8.1 Are the various proposals for Supplementary Planning Guidance appropriate and are the arrangements and timetable for preparing SPG clear and acceptable?
Are the proposals to require additional assessments in support of planning applications reasonable and justified?
8.2 Is the approach towards section 106 agreements envisaged in the Plan an acceptable and workable approach to achieving development?
8.3 Do the proposed implementation mechanisms and institutional arrangements in the draft Plan provide a clear means for translating the policies into action?
In particular, do they provide the context for informing the Mayor of London's other strategies?
Whole document, specifically Chapter 5
Para 5.33 says 'Londoners comprise the largest and in many ways the most important group of stakeholders'... Londoners need to be aware of the Plan and own its priorities'
The Vauxhall Society agrees with this. However, the provisions for consultation and taking notice of what Londoners want, particularly in their own neighbourhoods, are inadequate. Londoners will feel, correctly, that they do not own the priorities of the Plan unless they have had and have proper participation in setting them and in how they are implemented. The procedures for consultation on the Plan have set a bad precedent, with little time allowed for written representations on the draft and restrictions who could participate in the process. In the balance between on the one hand speed and efficiency in getting a Plan and on the other hand getting participation from Londoners, the latter has suffered. It is essential that this mistake is not perpetuated in implementing the Plan. There must be much greater weight given to people's participation in decisionmaking. Decisions on what is to happen in people's localities should come from principally from the locality.
Policy 5.2 point 2 insert after Urban Regeneration Companies 'with significant local participation'
point 4 'insert 'and maintain' between 'revenue funding to provide' and 'community facilities and services'
Too much capital has been spent without consideration of and provision for running costs.
Section 106 agreements.
Payments must be for local improvements decided according to the local authority and local people's previously determined priorities and should be spent in the immediate locality. Developers should not be able to pay to substitute one community facility for another under a 106 (for example by providing money for upgrading pen spaces in return for being allowed to build on one.)
Para 5.42 Proposal to recoup large increases in land values, much of which is attributable to the planning system or public investment, especially in public transport. No method is suggested. It is not at all clear whether an equitable way of doing this could be found, and it would take time to try to find one. What could be done immediately is to encourage siting where transport is needed rather than where it is good but often overstretched, and require developers to pay for/contribute for the needed transport improvements, but not to allow them to dictate where the new transport should go. .
Policy 5.6 Increasing capacity of London. We query the need for and the likelihood of growth. There should be Plan B: without growth. Public transport and reducing the need to travel. are essential anyway. Add to point 3 'support the development of local community strategies' 'and ensure that local communities have a much greater say in determining the future of their areas.' This agrees with the point in para 5.59
Para 5.61 Add ' but questions its proposals to overrule much local decisionmaking and its failure to propose a third party right of appeal
Timing of major transport schemes. The Cross River Tram should be started at least as soon as the West London Tram, or before. ie, by end 2005, not end 2007 and to open by end 2009, not end 2011and private money, particularly from the businesses to be served by it should be sought for this. This is essential for South Central London even if there is no growth. Its route should be modified to serve poorly accessible areas while keeping close to the original route.