4.1 How realistic are the draft Plan's population and household growth assumptions in the light of the emerging post 2001 Census projections?
4.2 How realistic are the housing provision figures for the sub regions, London Boroughs and Corporation of London in the light of the latest housing capacity assessments carried out by those authorities?
4.3 Are the draft Plan's policies for achieving additional housing provisions, including proposals for higher densities realistic and sustainable? Are these policies compatible with the needs of local communities and with the aim of creating a high quality built environment? Section 1A.12 -21, Section 3A, Policies 3A.1-5 and paragraphs 3A.6-30, Section 4B, Policy 4B.3 and paragraphs 4B.15-17, Table 4B.1
The main premise of the whole plan is that the population of London will increase by around 700 000 by 2016, and that economic growth will create a total of 636 000 new jobs. The population forecasts need to be revised downwards in the light of the new census figures, and in any case, the normal volatility of population projections should be allowed for. Much can depend on net migration - the small difference between two large figures. The forecast for job creation appears to be based mainly on the highly volatile financial services sector, which has suffered severe setbacks over the last two years, and anyone who has watched the recent gyrations of the Stock Exchange knows only too well that past results are no guarantee of future performance. Even without the deepening world recession that cannot be ruled out, the effects of mergers, globalization and new technology seem much more likely to reduce the number of jobs in this sector. Planning only to accommodate small recessions of the kind we have had in recent years, in a context of net growth over the whole period seems increasingly inadequate.
Encouraging further growth of London and the South East is damaging to the rest of the country, especially the North. It will discourage the actions that should be being 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.
There is no 'Plan B' for the absence of growth. The Plan seeks to accommodate growth and sees it as both desirable and inevitable. It cannot force it. Planning to accommodate growth which does not happen or is much less than foreseen would enable developers to cherry pick within the 'opportunity' and 'regeneration' areas for the modest amount they would then be prepared to do, leaving the parts in real need unimproved.
Too much growth has been allocated to Lambeth, possibly based on unrealistic assumptions about the need for and desirability of wholescale redevelopment, which is not wanted locally. Plans for housing, as 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, with the participation of all affected by them. A fine grained mix of uses and ownerships is needed, with no ghettoes, whether public or private and whether gated enclosures on the ground or vertical ghettoes in tower blocks.
Higher densities in central areas are desirable and can be high quality and compatible with local needs if achieved by medium rise, which should include rebuilding existing shed and carpark type of developments, flats over shops and building over some tube, rail and bus stations as long as that does not compromise their scope for future public transport and freight developments. Reducing the need to travel should be an important criterion. The amount of open space per head should be no less, preferably more than at present, and growth in local facilities including leisure, must keep pace with growth in population. There should be no new tower blocks, particularly by the river. There are enough, either newly built or acceptable with refurbishment.
Density standards should reflect the nature of the area and not be borough-wide. For example, the density standards appropriate for South Norwood (largely suburban) are unsuitable for North Lambeth, a central area.