Question 6.5 Is the draft Plan's approach to town centres and retail development consistent with national policy guidance and appropriate to the needs of London
Section 3D Policies 3D.1 to 3D.4 and Annex 5

The Vauxhall Society supports the aim of identifying and strengthening the roles of town and neighbourhood centres, but considers that the policies do not give enough recognition or support to the importance of local and neighbourhood centres, including their contribution to reducing the need to travel and to preserving access for all including the less abled to goods, services and leisure. We also consider that 'town centre' is a misleading overall description for including the many small neighbourhood centres in London. We propose that 'town centres' in headings and text is replaced by 'town and neighbourhood centres'

Policy 3D.1 amend first point to read
'* encouraging retail use in town and neighbourhood centres and, through UDPs and planning decisions, discouraging it on out of centre sites not readily reached on foot or by public transport and with large overground carparks.'
Add to the second point; 'and in local and neighbourhood centres and some district centres, ensuring provision of some short term (20-40 minutes) parking near small shops and customer services businesses.'
add another point: '- require retail developments to have compact high density designs which form part of town and neighbourhood centres in location and appearance, and have active street frontages. Encourage the replacement of existing 'shed and carpark' by similar designs'

Policy 3D2 Retail and leisure development Add two more points
'- Encourage the provision of residential accommodation over shops'
'- Do not permit shed and carpark type developments'

3D3 Monitoring and improving retail facilities. Amend the first point to read : '-work with retailers and others to prevent the loss of retail facilities that provide essential convenience, fresh produce and specialist shopping 'within walking distance or at most one or two public transport stops without changing'

There is a need to distinguish different kinds of retail. An additional poor quality convenience shops near another, both selling the same things and very little fresh fruit and vegetables is an unacceptable substitute for a shop with significant greengrocery. Access demands reducing the need for travel - schools, shops, libraries, sports facilities and entertainment should be localized so that more of these can be reached on foot, and more still by one or two stops on bus, tram or tube.

.3D4 Culture, leisure and sport Amend point 3 to read 'facilities are accessible to all sections of the community, including disabled and less abled people, with the possibility of exemption for facilities in buildings or parts of buildings of recognised historic or artistic merit which would be significantly and unavoidably damaged by alterations to ensure access and where alternative facilities exist reasonably close'

Paras 27-28 A new evening economy can be a good and stimulating addition to a neighbourhood. The damaging effects of a late night zone are quite different and should be distinguished, and residents and existing businesses' interests.should have priority. 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.
The recommendations of the Civic Trust's publication 'Open All Hours' should be followed.