Contact: Roger Lawes, ext 6743

1. Summary

1.1 The following decision is sought:

That the Mayor of London be informed that Hampshire County Council:

(i) continues to support the aim of developing London as an exemplary sustainable world city but nevertheless objects to the Plan because:

(a) by relying heavily on supplementary planning guidance and development briefs to provide details of how the strategy will be implemented, it fails to provide any clear evidence that development pressures will be managed in a way that is both beneficial to local communities and in the interests of areas beyond the Mayor's administrative boundary;

(b) it fails to provide specific and comprehensive guidance on the level of provision for both the management of waste and the supply of aggregate to be made within each borough, as without such guidance there is a real danger that inadequate provision to deal with all London's waste will be made, and consequently that waste will continue to be exported to the adjoining regions, and that London will continue to be heavily reliant on sand and gravel supplied from the adjoining regions; and

(ii) welcomes the prospect of a continuing dialogue with the Mayor over the policies and proposals to enhance the transport network with London and the wider south-east region.

2. Reason

2.1 To alert the Executive Member to those policies and proposals in the draft London Plan which could have an impact on Hampshire, and recommend a response to the Mayor.

3. Other Options Considered and Rejected

3.1 Not to offer a response. Rejected because of the need to influence the future development of London because of the possible impacts on Hampshire.

4. Conflicts of Interest Declared by the Decision Maker or a Member or Officer consulted - None.

5. Dispensation granted by the Standards Committee - Not applicable.

6. Reason(s) for the Matter being dealt with if Urgent - Not applicable.

Approved by: Date:

Councillor K B Estlin

7. Introduction

7.1 In May 2001 the Mayor of London published his initial thoughts on what a new plan for London should contain ('Towards the London Plan'). This new plan, the London Plan, will replace the existing strategic planning guidance for London (RPG3) issued by the Secretary of State in 1996. It will provide the context for local plans prepared by the 32 London boroughs and the City of London, and the framework against which the Mayor will consider his response to strategic planning applications.

7.2 The draft London Plan has been developed in the light of comments made on the May 2001 document. A copy of the draft Plan is available in the Planning and Surveyor's Library. It has been prepared with the benefit of advice from a wide range of stakeholders. The responses to the consultation, and the Mayor's views on those responses, will be considered by a Government appointed Panel at an Examination in Public early in 2003. Having considered the report of the Panel the final London Plan will be published by the Mayor in late 2003.

7.3 The County Council's former Environment Committee considered 'Towards the London Plan' on 25 June 2001. In the absence of any details the Committee concluded that the impact of the general policies and proposals promoted to develop London as "the exemplary sustainable world city ..." on Hampshire was difficult to gauge, but that inevitably there would be some impact beyond Greater London. In the meantime it made various comments on two aspects of the strategy: the management of development and transport pressures and waste for the Mayor to consider when developing the draft Plan.

8. Background to Strategic Planning in London

8.1 There are a number of unique features to the way in which the plan-making system works in London. Two of significance when considering the draft Plan are:

(i) it is the responsibility of the elected Mayor rather than the elected Greater London Authority to provide strategic planning guidance. The form of this guidance is clearly prescribed in The Town and Country Planning (London Spatial Development Strategy) Regulations 2000 which includes, amongst other matters, the rather cryptic requirement to maintain appropriate distances between establishments and residential areas, areas of public use and areas of particular natural sensitivity or interest; and

(ii) although the process of preparing the spatial development strategy is similar to that of preparing a structure plan (including the various consultation processes and the need for an Examination in Public), there appears to be no requirement to consult on changes to the strategy following such an Examination in Public.

9. The draft London Plan

9.1 The Mayor has established five common themes for all his plans and strategies aimed at developing London into his vision of an exemplary world city. These themes are a prosperous city, a city for people, an accessible city, a fair city and a green city. To influence the development of spatial policies an additional theme has been added to the London Plan, namely making the most efficient use of space and encouraging intensification and growth in areas of need and opportunity.

9.2 To help develop the themes into a plan a set of priorities has been identified, including:

(i) substantial growth, particularly of economic activity, in the Central Activity Zone and Central London;

(ii) major development to the east of London along the Thames Gateway, with an expansion of some Central London functions into the City fringe, Isle of Dogs and Stratford;

(iii) enhancing and diversifying the role of town centres in many places across London;

(iv) significant improvements in access, services and sustainability in suburban areas;

(v) focused integration of spatial policies, with policies for neighbourhood renewal, better health, improved learning and skills, greater safety, and better employment and housing opportunities in the Areas for Regeneration; and

(vi) appropriate intensification and mix of uses but with a special focus on Areas for Intensification.

9.3 The Plan uses the five administrative areas chosen for the Learning and Skills Councils to provide the basis for the spatial development framework for the city. For each area a sub-regional spatial framework will be prepared in consultation with a wide range of key stakeholders. In addition to the general themed policies, the Plan contains guidance for each of the sub-regional frameworks in the form of more detailed policy statements relating to areas of opportunity and areas for intensification within each sub-region. These frameworks will be published as Supplementary Planning Guidance.

9.4 To assist in the development of the sub-regional frameworks, the preparation of borough-wide unitary development plans and day to day development control, the draft Plan also proposes a raft of thematic policies under four headings: living in London (including policies on housing, key public services and local communities); working in London (including policies for office space, employment opportunities and improving skills); connecting London (including policies for integrating transport and spatial policies, new public transport and moving freight and goods); and enjoying London (including policies on retail, leisure, tourism and open space). There are also three cross-cutting policy packages involving London's metabolism (including policies on minerals and waste, energy, water and climate change); designs on London (including policies for design, tall and large buildings and historic conservation); and a reconciliation check (including sustainable development, health and equalities).

9.5 The specific proposals in the Plan seek to accommodate a target minimum provision of some 459,000 additional homes 1997-2016 and a growth of some 636,000 jobs over the 15 years 2001-2016. By far the largest proportion of this growth is expected in Central and East London (61 percent of the additional homes and 76 percent of the jobs). To help connect homes and jobs and facilitate social and cultural interaction, a raft of transport proposals are promoted mainly involving new public transport systems, including new cross London rail links, light transit schemes, bus routes, and cycling and walking links.

9.6 The Plan acknowledges London's heavy dependence on the adjoining regions for the management and disposal of much of its waste, and comments that London needs to become more self-sufficient in its treatment of waste. However, there is no clear policy statement for a move towards self-sufficiency in dealing with waste within a definite time frame. Boroughs are required to ensure that land resources are available to implement the Mayor's Municipal Waste Management Strategy. However, the policy appears only to cover municipal waste. Other waste streams, which together constitute the great majority of waste arising in London, appear to be omitted.

9.7 The Plan emphasises the need for an increase in waste minimisation, recycling and composting and that incineration capacity should be orientated towards non-recyclable residual waste, and includes a presumption against any increase in mass-burn incineration capacity. It assumes that new and emerging waste conversion technologies will provide preferable alternatives to mass-burn incineration. Boroughs are required to identify sites for waste management facilities in their Unitary Development Plans.

9.8 The Plan acknowledges London's heavy reliance on the supply of aggregates from other regions, due to its lack of primary aggregate resources. It proposes high targets for reuse of construction and demolition waste, and that boroughs should support the development of recycling facilities and safeguard wharves and railheads for aggregates use.

10. County Planning Officer's and County Surveyor's Comments

10.1 The London Plan is significant for two reasons. First, because decisions about how London should develop and change will inevitably influence plans and strategies for the surrounding counties in southern England, and possibly beyond; and second, because it is a 'spatial plan' and therefore illustrative of the new type of plan being trailed in the Planning Green Paper.

10.2 Many of the detailed policies promoted in the 'cross cutting' theme (including policies on energy, water, design and conservation) are not particularly unique to London and chime with actions being taken by strategic planning authorities across the United Kingdom to promote the broad social, economic and environmental aims of sustainable development. Whereas development plans elsewhere are limited to land use and transport matters, the London Plan has the advantage of being able to deal with other matters, such as health and education, that affect the overall well-being of the community.

10.3 The Mayor's vision of developing an exemplary sustainable world city is consistent with the views expressed in the Regional Planning Guidance (RPG9). The scale of housing provided in the Plan should ensure that the needs of London are met within the city rather than exported to adjoining counties. The Plan is, however, less clear about how the deficit between potential job growth and labour supply will be addressed.

10.4 On the face of it the Plan appears to promote a balance between London's housing and employment needs and a comprehensive strategy to accommodate the necessary development needs within its administrative boundary. However, it is still remarkably short on details and relies on future sub-regional studies and development briefs to provide the policies and proposals that will actually control development. In the absence of these details there must be uncertainty over the realism of the strategy and the consequences if either the balance of requirements or the supply of opportunities varies significantly from those assumed in the Plan. The Plan recognises London's close and complex links with surrounding regions but this relationship is not explored in any detail. Accordingly, it is impossible even to begin to consider the consequences of the strategy in terms of the possible fall-out of development pressure elsewhere in the south-east.

10.5 It is particularly regrettable that the Plan appears to have made no concessions to the need to balance the obvious desirability to make the best use of redundant and reusable land and building against the impact of the proposed new forms of development on the local environments - social, natural and built. The relationship between the thematic and cross-cutting policies (paragraph 9.4) is not explored. The reliance on further sub-regional studies and development briefs to provide supplementary planning guidance to assist implementation and development control means that many questions about the implications and consequences of the policies promoted in the draft plan remain unknown. The Mayor's strategy appears to be based on absorbing the demands for built development and linking activities by various forms of public transport to the exclusion of other environmental and social considerations. With the Plan also echoing regional planning policies strongly favouring the retention of the Metropolitan Green Belt and the proposed improvement to public transport links across London, the proposed development corridors of Central London and Thames Gateway become within commuting distance. The pressures on Hampshire, and other surrounding counties, will be further exacerbated if the Mayor's drive for high density development simply resulted in a living environment that many find unacceptable. Migration motivated by the desire for a better living environment would undermine the Mayor's vision of more inclusive local communities.

10.6 The absence of a clear policy statement for a move towards self-sufficiency in the management of waste within London within a definite time frame is a serious omission from the plan. Furthermore, the apparent omission of waste streams other than municipal waste, which together constitute the great majority of waste arising in London, is a serious failure, which will only serve to continue the current practice whereby very large quantities of London's waste are disposed in the adjoining regions, currently by landfill. The assumption that new and emerging waste conversion technologies will provide preferable alternatives to mass-burn incineration is not justified on current information, and the practical availability of such technologies at a commercial scale may be some years off. There is a real danger that an absence of additional recovery capacity will lead to the continued export of waste from London for treatment and disposal in surrounding counties, including the pressure for additional incineration capacity outside London as landfill availability declines.

10.7 The requirement for boroughs to identify sites for waste management facilities is to be welcomed, but there is a lack of specific and comprehensive guidance on the level of provision to be made within each borough. Without such guidance there is a danger that adequate provision for dealing with London's waste will not be made.

10.8 The policies for aggregates are to be welcomed as far as they go. However, it is unfortunate that the Plan does not give clearer, more specific guidance to the boroughs on the provision that should be made in Unitary Development Plans (UDPs) for the supply of aggregates, particularly in terms of identifying and safeguarding recycling sites, rail depots and wharves. If London is to minimise its demands on the sand and gravel resources of the adjoining regions it is essential that maximum use is made of supplies of aggregates from recycling and from imports by rail and water. In the absence of a London-wide Minerals Local Plan, this will only be achieved if the necessary guidance is given to the boroughs on what they should be making provision for in their UDPs.

10.9 The London Plan has been designed to be complementary to the London Transport Strategy, the draft of which was consulted on earlier this year. The document sets an overall context for both immediate and longer term priorities for improving transport in London. Inevitably, the Plan is very London-focused and does not consider fully the important role that the city plays in a regional context. Clearly, decisions made in London on a wide range of issues can have a significant impact on transportation demand throughout the south-east. However, the Plan does acknowledge that the economy of London depends upon and sustains a host of support businesses throughout the south-east region, which will clearly impact on overall transport demand. Nevertheless, many of the policies and proposals will have a beneficial effect on the wider region in terms of meeting the goals of the overall transport strategy and is much in keeping with Hampshire's own transport strategy, such as the goal to reduce the share of travel by private car and so reduce traffic congestion.

10.10 The Plan refers throughout to the important links between land use policy and transportation, and is keen to encourage high density trip generating development at locations accessible by public transport, with accompanying capacity improvements where needed in order to reduce congestion and accommodate growth.

10.11 The Plan acknowledges that within outer London the car will continue to be the preferred mode, and policies and proposals reflect this, which could in turn impact on modal choice in North East Hampshire, commuting patterns in general, and on overall transport demand that may bring tensions between the goals of the Plan and the County Council's transport strategy.

10.12 National rail is also identified as a crucial component of the capital's transport system. The Plan seeks to continue collaboration with stakeholders and partners to improve inter-regional rail commuting services, develop cross-boundary services, encourage public transport access to international termini by public transport, including those to airports, seaports, and rail stations for both passenger and freight services, to allow long distance traffic, especially freight, to bypass London. Other objectives include ensuring that operators provide vastly improved services, reduce overcrowding and increase passenger comfort, and that multi-modal freight interchanges are developed on the periphery of the capital, although the location is yet to be determined.

10.13 Several major projects are of interest to Hampshire. Of particular relevance is the proposed Hackney to South West London railway line, which will provide a new link across the heart of the city. An assessment of this project is currently under way, within which consideration is being given to the merits of serving Clapham Junction with a major new transport interchange. The merits of the line forming the third Regional Metro, with services through running over the National Rail network, will also be examined. If this was to be achieved it would offer up a wide range of new direct destinations for services from Hampshire and allow them to run directly into the heart of the city rather than terminating at Waterloo.

10.14 Hampshire already participates at European, national, regional and local level to enhance the transport network, and overall welcomes the opportunity that the Plan provides to continue dialogue and to be involved in developments on the transport network, especially the railway line out of Waterloo, which provides the main rail link between London and Hampshire, Southampton and Portsmouth and elsewhere. It would be appropriate for the County Council to continue to be involved in these discussions to ensure that the economy, residents and other sectors continue to be able to influence and benefit from the policies and proposals in the draft London Plan and the London Transport Strategy.

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