Questions
3.4 Can the Central London area support the scale and intensity of development envisaged in the draft Plan; what are the implications for local communities and for meeting transport needs to and within Central London?
3.5 Is the definition of the Central Activities Zone and the policies within it appropriate?

The Vauxhall Society questions the desirability of encouraging further growth of London and the South East. This would be damaging to the rest of the country, especially the North. It will discourage the actions that ought to be taken to regenerate deprived areas where houses cannot be given away and jobs are non-existent. It will increase their deprivation and increase the pressure on the already overheated South East. This is irresponsible and wrong. The idea that London needs more growth 'to be a World City' shows a shocking lack of confidence in our capital. Moreover the Plan only allows for small recessions of the kind we have had recently, in the context of net growth. There is no Plan B for the absence of growth and there should be.

Planning to accommodate growth which does not happen or is much less than foreseen would enable developers to cherrypick within the opportunity and regeneration areas for the modest amount they would then be prepared to do, leaving the parts in real need unimproved. The policies need to address this.

It is hard to see how any improvements can be made in London without getting public transport improvements first. Even without growth, public transport is expensive, overcrowded and increasingly unreliable, unpleasant and dirty. We support efforts to get public transport improved and more accessible, including to the less able, whether there is growth or not. If there is to be growth, public transport must be improved and expanded first.

We support some increased density, but not through tall buildings. High densities can be achieved without excessively tall buildings. There are excellent high density developments of six or eight stories. Replacement of the 'shed and carpark' form of development adopted by many supermarkets, superstores and industrial estates with medium rise public transport friendly developments would do much to increase overall densities. Tall buildings have a fortress feel: vertical ghettoes unrelated to their street context and neighbourhood, create dark windswept canyons and threaten London's distinctive character and skyline.

Plans for opportunity and regeneration areas in North Lambeth and its environs must respect their existing character, their place in their local context and must be overwhelmingly locally generated. Local participation in the plans must be inclusive: it may be appropriate for some local organisations to lead, but, especially if their remit is not for the whole area under consideration. they must not be the only organisations to make the plan. 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.

We support mixed developments. 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. They should also require that facilities be sited within easy reach of all users (see transport). This would ensure, for example, that it would not be permissible to propose to site a swimming pool for the whole of North Lambeth in the extreme north of the area, where it is difficult get to for many of the intended users.

3D.23, Strategic cultural areas. Neighbouring areas should be consulted on plans within these areas as they will be affected by them, for example by illegal coach parking.

3D.27, Night time economy and 3D.28, Entertainment Management Zones This contradicts the good policy of having. mixed areas. New areas should not be designated merely in order to relieve pressure on the West End, exporting problems to residents elsewhere. Areas should be decided locally.

3D.33-.41 Visitors' London. We question the desirability of seeking to increase London's dependence on tourism. Overdependence on one industry is undesirable. Jobs in tourism are mostly seasonal and low paid, and highly vulnerable to economic downturns and exchange rate fluctuations. Excessive reliance on them is risky. In addition, tourism does little more for many London residents than create more litter and overload our buses and tubes. Additionally in North Lambeth the streets, including local streets near schools, are congested by coaches, ignoring parking controls while their passengers visit attractions the other side of the river or a few miles away. However, developing an international conference centre which can be reached conveniently by rail from the rest of Europe is worth pursuing.