MINUTES OF THE MEETING HELD ON TUESDAY 12TH JUNE 2007 AT 2.30 TO 5.30PM. AT UCL COUNCIL ROOM, SOUTH WING, GOWER STREET, LONDON WC1E 6BT
Attendance: Brian Waters – Chairman
Alastair Gaskin: Reagh Consulting and Hon. Treasurer
Cllr John Bevan: LB Haringey
Bob Dolata: LB Hackney
Brian Mark: Director, Fulcrum Consulting
David Eversley: London Forum
Gary Young: Higgs Young
Helen Bangs: Conservation Officer, LB Barnet
Jessica Ferm: UCL/LB Enfield
Michael Edwards: UCL (Host)
Martin Simmons: for London Councils (formerly ALG)
Michael Bach: London Forum
Nicola Whittle: Environment Agency
Robin Brown: Hayes Community Development Forum
Stephen Greek: Researcher, Planning and Housing London
Assembly Conservative Group
Tarsem Flora: Architect, Landscape Architect (LASE)
Tessa Parnell: Fulcrum Consulting
Tim Wacher: RICS (Personal capacity)
Tom Ball: London Forum
Zoë Cooper: Environment Agency
1. Introductions and Apologies.
The Chairman welcomed those present and explained that the Forum would be taking the form of a Mock Examination in Public, with Michael Bach as Panel Chairman, into THE LONDON PLAN DRAFT FURTHER ALTERATIONS. The actual proceedings follow starting on 18th June. Although invited no-one from GLA or CLG had been able to attend, attributable to their concentrating on EIP preparations. Other apologies were received from Judith Ryser (Isocarp), Leonora Rozee (Planning Inspectorate) and Roger Chapman (CLG).
Michael Bach asked as Panel Chairman that participants provided bullet points rather than long speeches, and stressed the importance of valid arguments relating to the question posed. It was agreed that there should also be some discussion following any participant statements.
It was recognised that this would concentrate focus on very precise aspects of the draft alterations, rather than tackling any of the fundamentals of the Plan itself, for which the process should be criticised. (GLA had claimed in a former Forum meeting that there was no difference between altering and reviewing the plan, which is clearly not the case. It makes the Plan an administrative convenience for the Mayor rather than a dispassionate and practical assessment of London’s realistic future).
Matters for Discussion:
- ['Additional matter' excluded from the Formal EIP]: Is it reasonable to accept the GLA’s Growth rates on which the plan is predicated?
Michael Edwards, who is also representing the London Civic Forum with Marian Larragy at the EIP provided the following statement paper, from which his participant presentation is derived. As participant he also added
- The alterations should be subject to a sustainable environmental assessment to balance social, economic and environmental factors
- There are very substantial effects on housing prices and the benefits system from global investment flows resulting in powerful exclusions for both homes and employment.
- Central area employment is sucking in people from long distances resulting in inefficient use of infrastructure. (The proposed £10bn for Crossrail is for a very pared down alleviation of Central Line congestion, rather than the more genuine added value of the Superlink model).
- There should be a new policy 1.1 which includes SEA of alternative trajectories, starting now for the next plan revision.
'LONDON'S ECONOMY AND SUSTAINABLE DEVELOPMENT
London's growth is a poverty machine as well as a wealth machine, with much of the impoverishment being generated through the intensifying pressure of prices, rents and insecurity on low- and middle-income households. We consider that the Panel should welcome a debate on whether this is in fact in the best interests of London and of the UK.
Indeed we consider that, without consideration of fundamental alternatives, there is a serious contradiction between the growth strategy and the new importance attached to sustainability, energy and global warming. Further, under the European Union directive on Strategic Environmental Assessment, we are now bound to elaborate and evaluate alternatives to major policy directions and the EiP must take this on board.
We are effectively told that “There Is No Alternative”. London has to welcome all the GDP and population growth in prospect, has to fit it within the green belt, has to concentrate much of the incremental employment in the centre and tailor its transport networks to support this structure. None of these propositions is self-evident, indeed all are highly controversial and all have downsides and identifiable losers.
Attempts to challenge these propositions, or seek to explore either strategic alternatives or marginal alterations should not be met with negative responses.
The Further Alterations acknowledge, for example, that the 2004 projections overestimated the need for office space in the future in London. However, there were still concerns that the trend of planning on the type of jobs and where they would be based is predicted by simply projecting current trends. With the rising use of ICT, those trends may not continue in the future and with increases in flexible and home working, even the current estimates for office space could prove to be overly high. This also has important implications for reducing travel into London, congestion and pollution.
The arguments for welcoming growth tend to be based on the assertion that any increment of growth foregone by London would be lost to the UK. This is an unsubstantiated assertion, mainly associated with fears of losing leading financial and business services companies. In our view the GLA/LDA and the government should be scrutinising these assumptions very closely and weighing in the balance any plausible national losses of output against gains which would arise from a more even pattern of development across the UK (and across the EU).
The London Plan is based entirely on projections of the future from extrapolation of past trends -for population growth, employment growth and so on. We need to set up a modelling approach to forecasting alongside or instead of the projections. Paragraph 1.40 refers to a working age population increase of 690,000 to 950,000 by
2026. This range should be assessed further and the likelihood better defined. A real opening for reconsidering the fundamentals is the new importance attached to sustainability, energy and global warming .Further, in the European Union directive, the Strategic Environmental Assessment, we are now bound to elaborate and evaluate alternatives to major policy directions and the EiP must take this on board. The Further Alterations cite the Mayor's vision as "to develop London as an exemplary, sustainable world city, based on the three balanced and interwoven themes of strong, long-term and diverse economic growth, social inclusivity and fundamental improvements in the environment and use of resources". (paragraph xxiii of the Mayor's vision)
The emphasis on economic growth, as opposed to economic progress, is fundamentally at odds with the Government's Sustainable Development Strategy (SDS). The Government's Planning Policy Statement 1 (PPS1) states that "Sustainable Development is the core principle underpinning planning". The London Plan is the key strategy to embed sustainable development into the way London functions and is developed . PPS1 2005 states "In preparing development plans, planning authorities should seek to:...(v) Provide improved access for all to jobs, health, education, shops, leisure and community facilities, open space, sport and recreation by ensuring that new development is located where everyone can access services or facilities on foot, bicycle or
public transport rather than having to rely on access by car" (paragraph 27) .
PPSl 2005 goes on to say "Reduce the need to travel and encourage accessible public transport provision to secure more sustainable patterns of transport development. Planning should actively manage patterns of urban growth to make the fullest use of public transport and focus development in existing centres and near to major public transport interchanges." (paragraph vii) The revised London Plan must show how it will actually reduce the need to travel, not just by car. Walking and cycling are the most sustainable forms of travel. The plan further suggests that "growth must be accommodated in ways that respect and enhance the environment by being exemplary in mitigating and adapting to climate change, and in being energy and waste efficient" but we do not see adequate clarity on how this might be done. We also suggest that the very phrase "growth must be accommodated" is unhelpful and inappropriate.
We do not believe that the current levels of 'economic growth' are in any way sustainable within the longer-term and we would suggest that evidence in this plan and elsewhere is that London's economic growth is not helping tackle the fundamental inequalities that do so much damage to the lives of the poorest people and communities in London.
We note the statement from the LDA that "The employment rates of most disadvantaged groups do not appear to have improved relative to London's overall employment rate over the economic cycle to date" and "The employment rate in disadvantaged areas does not appear to have improved relative to the employment rate for London as a whole". We also note the reference in the Sustainability Appraisal of the need to "Do more to direct the flow of benefits arising from economic development to disadvantaged communities and monitor the
benefits and outcomes".
The core issue to which the panel should pay attention is the way in which the growth rate and pattern produce poverty while simultaneously producing wealth. The Further Alterations to the London Plan should pursue a more diverse and more evenly spread economy for London. However, the London Plan is not just about
Londoners. London's influence goes way beyond the south-east and a more even regional economic policy is essential if we are all to achieve environmentally sustainable development.
Questions?
We know there is a concentration of riches and power in London, but can we show the rate of change and how the rate of poverty is increasing? European statistics on regional GDP show London at about 300, when compared to an EU average of 100. Paris for example is about 180.
Can we write a section which shows the environmental damage caused by current levels of economic growth?
The most damaging mechanism through which London's current growth pattern increases poverty is considered to be the interplay of growth with housing conditions. Briefly stated, we are experiencing substantial
real growth of house prices in London, fuelled by .net in-migration .changing household structure .multiple home-ownership
.rising real incomes among perhaps half the population
.easy credit
.distrust of pension provision, and crucially
.the widespread belief that 'investment' in house purchase is a good investment however high the prices, since they will continue to rise.
In this context middle- and low-earning households are excluded from the owner-occupier market and driven to live in expensive private renting or (if they are lucky enough to have a foothold there) in the dwindling council housing sector. Millions of Londoners work in
.fundamentally low-paid jobs (retail, catering, cleaning etc) and are condemned to bad and worsening conditions in this way.
Many other Londoners are living on benefits or are eligible for benefits to supplement their low earned or pension incomes. Some consider it undignified to claim and thus live in acute deprivation; many of those on housing benefit are effectively trapped because the wages they could earn would leave them poorer than they are on benefit; those on state pensions have seen the purchasing power of their incomes fall relative to London housing costs and are thus also being impoverished.
The many symptoms of this worsening housing stress are the daily experience of many of the equalities groups and NGOs which have led to this submission to the panel: recorded and invisible homelessness, overcrowding, insanitary living conditions; the near-impossibility and high cost to housing authorities when they seek to meet the needs of people with disabilities or health problems, mounting debt problems and child poverty (get shelter to help expend...)
In discussion Peter Eversden said that the density strategy is further undermining the plan’s sustainability since 2/3 of schemes are at higher densities than they should be, involving for example children being obliged to sleep in kitchens, buildings being half the distance apart they should be and having no play space. This is compounded by investment acquisitions taking place because of the housing shortage and then renting the space at inflated prices. All this suggests the growth rates should be challenged as unsustainable. There is the further concern that employers cannot pay the wages necessary to meet housing costs and so are leaving the Capital.
Tim Wacher recalled the decentralisation policies of the 1970’s and asked whether it was sensible to seek to reverse this, querying whether in fact the Mayor has much realistic control over growth rates.
Brian Waters said that true growth patterns in London are masked by the government in denial. It was predicted that by 2000 growth would be zero. In fact there was a 46,000 net increase and this has increased to 145,000 a year. Transport for London’s forecasts seem to have proved more accurate than their parent. This reinforces the need to explore different trajectories.
Drummond Robson added that the GLA persuaded the former EIP Panel to accept original draft London Plan projections with little or no challenge, but in spite of being clearly wrong in just three years after adoption there is again no scope to query the growth assumptions.
Martin Simmons said that both population and employment were predicated on trends and an increasing age structure. The pivotal role of migration flows has been seen within a parochial and not even national – still less global context, which is inconsistent with London’s Supra regional and World City roles.
- Climate Change:
- Do the Further Alterations offer a robust way forward for London to mitigate climate change?
- Are the Further Alterations robust with regard to the technologies promoted to counter climate change, including CCHP and the use of hydrogen as a fuel?
- Are the Further Alterations on flood protection consistent with national policy?
- Are the Further Alterations effective on matters of water supply, sewerage infrastructure and air quality?
Nicola Whittle and Zoë Cooper for The Environment Agency focused on c. and d. and stressed the key importance of flood protection, proposing that there needs to be a substantial change in London’s flood risk policy to bring it in line with national policy. The policy focuses on Flood Defence rather than, as the recent PPS25 advocates, Flood Prevention. Regional flood risk assessment by GLA does not demonstrate a robust enough test sequence.
Michael Bach pursued this asking whether GLA had taken any steps to restore flood plains. EA responded by referring to “Thames Estuary 2100” Climate Change Flood Risk and that EA was looking to the GLA for constructive plans for flood storage.
We have been working with the GLA to ensure that a Regional Flood Risk Appraisal (RFRA)[1] is delivered in line with the requirements of Planning Policy Statement 25[2] (PPS25). We acknowledge that the timing of the Further Alterations in relation to the publication of PPS25 is not ideal. However, as a RFRA was not completed in time to inform the Plan, it is crucial that the flood risk policies in the Plan are changed in line with the amendments suggested in our December 2006 response to the Further Alterations. These amendments are necessary to ensure that the flood risk policies are consistent with the requirements of PPS25, to ensure that a risk-based precautionary and sequential approach is taken, and to ensure they reflect the change in emphasis from flood defence to flood risk management.
Since writing our response to the Further Alterations, the Thames Estuary 2100 (TE2100) project has identified some areas covered by the London Plan that may need to be considered for storing floodwater in light of increased flood risk from climate change. The use of flood storage areas could reduce flood levels by 0.8m which, under current Defra climate change guidance[3], could ‘buy’ 50 to 60 additional years capacity for the tidal defences beyond 2030. The spatial planning process can assist with land safeguarding for these potential flood storage areas.
PPS25 lists safeguarding land from development that is required for current and future flood risk management as a key planning objective. It is essential that boroughs produce Strategic Flood Risk Assessments (SFRA) in line with PPS25. Land allocations informed by these SFRAs should identify land that may be needed for flood storage and other strategic flood risk management measures by taking into account the findings of the TE2100 project and the Thames Region Catchment Flood Management Plan (CFMP)[4]. It is important that this is reflected in the sub-regional sections of Chapter 5 of the Further Alterations as requested in our December 2006 response.