessary. The Mayor can and should provide leadership on this issue. 1

3 Western extension of the congestion charge We ate concerned that this might be dropped. If this is the case, the Mayor must substitute for this some alternate ways of protecting the environment. Fund retrofit housing projects While new builds are built according to new environmental regulations, it is equally important that older buildings be adapted to meet these same standards. Green mapping The Mayor should require every borough to map its green spaces and to map energy loss. Waste recycling The Mayor should give support through the London Plan to the widest range of recycling measures. Local Agenda 21 The Mayor is asked to promote LA 21 within the London Plan, as an important mechanism for devolving decision making to the local level. Accessibility issues We welcome the Mayor s support of the Lifetime Homes research and look forward to the recommendations being implemented. We would make the following comments:- Do more to ensure that people have a clear understanding of what a lifetime home is, clarifying the difference between an accessible home and a lifetime home Although all new builds should be lifetime there will be challenges in adapting older buildings/housing stock The waste involved when access adaptations are taken out once a disabled person has left Sheltered housing and extra care homes need to be accessible for BME communities and this may require Mayoral intervention There needs to be a focus on Lifetime communities where there is no separation between young/elderly/families The accessibility of a property doesn t deal with the elderly feeling isolated in their homes and other measures are required. When looking at accessible housing it is important to consider the area around the housing, in fact the whole public realm, and the provision of facilities such as public toilets and benches. Alongside the development of Lifetime Homes policy, there is a need to update the guidance on accessibility and inclusivity. For instance, the guidance given for accessible housing doesn t extend to such issues as well lit entrances and the appropriate positioning of light switches. Travelling on the tube is limited for the disabled as there aren t always disabled facilities at every tube station. New retail developments are in need of guidance 2

4 as access to the new Westfield shopping centre is problematic for those with disabilities. Equalities & Planning for All Londoners There is a need to review the advice and support to Boroughs in relation to equalities and diversity. The delivery of strategic commitments on equalities needs adequate underpinning at local level. This is an area that needs more specific consultation as some of the issues that need to be addressed are not universally well understood yet.. Faith communities Planning is currently struggling to address faith communities issues. There is considerable evidence that the needs of newer communities are being side stepped in a systemic way in relation to the use of premises. Post war changes introduced more diversity and a need for premises and sites for faith communities. There is ongoing conflict with planning authorities over interpretation of policy allowing re-use of vacant industrial buildings. Appeals and judicial review have found against faith groups despite precedence. For example, even where requirements for an empty space being advertised without uptake for more than three years and the alternative user providing employment opportunities. There needs to an examination of whether the guidance is not clear enough or not strong enough. This issue has been described as a blocked drain in need of plunging. This is not simply about places of worship, but about faith communities that provide additional forms of community support, often to people in great need. There has been research on this subject but no satisfactory resolution of how the Boroughs and the greater London Authority can make the system work in relation to this issue. Housing The impact of the credit crunch We would like to ask what consideration will the London Plan give to the changed financial circumstances. Less affordable housing will be available through s 106, so to compensate there should be more emphasis on publicly funded housing. Otherwise the promise of new affordable homes over the next 3 years will not be delivered. Furthermore, there will be an increased need for rented housing for those who are re-possessed. Given these changed circumstances, more affordable housing in total and a role for local authority housing to help meet these needs should be recognised. 3

5 The affordable housing definition We are seeking a review of what is meant by affordability, when even social housing rents are rising above people s ability to pay. Intermediate housing We can see no need to increase intermediate housing. There is no great desire for tenants to get on the home ownership ladder as tenants are in general committed to the ethos of council housing. Targets The overwhelming view of participants is that Mayoral targets are needed to deliver affordable homes. The previous Mayor could not achieve the affordable housing targets. So whatever targets are set they must be deliverable. If targets are localised there still needs to be central scrutiny otherwise we fear that boroughs will aim for the lowest possible number of affordable homes. The Mayor must have the teeth to enforce targets Choice based lettings offer more flexibility for tenants to move within boroughs and between boroughs. However, if individual boroughs set their own targets then you will have cases where some boroughs have more than 50% affordable housing and some have 0% affordable housing thus undermining the flexibility of choice based lettings. The process for deciding the borough agreements on affordable housing should be open and transparent. For instance, the Mayor s proposed figures for each borough should be made public on the Mayor s website. Consensus approach There is certainly a need for more co-operation between different landlords on housing estates and tenants are keen to be included in the consensus approach. Indeed, there is a strong feeling that if the agreement is only with developers and local authorities then this is not a consensus at all. A consensus approach between the Mayor and the 33 authorities on affordable housing delivery would not be helpful as clear targets with enforcement are required.. Space standards The London Plan should support Parker Morris plus space standards for new housing. There is plenty of evidence that new builds are of poor space standards and a commitment to high space standards should be written into the LDA Design Standards. New design led approach Economists and builders have been driving what is affordable. Land use investment has to be something that is worthwhile and sustainable from generation to generation and we propose a new approach to planning in London which would include setting standards for open spaces/privacy/parker Morris space standards a design led concept and not a financial led concept 4

6 Sustainable communities The Mayor needs to support the building of social communities. A definition of sustainable communities within the London Plan that is reached through consensus approach is an important first step. This is prompted by the following concerns:- There are too many instances of social infrastructure being sold off to make way for development Increasing density without social infrastructure is contrary to the notion of sustainable communities, The tension between the reputation of London as a young city but with increasing numbers of elderly. Right to Buy has impacted on communities because of flats being sold on the private market with new residents not interested in long term community Land Use policy should include provisions that take account of an increase in the demand for locally grown food and for land to made available for this purpose. Tall buildings We welcome the revision of the London View Management Framework. We would like this to connect with the new policy on tall buildings. For instance, it was problems with tall buildings in Greenwich which led to questions about the status of the World Heritage Sites. We also support the weight being given to local context and character when deciding the right places for tall buildings, but we feel this policy shift needs more clarity. For example, the wording could be that greater weight will be given to local context and character than to design quality. Implementation of policies The problem of London Plan policies not being implemented by local authorities is a systemic one. The implementation of policies needs to be more thoroughly monitored and we welcome the GLA providing more assistance to the boroughs. The voluntary and community sector can play a big role when it comes to the independent monitoring of the borough s planning performance. It would be helpful if the London Plan encouraged this as part of the Annual Monitoring Review. The voluntary and community sector can also promote examples of best practice, for instance in environmental awareness. London Planning Convention There was a general welcome for the Mayor s proposed annual London Planning Convention. This should be an open event, where the community sector can present its concerns to the Mayor and officers. To enable this, we propose that the Convention have community groups as be key partners in organising the Convention. 5

7 Just Space is a network of community and voluntary groups in London that has been working together for about two years. Is receives some financial support from the London Plan team at the Greater London Authority. Just Space hosted a consultation event on Planning for a Better London, on 3 rd November 2008 and many of the issues raised in this paper were discussed at that event. Inquiries in relation to the above should be sent to: Marian Larragy Policy Participation Co-ordinator London Civic Forum 18a Victoria Park Square E2 9PB marian@londoncivicforum.org.uk