The Vauxhall Society supports most of the aims of the policies in this section, but questions whether many of them will be achieved by the policies set out in the Plan. The Society proposes alterations to the Plan which would lead towards achievement of these aims.

As we stated in our initial response and objections to the draft plan, we consider that trying to encourage further growth of London, is irresponsible, unnecessary and damaging both to London and the South East and to deprived areas elsewhere, and cannot succeed in the face of a deepening world recession: a possibility which is not allowed for in the Plan. Growth without first making massive improvements in public transport and without corresponding growth in facilities and services would greatly damage all aspects of the quality of life of London's people. So would planning for growth which did not happen.

Policy 3.16 Protection of social infrastructure and community facilities.

We object to the policy as it stands since it is inadequate to achieve its aim. We propose that it should be redrafted as follows, including the additions shown in bold

'Boroughs, in reviewing UDPs, should include policies to resist the net loss, and enhance the net local provision, of social infrastructure, including libraries, community halls, public sports facilities and cemeteries, and of local shops. The policies should ensure that everyone including the disabled and less able has these facilities within easy reach, with most of them, except cemeteries, reachable on foot or via one or two bus or tube stops.'

Inaccessible social infrastructure is useless. Provisions for access need to be adequate not just for the fit and the registered disabled but also for the infirm, the less able and the burdened. Only by strong grass roots opposition did local residents stop some of the recently proposed closures of public libraries in Lambeth. The Council wanted to concentrate provision in a few so-called 'centres of excellence' (all in high crime locations) making them inaccessible to many including schoolchildren for their homework. It is proposed to site a swimming pool intended to provide for the whole of North Lambeth in the extreme north tip of the area, where it is difficult to get to for very many of the intended users. The policy as originally drafted would not stop either of these proposals.

Policies 3A 17-20 Provision of healthcare

Primary healthcare on a Borough basis causes confusion at boundaries. Some North Lambeth residents have been sent leaflets by Wandsworth telling them to go to Tooting or Kingston for A&E.

We propose: In Policy 3A.17 (First sentence In reviewing UDPs and planning applications boroughs should promote the objectives of the NS Plan, Local Health Improvement and Modernisation Programmes, the organisation of health care and the availability of local affordable housing for healthcare workers in the borough .

GPs should be within walking distance of most patients. In Policy 3A 18 'reachable by users on foot or via one or two bus or tube stops' should be substituted for 'accessible by public transport'. in order to make it clear what constitutes accessibility by public transport for all, including the less fit and able.

High levels of atmospheric pollution (for example at Vauxhall Cross) should be reduced. Much of this imposes local disadvantage for the benefit of those passing through. In Policy 3A20 Insert 'and of existing and planned private and freight motor transport, ' between 'development proposals' and 'as a mechanism'

Provision must be based on the best information about future demand. Perception that local schools are poor encourages parents to send children further away, adding to traffic. Walking and public transport journeys to school must be safe and perceived to be safe. Few inner London schools have adequate sports facilities. Both are bad for the health of our children.
In the policy:
Substitute 'the best official' for 'GLA' in line 3 Add after 'inter-borough provision' ' where reachable by safe routes by almost all of the schoolchildren on foot or via one or two bus or tube stops'. Substitute ' where reachable by safe routes by almost all the schoolchildren on foot or via one or two bus or tube stops' for 'accessibility by public transport' add to the list of criteria to be taken into account 'the need for each school to have outdoor sports facilities on their premises or within walking distance'

Policy 3A21 Higher education facilities These need to be accessible by public transport or local to reduce the need to travel.

Policy 3A23 Diverse communities
Standards and guidance on opportunity and regeneration areas should state that the development should be a fine grained mix both of public and private residential and of employment and residential and amenities, including open space, encouraging living streets, and that they should connect well with surrounding areas. Single use areas, which are therefore dead and uninviting at night (if business/industrial) or in the day (dormitory areas) have an inherent invitation to crime. Standards should also state that there must be no ghettoes, whether private gated housing or public housing with no ways through them. The Plan speaks of reversing social polarisation, but London is rapidly becoming a place only enjoyable by the young, the fit and the wealthy. Token preferences are given to the 'disabled', but many less able people and people in the middle and lower income groups. and all of us when we are carrying heavy loads, taking a push chair or young children, or just feeling ill, find that the centralization of health and social services and other amenities detract from their quality of life and make their daily round more difficult

Public transport must be improved, with escalators and lifts providing access without stairs from street to tube platforms, and with more conveniently sited bus stops, beside where people want to get on and get off, not further and further from street junctions for the convenience of cars and lorries. Connections and access should be planned not to suit a fit, youngish transport planner carrying only a small briefcase, but for everyone who sometimes takes a small child or a heavy load, and for everyone at the less fit stages of their lives as well as when they are a young, fit adult. Don't let's make people effectively disabled by bad, inconsiderate design. Not only are there very few underground or rail stations which can be accessed without using stairs, it is not very easy to find out in advance what and how many stairs there are.

In the short term, it should be required that any significant public transport improvement schemes incorporate 'access for all': proper disabled and less abled access, ie access which does not necessitate use of stairs or an attended/keyed lift.

Local authorities divide up communities by artificial boundaries which respect their existing character, their place in their local context and must be overwhelmingly locally generated, with the help of experienced professional planners. Local participation in the plans must be inclusive: it may be appropriate for some local organisations to lead, but not to plan exclusively, especially if their remit is not for the whole area under consideration. In addition, participation must not be strictly confined within the boundaries of these special areas. Their effects will be, and should be, felt beyond their boundaries, and people outside should be consulted. It is important not to repeat the mistakes made in not involving next door Lambeth residents or their Council about the failed Elephant and Castle plan or about Battersea Power Station plans, and in not involving residents across the road from the failed Project Vauxhall. Boundaries are fuzzy. Plans, consultations, involvement and designations of areas must recognise this.

In addition, in North Lambeth the boundary of 'London South Central' cuts through the area (as does the proposed congestion charging boundary), dividing communities to its east and west. We do not want to be divided. It also perpetuates the undesirable trend for overdevelopment towards the river which looks towards the north of the river and turns its back on the rest of our area. This boundary is in the wrong place. It also ends too close to the south and east of Vauxhall transport hub. A hub is a centre, not an edge. Boundaries should reflect the siting of hubs and include the areas for which they are foci.

The proposed areas in North Lambeth are deprived and degraded, but not uniformly. There are pockets of highly desirable excellence and of very expensive housing side by side with run down council estates. The riverside is a potentially very important resource for people who live and work in North Lambeth. There is much about the character of the area that needs to be preserved and improved, or to have mistaken redevelopment put right: for example Lambeth Walk and Spring Gardens. The historic street pattern should be preserved. The Plan should set some ground rules for the kinds of development and/or regeneration that are suitable for particular areas. In a few parts of London comprehensive rebuilding may be right: probably only in deserted wastelands. Here it has to start with and prioritise building on local and nearby communities and the nature and history of the area, rather then starting by planning the physical buildings. It must be done in an analogous way to thoroughly reconstructing the fabric of your house while the whole family continues to live and carry out normal family and social life there. The ground rules should be set with this in mind. Whatever the long term vision, we cannot afford to make extensive wastelands while we regenerate. The social cost is too great, and leads to the enormous financial costs of social disruption and crime.

SECTION 3B Working in London: Part 5
Policy 3B 13 Childcare, keeping local adventure playgrounds open, homework clubs and other such support are important.

Policies 3D 4-6 The need for formal sports areas is separate from the need for parks and informal leisure sport, such as non-bookable areas for kicking a ball around, general access tennis courts and children's play facilities. Formal sports do not mix well with parks and can take them over to the detriment of other users. The Plan should include a policy on provision of these facilities, and for protection of and an increase in school playing grounds beside or, if that is impossible, within walking distance of the school. These playing grounds could also be used out of school hours for non-school formal sports: this mix would work.

Policies 3D 8-11 Open Spaces The Plan proposes protection of existing open spaces. We support this. However, it proposes no increase in them. If the projected growth happens, there needs to be more open space for this reason alone. The Plan should at the very least have 'no increase in open space per head of population', ie an increase if population grows, and should allow for some additional increase in the areas which need it most.

Thames The Blue Ribbon policy should be given greater priority and so should access to the riverside. Designation of 'opportunity areas' should not allow views of the river to be taken over by private developers and blocked off from the rest of North Lambeth, and the Plan should also require improved public access to the river

Care for the environment is not just a matter of protecting open spaces. Local authorities must be enabled to resist unsuitable developments and supported when they do. Many bad developments are permitted because planning committees are reluctant to risk the financial burden of an appeal against planning consent. There are too many buildings designed as 'Landmark' structures, to glorify the architect rather than to provide convenient accommodation or amenities, and often without sufficient respect for, or consideration of their effects on, their immediate surroundings and the places they can be seen from. An example in Vauxhall is St George's proposed tower just south of the dense development they are building by Vauxhall Bridge. Only recently, the Government's Urban Affairs Sub-Committee* has expressed the opinion that tall buildings are merely symbols of prestige and power which may blight their immediate surroundings, and that London's transport system cannot cope with the resultant concentration of passengers.

High densities can be reached without excessively tall buildings. There are excellent high density developments of six or eight stories, and reconsideration and replacement of the 'shed and car-park' form of development adopted by many supermarkets and industrial estates could do much to increase overall densities. Tall buildings have a fortress feel: vertical ghettoes with little connection with the neighbourhood and streetscape they are in. The present system of project funding through regeneration partnerships encourages selling off of community assets and rebuilding them rather than repairing, as there is no funding for maintenance.