This is the response originally sent, with the accidental errors corrected1. Name and address
Organisation: The Vauxhall Society (the civic society for the north of Lambeth (from and including Stockwell) and adjacent parts of Wandsworth and SouthwarkAlternative contact:
2. We are commenting on several aspects of the plan in the following paragraphs, each of which proposes changes and is therefore an objection, although in many cases we support some or all of the aims behind the proposals but consider that the proposals in the plan will not achieve them and our proposed changes will. We wish to speak on them at the Examination in Public and argue for them if necessary at the two preliminary meetings. We are happy to give supplementary information and background and to expand on the rationale of our arguments.
Predicted Growth and opportunity and regeneration area
The main premise of the 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 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.
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 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.A 'World City'
We are told that growth, including tall buildings, is necessary for London to be and stay a World City. This shows a shocking lack of confidence in our great capital city.
One reason is supposed to be to encourage visitors. Who will this benefit? Should we really encourage more air travel, particularly as much of it passes through London anyway merely as a stepping stone to the continent. We should encourage train travel to and from the rest of Europe rather than air travel as it is environmentally much less damaging. 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. 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.
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. While the Plan calls for more accessible services, Lambeth is expected to provide a disproportionate share of London's new housing, and recent housing developments in the borough have mainly been achieved at the expense of schools, libraries and community facilities sold off by the Council.
Mix and fine grain in opportunity and regeneration areas
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.
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 action on this.
The Mayor's plans for London's transport network appear to disregard the need for orbital journeys - much of the congestion on public transport is due to the need for many journeys from suburb to suburb to be routed through the centre. Completing the outer rail circle (which needs very little new track and a little opening of freight lines for passengers as well) should be part of this, as well as tube, bus and tram routes. The Plan calls for a 50% increase in the capacity of public transport, but it is doubtful if that can be achieved and certainly it would be very difficult to achieve it quickly. The most urgent requirement is to reduce 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 or tube. Provisions for walking should be given greater priority, and routes made direct, at grade level and along desire lines. Provision for cyclists should be improved so that they have safe direct routes including over junctions and are not tempted or scared on to pavements which do not have separate cycle paths on them. 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 go, 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.
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. The Vauxhall Cross transport interchange currently being constructed would need more escalators down to the tube platforms and improved access with escalators from the rail station down to street level and then down to the tube to achieve increased capacity and access for all. It is already crowded even before St George's current development at the Effra site on the river is completed. The interchange scheme is actually making the access from outside the station to the tube worse, with the alternatives of a ramp and stairs at present being replaced by stairs and a single lift which requires a key to open it, so that there is not only less access, but it is being made more difficult for anyone burdened, inform or with a pushchair. Standards and requirements such as we propose would have prevented this.
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.
We support the protection of existing protected views over London, but in addition other panoramic views from the high ground in South London - including Herne Hill, Sydenham Hill and Blackheath - where the angle of daylight is so much better, should also be preserved and, where necessary, restored. Views form the Thames and of the Thames from the South of the river should also be preserved. The present protected views are almost entirely from the perspective of the north of the river. This imbalance needs to be corrected.
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.
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', and should allow for some additional increase in the areas which need it most.
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.