Lewisham Council Members
Members of the committee, listed below, are summoned to attend the meeting to be held on Wednesday, 23 September 2015.
Barry Quirk, Chief Executive September 15 2015
Councillor Obajimi Adefiranye Councillor Abdeslam Amrani Councillor Chris Barnham Councillor Paul Bell Councillor Peter Bernards Councillor Chris Best Councillor Kevin Bonavia Councillor Andre Bourne Councillor David Britton Councillor Bill Brown Mayor Sir Steve Bullock Councillor Suzannah Clarke Councillor John Coughlin Councillor Liam Curran Councillor Janet Daby Councillor Brenda Dacres Councillor Amanda De Ryk Councillor Joe Dromey Councillor Damien Egan Councillor Colin Elliott Councillor Alan Hall Councillor Carl Handley Councillor Maja Hilton Councillor Simon Hooks Councillor Ami Ibitson Councillor Mark Ingleby Councillor Stella Jeffrey Councillor Liz Johnston-Franklin Councillor Alicia Kennedy Councillor Roy Kennedy Councillor Helen Klier Councillor Jim Mallory Councillor Paul Maslin Councillor David Michael Councillor Joan Millbank Councillor Jamie Milne Councillor Hilary Moore Councillor Pauline Morrison Councillor John Muldoon Councillor Olurotimi Ogunbadewa Councillor Rachel Onikosi Councillor Crada Onuegbu Councillor Jacq Paschoud Councillor John Paschoud Councillor Pat Raven Councillor Joan Reid Councillor Gareth Siddorn Councillor Jonathan Slater Councillor Alan Smith Councillor Luke Sorba Councillor Eva Stamirowski Councillor Alan Till Councillor Paul Upex Councillor James-J Walsh Councillor Susan Wise
Council Agenda
Wednesday, 23 September 2015 7.30 pm, Council Chamber - Civic Suite Civic Suite Lewisham Town Hall London SE6 4RU
For more information contact: Kevin Flaherty 0208 3149327 (Tel: 0208 314 9327)
Part 1
Item Pages
1. Declaration of Interests 1 - 3
2. Minutes 4
3. Petitions 5
4. Announcements or Communications 6 - 7
5. Public Questions 8 - 29
6. Member Questions 30 - 51
7. Audit of Accounts 52 - 134
8. Lewisham Local Plan Consultation 135 - 236
9. Parks Byelaws 237 - 258
10. Blackheath Byelaws 259 - 274
11. Council Urgency Committee 275
12. Action by Chair of OSC 276
13. Public Spending in Lewisham Working Group 277 - 356
14. Motion 1 Proposed Councillor Morrison Seconded Councillor Daby 357 - 358
15. Motion 2 Proposed Councilor Hall Seconded Councillor Muldoon 359
16. Motion 3 Proposed Mayor Seconded Councillor Reid 360
Members of the public are welcome to attend committee meetings. However, occasionally, committees may have to consider some business in private. Copies of agendas, minutes and reports are available on request in Braille, in large print, on audio tape, on computer disk or in other languages. RECORDING AND USE OF SOCIAL MEDIA
You are welcome to record any part of any Council meeting that is open to the public.
The Council cannot guarantee that anyone present at a meeting will not be filmed or recorded by anyone who may then use your image or sound recording.
If you are intending to audio record or film this meeting, you must :
• tell the clerk to the meeting before the meeting starts
• only focus cameras/recordings on councillors, Council officers, and those members of the public who are participating in the conduct of the meeting and avoid other areas of the room, particularly where non- participating members of the public may be sitting.
• ensure that you never leave your recording equipment unattended in the meeting room.
If recording causes a disturbance or undermines the proper conduct of the meeting, then the Chair of the meeting may decide to stop the recording. In such circumstances, the decision of the Chair shall be final.
FIELD_TITLE
Members of the public are welcome to attend committee meetings. However, occasionally, committees may have to consider some business in private. Copies of agendas, minutes and reports are available on request in Braille, in large print, on audio tape, on computer disk or in other languages. COUNCIL
Report Title Declarations of Interests
Key Decision Item No. 1
Ward
Contributors Chief Executive
Class Part 1 Date: September 23 2015
Declaration of interests
Members are asked to declare any personal interest they have in any item on the agenda.
1 Personal interests
There are three types of personal interest referred to in the Council’s Member Code of Conduct :-
(1) Disclosable pecuniary interests (2) Other registerable interests (3) Non-registerable interests
2 Disclosable pecuniary interests are defined by regulation as:-
(a) Employment, trade, profession or vocation of a relevant person* for profit or gain
(b) Sponsorship –payment or provision of any other financial benefit (other than by the Council) within the 12 months prior to giving notice for inclusion in the register in respect of expenses incurred by you in carrying out duties as a member or towards your election expenses (including payment or financial benefit from a Trade Union).
(c) Undischarged contracts between a relevant person* (or a firm in which they are a partner or a body corporate in which they are a director, or in the securities of which they have a beneficial interest) and the Council for goods, services or works.
(d) Beneficial interests in land in the borough.
(e) Licence to occupy land in the borough for one month or more.
(f) Corporate tenancies – any tenancy, where to the member’s knowledge, the Council is landlord and the tenant is a firm in which the relevant person* is a partner, a body corporate in which they are a director, or in the securities of which they have a beneficial interest.
(g) Beneficial interest in securities of a body where:-
d:\moderngov\data\agendaitemdocs\4\4\0\ai00012044\$bj5xd4mh.doc (a) that body to the member’s knowledge has a place of business or land in the borough; and
(b) either (i) the total nominal value of the securities exceeds £25,000 or 1/100 of the total issued share capital of that body; or
(ii) if the share capital of that body is of more than one class, the total nominal value of the shares of any one class in which the relevant person* has a beneficial interest exceeds 1/100 of the total issued share capital of that class.
*A relevant person is the member, their spouse or civil partner, or a person with whom they live as spouse or civil partner.
(3) Other registerable interests
The Lewisham Member Code of Conduct requires members also to register the following interests:-
(a) Membership or position of control or management in a body to which you were appointed or nominated by the Council
(b) Any body exercising functions of a public nature or directed to charitable purposes , or whose principal purposes include the influence of public opinion or policy, including any political party
(c) Any person from whom you have received a gift or hospitality with an estimated value of at least £25
(4) Non registerable interests
Occasions may arise when a matter under consideration would or would be likely to affect the wellbeing of a member, their family, friend or close associate more than it would affect the wellbeing of those in the local area generally, but which is not required to be registered in the Register of Members’ Interests (for example a matter concerning the closure of a school at which a Member’s child attends).
(5) Declaration and Impact of interest on members’ participation
(a) Where a member has any registerable interest in a matter and they are present at a meeting at which that matter is to be discussed, they must declare the nature of the interest at the earliest opportunity and in any event before the matter is considered. The declaration will be recorded in the minutes of the meeting. If the matter is a disclosable pecuniary interest the member must take not part in consideration of the matter and withdraw from the room before it is considered. They must not seek improperly to influence the decision in any way. Failure to declare such an interest which has not already been entered in the Register of Members’ Interests, or participation where such an interest exists, is liable to prosecution and on conviction carries a fine d:\moderngov\data\agendaitemdocs\4\4\0\ai00012044\$bj5xd4mh.doc of up to £5000
(b) Where a member has a registerable interest which falls short of a disclosable pecuniary interest they must still declare the nature of the interest to the meeting at the earliest opportunity and in any event before the matter is considered, but they may stay in the room, participate in consideration of the matter and vote on it unless paragraph (c) below applies.
(c) Where a member has a registerable interest which falls short of a disclosable pecuniary interest, the member must consider whether a reasonable member of the public in possession of the facts would think that their interest is so significant that it would be likely to impair the member’s judgement of the public interest. If so, the member must withdraw and take no part in consideration of the matter nor seek to influence the outcome improperly.
(d) If a non-registerable interest arises which affects the wellbeing of a member, their, family, friend or close associate more than it would affect those in the local area generally, then the provisions relating to the declarations of interest and withdrawal apply as if it were a registerable interest.
(e) Decisions relating to declarations of interests are for the member’s personal judgement, though in cases of doubt they may wish to seek the advice of the Monitoring Officer.
(6) Sensitive information
There are special provisions relating to sensitive interests. These are interests the disclosure of which would be likely to expose the member to risk of violence or intimidation where the Monitoring Officer has agreed that such interest need not be registered. Members with such an interest are referred to the Code and advised to seek advice from the Monitoring Officer in advance.
(7) Exempt categories
There are exemptions to these provisions allowing members to participate in decisions notwithstanding interests that would otherwise prevent them doing so. These include:-
(a) Housing – holding a tenancy or lease with the Council unless the matter relates to your particular tenancy or lease; (subject to arrears exception) (b) School meals, school transport and travelling expenses; if you are a parent or guardian of a child in full time education, or a school governor unless the matter relates particularly to the school your child attends or of which you are a governor; (c) Statutory sick pay; if you are in receipt (d) Allowances, payment or indemnity for members (e) Ceremonial honours for members (f) Setting Council Tax or precept (subject to arrears exception)
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Report Title Minutes
Key Decision Item No.2
Ward
Contributors Chief Executive
Class Part 1 Date: September 23 2015
Recommendation
It is recommended that the minutes of the meeting of the Council which was open to the press and public, held on June 24 2015 be confirmed and signed (copy previously circulated).
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Report Title Petitions
Key Decision no Item No.
Ward n/a
Contributors Chief Executive (Head of Business & Committee)
Class Part 1 Date: September 23 2015
1. The Council is invited to receive petitions (if any) from members of the Council or the public. There is no requirement for Councillors to give prior notice of any petitions that might be presented.
2. The Council welcomes petitions from the public and recognises that petitions are one way in which people can let us know their concerns. All petitions sent or presented to the Council will receive an acknowledgement from the Council within 14 days of receipt. This acknowledgement will set out what we plan to do with the petition.
3. Paper petitions can be sent to :-
Governance Support, Town Hall, Catford, SE6 4RU
Or be created, signed and submitted on line by following this link
http://lewisham-consult.limehouse.co.uk/portal/petitions
4. Petitions can also be presented to a meeting of the Council. Anyone who would like to present a petition at a Council meeting, or would like a Councillor to present it on their behalf, should contact the Governance Support Unit on 0208 3149327 at least 5 working days before the meeting.
5. Public petitions that meet the conditions described in the Council’s published petitions scheme and which have been notified in advance, will be accepted and may be presented from the public gallery at the meeting.
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Report Title Announcements or Communications
Key Decision No Item No.
Ward n/a
Contributors Chief Executive
Class Part 1 Date: September 23 2015
Recommendation
The Council is invited to receive any announcements or communications from the Mayor or the Chief Executive.
ANNOUNCEMENT BY THE CHIEF EXECUTIVE
1. Attendance at Meetings
1. Purpose
The purpose of this report is to bring to the attention of the Council that notification has been received that owing to serious illness, Councillor David Britton has asked for a six month leave of absence commencing from December 23 2015 and Councillor Crada Onuegbu has requested a six month leave of absence from January 28 2016.
2. Reason for Urgency
If a Councillor does not attend a Council meeting for a period of six months the member ceases to be a member unless the Council approves the reason for non-attendance before expiry of the six month period.
3. Background
Councillor David Britton last attended a council meeting, the Children & Young People Select Committee on June 23 2015.
Councillor Crada Onuegbu last attended a council meeting, the Licensing Committee on July 29 2015.
4. Legal Implications
Section 85 of the Local Government Act 1972 states that if a member fails to attend any meeting of the authority for a period of six consecutive months from the date of his/her last attendance, he/she shall cease to be a member, unless the failure is due to a reason approved by the authority. Approval must be given before the expiry of the six months, otherwise a vacancy would have to be declared on the expiry of the six months and a by-election held.
d:\moderngov\data\agendaitemdocs\9\4\0\ai00012049\$pzrp31re.doc 5. Financial Implications
There are no specific financial implications.
6. Recommendations
That:
(1) The Council agrees a leave of absence for Councillor David Britton for a period of six months from December 23 2015 to June 23 2016; and
(2) The Council agrees a leave of absence for Councillor Crada Onuegbu for a period of six months from January 28 2016 to July 28 2016.
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Report Title Public Questions
Key Decision Item No.
Ward
Contributors Chief Executive (Head of Business & Committee)
Class Part 1 Date: September 23 2015
. The Council has received questions from members of the public in the order shown in the table below. Written responses will be provided to the questioners prior to the Council meeting and they will be entitled to attend and ask a supplementary question should they wish to.
Question Questioner
1. Mr Woolford 2. Mrs Richardson 3. Mr Richardson 4. Ms Onatade 5. Mr Lee 6. Mrs Richardson 7. Mr Woolford 8. Ms Onatade 9. Mr Woolford 10. Ms Onatade 11. Mr Richardson 12. Ms Onatade 13. Ms Onatade
d:\moderngov\data\agendaitemdocs\7\4\0\ai00012047\$igmluqlx.doc Question Q Time
PUBLIC QUESTION NO 1.
Priority 1
LONDON BOROUGH OF LEWISHAM
COUNCIL MEETING
23 SEPTEMBER 2015
Question asked by: Ray Woolfood – People before Profit
Member to reply: Cllr Egan
Question
Can the Council confirm what impact the extension of right to buy to housing Associations will impact on Lewisham Housing crises?
How many Housing Association tenants in Lewisham are likely to take up the right to buy, and what strategy does the Council have to cope with the number of Council properties that would need to be sold to subsidise these sales for this?
Reply
We are awaiting details of the proposed extension of the Right to Buy to Housing Associations and the proposed policy that would compel the Council to sell some higher value properties which are expected to be contained in the forthcoming Housing Bill.
The Council will assess the potential impact of measures contained in this Bill once it is published.
It is not possible to predict how many tenants in Lewisham may take up the extended Right to Buy if this policy becomes law. Question Q Time
PUBLIC QUESTION NO 2.
Priority 1
LONDON BOROUGH OF LEWISHAM
COUNCIL MEETING
23 SEPTEMBER 2015
Question asked by: Mrs Richardson
Member to reply: Deputy Mayor
Question
In view of the fact that the application for Planning permission to redevelop the Leegate Shopping Centre has been submitted to Lewisham Council, has the Council notified its boundary neighbour Council, the Royal Borough of Greenwich? If not, when, in the future, will that Council be notified and will it receive copies of the intended development so that it may comment on the possible impact on its own residents, housing, parking policies and roads of the proposed re-development. Would Lewisham Council consult both the Planning Department and Regeneration, at Greenwich?
Reply
As part of the statutory consultation exercise for the proposals to redevelop the Leegate Shopping Centre, the Royal London Borough of Greenwich (RLBG) were consulted in February this year. The consultation information contained the application reference and a link to view all of the application documents on the Council’s web site. The Council consider that it is a matter for RLBG to consider which of its departments should be involved in formulating its response to the consultation. On the 29 April 2015, the Council received a representation from RLBG regarding the proposals to which they raised no objections. No further comments to the proposals were made in the response.
The Leegate application was submitted with an Environmental Statement, to which further information has been received by the Council. In this respect, a second consultation exercise took place this week and RLBG were again consulted. To date, the Council has received no further formal comments from RLBG. Question Q Time
PUBLIC QUESTION NO 3.
Priority 1
LONDON BOROUGH OF LEWISHAM
COUNCIL MEETING
23 SEPTEMBER 2015
Question asked by: Mr Richardson
Member to reply: Councillor Onikosi
Question
On 1st September 2015, I received a letter from an Asset Strategy department officer regarding an 'Experimental Provision of Controlled Parking Zone' for the Lee Green CPZ. This involves a change of parking restriction in Lee Green CPZ from its current 9:00am through to 7:00pm Monday to Friday to become 10;00am through to 12 noon Monday to Friday. This time change was determined by a democratically conducted consultation of the residents in July 2014 with a definitive majority requesting the change would involve a 2-hour slot, and at the times noted above. lt is due to commence on 5th October 2015.
In view of the above resume of events, can the Council explain why it is deemed necessary that this provision should undergo an 'experiment', when by a clear majority the residents of Lee Green CPZ have already determined this change would occur?
Reply
As part of the 2012 Parking Policy review, it was agreed that new CPZs would be introduced using Experimental Traffic Orders. With this type of traffic order, measures are introduced on an experimental basis in the first instance so that their effects can be closely monitored and assessed, and modified should it be deemed necessary. This effectively builds a meaningful review period into the implementation process to allow for minor changes to the scheme. The scheme is then made permanent at a later stage - within 18 months.
The experimental basis is aimed particularly at the effectiveness of the detailed design of the new zone, for example the location and type of parking bays. The principle of the zone itself, the area of the zone, and the timing of the zone, have been determined by the detailed public consultation and will not be changed without further consultation of a similar kind. Question Q Time
PUBLIC QUESTION NO 4.
Priority 1
LONDON BOROUGH OF LEWISHAM
COUNCIL MEETING
23 SEPTEMBER 2015
Question asked by: Ms Onatade
Member to reply: Councillor Egan
Question
1. What influence does the Council have with Phoenix Community Housing? 2. When was the last time that a Phoenix leaseholder sat on the Phoenix Board and can this failing be rectified? 3. How many properties does Phoenix own in Bellingham, Grove Park, Whitefoot and Downham Wards? 4. In order to improve public accountability will the Council use its influence to increase the number of elected councillors on the Phoenix Board?
Reply
Phoenix Community Housing is both an independent organisation and an important partner of the Council. Two of the 12 members of the Phoenix Board are Councillors, currently Councillor Daby and Councillor Hall, which this Council considers to be an appropriate number, and will not be seeking to change.
The questions you pose about the stock that Phoenix holds and the arrangements it has in place for leaseholders to be represented on the board are questions for Phoenix to answer, as an independent organisation, and not for the Council to answer on its behalf. Phoenix can be contacted as follows:
Emma McSweeney - Head of Home Ownership and Income 0203 121 0144 [email protected] Question Q Time
PUBLIC QUESTION NO 5
Priority 1
LONDON BOROUGH OF LEWISHAM
COUNCIL MEETING
23 SEPTEMBER 2015
Question asked by: Mr Lee
Member to reply: Councillor Bonavia
Question
How can the directly elected Mayor system be changed to a different form of Governance for the London Borough of Lewisham?
Reply
The law states that as the directly elected mayoral system was adopted in Lewisham following a binding referendum which supported its establishment, the Council may only depart from that model of governance following a binding referendum that supported such a change. Question Q Time
PUBLIC QUESTION NO 6.
Priority 2
LONDON BOROUGH OF LEWISHAM
COUNCIL MEETING
23 SEPTEMBER 2015
Question asked by: Mrs Richardson
Member to reply: Deputy Mayor Question
Two years ago at an information exercise, held by St. Modwen, on the redevelopment of Leegate, a representative of TFL was present to inform us about the plans for the Lee Green junction should the redevelopment go ahead. He said how well TFL had done in restructuring the then current junction. But this was not everyone's opinion even then.
At present, the junction is undergoing more changes and it is difficult to discover what or why. Has Lewisham Council been informed about the changes, what they are and why they are being done now?
Reply
Lewisham Council’s Highways department were made aware of the proposed works to the Tiger’s Head junction during a TfL consultation exercise with residents and businesses in the local area in January 2014. The proposed works are intended to improve pedestrian safety.
Lewisham’s Highways officers, with the assistance of an independent Transport consultant, have been in dialogue with TfL and the applicant team in order to consider the proposed development at Leegate in the context of the current TfL improvement works. Question Q Time
PUBLIC QUESTION NO 7.
Priority 2
LONDON BOROUGH OF LEWISHAM
COUNCIL MEETING
23 SEPTEMBER 2015
Question asked by: Raymond Woolford
Member to reply: Councillor Bonavia
Question
Can the Council please confirm what monitoring is in place to assess the impact of rent errors as a direct result of the Council removing the phone line service that all Lewisham borough advice centres need and depended on to assist the huge numbers seeking help around Housing Benefit and eviction issues. What assistance is available for the large numbers of people who are unable to use the Internet?
Reply
A government cut in the Council’s Housing Benefit administration grant of £478K per annum (14%) meant the service had to decide how it would continue to deliver top quartile claim processing performance at a much lower cost. The choice was to either reduce the number of staff assessing claims and changes or to look at delivering the customer contact part of the service in a different way.
The option of reducing the staff assessing claims changes was quickly discarded as it would result in delays processing new claims and changes, impact negatively on claimants and actually create more customer contact and more work due to the backlogs it would generate. The only option was to try and transform the way the service dealt with customer contact. On 9 March 2015 the service piloted a new approach to customer contact, providing a telephone route for new claims, supported by online and postal channels to report changes, access information and make enquiries. A telephone ‘callback’ service was introduced to help those who need to contact the service but are unable to do so using the online or postal routes.
The service liaised with representatives of local advice agencies and landlords in advance of the changes and regularly since to make the transition as smooth as possible. The ‘Do It Online’ landlord service has been in place for a number of years, enabling landlords receiving payments to keep up to date with their tenants’ claims and continues to be the quickest way to access claim information other than through the tenant themselves.
Looking forward, the service aims to introduce an online self-serve portal for claimants themselves in 2016, which will reduce the number of incoming enquiries by a further 50%.
Monitoring has been in place since the changes were introduced and there is no evidence of significant numbers of claimants being unable to access the service using the channels in place. There is also no evidence of an associated increase in the number of rent errors.
To date less than 1% of contacts made, have resulted in an escalation where the claimant felt they could not use our online or postal service and all of those were assisted to make use of one of these routes or provided with a suitable alternative.
The transformation means the service has reduced the number of calls being dealt with by 74% (560 calls per week during July 2015 compared to 2,130 a week during the same period last year) and continues to deliver top quartile processing performance (average 6 days to process new claims and changes) despite the government cut in grant. In addition this approach is helping to prepare claimants for Universal Credit which the DWP will administer in a similar way. Question Q Time
PUBLIC QUESTION NO 8.
Priority 2
LONDON BOROUGH OF LEWISHAM
COUNCIL MEETING
23 SEPTEMBER 2015
Question asked by: Ms Onatade
Member to reply: Councillor Egan
Question
1. How much money did Lewisham Council spend on Decent Homes work on the leasehold flats on the Meadows Estate prior to the stock transfer? 2. How much money is Phoenix now proposing to spend on the same flats? 3. Does the Council think that this expenditure can be justified, as Phoenix has admitted that it has lost details of what works was carried out prior to the stock transfer? 4. Will Lewisham Council clarify why the formal Section 20 notices issued by Phoenix for the major works on the above leasehold flat, do not contain details of the specific work to be carried out on these flats, when the Phoenix major works policy on the website states that full details of the proposed works will be included in the formal notices?
Reply
1. The Decent Homes programme was carried out by Phoenix after the stock was transferred from Lewisham Council. The Council did not carry out Decent Homes works itself prior to this date. 2. This is not information the Council holds and should be obtained from Phoenix Community Housing. 3. The requirement for repair works to properties owned by Phoenix is a decision for Phoenix to make in consultation with its residents and leaseholders, and not something on which the Council can comment.
4. The formal Section 20 process allows leaseholders to query and challenge planned works by following the process set out in legislation relating to this matter. The Phoenix’s leasehold management team will be best able to advise you in relation to this matter.
Phoenix can be contacted as follows:
Emma McSweeney - Head of Home Ownership and Income 0203 121 0144 [email protected] Question Q Time
PUBLIC QUESTION NO 9.
Priority 3
LONDON BOROUGH OF LEWISHAM
COUNCIL MEETING
23 SEPTEMBER 2015
Question asked by: Raymond Woolford
Member to reply: Councillor Bonavia
Question
Since the introduction of the Bedroom tax, Council tax payments must be made by tenants on housing benefit, can the Cabinet Member confirm the percentage increase of numbers forced into arrears and the numbers served with a letter warning of eviction?
Reply
Since April 2013, tenants of working age in social housing who are deemed to have more bedrooms than they need, have had their housing benefit reduced by 14% if they have one bedroom more than they need and 25% if they have 2 or more bedrooms than they need. The reduced housing benefit means they have to contribute more towards their rent.
When the Bedroom Tax was introduced in April 2013 there were 2,736 households affected. The latest figures show this number has reduced to 2,182.
To assist tenants affected by the Bedroom Tax, the Council has worked closely with social housing landlords in the borough and made use of the Discretionary Housing Payment funding. The Council has also organised events to help facilitate moves to smaller properties, incentivised moves to smaller properties and run exchange programmes.
Lewisham Homes report they have seen a 23% increase in the number of households in arrears, some of which may be due to bedroom tax, but a drop in the total value of the arrears. In all cases, households in arrears have been contacted to try and arrange payment and made aware of the situation. However, to date there have been no evictions on cases where the arrears as just related to Bedroom Tax.
Information across housing associations is less consistent, the general picture is there has not been a significant increase in rent arrears, generally Bedroom Tax makes-up around 6% of rent arrears. Again, there is no evidence yet of anyone being evicted due to rent arrears arising from Bedroom Tax only at this stage. Question Q Time
PUBLIC QUESTION NO 10.
Priority 3
LONDON BOROUGH OF LEWISHAM
COUNCIL MEETING
23 SEPTEMBER 2015
Question asked by: Ms Onatade
Member to reply: Councillor Egan
Question
Will Lewisham Council confirm that it is a criminal offence for any Housing Association to fail to provide on request from a leaseholder in a block of flats with more than 4 leasehold flats an audited set of accounts for service charge?
Reply
There is no statutory requirement for a Housing Association to provide, on request from a leaseholder in a block of flats with more than 4 leasehold flats, an audited set of accounts for the service charge.
Consequently, there is no such criminal offence.
Under Section 21 of the Landlord and Tenant Act 1985, a Housing Association leaseholder may make a written request for a written summary of the relevant costs incurred in relation to the service charge. If the service charge relates to more than four dwellings, then the summary shall be certified by a qualified accountant. Section 22 of the Landlord and Tenant Act 1985 states that where a tenant has obtained a written summary of relevant costs under Section 21, then that tenant may require the landlord, in writing, to afford him reasonable facilities to inspect the Housing Association accounts and take copies or extracts from them.
The failure to comply with the above obligations can amount to a criminal offence. However, each case must be taken on its own specific facts and is subject to the evidence. Question Q Time
PUBLIC QUESTION NO 11.
Priority 3
LONDON BOROUGH OF LEWISHAM
COUNCIL MEETING
23 SEPTEMBER 2015
Question asked by: Mr Richardson
Member to reply: Councillor Best
Question
The minutes of the Society of Chief Librarians Executive Committee meeting, 3rd June 2015, discussed interesting topics and there are points for action which will affect the future of the Public Library Service. As the Head of Library Information Service attended the meeting, can he be asked if he consider the interests, opinions and suggestions made will be able to influence a steadily deteriorating and fragmenting PLS across the country, as well as Lewisham's library service?
What development can we expect to see in our own libraries in consequence of what the committee agreed and will they extend to all libraries in the borough, including the Community libraries?
Is the action agreed on the Reference on-line Strategy likely to result in visitors to our Community libraries having full use of the services available in Council run libraries, such as "Access to Research" and "Ancestry"? Reply
The Society of Chief Librarians’ Executive Meeting covered the following topics: Digital Leadership pilot This item relates to equipping library staff with the digital skills needed today. Lewisham has participated in the design of this project and in the rollout of the pilot. The Council will be linking up with London colleagues to evaluate the impact of the course.
Development of the Learning Offer This item links to an extension to the four existing Universal Offers that Lewisham participated in developing, which cover Reading, Information, Digital, and Health. The proposal put to SCL in June is still being developed, and Lewisham is very much involved in the discussions.
Children and Young People Survey Lewisham is aware of CIPFA’s research and welcomes a national report.
Information offer Lewisham is evaluating the www.information4living.org.uk proposal, as this may replicate existing provision.
Digital offer Lewisham is not planning to develop a bid for the Wi-Fi funding at this time. Lewisham is supporting the continuation of the Reference Online service but presented the proposal that the additional £50 cost of the JISC subscription should be absorbed by SCL, rather than be added to the individual annual subscription. This position has been supported by the vast majority of London boroughs and returned to SCL.
Health offer Lewisham is particularly keen to link up with the Wellcome Trust to support the Books on Prescription in Lewisham. This is a service that Lewisham has enthusiastically supported since its inception.
Reading offer Lewisham welcomes closer collaboration between SCL and Save the Children’s “Read on Get on” campaign and has helped pilot Access to Research which was launched nationally at Deptford Lounge.
Shakespeare Week While SCL is evaluating the 2015 initiative, Lewisham is planning to join up with London colleagues in a number of national and regional initiatives for 2016, as well as developing its own locally.
eLending Lewisham has been involved in discussing the promotion of eLending through public libraries and will be working with the Task Force on this. Lewisham’s interpretation of the provision of library and information services is demonstrated by the Council’s approach to developing the Service over many years. As a result, Lewisham’s performance, particularly in relation to participation and service offer, is often substantially ahead of the rest of the country. Lewisham has demonstrated, by implementing the Community Library Model, that the service available to residents is one, whether it is accessed in hub libraries, community libraries or online. Indeed, specifically related to the community libraries, Lewisham owns the stock, evaluates its usage and quality and allows its access through the Lewisham library card. There is no plan to depart from this approach.
Access to Research and Ancestry are two substantially different products. The former is accessible free of charge in libraries. Access is allowed through a restricted range of IP addresses by which computers in libraries can be identified. We are working to extend this to the computers in community libraries.
Ancestry is an American product distributed by ProQuest which allows access through local authority identified computers – again through IP addresses. In this instance, however, there seem to be less room for negotiation, although Lewisham is still trying to make a case for the service to be extended to identified providers. The trend, however, shows an expansion of these services and Lewisham continues to be at the forefront of these developments as they become available. Question Q Time
PUBLIC QUESTION NO 12.
Priority 4
LONDON BOROUGH OF LEWISHAM
COUNCIL MEETING
23 SEPTEMBER 2015
Question asked by: Ms Onatade
Member to reply: Councillor Egan
Question
Does Phoenix still maintain that any ground floor flat owned by a leaseholder has to have a fire proof door and is this opinion shared by the London Fire Brigade?
Reply
This Council is not able to provide an answer on behalf of Phoenix or the London Fire Brigade on this topic.
Phoenix can be contacted as follows:
Emma McSweeney - Head of Home Ownership and Income 0203 121 0144 [email protected] Question Q Time
PUBLIC QUESTION NO 13.
Priority 5
LONDON BOROUGH OF LEWISHAM
COUNCIL MEETING
23 SEPTEMBER 2015
Question asked by: Ms Onatade
Member to reply: Councillor Egan
Question
Will Lewisham Council use its influence to set up a meeting between Phoenix and Phoenix Leaseholders?
Reply
Yes. Phoenix has confirmed that it would meet with leaseholders as requested, and the arrangements for this to happen are being put in place. COUNCIL
Report Title Member Questions
Key Decision Item No.6
Ward
Contributors Chief Executive (Head of Business & Committee)
Class Part 1 Date: September 23 2015
7. Questions from Members of the Council
Section C, paragraph 14 of the Constitution, provides for questions relevant to the general work or procedure of the Council to be asked by Members of the Council. Copies of the questions received and the replies to them will be circulated at the meeting.
d:\moderngov\data\agendaitemdocs\8\4\0\ai00012048\$2fyiq1re.doc QUESTION No. 1
Priority 1
LONDON BOROUGH OF LEWISHAM
COUNCIL MEETING
23 SEPTEMBER 2015
Question by Councillor Curran of the Cabinet Member for Health, Wellbeing and Older People
Question
Will the Mayor provide the Friends of Sydenham Community Library with a copy of the agreement between the Council and Eco Computers for that company to run Sydenham Community Library?
Reply
No agreement exists for Eco Communities, Bold Vision / New Cross Learning, or Age Exchange to run library services on behalf of the London borough of Lewisham.
Eco Communities negotiated three leases to occupy the Sydenham, Crofton Park, and Grove Park library buildings.
Bold Vision / New Cross Learning have a tenancy agreement that allows them to occupy the New Cross library building.
The lease that the Council had on the Blackheath Village library building was surrendered. Library services can be accessed from the Reminiscence Centre in Blackheath.
The individual leases are commercially sensitive documents which cannot be made public. QUESTION No. 2
Priority 1
LONDON BOROUGH OF LEWISHAM
COUNCIL MEETING
23 SEPTEMBER 2015
Question by Councillor Hall of the Mayor
Question
What assessment has the Mayor made of the trajectory of the public finances in Lewisham over the next four years?
Reply
To answer this question I need to take a view on whether the Government will listen to what they are being told by Local Authorities and other public bodies ahead of the Comprehensive Spending Assessment or if they will plough ahead with another round of cuts in excess of 25% for “unprotected” areas of spend.
London Councils’ submission sets out in detail the challenges London faces and invites Government to work with them to deliver a set of reforms that fit London’s circumstances. In one area of activity alone, Adult Social Care, it identifies a gap of £900m by 2020 on current projections. Further cuts to the General Fund in November will make this much worse leading to impacts not only on Social care but the NHS too.
If government listens we will face a difficult but manageable four years, if on the other hand they pursue cuts which can only be delivered by dramatically shrinking some services and removing others entirely, they will be responsible for damaging the quality of life for millions of Londoners for no better reason than political dogma. QUESTION No. 3
Priority 1
LONDON BOROUGH OF LEWISHAM
COUNCIL MEETING
23 SEPTEMBER 2015
Question by Councillor Milne of the Cabinet Member for Resources
Question
Please provide a list of Lender Option Borrower Option (LOBO) loans taken out by the council including the interest rate paid on these loans and the breakage fee.
Reply
The table below lists the Council’s LOBO loans, the applicable interest rates and respective breakage terms.
Lender Value Interest Type Start date Years Breakage fees £m rate Bayern 10.0 7.95% Fixed 30/03/1992 26 No provision for early repayment other than option to break at no cost if interest rate change proposed. Bayern 15.0 4.67% Variable 01/03/2001 35 No provision for early repayment other than option to break at no cost if interest rate change proposed. Bayern 10.0 4.40% Variable 01/11/2001 40 No provision for early repayment other than option to break at no cost if interest rate change proposed. FMS 10.0 4.50% Fixed 05/04/2004 45 Option to break at no cost if interest rate change proposed. Lender Value Interest Type Start date Years Breakage fees £m rate Dexia 5.0 4.50% Fixed 19/03/2004 50 Option to break at no cost if interest rate change proposed or with fees at any other date. Dexia 10.0 4.12% Fixed 25/07/2005 60 Option to break at no cost if interest rate change proposed or with fees at any other date. Dexia 25.0 3.58% Fixed 18/01/2006 60 Option to break at no cost if interest rate change proposed or with fees at any other date. Dexia 7.5 3.98% Fixed 08/08/2006 60 Option to break at no cost if interest rate change proposed or with fees at any other date. Total 92.5 QUESTION No. 4
Priority 1
LONDON BOROUGH OF LEWISHAM
COUNCIL MEETING
23 SEPTEMBER 2015
Question by Councillor Ingleby of the Cabinet Member for the Public Realm
Question
Last year residents and some of the Council’s housing partners were offered the Love Lewisham app for the instant reporting of fly-tipping and other environmental hazards. This has now stopped working and, like the Keep Britain Tidy digital reporting system, is also inaccessible from laptops or websites.
Therefore, is it true that the Love Lewisham app is or was due to be restored or to run in collaboration with other similar apps that Lewisham residents can use?
Can you confirm the current accessibility and functioning of the Love Clean Streets reporting tool – or other digital options - for both mobiles and laptops at present, both for potential and current Lewisham users?”
Reply
The contract with an external provider for the supply of the LoveLewisham came to an end. An in-house version of LoveLewisham has been developed and is currently being tested by our workforce. This new system will save money and improve service delivery. A decision on whether to make this system available to the public has yet to be made. The LoveCleanStreets reporting tool is still available and currently allows reports from web browsers. This system is not controlled by the council, so we would be unable give assurances for its continued availability. FixMyStreet.com provides an excellent web reporting user interface. Environment staff will endeavour to provide updates to reports made via FixMyStreet. www.fixmystreet.com http://www.lewisham.gov.uk/doitonline/report-it/Pages/report-it.aspx Residents can also report issues from their web-browsers using the Council's website. QUESTION No. 5 Priority 1
LONDON BOROUGH OF LEWISHAM
COUNCIL MEETING
23 SEPTEMBER 2015
Question by Councillor Ibitson of the Deputy Mayor
Question
Elm Lane is an un-adopted highway with a variety of frontagers, including the Council (CYP and Lewisham Homes), and some private homes and businesses. The condition of Elm Lane is now badly deteriorated, and can become impassable on foot after heavy rain – including for parents taking children to St George’s playgroup, and coaches bringing teams and schools to use the sports ground which park in Perry Hill, and can obstruct the bus stops. Could TfL be approached, via the borough’s LIP allocation for works (Corridors, Neighbourhoods and Supporting Measures theme) to create a mixed use open space along at least part of Elm Lane, which could be used for coach parking when required and an improved shared space public realm when the sports ground is not in use, while retaining vehicle access to homes in Elm Lane?
Reply
The LIP Corridors, Neighbourhoods and Supporting Measures have a limited funding allocation with many competing demands. Schemes are therefore prioritised according to the objectives of the LIP, which generally results in schemes located on strategic corridors or in local centres. The suggested improvement scheme would appear to offer benefits to the local area, but is unlikely to provide the scale of benefits (for instance footfall levels, strategic cycle route, road safety improvements) which would justify its inclusion in the current borough-wide LIP programme.
QUESTION No. 6
Priority 1
LONDON BOROUGH OF LEWISHAM
COUNCIL MEETING
23 SEPTEMBER 2015
Question by Councillor Bourne of the Deputy Mayor
Question
A number of roads, including Bamford Road and Chelford Road surround the River Ravensbourne; how many times in the past 2 years have the roads and pavements been inspected for damage? And what actions will be taken to treat the problems?
Reply
Please see attached inspection records for both roads which show how many times the roads have been inspected in the last 2 years and the work/repairs identified.
QUESTION No. 7
Priority 2
LONDON BOROUGH OF LEWISHAM
COUNCIL MEETING
23 SEPTEMBER 2015
Question by Councillor Milne of the Cabinet Member for Resources
Question
What percentage of our borrowing portfolio is made up of LOBO loans?
Reply
As per the draft financial statements presented to the Audit Panel in June, at the 31 March 2015 the Council’s total liabilities for borrowing from financial instruments stood at £192.5m (note 11c). This includes the £92.5m of LOBO loans listed above, representing 48% of the total.
NB - this excludes £239.0m of PFI and finance lease liabilities (note 11a). If PFI and finance lease liabilities are included, at 31 March 2015 LOBOs represent 21% of the Council’s borrowing portfolio. QUESTION No. 8
Priority 2
LONDON BOROUGH OF LEWISHAM
COUNCIL MEETING
23 SEPTEMBER 2015
Question by Councillor Ibitson of the Deputy Mayor
Question
Each year, Skanska charge the organisers of various festive events, including Carols on the Green in Bellingham – organised by Churches Together in Bellingham - several hundred pounds for the installation and switching on of lights on community Christmas Trees, as this is apparently not covered by the streetlighting contract, including under ‘festive lights’ (which only covers the unfortunate items attached to the streetlamp columns). In the case of Carols on the Green, this has almost doubled the cost of putting on this popular annual event which brings together all the local schools and our diverse community for a multi-faith celebration. Are there any alternative options for providing Christmas Tree lights for community events such as these which would be acceptable to the Council, or could a commitment be given to revisit this issue with a view to reducing costs? Could there be any negotiation on this – for example, forfeiting streetlight column lighting in order for Christmas tree lights to be funded?
Reply
The Street Lighting PFI only includes for the installation and removal of Christmas Lights onto lighting stock that is managed by Skanska as part of the contract. Christmas Trees do not form part of this stock and subsequently Skanska will charge for any such works. QUESTION No.9 Priority 3
LONDON BOROUGH OF LEWISHAM
COUNCIL MEETING
23 SEPTEMBER 2015
Question by Councillor Milne of the Cabinet Member for Resources
Question
What is the sum total of brokerage fees paid in setting up all the Council's LOBO loans.
Reply
The total brokerage fees paid for setting up all of the Council’s LOBO arrangements (see Q3) was £109k, which represents 0.1% of the total principal of loans taken out of £92.5m. QUESTION No. 10 Priority 3
LONDON BOROUGH OF LEWISHAM
COUNCIL MEETING
23 SEPTEMBER 2015
Question by Councillor Ibitson of the Deputy Mayor
Question
A new zebra crossing has been installed on the ‘spine road’ in Bell Green retail park to improve pedestrian access between Sainsbury’s and the new shops, for which my colleagues and I are appreciative. We have also been approached by a local resident who feels that crossing the other road in the retail park (which runs into the Sainsbury’s car park behind the new flats) could also be made safer. I agree that this road can be difficult to cross, for example when walking from Sainsbury’s to access the bus stops at the junction of Perry Hill and Southend Lane. I understand that a further pedestrian/zebra crossing is not feasible but do think some kind of informal crossing would be an improvement. Please could this be considered further?
Reply
An informal crossing can be further investigated and will be considered as part of the small scale scheme list for next year, as this year’s list of schemes has already been agreed.
QUESTION No. 11 Priority 4
LONDON BOROUGH OF LEWISHAM
COUNCIL MEETING
23 SEPTEMBER 2015
Question by Councillor Milne of the Cabinet Member for Resources
Question
In the opinion of the Cabinet Member for Resources, do the Council's LOBO loans represent the best possible value for money?
Reply
Yes, when entered into at the time. All Council treasury management decisions are taken in line with the Treasury Management Strategy agreed by Council when setting the annual budget. This includes having regard to professional advice on available products in the market and complying with the CIPFA prudential borrowing requirements. The Council’s borrowing and investment needs are continually reviewed and opportunities to improve our cash flow monitored. QUESTION No. 12 Priority 4
LONDON BOROUGH OF LEWISHAM
COUNCIL MEETING
23 SEPTEMBER 2015
Question by Councillor Ibitson of the Deputy Mayor
Question
A few months ago the Bellingham Safer Neighbourhood Team raised the issue of motorbikes/mopeds using the public footpath/right of way between Haseltine School and Ridgewell Close as a ‘cut through’ causing safety concerns for pedestrians and local residents who use the footpath. The Highways team agreed to look at installing some railings on the pavement at the end of the footpath, which could deter powered-two-wheelers while maintaining access to the path for pedal cyclists. We were aware that this was not likely to take place until this financial year. Please could we have an update?
Reply
This issue is on the Small Scale Schemes list but is not in the list for this year due to the limited funds available. Schemes are prioritised and selected according to the funds available. It is likely to be considered as part of next year’s list. QUESTION No. 13 Priority 5
LONDON BOROUGH OF LEWISHAM
COUNCIL MEETING
23 SEPTEMBER 2015
Question by Councillor Ibitson of the Deputy Mayor
Question
The Public Transport Liaison Meeting forum has not met for several months since the officer who provided admin support for the meeting left the council. While resources are clearly stretched I was under the impression that officers were exploring options for how the work of these meetings (a unique opportunity for members, residents and amenity societies to directly question transport providers) might be continued, even if in a revised form. Several amenity society reps and transport operator staff have asked me what is happening with the meetings and I would like to ask for an update?
Reply
The Council recognises the value of the Public Transport Liaison Meeting as a useful forum between local stakeholders, Transport for London, and public transport operators.
Officers are exploring the options for maintaining the dialogue with transport providers that the forum offered. The current Chair of the Public Transport Liaison Meeting will be provided with further details shortly.
QUESTION No. 14 Priority 6
LONDON BOROUGH OF LEWISHAM
COUNCIL MEETING
23 SEPTEMBER 2015
Question by Councillor Ibitson of the Deputy Mayor
Question
Over the next two/three years the shopping parade in Randlesdown Road in Bellingham should benefit from the revamp of the Fellowship Inn public house and new community venue. Could consideration be given to applying for future Local Implementation Funding from TfL to give the high street area a complementary revamp such as renewed pavements and improved pedestrian crossing facilities between the shops/pub and leisure centre?
Reply
The LIP Corridors, Neighbourhoods and Supporting Measures have a limited funding allocation with many competing demands and are fully committed. Schemes are therefore prioritised according to the objectives of the LIP, which generally results in schemes located on strategic corridors or in local centres.
A pedestrian improvement scheme was implemented in Randlesdown Road in 2006/07, as part of the Bellingham 20mph zone. This included new footways, inset parking bays, and a pedestrian crossing point with a raised table at the entrance to the leisure centre.
The redevelopment of the Fellowship Inn offers an opportunity to better integrate the development with the surrounding public realm, or to make further complimentary improvements
As a number of key underlying transport objectives have been delivered as part of the 2006/07 scheme, the best way to consider further appropriate improvements is via the planning process, through which detailed highways advice will be provided, and potential highway improvements and development-related funding mechanisms will be identified. However, the Council will need to be mindful of the impact of this approach in potentially increasing overall Fellowship Inn scheme costs and will have to take a balanced view of the extent of improvements which might be secured. QUESTION No. 15 Priority 7
LONDON BOROUGH OF LEWISHAM
COUNCIL MEETING
23 SEPTEMBER 2015
Question by Councillor Ibitson of the Cabinet Member for the Public Realm
Question
When will the trees in Kangley Bridge Road be cut back, they are blocking out light to windows in the houses? My colleagues and I have been dealing with this complaint for almost a year now.
Reply
I can confirm that the trees in Kangley Bridge Road have been inspected with the majority being identified as Priority 2 (P2*).
The removal of basal/epicormic growth to crown break was completed this summer.
We aim to complete further pruning to the canopy of all the trees in Kangley Bridge Road in July/August 2016.
* P2 Trees assessed to be causing problems or Indicative timescale nuisance, such as trees that are very close to dwellings. These trees require remedial 2 months -24 months works but do not pose a direct risk to public health and safety.
COUNCIL
Report Title 2014/15 FINAL ACCOUNTS AND EXTERNAL AUDITORS REPORTS Key Decision No Item No. Ward ALL Contributors EXECUTIVE DIRECTOR FOR RESOURCES AND REGENERATION Class Date: 23 SEPTEMBER 2015
1 PURPOSE
1.1 The purpose of this report is to present to Council the External Auditor’s reports (Audit Findings and Value for Money) on the audit of the Council’s 2014/15 main accounts and Pension Fund accounts and to obtain members’ approval of the Statement of Accounts for 2014/15 (including the Annual Governance Statement).
1.2 The Audit Findings Reports are attached, and set out:
“…the key matters and audit findings arising from the 2014/15 audit of the financial statements…whether the accounts present a true and fair view of the financial position and have been properly prepared……..and whether you have put in place proper arrangements to secure value for money in your use of resources.”
1.3 The reports set out any issues arising from the audits that, in the opinion of the external auditor, are of sufficient significance to warrant informing and discussing with Members.
1.4 The pre-audit draft Statement of Accounts have been on the council’s website since the end of June 2015. In the interests of not printing large amounts of paper, copies have not separately been despatched with this agenda, but they are available on request.
2 EXECUTIVE SUMMARY
2.1 As at the date of despatch of this report, the audits were substantially complete and the external auditor, Grant Thornton, anticipates that unqualified opinions on the financial statements will be issued. The external auditors reports were discussed at the Audit Panel on 17 September 2015.
2.2 This report sets out the recommendations necessary to ensure that the statutory requirements are met. The external auditor requests that Members: Note the adjustments to the financial statements in the reports Approve the letters of representation on behalf of the council Agree the recommendations in the proposed action plan 2.3 Under the council’s constitution these matters will be for Council to determine.
3. RECOMMENDATIONS
3.1 The Council are recommended to:
i. Note the adjustments to the financial statements in the Audit Findings Reports ii. Agree the Action Plans set out in the Reports iii. Approve the Letter of Representation on behalf of the Council iv. Approve the Annual Governance Statement (AGS) v. Approve the 2014/15 audited Statement of Accounts
4. POLICY CONTEXT
4.1 Completing the audit of the council’s accounts and receiving the auditor’s report thereon contributes directly to the council’s tenth corporate priority:
Inspiring efficiency, effectiveness and equity: ensuring efficiency and equity in the delivery of excellent services to meet the needs of the community.
5. DETAIL
5.1 As at the date of despatch of this report, the audits were substantially complete and the external auditors, Grant Thornton, anticipate that subject to completing their outstanding work they will be giving an unqualified opinion on the financial statements and be giving an unqualified value for money conclusion.
5.2 By virtue of paragraph 8(3) of the Accounts & Audit Regulations 2011 (“The Regulations”) the Council must, by no later than 30 September 2015: a. Consider either by way of a committee or by the members meeting as a whole the statement of accounts; b. Following that consideration, approve the statement of accounts by a resolution of that committee or meeting; c. Ensure that the statement of accounts is signed and dated by the person presiding at the committee or meeting at which that approval was given; d. Publish (which includes publication on the body’s website), the statement of accounts together with any certificate, opinion, or report given or made by the auditor under section 9 (general report) of the 1998 Act.
5.3 The Audit Panel have already considered the reports and officers’ responses to them in detail and a short summary will be provided at the meeting. By considering that summary, Members will have discharged their duty under regulation 8(3)(a). 5.4 The draft accounts have been amended for the agreed findings of the audit and the Letter of Representation by the Executive Director for Resources and Regeneration will be signed accordingly.
5.5 Members are therefore, by recommendation 3.1(v) to this report, recommended to approve the accounts.
5.6 Officers will ensure that the correct protocols for the signature and publication of the accounts are followed, to ensure compliance with the requirements of The Regulations.
6 ANNUAL GOVERNANCE STATEMENT
6.1 This document has been slightly updated from that considered at the Audit Panel on 18th June 2015 to reflect the comments of the external auditors and is submitted for approval.
7 FINANCIAL IMPLICATIONS
7.1 There are no direct financial implications in agreeing the recommendations in this report.
7.2 The cost of external audit services in respect of 2014/15 is expected to be £255,000, including the cost of the audit of the accounts and the certification of grant claims and returns. The cost of the Pension Fund audit was £21,000.
8 LEGAL IMPLICATIONS
8.1 The key legal requirements are set out in paragraph 5.2 of this report. By agreeing the recommendations of this report Members will have put in place appropriate authority and arrangements to ensure that these are complied with.
9 EQUALITIES IMPLICATIONS
9.1 There are no equalities implications in this report.
10 CONSULTATION
10.1 The draft accounts have been published, and local electors have been able to exercise their rights to ask questions of the auditor in respect of them, and to inspect accounting records.
11 ENVIRONMENTAL IMPLICATIONS
11.1 There are no environmental implications in this report.
12 CRIME AND DISORDER IMPLICATIONS
12.1 There are no crime and disorder implications arising from this report. 13 BACKGROUND PAPERS
Draft audited 2014/15 Statement of Accounts
APPENDICES
1. 2014/15 Annual Governance Statement 2. Grant Thornton – The Audit Findings for the London Borough of Lewisham (including the Value for Money conclusion). 3. Grant Thornton – The Audit Findings for the Lewisham Pension Fund. 4. Letter of Representation – Main Accounts and Pension Fund Accounts
For further information on this report please contact:
Selwyn Thompson, Head of Financial Services, 0208 314 6932
Lewisham Annual Governance Statement 2014/15
1
What is Corporate Governance?
The Council is responsible for ensuring that its business is conducted in accordance with the law and proper standards; and for having a governance framework that comprises of the “Corporate governance culture, values, systems and processes by which this is achieved. It must make sure that public money is safeguarded, properly accounted for and used economically, efficiently and is about making sure effectively to meet its strategic objectives. the Council is run It also has a duty, through the establishment of internal control measures, to manage risk to a reasonable level by identifying, prioritising, evaluating and managing the risks to the properly. It is about achievement of its policies, aims and objectives. Finally, it has a duty to secure continuous improvement in the way in which its functions are exercised. ensuring the Council
The Council has approved and adopted a Local Code of Corporate Governance, which is consistent with the principles does the right things, of the CIPFA (the Chartered Institute of Public Finance and Accountancy) and SOLACE (the Society of Local Authority Chief at the right time and in Executives and Senior Managers) Framework Delivering Good Governance in Local Government. This statement explains how the authority has complied with the code and also how it the right way.” meets the requirements of the Accounts and Audit (England) Regulations 2011 in relation to the publication of a statement on internal control.
2
How has this statement been prepared? the Annual Governance Statement by the Council’s Audit Panel. Every year a review of the effectiveness of the Council’s governance framework is conducted by the Annual Governance Statement working party which comprises a team . A review of the Council’s Local Code of of policy, legal and audit officers with expertise in governance Corporate Governance by the Standards and internal control matters. Committee, with reference to CIPFA/Solace The group meets quarterly to collate and evaluate governance Guidance. evidence and identify areas requiring action; and is responsible for analysing CIPFA/SOLACE guidance in relation to the . Referral of the Annual Governance development of this statement and ensuring that the statement is approved via the Council’s key control Statement to full Council with the mechanisms. Statement of Accounts.
The governance review process includes: . Sign off by the Chair of the Council and Chief Executive, once approved. . The consideration of the Annual Governance Statement Action Plan by the . This year no significant gaps or governance Council’s Internal Control Board (ICB) on a issues have been identified and the actions quarterly basis. outlined at the end of this statement summarise the areas of governance focus . The consideration of the Accounts, the needed to maintain an effective governance Head of Audit and Risk’s Annual Report and framework.
3
What are the Council’s governance arrangements?
The Council’s governance arrangements aim to foster effective leadership and high standards of behaviour; a culture based on 1 Mayor (Labour) openness and honesty; and an external focus on the needs of service users and the public. The diagram on page 5 shows the Council’s external facing governance structure, as set out in the Council’s constitution.
Lewisham’s directly elected Mayor provides the Council with clear strategic direction and effective leadership but the Council also benefits from the perspectives and contributions of its 54 Councillors. The Council’s constitution clearly defines the roles of councillors and officers, and this clarity contributes to effective working relationships across the Council. The Constitution Working Party, the Standards Committee and the Audit Panel monitor and challenge the governance arrangements and ensure their robustness.
The Council has worked closely with its partners, both strategic and operational, primarily through the newly established Lewisham Congress, which had its first annual meeting in October 2014. The Council has two statutory partnership boards: the Safer Lewisham Partnership which works to protect the community from crime and help people feel safer; and the Health and Wellbeing Board which works to identify local health challenges and lead on the activity necessary to 54 Councillors (53 Labour, 1 Green Party) address them.
4 Mayor and Cabinet Council Statutory Committees Standards Committee The Mayor •Consists of 54 elected councillors, three for each of the 18 wards. • promotes high standards of conduct. •Appoints the overview & scrutiny committee and other committees. Pension Board Is elected by the whole •secures compliance with borough to lead and speak up •Approves the policy framework and budget. Local Government Pension for the whole borough; Scheme.
chooses up to nine councillors Overview and Scrutiny to form the Cabinet with specific Regulatory areas of responsibility; •Meets at least once a year and is ultimately responsible for overview Committees and scrutiny; sets out major decisions to be Licensing committees (x2) taken in a Forward Plan •Delegates work to other scrutiny bodies – six select committees, two published monthly; business panels all of which are formally subcommittees of overview •responsible for all
and scrutiny; entertainment licensing proposes budget and key policy and the provision of late proposals to Council •The Business Panel co-ordinates the select committees work night refreshment.
programmes. Planning committes(x4) takes decisions to implement policy with agreed policy •The six select committees draw up work programmes each year to: •consider planning framework; matters across the whole 1. Hold the Mayor and senior officers to account for decisions and borough. The Strategic considers recommendations for check performance. Planning Committee actions with officer advice. consider strategic The Cabinet 2. Examine issues in depth and make recommendations for policy regeneration proposals. Provide advice to the Mayor; development.
To find out what each of the Select Committees does please click the Other Committees & jointly with the Mayor takes Working Parties decisions relating to contracts. links below •Audit Panel •Appointments •Elections Business Panel & Education Business Panel •Health & Safety •Pensions Investment •Constitution Healthier Public Sustainable Housing Select Safer Stronger Children & Young CommunitiesHealthier SaferCommunities Stronger Children & Accounts DevelopmentSustainable Internal Control HousingCommittee Select People Select Public Accounts SelectCommunities Committee SelectCommunities Committee Young People Select SelectDevelopment Committee Board: Committee Committee Select Select Select Committee Select Committee Select Committee Committee • Manages the approach Committee Committee 5 to risk.
The Sustainable Community Strategy (SCS) outlines how all partners will work towards the vision by contributing to six key priorities:
Ambitious and achieving – where people are inspired and ‘Together we will supported to fulfil their potential. make Lewisham the Safer – where people feel safe and live free from crime, antisocial behaviour and abuse. best place in London Empowered and responsible – where people are actively involved in their local area and contribute to supportive communities. to live, work and Clean, green and liveable – where people live in high quality housing and can care for and enjoy their environment. learn’ Healthy, active and enjoyable – where people can actively participate in maintaining and improving their health and well- being.
Communicating and reviewing the Council’s Vision Dynamic and prosperous – where people are part of vibrant communities and town centres, well connected to London and beyond. The Council has an overarching vision for the borough which is shared by its key partners and which was developed following extensive consultation with the community: ‘Together we will The Council, in turn, has developed ten corporate priorities make Lewisham the best place in London to live, work and which articulate its contribution. learn’.
6
Delivering Quality Services Peer Challenge by the Local Government Association found Lewisham Council to be: The Council seeks to use its resources efficiently and effectively to provide quality services which help deliver its vision for the “a strongly performing Council, which borough. In the 2013/14 Annual Audit Letter Grant Thornton, approaches local government delivery and the Council’s external auditors commented that: practice in an innovative way” “we are satisfied that in all significant The Lewisham Future Programme has been established to respects the Council put in place proper spearhead how the Council can move forward in the face of arrangements to secure economy, reduced government funding. A number of thematic and cross- cutting reviews are being carried out. This work is underpinned efficiency and effectiveness in its use of by four core values: resources”
The Council’s performance is monitored via a monthly We put service to the public first management report which tracks 58 performance indicators, grouped according to the Council’s ten corporate priorities, and associated risks. The report uses Red exception reporting We respect all people and all to focus attention on areas of poor performance or high risk communities and is a critical tool for supporting decisions across the organisation. The report is seen by the Executive Management Team (EMT) monthly and the Public Accounts Select Committee and Mayor & Cabinet quarterly and is published on We invest in employees the Council website. The quality of services for users is also measured through satisfaction surveys and information from the complaints and management resolution process. A recent We are open, honest and fair in all we do
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Roles and responsibilities ‘The Mayor is elected to lead the Council. They serve for a period of four years. They The Council’s constitution sets out the roles and responsibilities of the Mayor, the Chair of Council, the Council must act in the interests of the borough as a as a whole, the Executive, Statutory Officers, Overview and whole. They are responsible for taking most Scrutiny committees, Standards committees and other committees to help ensure that all decision making activity is of the main decisions, and for giving the lawful and transparent. Decisions are taken and scrutinised in power to others to do so.’ accordance with the Council and Mayoral scheme of delegation, the procedure rules set out in the constitution and on the basis of professional officer advice, as part of an annual programme of regular meetings. ‘Councillors are elected for a term of four Embedding Roles and Responsibilities years. Councillors who are elected to The Local Code of Corporate Governance and the Codes of represent local wards must both represent Conduct for Members and Officers, set out in the constitution, demand the highest standards of ethical behaviour. These are the people of the ward that elected them reviewed regularly and are communicated widely. The and act in the interest of the whole area. Standards Committee received its annual report on Member They are all expected to contribute to the compliance with the Code of Conduct in December 2014 and considered that there was a high level of compliance. good governance of the area and to Following the elections in May 2014, training on the Member encourage community participation. They Code of Conduct was delivered to all Councillors in June 2014, as part of a comprehensive induction programme to enable must respond to their constituents’ them to understand and access all appropriate support and enquiries fairly and without prejudice.’ development to undertake their role.
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Decision making
The constitution requires councillors to follow formal procedures when taking decisions to make sure that decisions ‘The constitution are made transparently and openly. This includes declaring if they have a personal interest in the matters under discussion and, if required, withdrawing from the room whilst the requires councillors to decision is taken. Reports are produced in a standard format to ensure that report authors address all significant follow formal considerations such as the legal, financial and equalities implications of decisions. The minutes of every formal meeting are published on the Council website. procedures when
The constitution requires Executive decisions to be published taking decisions to within two working days of being taken and they may be called-in (referred to the Mayor for reconsideration) by the Overview and Scrutiny Business Panel and the Education make sure that Business Panel. Two matters were called in by the Education Business Panel in the 2014/15 period. The Council has a Constitution Working Party (CWP) to advise it on the operation decisions are made of its constitutional arrangements but in practice, the procedure rules set out in the constitution are under constant review to reflect changing needs. transparently and
openly’
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Internal Audit Audit Panel The role of internal audit is to provide an independent and The Council’s Audit Panel meets quarterly and is made up of a objective opinion on the internal control environment within mixture of Councillors and independent advisors. The key roles the Council. Its work is set out in an annual internal audit plan of the Panel are to: that covers the activities where internal audit and management perceive there are risks to achieving objectives. A . Review and comment on the strategy, plans and number of audits take place each year to analyse relevant resources of Internal Audit. Internal Audit update controls and following each audit an assurance statement reports, summarising the audit reports issued, indicating the level of assurance that management can place management’s progress on implementing any on the adequacy and effectiveness of the internal controls is produced. In 2014/15 75 assurance reviews were recommendations and the performance of the commissioned. There were 11 in the Resources and Internal Audit function, are received by the Panel Regeneration Directorate, 13 in the Customer Services on a quarterly basis. Directorate, 9 in the Community Services Directorate, 11 in the Children and Young People Directorate and 31 for Schools. . Consider and monitor the effectiveness of the Council’s risk management arrangements, the
control environment and associated anti-fraud External audit The Council’s governance, risk and control management and anti-corruption arrangements. arrangements are subject to an annual independent review by Grant Thornton, the Council’s external auditors. The last . Consider the external auditor’s annual plan and review took place in October 2014 and it was noted that other relevant external reports which contribute to the level of assurance. “… we are satisfied that in all significant respects the Council put in place proper arrangements to secure economy, efficiency . Consider the Council’s annual Statement of and effectiveness in its use of resources…”. Accounts and this statement and make comments to Full Council when it considers the accounts.
10 Risk and Strategy Framework
Mayor and Cabinet - Scrutinise risks by considering the management report and updates to the capital programme. Quarterly
-Approve the Risk Management Policy & Strategy. -Receive an annual report to provide assurance that the Council has considered and documented risk in the Corporate Risk Register. Annually/ Audit Panel - Scrutinise the risk process. - Make reports & recommendations on the acceptance of the Risk Management Policy & Quarterly Strategy.
Internal Control Board (ICB) - Approve the Risk Management Policy & Strategy for consideration by Audit Panel. - Oversee the annual review of effectiveness of the system of internal control. - Determine & prioritise corporate strategic risks. Annually/ - Review the Corporate Risk Register and monitoring of risks. Quarterly - Ensure a corporate approach to the management of risk, health & safety and emergency planning.
Corporate Risk - Develop and review the Risk Management Policy & Strategy. Management Working - Co-ordinate the development of directorate risk registers and the corporate risk register and monitor these quarterly Quarterly Party - Provide executive control and support.
- Maintain a Directorate risk register aligned to service plan objectives which records significant Directorate Management risks and scores them in terms of impact and likelihood, sets target scores. Teams (DMTs) - Monitor the register quarterly. Quarterly - Identify and monitor risk mitigation actions.
Capital Programme - Approve project initiation documents and consider project progress reports. - Review and update project risks quarterly. Delivery Board - Notify relevant DMT/EMT of any risks that affect the project’s ability to meet corporate objectives.
- Work with project teams to analyse and manage service risks. Project Review Groups - Monitor progress on managing risk and report to the Directorate Management Team quarterly.
Heads of Service - Work with project teams to analyse and manage service risks and record in service plans. 11 - Monitor progress on managing risk and report to the Directorate Management Team quarterly.
Compliance
The Monitoring Officer is central to ensuring compliance with the rules and procedures set out in the constitution. The Monitoring Officer attends Mayor and Cabinet and Full Council meetings and regularly briefs EMT, councillors and relevant staff on corporate legislative developments; and legal advice is incorporated in every council report. Where gaps or non- compliance are identified, appropriate action is taken. The financial management of the authority is conducted in accordance with financial regulations set out in the constitution and the Council has designated the Executive Director of Resources and Regeneration as its Chief Finance Training and Development Officer, who advises on the proper administration of the Council’s financial affairs, keeping proper financial records and The Council runs a Member Development Programme, maintaining effective systems of financial control. The Council focussed on the period following local elections, which ensures has a whistle-blowing policy in place which is publicised on the that all Councillors have access to the training and Council’s website. Complaints made under this policy are development opportunities they need to fulfil their handled by the Monitoring Officer and an annual review is responsibilities to the local community and provide clear considered by the Standards Committee. leadership and effective scrutiny of local Council functions. The development needs of senior officers are the responsibility of the Head of Personnel and Development and the Monitoring Officer ensures that they are aware of their statutory duties and any changes in relevant legislation. At the start of the financial year the Chief Executive defines objectives for each of the Executive Directors which are then cascaded to officers throughout the organisation through the Performance Evaluation Scheme.
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Engaging the community and partners money comes from, what services it provides for the community, and to choose their own way to trim the budget The Council’s engagement activity is overseen by the Strategy using the online budget simulator. Performance and Communications Board (SPCB) which operates at Executive Director level and provides a strategic How do we know our arrangements are working? steer on the communication and consultation agendas within the Council. It is supported by the Strategy, Performance and Throughout the year, the Council regularly reviews the Communications Board Delivery Group (SPCBDG), which has effectiveness of its governance framework, including its system representation from across the Council and supports effective of internal control. Activity undertaken includes: resident engagement at an operational level. . Consideration of governance issues by the ICB – The Council promotes e-Participation through its online including risk registers, counter-fraud updates engagement system which provides a platform through which and internal audit reports. citizens can respond to online consultations as well as set up and respond to e-Petitions. Ward-level Local Assemblies are an opportunity for residents to work with their ward councillors . Preparation of a rolling plan of audit coverage to to shape the future of their neighbourhood; and the Young be achieved in the forthcoming year by the Head Citizens Panel gives young people aged 11 – 18 the chance to of Audit and Risk, primarily based on an feed into council policy and spending decisions, including the assessment of the Council’s risk profile, and use of the Young Mayor’s budget. review of the plan by ICB. The Council website includes a page on open data and transparency, which gives information on spending; wages of . Receipt of the Internal Audit Strategy by the senior managers; Freedom of Information requests; the annual audit of accounts; the pay policy; and Council decisions. The Audit panel and approval of the annual audit arrangements for strategic partnership working are set out plan. earlier in this statement. Periodically the Council also engages in wide consultation and communication activities. In 2014/15 . Preparation of the annual assurance report by it ran the Big Budget Challenge which provided local people the Head of Audit & Risk, setting out his opinion the chance to find out what we currently spend, where the
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on the Council’s overall control environment and . Changes made by the Constitution Working Party approval of the report by the Audit Panel. such as the introduction of the Pension Board
. Annual updates to the Public Accounts Select What are our governance priorities going forward? Committee on the work of the Audit Panel Our priorities include: . Consideration by EMT of a full range of governance and performance issues throughout . the year, including issues relating to the Managing change across Council services in improvement of the Internal Audit Service and light of the further budget reductions the scrutiny of performance and risk (ensuring Council faces, whilst at the same time management action is taken where necessary). maintaining internal control;
. Consideration of the following reports by the . Responding to policy and priority changes Standards Committee: for Lewisham, following the General
- Council’s annual complaints report Election in May 2015. (December 2014) - Compliance with the Member Code of Conduct (December 2014) . Addressing the external and internal audit - Review of the Council’s Code of Corporate findings reported to the Audit Panel in Governance (July 2014) 2014/15 to maintain and, where necessary, improve the Council's financial controls. . Consideration of external audit reports by Mayor and Cabinet, Audit Panel and relevant Select Committees. Signed
14 Cover page DRAFT This version of the report is a draft. Its contents and subject matter remain under review and its contents may change and be The Audit Findings expanded as part of the finalisation of the report. for London Borough of Lewisham
Year ended 31 March 2015 September 2015
Darren Wells Director T 01293 554 120 E [email protected]
Jamie Bewick Senior Manager T 07880 456 144 E [email protected]
Stephen Richards Executive E [email protected]
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 Letter
DRAFT Guidance note Red text is generic and should be updated specifically for your client. Once updated, change text colour back to black.
The disclaimer paragraph should not be edited or removed as this is there for Councillor Klier Grant Thornton UK LLP the auditor’s protection and Gatwick office its absence could possibly Chair of Audit Panel Fleming Way weaken our defence if a London Borough of Lewisham Manor Royal complaint or claim is made. LONDON Crawley RH10 9GT
SE 6 4RU www.grant-thornton.co.uk
Dear Councillor Klier
Audit Findings for London Borough of Lewisham for the year ending 31 March 2015 This Audit Findings report highlights the significant findings arising from the audit for the benefit of the Audit Panel , as required by International Standard on Auditing (UK & Ireland) 260. Its contents have been discussed with management. . As auditors we are responsible for performing the audit, in accordance with International Standards on Auditing (UK & Ireland), which is directed towards forming and expressing an opinion on the financial statements that have been prepared by management with the oversight of those charged with governance. The audit of the financial statements does not relieve management or those charged with governance of their responsibilities for the preparation of the financial statements. The contents of this report relate only to those matters which came to our attention during the conduct of our normal audit procedures which are designed primarily for the purpose of expressing our opinion on the financial statements. Our audit is not designed to test all internal controls or identify all areas of control weakness. However, where, as part of our testing, we identify any control weaknesses, we will report these to you. In consequence, our work cannot be relied upon to disclose defalcations or other irregularities, or to include all possible improvements in internal control that a more extensive special examination might identify. We do not accept any responsibility for any loss occasioned to any third party acting, or refraining from acting on the basis of the content of this report, as this report was not prepared for, nor intended for, any other purpose. We would like to take this opportunity to record our appreciation for the kind assistance provided by the finance team and other staff during our audit. Yours sincerely
Chartered Accountants Grant Thornton UK LLP is a limited liability partnership registered in England and Wales: No.OC307742. Registered office: Grant Thornton House, Melton Street, Euston Square, London NW1 2EP. Darren Wells (Director) A list of members is available from our registered office. Grant Thornton UK LLP is authorised and regulated by the Financial Conduct Authority. Grant Thornton UK LLP is a member firm of Grant Thornton International Ltd (GTIL). GTIL and the member firms are not a worldwide partnership. Services are delivered by the member firms. GTIL and its member firms are not agents of, and do not obligate, one another and are not liable for one another’s acts or omissions. Please see grant-thornton.co.uk for further details.
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | Date 2 Contents DRAFT Contents
Section Page 1. Executive summary 4 2. Audit findings 7 3. Value for Money 21 4. Fees, non-audit services and independence 32 5. Communication of audit matters 34 Appendices A Action plan B Audit opinion
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 3 DRAFT Section 1: Executive summary
01. Executive summary
02. Audit findings
03. Value for Money
04. Fees, non-audit services and independence
05. Communication of audit matters
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 Overall review of financial statements Executive summary DRAFT Executive summary
Purpose of this report • obtaining and reviewing the final management letter of representation This report highlights the key matters arising from our audit of London Borough • review of final version of the Annual Governance Statement of Lewisham (the Council) financial statements for the year ended 31 March 2015. • updating our post balance sheet events review, to the date of signing the It is also used to report our audit findings to management and those charged with opinion and governance in accordance with the requirements of International Standard on • Whole of Government Accounts. Auditing 260 (ISA UK&I). We received draft financial statements and accompanying working papers at the Under the Audit Commission's Code of Audit Practice we are required to report start of our audit, in accordance with the agreed timetable. whether, in our opinion, the Council's financial statements present a true and fair view of the financial position and expenditure and income for the year and Key issues arising from our audit whether they have been properly prepared in accordance with the CIPFA Code of Financial statements opinion Practice on Local Authority Accounting. We are also required to reach a formal Subject to the satisfactory completion of outstanding work we anticipate conclusion on whether the Council has put in place proper arrangements to secure providing an unqualified opinion in respect of the financial statements. economy, efficiency and effectiveness in its use of resources (the Value for Money conclusion). The financial statements presented for audit were of a good quality overall. We did not identify any misstatements affecting the Council's net expenditure Introduction position. In the conduct of our audit we have not had to alter or change our planned audit approach, which we communicated to you in our Audit Plan dated June 2015. We identified a number of classification and disclosure issues regarding the Council's accounting for property plant and equipment, including the Our audit is progressing well with the aim of giving the opinion in the final week accounting treatment of schools. This has led to some material amendments to of September. We are finalising our work in the following areas: the financial statements which are detailed on pages 20 and 21. • review of housing benefit payments • completion of work on operating expenses We also highlighted a number of other classification and disclosure errors which • review of the final version of the financial statements are also detailed on pages 20 and 21. • dealing with closing queries on the file None of the matters we identified affect the Council's reported financial position. Further details are set out in section two of this report.
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 5 Overall review of financial statements Executive summary DRAFT
Early close down Council staff have been helpful in engaging with the audit and responding to our Our audit is not designed to test all internal controls or identify all areas of queries. However from 2017/18 accounts the Council will have to submit draft control weakness. However, where, as part of our testing, we identify any accounts for audit by 31 May, a month earlier than present. The deadline for audit control weaknesses, we report these to the Council. certification will move forward to 31 July . This is a challenging timescale which will require the Council and the audit team to work together closely. Grant Findings Thornton are the external auditors for several councils who are already achieving the earlier deadline. We plan to meet with finance staff to discuss simplifying and We draw your attention to control issues identified in relation to: improving the closedown process, drawing on lessons from those councils. • Internal audit coverage during the year; • IT security controls in place at the shared service provider; and Value for Money conclusion • On-going reconciliations of the bank account and key financial systems. The Council continues to face significant financial challenges. We have reviewed the Council's arrangements to secure financial resilience. Although the Council Further details are provided within section two of this report. faces significant risks to its financial position, our view is that it has arrangements in place to manage those risks. Based on our review of the Council's arrangements The way forward to secure economy, efficiency and effectiveness in its use of resources, we propose Matters arising from the financial statements audit and review of the Council's to give an unqualified Value for Money conclusion. arrangements for securing economy, efficiency and effectiveness in its use of resources have been discussed with the Executive Director for Resources and Further detail of our work on Value for Money is set out in section three of this Regeneration. report. We have made a number of recommendations, which are set out in the action Whole of Government Accounts (WGA) plan in Appendix A. Recommendations have been discussed and agreed with We will complete our work in respect of the Whole of Government Accounts in the Executive Director for Resources and Regeneration and the finance team. accordance with the national timetable. Acknowledgment Controls We would like to take this opportunity to record our appreciation for the Roles and responsibilities assistance provided by the finance team and other staff during our audit. The Council's management is responsible for the identification, assessment, management and monitoring of risk, and for developing, operating and monitoring the system of internal control. Grant Thornton UK LLP © 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 September 2015 6
DRAFT Section 2: Audit findings
01. Executive summary
02. Audit findings
03. Value for Money
04. Fees, non-audit services and independence
05. Communication of audit matters
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 Overview of audit findings Audit findings DRAFT Audit findings
In this section we present our findings in respect of matters and risks identified at the planning stage of the audit and additional matters that arose during the course of our work. We set out on the following pages the work we have performed and the findings arising from our work in respect of the audit risks we identified in our audit plan presented to the Audit Panel. We also set out the adjustments to the financial statements arising from our audit work and our findings in respect of internal controls.
Changes to Audit Plan We have not made any changes to our Audit Plan as previously communicated to you in June 2015.
Audit opinion Our proposed audit opinion is set out in Appendix B.
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 8 Significant findings
Audit findings DRAFT Audit findings against significant risks "Significant risks often relate to significant non-routine transactions and judgmental matters. Non-routine transactions are transactions that are unusual, either due to size or nature, and that therefore occur infrequently. Judgmental matters may include the development of accounting estimates for which there is significant measurement uncertainty" (ISA (UK&I) 315). In this section we detail our response to the significant risks of material misstatement which we identified in the Audit Plan. As we noted in our plan, there are two presumed significant risks which are applicable to all audits under auditing standards.
Risks identified in our audit plan Work completed Assurance gained and issues arising
1. Improper revenue recognition review and testing of revenue recognition Having considered the risk factors set out in ISA240 and Under ISA (UK&I) 240 there is a presumed risk policies the nature of the revenue streams at Lewisham Council , that revenue may be misstated due to improper testing of material revenue streams we have determined that the risk of fraud arising from revenue recognition can be rebutted, because: recognition review of unusual significant transactions • there is little incentive to manipulate revenue recognition • opportunities to manipulate revenue recognition are very limited • the Council has a strong counter fraud culture and ethical frameworks.
2. Management override of controls review of journal entry policies and procedures Our audit work has not identified any evidence of Under ISA (UK&I) 240 there is a presumed risk review of accounting estimates, judgements and management override of controls. In particular the findings of management over-ride of controls decisions made by management of our review of journal controls and testing of journal entries has not identified any significant issues. testing of journal entries We have not been made aware of nor identified any review of unusual significant transactions unusual significant transactions. We set out later in this section of the report our work and findings on key accounting estimates and judgments.
3. Ledger upgrade • We reviewed the general ledger account We confirmed through our audit procedures that account The general ledger migrated to a shared service balances pre and post conversion to ensure that balances transferred to the shared service provider were provider, along with five other London Boroughs. they are in agreement. materially complete and accurate. As this is a significant non-routine event it is our We reviewed the controls the Council has in We identified a number of risks to the IT arrangements view that this represents a significant risk under place to ensure the completeness and integrity of between the Council and the shared service provider. In our ISA 315 data from the service provider. view these do not present a material risk to the opinion on the accounts, however we have raised these as reporting matters under the internal control section (page 17).
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 9 Significant findings (continued) Audit findings DRAFT Audit findings against other risks In this section we detail our response to the other risks of material misstatement which we identified in the Audit Plan. Recommendations, together with management responses, are attached at Appendix A.
Transaction cycle Description of risk Work completed Assurance gained & issues arising
Operating expenses Creditors understated or not • Walkthrough of operating expenses system, updating our Our work in this area is still on-going. Based on our work recorded in the correct period understanding to date we have not identified any material issues • Review and test the year end creditors control account against the risk identified. reconciliation. • Test a sample of transactions at the year end to confirm they are accounted for in the correct period (cut-off testing) • Review your accruals policy and confirm that it has been properly applied
Employee remuneration Employee remuneration Walkthrough payroll system, updating our understanding We have completed our work in this area and we have accrual understated Reconciliation of payroll to the General Ledger (for not identified any material issues against the risk completeness) identified Undertake analytical procedures e.g. trend analysis Test a sample of transactions at the year end to confirm they are accounted for in the correct period (cut-off testing)
Welfare expenditure Welfare benefit expenditure Our work to certify your Housing and Council Tax Our work in this area is still on-going improperly computed benefits claim will give us assurance over the accuracy of your financial statements We reviewed the reconciliation between your financial statements and the Housing benefits claim
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 10 Significant findings (continued) Audit findings DRAFT Audit findings against other risks In this section we detail our response to the other risks of material misstatement which we identified in the Audit Plan. Recommendations, together with management responses, are attached at Appendix A.
Transaction cycle Description of risk Work completed Assurance gained & issues arising
Property, plant and Revaluation measurements We carried out a walkthrough of the system for PPE Our work in this area is substantially complete. equipment (PPE). not correct valuations Our work to date has highlighted a number of We substantively tested the accounting entries for PPE classification and disclosure issues with the treatment of valuations to underlying records Property Plant and Equipment, however these do not We reviewed the reconciliation between the general affect the overall financial position. ledger and fixed asset register We wrote to the external valuer to establish the scope and basis of valuations work for the 2014/15 financial statements. We reviewed the valuations information in your financial statements to confirm they have been accounted for correctly, in line with the Local Government Code of Accounting and accounting standard IAS16. We considered the reasonableness of your valuations information by reference to valuation trend data provided by the auditor's expert.
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 11 Significant findings - significant matters discussed Guidance note with management Audit findings DRAFT This section addresses the requirement under ISA 260.16 to communicate with those Significant matters discussed with management charged with governance 'significant matters, if any, arising from the audit that were discussed or subject to Significant matter Commentary correspondence with management ' 1. Accounting for schools The Council carried out a review of its accounting for schools, in response to new guidance issued during the year by The items suggested are those CIPFA. As part of this exercise the Council reviewed the accounting treatment of all maintained schools in the Borough included as examples in ISA and a result of this review the Council decided to remove four schools from its balance sheet. 260.A19. The Council provided us with insufficient evidence to support this judgement and there was also very little commentary These examples should be on it within the financial statements. Following further discussion, management have agreed to provide further amended and tailored to reflect justification of the decision to reclassify the schools and to make additional disclosure of this in the financial statements. the particular matters relevant to the individual audit, e.g. you may The financial statements show a significant reduction in the net book value of other land and buildings compared with want to include discussions on the prior year. The derecognition of schools is a significant factor in this. fixed asset valuations or PPE capitalisation if these have been Where there is a change of accounting policy which has a material effect, as in this case, accounting standard IAS8 topics for debate during the requires a prior period adjustment so that the accounts are comparable year on year. audit We have discussed this with management who have agreed to make the relevant PPA to the treatment of schools. Red text is generic and should be updated specifically for your We are still completing our work on operating expenses, which includes the income and expenditure relating to client. schools. Once updated, change text colour back to black.
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | Date 12 Significant findings – accounting policies# Audit findings DRAFT Accounting policies, estimates & judgements
In this section we report on our consideration of accounting policies, in particular revenue recognition policies, and key estimates and judgements made and included with the Council's financial statements.
Accounting area Summary of policy Comments Assessment
Revenue recognition The Council's accounting policy is to We did not identify any issues with this policy or with the application recognise income " from the provision of of the policy. services or sale of goods is recognised However we noted that the Council's policies do not cover non when it is probable that the economic exchange transactions (principally council tax and NNDR) and we benefits or service potential associated asked the Council to include a separate policy on this. with the transaction will be received by the Council "
Estimates and judgements Key estimates and judgements are We reviewed the Council's material accounting estimates. • accruals We reviewed a sample of accruals and found these to be fairly • useful life of capital equipment stated. • pension fund valuations and We reviewed the valuation estimates made by the Council's valuer. settlements The Council has engaged a new valuer this year. As a result of different valuation methodologies some valuations have significantly • revaluations reduced compared with the previous year. We have selected • Impairments example assets to confirm that the methods are reasonable and are still discussing this with management. • PPE valuations. We noted that there are two schools which were not revalued in
year, so that the Council did not fully comply with the requirement to revalue all assets in a class simultaneously. However we do not consider that this would have a material impact on the accounts. We confirmed that pension fund valuations in the accounts are based on the actuary's report and are in line with our expectations.
Assessment Marginal accounting policy which could potentially attract attention from regulators Accounting policy appropriate but scope for improved disclosure Accounting policy appropriate and disclosures sufficient
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | Date 13 Significant findings – accounting policies# Audit findings DRAFT Accounting policies, estimates & judgements continued
Accounting area Summary of policy Comments Assessment
Judgements - local authority In 2014 CIPFA published its LAAP The Council provided limited information to justify its decision to maintained schools premises bulletin 101 on the accounting derecognise the schools in question treatment of schools. After Following further discussions the Council has provided further information reviewing the treatment of all in support of its judgement, and to document the reason for this as part of schools the Council decided it was the critical judgements disclosure in the financial statements appropriate to remove four schools from its balance sheet.
Going concern The Directors have a reasonable The Council has not formally documented its judgement on going concern. expectation that the services provided The Council has recently published its medium term financial strategy by the Council will continue for the setting out how it plans to meet its financial challenges over the next five foreseeable future. For this reason, years. We consider it reasonable that the Council prepares its statements they continue to adopt the going on a going concern basis. We have requested a statement on going concern basis in preparing the concern is included in the financial statements. financial statements.
Other accounting policies We have reviewed the Council's Our review of accounting policies has not highlighted any issues which we policies against the requirements of wish to bring to your attention the CIPFA Code and accounting standards.
Assessment Marginal accounting policy which could potentially attract attention from regulators Accounting policy appropriate but scope for improved disclosure Accounting policy appropriate and disclosures sufficient
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | Date 14 Other communication requirements# Audit findings DRAFT Other communication requirements
We set out below details of other matters which we are required by auditing standards to communicate to those charged with governance.
Issue Commentary
1. Matters in relation to fraud We have received letters from management and from the Chair of the Audit Panel outlining the Council's arrangements to identify and minimise fraud.
2. Matters in relation to laws and We are not aware of any significant incidences of non-compliance with relevant laws and regulations. regulations
3. Written representations A standard letter of representation has been requested from the Council.
4. Disclosures Our review found no significant omissions in the financial statements over and above those mentioned elsewhere in this report
5. Matters in relation to related In our view the related parties disclosure in note 31 of the draft financial statements did not meet the requirements of the Code, in parties that material related party transactions should be disclosed in the financial statements. We discussed this with management, who have agreed to extend the note by disclosing those transactions they consider to be material.
6. Confirmation requests from We have requested direct confirmations of loans, cash and investment balances. third parties Most responses have now been obtained however in some cases we are still chasing responses or are performing alternative audit procedures to gain our assurance.
7. Annual Governance Statement • We have reviewed the Council's annual governance statement, which is published alongside the statement of accounts. • The original annual governance statement made no mention of control issues which had arisen during the year. Following discussion management agreed to add additional context to the AGS.
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 15 Internal controls
Audit findings DRAFT Guidance note Issue and risk must include a description of the deficiency and an explanation of its potential Internal controls effect. In explaining the potential effect it is not necessary to quantify.
The purpose of an audit is to express an opinion on the financial statements. Red text is generic and should Our audit included consideration of internal controls relevant to the preparation of the financial statements in order to design audit procedures that are appropriate in be updated specifically for your the circumstances, but not for the purpose of expressing an opinion on the effectiveness of internal control. We considered and walked through the internal controls client. Once updated, change text for Employee Remuneration, Property Plant and Equipment, welfare benefits and Operating Expenses. colour back to black. The matters that we identified during the course of our audit are set out in the table below. These and other recommendations, together with management responses, are included in the action plan attached at Appendix A.
Assessment Issue and risk Recommendations
1. In our audit plan we reported that reconciliations of bank Carry out and retain evidence of key financial reconciliations on a monthly basis accounts and key financial systems were not taking place on a regular or timely basis. Management subsequently updated the reconciliations to the year end.
2. We reviewed the migration of ledger information to the new oracle R12 shared ledger. We did not identify any issues with the completeness of the data. However we noted that the Council did not retain full evidence over the migration at the time that it happened. There was no internal audit coverage of the data migration. During much of 2014/15 the Council was operating under interim arrangements for internal audit. However the Council has subsequently brought its coverage up to date.
Assessment Significant deficiency – risk of significant misstatement Deficiency – risk of inconsequential misstatement
The matters reported here are limited to those deficiencies that we have identified during the course of our audit and that we have concluded are of sufficient importance to merit being reported to you in accordance with auditing standards.
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 16 Internal controls
Audit findings DRAFT Guidance note Issue and risk must include a description of the deficiency and an explanation of its potential Internal controls (continued) effect. In explaining the potential effect it is not necessary to quantify.
Red text is generic and should Assessment Issue and risk Recommendations be updated specifically for your client. 3. As part of our audit we carried out a high level review of IT Management should review and respond to the detailed findings of our IT controls review arrangements at the new ledger shared services provider. and ensure there is adequate and timely audit coverage of IT controls at the shared Once updated, change text service provider. colour back to black. We identified a number of control weaknesses. Similar issues were raised by internal audit in their review of the ledger. We have shared the detailed findings with management. Key issues highlighted were as follows. • We identified seven accounts with default passwords • Excessive number of system administrators • Multiple users for the same person • Some individuals have excessive access levels • Weak and inconsistent password policies • Lack of segregation of duties • Incomplete logging of activity • Access rights that are not linked to an individual • Access rights are not formally reviewed for appropriateness
Assessment Significant deficiency – risk of significant misstatement Deficiency – risk of inconsequential misstatement
The matters reported here are limited to those deficiencies that we have identified during the course of our audit and that we have concluded are of sufficient importance to merit being reported to you in accordance with auditing standards.
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 17 Adjusted misstatements Audit findings DRAFT Guidance note The table is available in the ‘Audit Findings template’ on the Mercury tab in Excel. Adjusted misstatements Tab: Adjusted misstatements
A number of adjustments to the draft financial statements have been identified during the audit process. We are required to report all non-trivial misstatements to those charged with governance, whether or not the financial statements have been adjusted by management. The table below summarises the adjustments arising from the audit which have been processed by management.
Impact of adjusted misstatements All adjusted misstatements are set out below along with the impact on the primary statements and the reported financial position. Detail Comprehensive Income Balance Sheet Impact on total net and Expenditure £'000 expenditure Account £000 £'000 1 Incorrect classification of income relating to the Glass Mill 24,065 0 0 Centre on the face on the income and expenditure statement 2 expenditure relates to schools which have been removed from 0 3,582 0 the Council's balance sheet and therefore should be treated as REFCUS
Overall impact £24,065 £3,582 £0
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 18 Adjusted misstatements Audit findings DRAFT Guidance note The table is available in the ‘Audit Findings template’ on the Mercury tab in Excel. Unadjusted misstatements Tab: Adjusted misstatements
We did not identify any significant misstatements which the Council has declined to amend.
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 19 Adjusted misstatements Audit findings DRAFT Guidance note The table is available in the ‘Audit Findings template’ on the Mercury tab in Excel. Misclassifications & disclosure changes Tab: Adjusted misstatements
The table below provides details of misclassification and disclosure changes identified during the audit which have been made in the final set of financial statements.
Adjustment Value Account balance Impact on the financial statements type £'000 1 Misclassification 2,016 Note 14 - Cash and A misclassification within note 14 to the financial statements which does cash equivalents not affect the balance sheet totals 2 Misclassification 6,876 Note 19 – Revaluation A misclassification between impairments and revaluations within the reserve revaluation reserve 5 Misclassification 5,611 Note 32 – Asset Misclassification within note 32 between REFCUS and PPE additions financing 6 Disclosure TBC Accounting for schools The de-recognition of schools is a change in accounting policy which should give rise to a prior period adjustment 7 Misclassification Various Note 9b Property, Management identified and made 17 classification adjustments within note plant and equipment 9b subsequent to submitting the draft accounts. 8 Disclosure Various We identified a number of minor typos, arithmetic and consistency issues which management has agreed to correct 9 Misclassification 1,693 Note 29 grant revenues Difference between the value in note 29 and the Housing and Council Tax benefits claim regarding the amount of benefits income TBC 10 Misclassification 1,310 Note 9b Note 9b includes a line entitled 'post audit adjustments'. We agreed with management that this is not an appropriate category under the Code, and management have agreed to reclassify these entries against the relevant headings. 11 Misclassification 39,199 Note 9a Classification adjustment within note 9a relates to HRA assets which were last valued in 2013/14 rather than 2014/15
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 20 DRAFT Section 3: Value for Money
01. Executive summary
02. Audit findings
03. Value for Money
04. Fees, non-audit services and independence
05. Communication of audit matters
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 Value for Money DRAFT Value for Money
Value for money conclusion The Code of Audit Practice 2010 (the Code) describes the Council's The Council faces significant challenges in respect of its arrangements for financial responsibilities to put in place proper arrangements to: strategy, governance and control. The Council has significant budget overspends at • secure economy, efficiency and effectiveness in its use of resources; service level in 2014/15 and 2015/16. The Council will also need to identify and • ensure proper stewardship and governance; and realise significant savings in 2016/17 and subsequent years to maintain a resilient • review regularly the adequacy and effectiveness of these arrangements. financial position. Overall our view is that the Council is managing those risks appropriately and has adequate arrangements for securing financial resilience. We are required to give our VfM conclusion based on two criteria specified by the Audit Commission which support our reporting responsibilities under the Code. Challenging economy, efficiency and effectiveness We have considered the Council's arrangements to challenge economy, efficiency These criteria are: and effectiveness against the following themes: The Council has proper arrangements in place for securing financial • Prioritising resources resilience - the Council has robust systems and processes to manage effectively • Improving efficiency & productivity financial risks and opportunities, and to secure a stable financial position that enables it to continue to operate for the foreseeable future. Overall our work highlighted adequate arrangements in place to challenge economy, efficiency and effectiveness. We noted one area of risk relating to the The Council has proper arrangements for challenging how it secures Council's ability to understand the impact that headcount reductions and economy, efficiency and effectiveness - the Council is prioritising its resources transitioning to new roles may have on financial management. within tighter budgets, for example by achieving cost reductions and by improving efficiency and productivity. Overall VfM conclusion On the basis of our work, and having regard to the guidance on the specified Key findings criteria published by the Audit Commission, we are satisfied that in all significant Securing financial resilience respects the Council has put in place proper arrangements to secure economy, We have undertaken a review which considered the Council's arrangements against efficiency and effectiveness in its use of resources for the year ending 31 March the three expected characteristics of proper arrangements as defined by the Audit 2015. Commission: • Financial governance; • Financial planning; and • Financial control.
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 22 Value for Money DRAFT
We set out below our detailed findings against six risk areas which have been used to assess the Council's performance against the Audit Commission's criteria. We summarise our assessment of each risk area using a red, amber or green (RAG) rating, based on the following definitions:
Green Adequate arrangements Amber Adequate arrangements, with areas for development Red Inadequate arrangements
The table below summarises our overall rating for each of the themes reviewed. Those areas rated amber are explored in more detail in the pages which follow.
Theme Summary findings RAG rating
Key indicators of performance The Council set a balanced budget for 2014/15 and for 2015/16. However, there was an overspend of £9.1 million on Amber revenue budgets in 2014/15 which was mitigated by use of contingencies and reserves. While reserve levels have seen a net increase over the last two years, this is unlikely to be sustainable from 2015/16 onwards. Strategic financial planning The Council is also forecasting a budget overspend for 2015/16. Arrangements around strategic financial planning are Amber generally adequate, although key financial assumptions around the demand for services require greater challenge and consideration of adverse scenarios and there is further scope to anticipate the risks associated with the financial performance of key partners. Financial governance In 2014/15 the Council engaged in a peer review, which commented positively on the Council's governance Green arrangements. The Council is developing its strategy to focus more on the development of Place and to strengthen the performance management of senior officers. This will be important in the context of securing financial resilience. Financial control 2014/15 has seen a number of significant changes including a restructuring of the finance team, migration to a new Amber ledger and a change of internal audit provider. During this period a number of risks around financial control have been highlighted which the Council needs to address. Prioritising resources Arrangements around prioritising resources are generally adequate, however there is evidence that reductions in Green headcount and the subsequent transfer of responsibilities has contributed to a number of financial control issues. There is a risk that current arrangements do not adequately manage the risk to operational performance posed by implementing savings plans and the voluntary redundancy process.
Improving efficiency & productivity Arrangements around improving efficiency and productivity were found to be adequate and we noted that although the Green Council delivers some services at a higher cost to many of its peers, it has made good use of benchmarking in these areas to drive savings plans.
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To support our VfM conclusion against the specified criteria we performed a risk assessment against VfM risk indicators specified by the Audit Commission. and additional indicators identified by ourselves. Following completion of our work we noted the following residual risks to our VfM conclusion:
Residual risk identified Summary findings RAG rating
Key indicators of performance: The Council has had significant issues in 2014/15 with over-spending against budgets within the services. The Performance against budgets directorates’ net general fund revenue budget was overspent by £9.1m and after applying the corporately held sum of (Revenue Capital & Savings) £3.9m for ‘risks and other pressures’ this reduced the overspend to £5.2m.The remaining overspend has been covered by underspends elsewhere in the budget and reserves.
Key overspending areas were
• £10.2m, mainly in respect of clients with ‘no recourse to public funds’, including bed & breakfast temporary accommodation. • £3.1m on budgets relating to bed and breakfast accommodation, caused by a significant increase in the number of people in this type of accommodation. Amber • Net overspends were also caused by the underperformance of parking and environment income Overspends were partly mitigated by underspends in the Community Services (£2.3m) and Resources and Regeneration (£2.1m) directorates. While the Council was able to mitigate the overspends in 2014/15, this outcome adds to the recurring pressure on future years' budgets and is unlikely to be sustainable in the longer term. The outcome in terms of financial performance presents a risk to financial resilience.
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 24 Value for Money DRAFT
To support our VfM conclusion against the specified criteria we performed a risk assessment against VfM risk indicators specified by the Audit Commission. and additional indicators identified by ourselves. Following completion of our work we noted the following residual risks to our VfM conclusion:
Residual risk identified Summary findings RAG rating
Key indicators of performance: The Council has been able to increase its total level of useable reserves in each of the past two years (13% and 22% Reserves balances respectively), strengthening its ability to use reserves to manage financial shocks, including budget pressures and the risk of savings plans not being delivered. However, the total level of reserves remains low in comparison to other councils of a similar size and demographic profile. Within the 2014/15 Budget, the Council had to make use of £6.3m of one-off reserves and provisions in order to achieve a Balanced Budget for 2014-15. The Council again drew on £10m of reserves to set a balanced budget for 2015/16. We recognise that the use of reserve is a managed process and Earmarked reserves (excluding schools balances) actually increased by £4.6m in the year to March 2015, primarily due to £6.6m of unused new homes bonus monies received in year. The Council has not yet had to resort to a significant unplanned drawdown of reserves – the significant budget overspends reported in 2014/15 were able to be covered by a combination of in year budgeted contingencies (including Amber the use of earmarked reserves), budget underspends and unbudgeted income within the net resource position for the year (including New Homes Bonus monies). However, if significant budget overspends continue for 2015/16 and beyond reserve levels are likely to decrease in future years. The Council needs to identify a further £45m of savings in the period leading up to 2017-18, and should significant shortcomings be identified in this process, the ability of the Council to use reserves to maintain financial balance beyond this point would be limited. Beyond this point, the Council is looking London wide service transformation as part of the devolution agenda to provide financial sustainability as are many of its peers.
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 25 Value for Money DRAFT
To support our VfM conclusion against the specified criteria we performed a risk assessment against VfM risk indicators specified by the Audit Commission. and additional indicators identified by ourselves. Following completion of our work we noted the following residual risks to our VfM conclusion:
Residual risk identified Summary findings RAG rating
Key indicators of performance: 2015/16 Performance against budgets A forecast year end overspend of £8.6m is being reported as at the end of May 2015. At the same time last year, an (Revenue Capital & Savings) overspend of £11.2m was forecast. For 2015/16 there is a sum of £3.2m held corporately for managing ‘risks and other budget pressures’ which emerge during the year. Although similar to the scale of the variances projected (and realised) in 2014/15, the current overspending projections are significantly greater than those in recent earlier years. The forecast overspend is partly mitigated by a projected underspend of £1.1m in the Resources & Regeneration directorate. As at the end of May 2015, the children and young people’s directorate is forecasting an overspend of £4.7m. At the same time last year, the year-end forecast was an overspend of £8.1m, with the actual year-end outturn being an overspend of £9.9m. For clients with no recourse to public funds, there is cost pressure of £1m but this is being addressed by improved management arrangements. The placement budget for looked after children is currently forecast to over spend by £1.7m. Total revenue budget savings on the placement budget of £1.5m were agreed for 2015/16 but the work to implement these savings has been delayed due to staff changes. It is expected that some savings will be generated, but only toward the end of the financial year, with the full year effect likely to come through in 2016/17. Children leaving care is currently forecast to overspend by £1m due to levels of demand above what had been anticipated. As at the end of May 2015, the community services directorate is forecasting an overspend of £2.0m. At the Amber same time last year, the year-end forecast was an overspend of £1.1m, with the actual year-end outturn being an underspend of £2.3m. The forecasts include the drawdown of £0.6m from earmarked reserves which had been created at the end of 2014/15 from underspends in that year. The adult services division is forecast to overspend by £1.9m. This projection assumes achievement later in the year of revenue budget savings of £1m in addition to savings already achieved and includes use of non-recurrent funding totalling £1.3m. At the end of the last financial year, adult services overspent by £2m. There are a number of over and underspends forecast against individual services within adult social care. The key issues are due to savings not being realised with full year effect due to delays in reviewing individual care packages. The impact of delayed achievement has been partially offset in 2015/16 by use of non-recurrent funding received from health of £1.25m. The underlying overspend, excluding this one-off support, is £3.1m. As at the end of May 2015, the customer services directorate is forecasting an overspend of £3m. At the same time last year, the year-end forecast was an overspend of £2.2m, with the actual year-end outturn being an overspend of £3.6m.Within this, the strategic housing service is projecting an overspend of £2.4m relating solely to nightly paid temporary accommodation, more commonly referred to as bed and breakfast. The Council has plans in place to manage this cost pressure by addressing the charging of excessive rents by providers and by reviewing the supply of places.
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 26 Value for Money DRAFT
Residual risk identified Summary findings RAG rating
Strategic financial planning: The Chancellor has asked unprotected central government departments to look at scenarios for a 25% and a 40% Focus of the MTFP reduction. Lewisham has modelled the impact this would have if applied to their own grant funding. It has used London Councils benchmarking to look at a range of funding deficit options for Lewisham that range from £25m to £150m up to 2020. The Council has modelled the Medium Term Financial Strategy (MTFS) at the upper mid-range giving a revised projected deficit of £80m. However, it will not be able to confirm this until the announcement in December. Therefore the Council is continuing to focus on the £45m projected deficit remaining from the current MTFS. The upper mid range Amber scenario would require a further £35m of savings to be found, in addition to the £45m currently being developed. This would be likely to require significant financial benefits to be derived from London wide reconfiguration of services under the devolution agenda. This creates a significant degree of uncertainty over the longer term financial position.
Strategic financial planning: In 2014/15 budget assumptions around Non-recourse to public funds, the cost of children's social care packages and Adequacy of planning the cost of and demand for temporary accommodation did not anticipate the full cost of and demands for these services. assumptions The cost of care packages in adult's social care has increased above the levels assumed in the budget. One source of overspend was the failure of one of the key providers who became insolvent. The Council believe this could not reasonably be anticipated and occurred relatively suddenly. The Care Quality Commission (CQC) rated the Ranyard Care Home in Lewisham as inadequate in 2014 and despite progress being made the provider was unable to attract enough residents back to remain solvent. This meant that in July the Council had to incur costs to relocate its residents and manage the backlog of capacity this created. The Council should consider the extent to which the organisation identifies and monitors the financial position of its key strategic providers, including accounting for the potential impact of adverse CQC inspections, to ensure that potential financial failure can be anticipated and mitigated to minimise the impact on the Council's financial plans. Lewisham is leading on a joint borough piece of work to tackle the issue of the rising cost of social care cases for foreign nationals with no-recourse to public funds, and some funds have now been received to facilitate this. The pilot Amber work done so far has helped to slow the acceptance of new claimants and this in turn has freed up time to go back and re-evaluate previous claims. The result has been that during 2015/16 the inflow of new cases is no longer growing and is gradually coming down. At Lewisham the problem is now being better managed and the 2015/16 budget has been flexed to ensure that additional funds are available to deal with demand. Better management of temporary accommodation placements has also helped ease the problem. For clients with no recourse to public funds, the Council identified a cost pressure of £1m for 2015/16. There were 236 clients with no recourse to public funds against a peak of 286 in June 2014 indicating that the new arrangements have been successful in managing the level of exposure. The estimated cost to the end of year 2015/16 was £4.6m. The pilot team has been working with the Home Office to obtain additional financial resources granted for cases the council is supporting (102 cases have so far been granted the required change of status). The full year impact, once all of these cases have been transitioned is estimated at £2.5m per annum. It is anticipated that it takes an average of four to five months to ensure that a comprehensive resettlement process is completed. Once the full year impact of this is seen in 2016/17, it is expected that spend will fall back within the current budgeted level of £3.6m.
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 27 Value for Money DRAFT
Residual risk identified Summary findings RAG rating
Financial Control: The finance team was reduced following a review in 2012/13 and benchmarking carried out by the Council shows that Finance department resourcing the team is below the average in terms of capacity compared to other London Councils. While the team has sufficient capacity to deal with the day to day operations – there is a risk that there is limited spare capacity for one off projects or significant absences. The experience with implementing the new Oracle system highlighted this problem putting pressure on financial control and contributing to adverse findings on a number of core financial control systems reviewed by internal audit. Amber The Council should consider whether the finance team has adequate capacity including to support project work alongside routine processes, and ensure that identified financial control weaknesses are quickly and effectively mitigated.
Financial Control: As noted previously, significant overspends against budget have arisen in some services, in both 2014/15 and 2015/16. Budget setting & monitoring - This is partly due to uncertainties within the related key financial assumptions, linked to the demand for services. In revenue & capital addition, there have been issues with the way that the benefits of savings plans have been phased into the budget (explored below). In both cases budget holders should ensure that the budget is based on robust financial assumptions and the finance team should support them in this. This in turn should enable budget holders to be effectively held to account for delivering significant overspends. Amber We note that the internal audit review of budgetary control was rated satisfactory for 2014/15. Directorate Expenditure Panels (DEPs) have been in operation throughout 2014/15, with the Corporate Expenditure Panel (CEP) becoming operational in October 2014. This ensures regular corporate oversight of the Council’s financial spending position and effective mitigating action. Subject to a review by the Chief Executive and the Executive Director for Resources and Regeneration, the CEP is expected to remain in operation until the need for this level of scrutiny has subsided.
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 28 Value for Money DRAFT
Residual risk identified Summary findings RAG rating
Financial Control: It is common practice for councils to identify a funding gap over the life of the Medium term financial strategy, and to Savings plans setting & allocate a savings requirement to each year. It is also common practice to develop specific savings schemes in detail in monitoring the year preceding, that from which the saving needs to be stripped out of the budget. This enables costs to be stripped out of the budget from day one of the financial year in question. While it is acceptable to develop detailed schemes one year at a time, it is expected that the organisation will have established a broad strategy for savings reduction over the life of the MTFS enabling it to set in train longer term transformational projects. Lewisham has consistently met this criteria. However, there has been an issue in 2014/15 with the phasing of benefits. The full year effect of some savings schemes expected to be delivered by 1st April 2015 were stripped from the budget from the start of the new year 2015/16. However, a number of schemes had not been fully delivered by this point so the full year effect of the saving was not realised from the start of 2015/16 as had been assumed in the budget. This is principally a timing issue meaning that some residual unbudgeted costs are having to be incurred in the first part of the year. The Council has recognised that this was a weakness in the budget setting process and plans to prevent this from happening in the planning for the 2016/17 budget, by ensuring that there is greater clarity over the phasing of savings between budget holders and the corporate finance team. In adult and children's social care, although there are some demographic pressures, the continuing budget overspends are largely as a result of delayed achievement of savings proposals. Savings totalling £7.5m were agreed for adult Amber social care for 2015/16 and these are in addition to the revenue budget savings of £6.8m agreed for 2014/15. In most cases, the savings schemes are being implemented, but the full year impact will take some months to come through because it requires a review of individual care packages which is not yet complete. Ensure the phasing of approved savings plans is realistic and accurately reflected in budgets The Council is continuing with its current stretch target to make £45m of savings over the next two years to 2017/18. However, this has proved difficult as the options to change services at the scale and in the timeframes available that also bring service users and staff along the journey is very challenging, given the efficiency savings already delivered since 2010. Under the current savings programme £26m of the £45m gap remaining has been matched to defined projects and presented to the Mayor for approval in September 2015, comprising £12m for 2016/17 and £14m for 2017/18. Up to £5m of new homes bonus money has also been secured that could be deployed to help close the gap(£10m over 2 years). The Council has brought forward the approval of savings plans to be stripped out of the 2016/17 budget from November (as last year) to September to enable the ground-work to start earlier and provide an earlier planning horizon. Further work is required to develop savings to cover the remaining financial gap.
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 29 Value for Money DRAFT
Residual risk identified Summary findings RAG rating
Financial Control: The Head of Internal Audit opinion for 2015/16 is unqualified. However, there had been a significant increase in the Key financial accounting number of reported weaknesses in the core financial systems. The Oracle finance system implementation had been systems problematic, contributing to the number of financial control issues being reported. We note that the risk associated with the transitional internal audit arrangements which meant there was limited coverage for much of the year, has now been mitigated. However, the completion of the work has raised concerns Amber about a number of core financial systems linked to the Oracle IT implementation and the change in banking arrangements. We note that 6 out of 16 reviews of core financial systems were given limited assurance. While none of the findings are in themselves material to VfM, the prevalence of financial control issues presents a risk that could affect the Council's ability to effectively manage its finances in future, if not effectively addressed.
Financial Control: We noted that the Council had limited internal audit coverage in place for a significant part of 2014/15, due to issues Adequacy of Internal audit with the transfer to a new external supplier. This resulted in some significant delays to the production of internal audit arrangements reports and their availability of timely reporting to those charged with governance during the year. The Council has been able to successfully introduce a new supplier and has now cleared the backlog of work. Internal Audit's work has highlighted a number of control issues that could have been identified and rectified sooner, had adequate internal audit arrangements been in place. We are satisfied that the issue has now been addressed and should not recur in 2015/16 providing that the new arrangements embed effectively. Amber As in previous years the Head of Corporate Resources signs the Head of Internal Audit opinion and oversees internal audit activity, in addition to holding extensive management responsibilities. The Council has mitigating arrangements in place to maintain the independence and objectivity of internal audit, but should continue to keep the arrangements under review for assurance that they remain appropriate.
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 30 Value for Money DRAFT
Residual risk identified Summary findings RAG rating
Prioritising Resources: There is no directly attributable correlation between the level of voluntary redundancies and the difficulties the Council Understanding impact and experiences in delivering savings plans and budget in 2014/15 and 2015/16, or in the difficulties with core financial outcome of decisions controls. However, it is likely that reductions in headcount in the services and in finance has affected the Council's level of spare capacity to deliver project based transformation of services (including savings plans) on the current large scale, alongside business as usual. There has also been some knowledge loss and weaknesses in the handover of responsibilities that have been identified as key cause of some of the financial control weaknesses identified by internal audit.
The Council has identified that the lack of a formal service planning exercise for 2015/16 has weakened its ability to Amber identify and monitor operational risks, including the impact of staff reductions. Changes to service representatives in the Risk Management Working Party (RMWP) has further weakened the process. The impact that staff reductions and other savings schemes have on operational capacity needs to be carefully monitored, with flexible project support resources made available for deployment on a short term basis to those areas that are having acute difficulty with capacity.
Improving Efficiency & VfM benchmarking against nearest neighbours indicates that Lewisham's corporate services are below average cost, Productivity: but are above average for some services - including social care – however, this must be considered alongside the fact that Lewisham have comparatively high levels of deprivation particularly when compared to London as a whole. Understanding costs The council is aware of its comparative cost profiles and uses these in its transformational planning. Social care is a key Amber area where the council is working to reduce the average cost of the service and the current benchmarking reflects their current position in progressing this transformation.
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 31 DRAFT Section 4: Fees, non-audit services and independence
01. Executive summary
02. Audit findings
03. Value for Money
04. Fees, non-audit services and independence
05. Communication of audit matters
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015
Fees, non audit services and independence DRAFT Guidance note 'Fees for other services' is to be used where we need to communicate agreed fees in Fees, non-audit services and independence advance of the audit. At the time of preparation of the Audit We confirm below our final fees charged for the audit. We have yet to complete our work on the Housing benefits claim certification and the fee quoted is the scale fee Plan it is unlikely that full notified by Public Sector Audit Appointments. information as to all fees charged by GTI network firms The Council has requested that we carry out the certification of grant claims for Teachers pension, housing capital receipts and decent homes. We will undertake this work in will be available. Disclosure of October / November these fees, threats to independence and safeguards Fees will therefore be included in the Audit Findings report. Per Audit plan Actual fees Independence and ethics £ £ We confirm that there are no significant facts or matters that impact on our Red text is generic and should Council audit 255,044 255,044 independence as auditors that we are required or wish to draw to your attention. We be updated specifically for your Grant certification on behalf of 39,980 TBC have complied with the Financial Reporting Council's Ethical Standards and client. Audit Commission therefore we confirm that we are independent and are able to express an objective Once updated, change text Total audit fees 295,024 TBC opinion on the financial statements. colour back to black. We confirm that we have implemented policies and procedures to meet the requirements of the Auditing Practices Board's Ethical Standards.
Fees for other services
Service Fees £
Audit related services TBC Teachers Pension, housing pooling claim and Decent homes funding
Non audit related services Review of PFI models 10,000
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 33 DRAFT Section 5: Communication of audit matters
01. Executive summary
02. Audit findings
03. Value for Money
04. Fees, non-audit services and independence
05. Communication of audit matters
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 Communication of audit matters DRAFT Communication of audit matters to those charged with governance
Audit Audit International Standard on Auditing ISA (UK&) 260, as well as other (UK&I) ISAs, Our communication plan Plan Findings prescribe matters which we are required to communicate with those charged with Respective responsibilities of auditor and management/those governance, and which we set out in the table opposite. charged with governance The Audit Plan outlined our audit strategy and plan to deliver the audit, while this Audit Findings report presents the key issues and other matters arising from the audit, together Overview of the planned scope and timing of the audit. Form, timing with an explanation as to how these have been resolved. and expected general content of communications Views about the qualitative aspects of the entity's accounting and financial reporting practices, significant matters and issues arising Respective responsibilities during the audit and written representations that have been sought The Audit Findings Report has been prepared in the context of the Statement of Confirmation of independence and objectivity Responsibilities of Auditors and Audited Bodies issued by the Audit Commission (www.audit-commission.gov.uk). A statement that we have complied with relevant ethical requirements regarding independence, relationships and other We have been appointed as the Council's independent external auditors by the Audit matters which might be thought to bear on independence. Commission, the body responsible for appointing external auditors to local public bodies in England. As external auditors, we have a broad remit covering finance and Details of non-audit work performed by Grant Thornton UK LLP and governance matters. network firms, together with fees charged Our annual work programme is set in accordance with the Code of Audit Practice (the Details of safeguards applied to threats to independence Code) issued by the Audit Commission and includes nationally prescribed and locally Material weaknesses in internal control identified during the audit determined work. Our work considers the Council's key risks when reaching our conclusions under the Code. Identification or suspicion of fraud involving management and/or It is the responsibility of the Council to ensure that proper arrangements are in place for others which results in material misstatement of the financial the conduct of its business, and that public money is safeguarded and properly statements accounted for. We have considered how the Council is fulfilling these responsibilities. Compliance with laws and regulations Expected auditor's report Uncorrected misstatements Significant matters arising in connection with related parties Significant matters in relation to going concern
Matters in relation to the Group audit, including: Scope of work on components, involvement of group auditors in component audits, concerns over quality of component auditors' work, limitations of scope on the group audit, fraud or suspected fraud [delete if N/A]
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 35 Appendices DRAFT
Appendices
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 36 Appendices DRAFT Appendix A: Action plan
Rec Implementation date & No. Recommendation Priority Management response responsibility
Review and improve arrangements for capital accounting, to Medium minimise errors in this area
Carry out and retain evidence of key financial reconciliations Medium on a monthly basis
Management should review and respond to the detailed Medium findings of our IT controls review and ensure adequate internal audit coverage at the shared service provider.
Consider the extent to which the Council identifies and Medium monitors the financial position of its key strategic providers
Consider whether the finance team has adequate capacity Medium including to support project work alongside routine processes, and ensure that identified financial control weaknesses are quickly and effectively mitigated
Ensure the phasing of approved savings plans is realistic Medium and accurately reflected in budgets
Monitor the impact of service changes and staff reductions, Medium possibly including flexible project support resources for deployment on a short term basis to those areas that are having acute difficulty with capacity.
Priority High, Medium or Low
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 37 Audit opinion – option 1 Appendices DRAFT Guidance note Red text is generic and should be updated specifically for your client. Appendix B: Audit opinion Once updated, change text colour back to black.
We anticipate we will provide the Council with an unmodified audit report Please choose option 1, 2 or 3 and delete the slides that are not required.
INSERT FULL TEXT OF THE PROPOSED OPINION BASED ON THE TEMPLATE AVAILABLE FROM THE AUDIT LIBRARY
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 38 Audit opinion – option 1 Appendices DRAFT Guidance note Red text is generic and should be updated specifically for your client. Once updated, change text colour back to black.
Please choose option 1, 2 or 3 and delete the slides that are not required.
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 39 Back page DRAFT
© 2015 Grant Thornton UK LLP. All rights reserved. 'Grant Thornton' means Grant Thornton UK LLP, a limited liability partnership. Grant Thornton is a member firm of Grant Thornton International Ltd (Grant Thornton International). References to 'Grant Thornton' are to the brand under which the Grant Thornton member firms operate and refer to one or more member firms, as the context requires. Grant Thornton International and the member firms are not a worldwide partnership. Services are delivered independently by member firms, which are not responsible for the services or activities of one another. Grant Thornton International does not provide services to clients. grant-thornton.co.uk
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 Cover page DRAFT This version of the report is a draft. Its contents and subject matter remain under review and its contents may change and be The Audit Findings expanded as part of the finalisation of the report. for Lewisham Pension Fund
Year ended 31 March 2015 September 2015
Darren Wells Director T 01293 554 120 E [email protected]
Jamie Bewick Senior Manager T 07880 456 144 E [email protected]
Pratheesh Kulendran Associate E [email protected]
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 Letter
DRAFT Guidance note Red text is generic and should be updated specifically for your client. Once updated, change text colour back to black.
The disclaimer paragraph should not be edited or removed as this is there for Councillor Klier Grant Thornton UK LLP the auditor’s protection and Gatwick office its absence could possibly Chair of Audit Panel Fleming Way, Crawley weaken our defence if a London Borough of Lewisham West Sussex complaint or claim is made. London www.grant-thornton.co.uk SE6 4RU September 2015 Dear Councillor Klier
Audit Findings for Lewisham Pension Fund for the year ending 31 March 2015 This Audit Findings report highlights the significant findings arising from the audit for the benefit of the Audit Panel, as required by International Standard on Auditing (UK & Ireland) 260. Its contents have been discussed with management. As auditors we are responsible for performing the audit, in accordance with International Standards on Auditing (UK & Ireland), which is directed towards forming and expressing an opinion on the financial statements that have been prepared by management with the oversight of those charged with governance. The audit of the financial statements does not relieve management or those charged with governance of their responsibilities for the preparation of the financial statements. The contents of this report relate only to those matters which came to our attention during the conduct of our normal audit procedures which are designed primarily for the purpose of expressing our opinion on the financial statements. Our audit is not designed to test all internal controls or identify all areas of control weakness. However, where, as part of our testing, we identify any control weaknesses, we will report these to you. In consequence, our work cannot be relied upon to disclose defalcations or other irregularities, or to include all possible improvements in internal control that a more extensive special examination might identify. We do not accept any responsibility for any loss occasioned to any third party acting, or refraining from acting on the basis of the content of this report, as this report was not prepared for, nor intended for, any other purpose. We would like to take this opportunity to record our appreciation for the kind assistance provided by the finance team and other staff during our audit. Yours sincerely
Darren Wells Chartered Accountants Grant Thornton UK LLP is a limited liability partnership registered in England and Wales: No.OC307742. Registered office: Grant Thornton House, Melton Street, Euston Square, London NW1 2EP. Director A list of members is available from our registered office. Grant Thornton UK LLP is authorised and regulated by the Financial Conduct Authority. Grant Thornton UK LLP is a member firm of Grant Thornton International Ltd (GTIL). GTIL and the member firms are not a worldwide partnership. Services are delivered by the member firms. GTIL and its member firms are not agents of, and do not obligate, one another and are not liable for one another’s acts or omissions. Please see grant-thornton.co.uk for further details.
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | Date 2 Contents DRAFT Contents
Section Page 1. Executive summary 4 2. Audit findings 7 3. Fees, non-audit services and independence 17 4. Communication of audit matters 19 Appendices Audit opinion
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 3 DRAFT Section 1: Executive summary
01. Executive summary
02. Audit findings
03. Fees, non-audit services and independence
04. Communication of audit matters
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 Overall review of financial statements Executive summary DRAFT Executive summary
Purpose of this report • review of the final version of the financial statements This report highlights the key matters arising from our audit of Lewisham Pension • obtaining and reviewing the final management letter of representation Fund's (the Fund) financial statements for the year ended 31 March 2015. It is also • updating our post balance sheet events review, to the date of signing the used to report our audit findings to management and those charged with opinion and governance in accordance with the requirements of International Standard on • final review of the Pension Fund annual report. Auditing 260 (ISA UK&I).
Under the Audit Commission's Code of Audit Practice we are required to report whether, in our opinion, the Fund's financial statements present a true and fair view of the financial position and expenditure and income for the year and whether they have been properly prepared in accordance with the CIPFA Code of Practice on Local Authority Accounting.
Introduction In the conduct of our audit we have not had to alter or change our planned audit approach, which we communicated to you in our Audit Plan dated June 2015. We received draft financial statements and accompanying working papers at the start of our audit, in accordance with the agreed timetable.
Our audit is substantially complete although we are finalising our work in the following areas: • dealing with closing queries arising from the final Engagement Lead review of the audit file.
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 5 Overall review of financial statements Executive summary DRAFT
Key issues arising from our audit Our audit is not designed to test all internal controls or identify all areas of Financial statements opinion control weakness. However, where, as part of our testing, we identify any We anticipate providing an unqualified opinion in respect of the Fund's financial control weaknesses, we report these to the Council as the administering statements. authority.
The pension fund accounts presented for audit were of a good quality overall. Findings Management engaged positively with the audit, and this assisted the audit team to complete the audit work in a significantly shorter time scale than in previous years. The Council has continued to increase its use of the Pension Fund Bank Account to include monthly reconciliations. However it is still not fully We have not identified any adjustments affecting the Fund's reported financial compliant with LGPS Regulations to use the separate account for all pensions position. However, we have agreed with officers some minor adjustments to transactions. correct misclassifications and to improve the presentation of the financial statements. Further details are provided within section two of this report.
Further details are set out in section two of this report. The way forward Matters arising from the financial statements audit have been discussed with the Controls Executive Director for Resources and Regeneration. Roles and responsibilities The Council's management is responsible for the identification, assessment, management and monitoring of risk, and for developing, operating and monitoring Acknowledgment the system of internal control. We would like to take this opportunity to record our appreciation for the assistance provided by the finance team and other staff during our audit.
Grant Thornton UK LLP September 2015
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 6 DRAFT Section 2: Audit findings
01. Executive summary
02. Audit findings
03. Fees, non-audit services and independence
04. Communication of audit matters
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 Overview of audit findings Audit findings DRAFT Audit findings
In this section we present our findings in respect of matters and risks identified We also propose to give an unqualified consistency with opinion on the at the planning stage of the audit and additional matters that arose during the financial statements in the Annual Report. course of our work. We set out on the following pages the work we have performed and the findings arising from our work in respect of the audit risks we identified in our audit plan, presented to the Audit Panel on 18 June 2015. We also set out the adjustments to the financial statements arising from our audit work and our findings in respect of internal controls.
Changes to Audit Plan We have not made any changes to our Audit Plan as previously communicated to you.
Audit opinion We provide two opinions on the Pension Fund, as follows: • an audit opinion on the Pension Fund financial statements included in the Council's Statement of Accounts • an opinion on the Pension Fund financial statements included in the Pension Fund Annual Report, which confirms if these financial statements are consistent with the financial statements in the Statement of Accounts
Our proposed audit opinion on the Pension Fund financial statements in the Statement of Accounts is set out in Appendix B.
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 8 Significant findings
Audit findings DRAFT Audit findings against significant risks "Significant risks often relate to significant non-routine transactions and judgmental matters. Non-routine transactions are transactions that are unusual, either due to size or nature, and that therefore occur infrequently. Judgmental matters may include the development of accounting estimates for which there is significant measurement uncertainty" (ISA (UK&I) 315). In this section we detail our response to the significant risks of material misstatement which we identified in the Audit Plan. As we noted in our plan, there are two presumed significant risks which are applicable to all audits under auditing standards.
Risks identified in our audit plan Work completed Assurance gained and issues arising
1. Improper revenue recognition We rebutted this presumption during the interim phase Our audit work has not identified any issues in respect Under ISA (UK&I) 240 there is a presumed risk that of the audit, and this was communicated to members of revenue recognition. revenue may be misstated due to improper as part of the audit plan. recognition
2. Management override of controls review of accounting estimates, judgements and Our audit work has not identified any evidence of Under ISA (UK&I) 240 there is a presumed risk of decisions made by management management override of controls. In particular the management over-ride of controls testing of journal entries findings of our review of journal controls and testing of journal entries has not identified any significant review of unusual significant transactions issues. We have not been made aware of, not identified any unusual significant transactions. We set out later in this section of the report our work and findings on key accounting estimates and judgments.
3. Level 3 Investments – Valuation is incorrect We identified and walked through the controls put in We reviewed the HarbourVest listed equity valuation Level 3 investments by their very nature require a place by management to ensure investments are not and also the audited accounts for each private equity significant degree of judgement to reach an materially misstated at the year end. fund to ensure reliance can be placed on the valuation appropriate valuation at year end. For a sample of investments, test valuations by of each private equity fund. obtaining and reviewing audited accounts at latest We then reconciled from the audited accounts to the fair date for individual investments and agreeing these value, taking into accounts distributions and to the fund manager reports at that date. commitments. We have also performed a reconciliation Reconciliation of those values to the values at 31st between the Custodian, the general ledger and fund March with reference to known movements in the manager reports. intervening period. Based on the work performed there are no matters To review the nature and basis of estimated values. arising which impact on the opinion.
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 9 Significant findings (continued) Audit findings DRAFT Audit findings against other risks In this section we detail our response to the other risks of material misstatement which we identified in the Audit Plan. Recommendations, together with management responses, are attached at Appendix A.
Transaction cycle Description of risk Work completed Assurance gained & issues arising
Investments Investments not valid • Walkthrough tests of controls on investments Our audit work has not identified any significant issues in • Tested a sample of purchases and sales to relation to the risks identified Valuation is incorrect confirm they are appropriate
• Tested a sample of level 2 investments to independent information from custodian/manager on units and on unit prices.
Contributions Recorded contributions not • Walkthrough tests of controls on contributions Our audit work has not identified any significant issues in correct. • We rationalised contributions received with relation to the risk identified reference to changes in member body payrolls and numbers of contributing pensioners to ensure that any unexpected trends are satisfactorily explained.
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 10 Significant findings (continued) Audit findings DRAFT Audit findings against other risks continued
Transaction cycle Description of risk Work completed Assurance gained & issues arising
Benefit payments Benefits improperly • Walkthrough tests of controls on benefits payable Our audit work has not identified any significant issues in calculated/claims liability • Controls testing over, completeness, accuracy relation to the risk identified understated and occurrence of benefit payments, • Test a sample of individual pensions in payment by reference to member files. • We will rationalise pensions paid with reference to changes in pensioner numbers and increases applied in the year to ensure that any unusual trends are satisfactorily explained.
Member data Member data not correct Walkthrough tests of controls on member data Our audit work has not identified any significant issues in Sample testing of changes to member data made relation to the risk identified during the year to source documentation
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 11 Significant findings – accounting policies# Audit findings DRAFT Accounting policies, estimates & judgements
In this section we report on our consideration of accounting policies, in particular revenue recognition policies, and key estimates and judgements made and included with the Council's financial statements.
Accounting area Summary of policy Comments Assessment
Revenue recognition Accounting policies state that income is We did not identify any issues with the revenue recognition policy or recognised on an accruals basis, as it falls with the application of the policy due
Estimates and judgements Key estimates and judgements concern the We reviewed the valuation of investments and concluded that valuation of investments and the valuation of relevant estimates are reasonable the pension fund liability We reviewed the pension fund liability for consistency with the actuary's report and concluded that it is fairly stated in the pension fund accounts.
Assessment Marginal accounting policy which could potentially attract attention from regulators Accounting policy appropriate but scope for improved disclosure Accounting policy appropriate and disclosures sufficient
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | Date 12 Significant findings – accounting policies# Audit findings DRAFT Accounting policies, estimates & judgements continued
Accounting area Summary of policy Comments Assessment
Other accounting policies We have reviewed the Fund's policies Our review of accounting policies has not highlighted any issues which we against the requirements of the CIPFA wish to bring to your attention Code and accounting standards.
Assessment Marginal accounting policy which could potentially attract attention from regulators Accounting policy appropriate but scope for improved disclosure Accounting policy appropriate and disclosures sufficient
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | Date 13 Other communication requirements# Audit findings DRAFT Other communication requirements
We set out below details of other matters which we are required by auditing standards to communicate to those charged with governance.
Issue Commentary
1. Matters in relation to fraud We are still awaiting a reply to our letter to the Chair of the Audit Panel
2. Matters in relation to laws and We are not aware of any significant incidences of non-compliance with relevant laws and regulations. regulations
3. Written representations A standard letter of representation has been requested from the Fund.
4. Disclosures Our review of disclosures did not identify any non-trivial omissions in the financial statements
5. Matters in relation to related We are not aware of any related party transactions which have not been disclosed parties
6. Confirmation requests from We obtained direct confirmations from banks and investment brokers which supported the values of investments stated in the third parties accounts
7. Going concern Our work has not identified any reason to challenge the Fund's decision to prepare the financial statements on a going concern basis.
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 14 Internal controls
Audit findings DRAFT Guidance note Issue and risk must include a description of the deficiency and an explanation of its potential Internal controls effect. In explaining the potential effect it is not necessary to quantify.
The purpose of an audit is to express an opinion on the financial statements. Red text is generic and should Our audit included consideration of internal controls relevant to the preparation of the financial statements in order to design audit procedures that are appropriate in be updated specifically for your the circumstances, but not for the purpose of expressing an opinion on the effectiveness of internal control. We considered and walked through the internal controls client. Once updated, change text for the risks identified as set out on pages 9-11 above. colour back to black. The matters that we identified during the course of our audit are set out in the table below.
Assessment Issue and risk Recommendations
1. In last year's Audit Findings Report we commented that We note the position on the pension fund bank account for your information the Council has been increasing its use of the Pension Fund Bank Account, but is still not fully compliant with LGPS Regulations to use the separate account for all pensions transactions. The Council has continues to increase use of the separate bank account in 2014/15, to include monthly reconciliations.
Assessment Significant deficiency – risk of significant misstatement Deficiency – risk of inconsequential misstatement
The matters reported here are limited to those deficiencies that we have identified during the course of our audit and that we have concluded are of sufficient importance to merit being reported to you in accordance with auditing standards.
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 15 Adjusted misstatements Audit findings DRAFT Guidance note The table is available in the ‘Audit Findings template’ on the Mercury tab in Excel. Misclassifications & disclosure changes Tab: Adjusted misstatements
The table below provides details of misclassification and disclosure changes identified during the audit which have been made in the final set of financial statements.
Adjustment type Value Account balance Impact on the financial statements £'000 1 Misclassification 67 Note 15 – Additional Omission from the Additional Voluntary Contributions note Voluntary Contributions 2 Misclassification 138 Note 5 – Investment Reclassification between investment income and cash Analysis 3 Misclassification 1,074 Note 4 – Investment Reclassification of fixed income income 4 Disclosure Various We identified a number of minor arithmetic, consistency and typographical errors which management has agreed to correct. While none of these was individually significant they indicate some scope to improve quality control arrangements. 5 Misclassification TBC Note 5 – Investment We noted a misclassification between level 2 and level 3 investments, analysis which is to be confirmed with council officers. 6
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 16 DRAFT Section 3: Fees, non-audit services and independence
01. Executive summary
02. Audit findings
03. Fees, non-audit services and independence
04. Communication of audit matters
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015
Fees, non audit services and independence DRAFT Guidance note 'Fees for other services' is to be used where we need to communicate agreed fees in Fees, non-audit services and independence advance of the audit. At the time of preparation of the Audit We confirm below our final fees charged for the audit. Plan it is unlikely that full information as to all fees charged by GTI network firms will be available. Disclosure of these fees, threats to independence and safeguards will therefore be included in the Independence and ethics Audit Findings report. Fees We confirm that there are no significant facts or matters that impact on our Red text is generic and should Per Audit plan Actual fees independence as auditors that we are required or wish to draw to your attention. We be updated specifically for your £ £ have complied with the Financial Reporting Council's Ethical Standards and client. Pension fund scale fee 21,000 21,000 therefore we confirm that we are independent and are able to express an objective Once updated, change text opinion on the financial statements. colour back to black. Total audit fees 21,000 21,000 We confirm that we have implemented policies and procedures to meet the requirements of the Auditing Practices Board's Ethical Standards.
Fees for other services
Service Fees £
Audit related services Nil
Non audit related services Nil
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 18 DRAFT Section 4: Communication of audit matters
01. Executive summary
02. Audit findings
03. Fees, non-audit services and independence
04. Communication of audit matters
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 Communication of audit matters DRAFT Communication of audit matters to those charged with governance
Audit Audit International Standard on Auditing ISA (UK&) 260, as well as other (UK&I) ISAs, Our communication plan Plan Findings prescribe matters which we are required to communicate with those charged with Respective responsibilities of auditor and management/those governance, and which we set out in the table opposite. charged with governance The Audit Plan outlined our audit strategy and plan to deliver the audit, while this Audit Findings report presents the key issues and other matters arising from the audit, together Overview of the planned scope and timing of the audit. Form, timing with an explanation as to how these have been resolved. and expected general content of communications Views about the qualitative aspects of the entity's accounting and financial reporting practices, significant matters and issues arising Respective responsibilities during the audit and written representations that have been sought The Audit Findings Report has been prepared in the context of the Statement of Confirmation of independence and objectivity Responsibilities of Auditors and Audited Bodies issued by the Audit Commission (www.audit-commission.gov.uk). A statement that we have complied with relevant ethical requirements regarding independence, relationships and other We have been appointed as the Council's independent external auditors by the Audit matters which might be thought to bear on independence. Commission, the body responsible for appointing external auditors to local public bodies in England. As external auditors, we have a broad remit covering finance and Details of non-audit work performed by Grant Thornton UK LLP and governance matters. network firms, together with fees charged Our annual work programme is set in accordance with the Code of Audit Practice (the Details of safeguards applied to threats to independence Code) issued by the Audit Commission and includes nationally prescribed and locally Material weaknesses in internal control identified during the audit determined work. Our work considers the Fund's key risks when reaching our conclusions under the Code. Identification or suspicion of fraud involving management and/or It is the responsibility of the Council to ensure that proper arrangements are in place for others which results in material misstatement of the financial the conduct of its business, and that public money is safeguarded and properly statements accounted for. We have considered how the Council is fulfilling these responsibilities. Compliance with laws and regulations Expected auditor's report Uncorrected misstatements Significant matters arising in connection with related parties Significant matters in relation to going concern
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 20 Audit opinion – option 1 Appendices DRAFT Guidance note Red text is generic and should be updated specifically for your client. Appendix : Audit opinion Once updated, change text colour back to black.
We anticipate we will provide the Council with an unmodified audit report on the Pension Fund Please choose option 1, 2 or 3 and delete the slides that are not required.
INDEPENDENT AUDITOR’S REPORT TO THE MEMBERS OF LEWISHAM PENSION Scope of the audit of the pension fund financial statements FUND An audit involves obtaining evidence about the amounts and disclosures in the financial statements sufficient We have audited the pension fund financial statements of Lewisham Pension Fund for the year ended 31 to give reasonable assurance that the financial statements are free from material misstatement, whether March 2015 under the Audit Commission Act 1998. The pension fund financial statements comprise the caused by fraud or error. This includes an assessment of: whether the accounting policies are appropriate to Fund Account, the Net Assets Statement and the related notes. The financial reporting framework that has the pension fund’s circumstances and have been consistently applied and adequately disclosed; the been applied in their preparation is applicable law and the CIPFA/LASAAC Code of Practice on Local reasonableness of significant accounting estimates made by the Executive Director for Resources and Authority Accounting in the United Kingdom 2014/15. Regeneration; and the overall presentation of the pension fund financial statements. In addition, we read all the financial and non-financial information in the explanatory foreword and the annual report to identify This report is made solely to the members of Lewisham Pension Fund , as a body, in accordance with Part II material inconsistencies with the audited pension fund financial statements and to identify any information of the Audit Commission Act 1998 and as set out in paragraph 48 of the Statement of Responsibilities of that is apparently materially incorrect based on, or materially inconsistent with, the knowledge acquired by us Auditors and Audited Bodies published by the Audit Commission in March 2010. Our audit work has been in the course of performing the audit. If we become aware of any apparent material misstatements or undertaken so that we might state to the members those matters we are required to state to them in an inconsistencies we consider the implications for our report. auditor's report and for no other purpose. To the fullest extent permitted by law, we do not accept or assume responsibility to anyone other than the Authority and the Authority's members as a body, for our audit work, Opinion on the pension fund financial statements for this report, or for the opinions we have formed. In our opinion the pension fund’s financial statements: Respective responsibilities of the Executive Director for Resources and Regeneration and auditor give a true and fair view of the financial transactions of the pension fund during the year ended 31 March 2015 and of the amount and disposition of the fund’s assets and liabilities as at 31 March 2015, and As explained more fully in the Statement of Responsibilities for the Statement of accounts, the Executive have been properly prepared in accordance with the CIPFA/LASAAC Code of Practice on Local Authority Director for Resources and Regeneration is responsible for the preparation of the Authority’s Statement of Accounting in the United Kingdom 2014/15 and applicable law. Accounts, which include the pension fund financial statements, in accordance with proper practices as set out in the CIPFA/LASAAC Code of Practice on Local Authority Accounting in the United Kingdom Opinion on other matters 2014/15, and for being satisfied that they give a true and fair view. Our responsibility is to audit and express an opinion on the pension fund financial statements in accordance with applicable law and International In our opinion, the information given in the explanatory foreword and the annual report for the financial Standards on Auditing (UK and Ireland). Those standards also require us to comply with the Auditing year for which the pension fund financial statements are prepared is consistent with the pension fund Practices Board’s Ethical Standards for Auditors. financial statements.
Darren Wells for and on behalf of Grant Thornton UK LLP, Appointed Auditor
September 2015
© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 21 Back page DRAFT
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© 2015 Grant Thornton UK LLP | Audit Findings Report 2014/15 | September 2015 RESOURCES AND REGENERATION - FINANCE Darren Wells Director 5th Floor Grant Thornton UK LLP Laurence House The Explorer Building Catford Fleming Way London Manor Royal SE6 4RU Crawley Direct line 020 8314 8013 West Sussex e-mail:[email protected] RH10 9GT Date: 17th September 2015
Dear Darren
London Borough of Lewisham and Lewisham Pension Fund
Financial Statements for the year ended 31 March 2015 This representation letter is provided in connection with the audit of the financial statements of the London Borough of Lewisham and Lewisham Pension Fund for the year ended 31 March 2015 for the purpose of expressing an opinion as to whether the financial statements give a true and fair view in accordance with the CIPFA/LASAAC Code of Practice on Local Authority Accounting in the United Kingdom 2014/15 and applicable law. We confirm that to the best of our knowledge and belief having made such enquiries as we considered necessary for the purpose of appropriately informing ourselves:
Financial Statements i We have fulfilled our responsibilities for the preparation of the financial statements in accordance with proper practices as set out in the CIPFA/LASAAC Code of Practice on Local Authority Accounting in the United Kingdom ("the Code"), which give a true and fair view in accordance therewith. ii We have complied with the requirements of all statutory directions affecting the Council and these matters have been appropriately reflected and disclosed in the financial statements. iii The Council has complied with all aspects of contractual agreements that could have a material effect on the financial statements in the event of non- compliance. There has been no non-compliance with requirements of regulatory authorities that could have a material effect on the financial statements in the event of non-compliance. iv We acknowledge our responsibility for the design, implementation and maintenance of internal control to prevent and detect fraud. v Significant assumptions used by us in making accounting estimates, including those measured at fair value, are reasonable. vi We are satisfied that the material judgements used in the preparation of the financial statements are soundly based, in accordance with the Code, and adequately disclosed in the financial statements. There are no further material judgements that need to be disclosed. vii Except as stated in the financial statements: a. There are no unrecorded liabilities, actual or contingent. b. None of the assets of the council has been assigned, pledged or mortgaged. c. There are no material prior year charges or credits, nor exceptional or non-recurring items requiring separate disclosure. viii We confirm that we are satisfied that the actuarial assumptions underlying the valuation of pension scheme liabilities for IAS19 Employee Benefits disclosures are consistent with our knowledge. We confirm that all settlements and curtailments have been identified and properly accounted for. We also confirm that all significant post-employment benefits have been identified and properly accounted for. ix Related party relationships and transactions have been appropriately accounted for and disclosed in accordance with the requirements of the Code. x All events subsequent to the date of the financial statements and for which the Code require adjustment or disclosure have been adjusted or disclosed. xi Actual or possible litigation and claims have been accounted for and disclosed in accordance with the requirements of the Code. xii We have considered the adjusted misstatements, and misclassification and disclosures changes schedules included in your Audit Findings Report. The financial statements have been amended for these misstatements, misclassifications and disclosure changes and are free of material misstatements, including omissions. xiii We have no plans or intentions that may materially alter the carrying value or classification of assets and liabilities reflected in the financial statements. xiv We believe that the Council’s financial statements should be prepared on a going concern basis on the grounds that current and future sources of funding or support will be more than adequate for the Council’s needs. We believe that no further disclosures relating to the Council's ability to continue as a going concern need to be made in the financial statements.
Information Provided xv We have provided you with: a. access to all information of which we are aware that is relevant to the preparation of the financial statements such as records, documentation and other matters; b. additional information that you have requested from us for the purpose of your audit; and c. unrestricted access to persons within the Council from whom you determined it necessary to obtain audit evidence.
2 xvi We have communicated to you all deficiencies in internal control of which management is aware. xvii All transactions have been recorded in the accounting records and are reflected in the financial statements. xviii We have disclosed to you the results of our assessment of the risk that the financial statements may be materially misstated as a result of fraud. xix We have disclosed to you all information in relation to fraud or suspected fraud that we are aware of and that affects the Council and involves: a. management; b. employees who have significant roles in internal control; or c. others where the fraud could have a material effect on the financial statements. xx We have disclosed to you all information in relation to allegations of fraud, or suspected fraud, affecting the Council’s financial statements communicated by employees, former employees, regulators or others. xxi We have disclosed to you all known instances of non-compliance or suspected non-compliance with laws and regulations whose effects should be considered when preparing financial statements. xxii We have disclosed to you the identity of the Council's related parties and all the related party relationships and transactions of which we are aware. xxiii We have disclosed to you all known actual or possible litigation and claims whose effects should be considered when preparing the financial statements.
Annual Governance Statement We are satisfied that the Annual Governance Statement (AGS) fairly reflects the Council's risk assurance and governance framework and we confirm that we are not aware of any significant risks that are not disclosed within the AGS
Approval The approval of this letter of representation was minuted by the Council's Audit Panel at its meeting on 17 September 2015.
Signed on behalf of the Council and the Lewisham Pension Fund
Janet Senior
Executive Director for Resources and Regeneration
23rd September 2015
3 COUNCIL
Report Title Lewisham Local Plan: consultation on main issues
Key Decision Yes Item No.
Ward All
Contributors Executive Director of Resources and Regeneration
Class Part 1 Date:23 September 2015
1. Purpose
1.1 This report seeks the Council’s formal resolution to agree public consultation on the Main Issues for the new Lewisham Local Plan.
2. Summary
2.1 The Planning Service is undertaking a first round of public consultation on the production of a new Lewisham wide Local Plan. There are statutory requirements which specify the process for adopting a Local Plan. These involve an early round of public consultation on the main issues to be addressed in the Local Plan. This round of consultation seeks to meet the requirements for initial consultation. As part of the development plan process the Lewisham constitution requires the consultation document be approved by Full Council.
3. Recommendation
3.1 The Council formally resolve to agree public consultation on the Lewisham Local Plan Main Issues document set out as Appendix 1 to this report and the consultation questionnaire in Appendix 2.
4. Policy context
4.1 The contents of this report are consistent with the Council’s policy framework. The new Lewisham Local Plan will replace in time the current Lewisham development plan documents including the Core Strategy and Development Management Local Plan. All development plan documents are part of the Council’s policy framework.
5. Background
5.1 The full background, policy context and details of the Lewisham Local Plan Main Issues Consultation is set out in the report to Mayor and Cabinet dated 15th July 2015 which is included as Appendix 3 to this report. 5.2 The Council is required under planning legislation to produce, adopt and keep up to date a Local Plan for the borough. The process for adopting a local plan are set out in legislation and Government guidance. The formal process requires early consultation with the public and other stakeholders on the main issues to be considered as part of the Local Plan. This first round of public consultation will be met by consultation on the document set out as appendix 1 to this report.
6. The Lewisham Local Plan: Consultation on Main issues
6.1 The ‘Lewisham Local Plan: Consultation on Main Issues’ document is set out as Appendix 1 to this report. The document is structured as follows: Introduction What is a Local Plan? Sustainability Appraisal Drivers for Change The Spatial Strategy Housing Employment Retail Transport The Environment Urban Design and Conservation Community Facilities, Education and Health Next Steps
6.2 The report to Mayor and Cabinet obtained delegated authority for the Executive Director of Resources and Regeneration to make minor alterations to the consultation document prior to the start of formal consultation. Some minor changes have been made to the document to remove errors, improve clarity and improve the visual presentation.
6.3 The main changes to the text include a new paragraph 1.6 to explain the ‘duty to cooperate’; minor changes to the spatial strategy and changes to the wording of the consultation questions both to improve clarity. In addition a new Glossary has been added as appendix 4 to the consultation document.
7. Legal implications
7.1 The procedures which the Council is required to follow when producing a new local plan derive from the Planning and Compulsory Purchase Act 2004 and the Town and Country Planning (Local Planning) (England) Regulations 2012.
7.2 This report seeks authority to consult on the Council’s proposed intention to create a new local plan.
8. Conclusion 10.1 The Council is asked to resolve to agree public consultation on the Lewisham Local Plan Main Issues document set out as Appendix 1 to this report. The consultation meets the requirements for the first stage of formal consultation on a statutory Local Plan.
Background documents
Short Title Date File File Contact Exempt Document Location Reference Officer Planning & 2004 Laurence Planning Brian No Compulsory House Policy Regan Purchases Act 2004 (as amended) National 2012 Laurence Planning Brian No Planning House Policy Regan Policy Framework Local Plan 2012 Laurence Planning Brian No Regulations House Policy Regan
If you have any queries on this report, please contact Brian Regan, Planning Policy, 3rd floor Laurence House, 1 Catford Road, Catford SE6 4RU – telephone 020 8314 8774.
Appendix 1: Lewisham Local Plan: Consultation on Main Issues Appendix 2: Consultation Questionnaire Appendix 3: Report to Mayor and Cabinet dated 15th July 2015
Lewisham Local Plan Consultation on Main Issues
September 2015 | Copy for Full Council
Contents
How do I comment? 4
Foreword 5
1 Introduction 6 Introduction 6 Purpose of the Lewisham Local Plan 6 Localism and the Duty to Co-operate 7
2 What is a Local Plan? 8 What is a Local Plan? 8
3 Sustainability Appraisal 10 Sustainability Appraisal 10
4 Drivers for Change 11 Housing 11 Population Growth 11 Transport Improvement Proposals 12
5 The Spatial Strategy 13 Regeneration and Growth Areas 15 District Hubs 15 Local Hubs 15 Areas of Stability and Managed Change 15 Local Regeneration Areas 16 Managing Future Growth 16
6 Housing 18 Lewisham's Housing Need 18 Affordable Housing 19 Vacant Building Credit 19 Housing Standards 20 Specialist Housing 20
Lewisham Local Plan Consultation on Main Issues 2015 Contents
Infill, Backland and Back Garden Developments 20 Conversion of Larger Dwellings to Flats 21 Conversion of Offices to Dwellings 21 Houses in Multiple Occupation 21 Residential Design at Higher Densities 22
7 Employment 23 Lewisham's Economy 23 Employment Sites and Buildings in Lewisham 23 Employment Land in Lewisham - Past and Future Trends 24
8 Retail 26 Lewisham's Retail Hierarchy 26 Local Centres and Parades 28 Retail Vacancy Rates 28 Quality of Shopping in Lewisham 29 Out of Town Retailing 30
9 Transport 31 Delivering Transport Infrastructure 31 Location of Major Developments 32 Parking 32 Promoting Sustainable Movement 32 Protecting Essential Transport Infrastructure 33
10 The Environment 34 Climate Change 34 The Natural Environment 35 Waste 36 Air Quality 37 Water Quality 37 Contaminated Land 37 Noise and Light Pollution 37
Consultation on Main Issues 2015 Lewisham Local Plan Contents
11 Urban Design and Conservation 39 The Challenge of New High Density Development 40 Urban Design and Conservation in Regeneration and Growth Areas 40 Urban Design and Conservation in District Hubs 41 Urban Design and Conservation in Local Hubs 41 Urban Design and Conservation in the Areas of Stability and Managed Change 41
12 Community Facilities, Education and Health 43 Education 43 Health and Wellbeing 44
13 Next Steps 46
Appendix 1 Role and Function of the Major and District Shopping 48 Centres
Appendix 2 Age Population Projections 50
Appendix 3 London Plan Car Parking Standards 51
Appendix 4 Glossary 52
Lewisham Local Plan Consultation on Main Issues 2015 How do I comment?
How do I comment?
The Council is inviting comments on the Lewisham Local Plan – Consultation on Main Issues (2015) as part of a formal public consultation.
This consultation runs for 6 weeks from XXX to XXX 2015.
You can respond in the following ways:
On-line: http://consult.lewisham.gov.uk/portal E-mail: [email protected] Post: Planning Policy, London Borough of Lewisham, 3rd Floor, Laurence House, 1 Catford Road, SE6 4RU
You can also respond by completing a questionnaire which can be filled out online at [INSERT WEBSITE], from Laurence House, or downloaded from our website at [INSERT WEBSITE]
Copies of the document can be:
viewed on the Councils website www.lewisham.gov.uk/ inspected at all borough libraries and Council’s AccessPoint, Ground Floor, Laurence House, Catford, SE6 4RU and obtained by contacting the Planning Policy Team on 020 8314 7400 who will also be happy to answer any questions you may have.
4 Consultation on Main Issues 2015 Lewisham Local Plan Foreword
Foreword
The ‘Lewisham Local Plan – Consultation on Main Issues (2015)’ is about shaping the future of the borough as a better place to live, work, relax and visit. This means deciding what sort of place we want the borough to be in 2033. The solution for one area of the borough may well not be appropriate for another so the Lewisham Local Plan will need to be locally distinctive for the borough as a whole and the individual places within it.
Lewisham is made up of a collection of diverse neighbourhoods and strong communities, great transport links and a thriving cultural scene. This sense of place ensures that while the borough and its neighbourhoods develop, they maintain their unique identities and preserve Lewisham’s rich natural and architectural heritage.
A lot has changed since the Council adopted of the Core Strategy in 2011. It is clear that the requirement to provide for housing, job growth and educational facilities in the future has increased from previous years. Lewisham’s population will significantly increase over the plan period. The government has significantly changed planning policy and our Local Plan needs to reflect these changes. For this reason we are looking at the key issues during this first stage of public consultation.
Lewisham Local Plan Consultation on Main Issues 2015 5 1 Introduction
Introduction
1.1 Lewisham adopted its Core Strategy in 2011 and now needs to prepare a new Local Plan because the Government and the London Mayor have revised their own planning policies.
1.2 Our new Local Plan has to be consistent with the National Planning Policy Framework (1) (NPPF) which came into force in March 2012 and in general conformity with the Further Alterations to London Plan (2) (FALP) adopted March 2015, the spatial development plan for London.
Picture 1.1 Chain of Conformity
1.3 The Local Plan will need to be informed by a robust evidence base which the Council is currently progressing. The Infrastructure Delivery Plan will be updated and will set out in general detail the infrastructure needed to support the growth and objectives set out in the new Local Plan. A framework document for the Lewisham Infrastructure Delivery Plan (IDP) is being prepared.
Purpose of the Lewisham Local Plan
1.4 The process for preparing statutory Local Plans is set out in the Town and Country Planning (Local Planning) (England) Regulations 2012. Regulation 18 represents the first (statutory) stage in the process of preparing a Local Plan and relates to the “scoping” stage of the Local Plan preparation process, where the public are asked what they think the Local Plan should contain. This initial round of consultation notifies interested people about the Council’s intention to produce a new Lewisham Local Plan.
1.5 This document sets out a proposed spatial strategy and identifies the main issues that the new local plan will address. It has been produced in accordance with Regulation 18 and its purpose is therefore to invite representations about the proposed content of the new local plan.
1 https://www.gov.uk/government/publications/national-planning-policy-framework--2 2 http://www.london.gov.uk/priorities/planning/london-plan
6 Consultation on Main Issues 2015 Lewisham Local Plan Introduction 1
Localism and the Duty to Co-operate
1.6 The Localism Act (2011) introduced a Duty to Co-operate which requires planning authorities and other public bodies to actively engage and work jointly on strategic matters. There are a number of issues such as housing, transport and waste management that have impacts that cross borough boundaries. The Council will explore constructive approaches to such issues jointly with neighbouring authorities and public bodies to ensure that strategic priorities are reflected and, where appropriate, addressed in the Local Plan.
Lewisham Local Plan Consultation on Main Issues 2015 7 2 What is a Local Plan?
What is a Local Plan?
2.1 The Lewisham Local Plan will be the key planning document for the borough. It will set out the planning strategy for growth, that is, how we will deliver the new homes and the related infrastructure needed over the next 15 years, from 2018-2033. It will identify the areas in the borough where growth is expected and how these areas are likely to change in order to accommodate that growth. It will contain the planning policies that will be used to assess planning applications in the future.
2.2 Alongside this expected growth, there will be a need for expanded and improved infrastructure to service a more densely populated borough. Local Plans are expected to plan positively for the development and infrastructure required in the area to meet the objectives, principles and policies of the NPPF.
2.3 The Local Plan will eventually replace the existing Local Development Framework which is a suite of planning documents consisting of the:
Core Strategy (adopted June 2011) Development Management Local Plan (adopted November 2014) Site Allocations Local Plan (adopted June 2013) and Lewisham Town Centre Local Plan (adopted February 2014)
Picture 2.1 Existing Lewisham planning framework
8 Consultation on Main Issues 2015 Lewisham Local Plan What is a Local Plan? 2
Picture 2.2 Forthcoming Lewisham planning framework
2.4 The Local Plan will be supported by supplementary planning documents (SPDs) and a separate Gypsy and Traveller Site(s) Local Plan.
2.5 All the borough’s current planning policy documents can be viewed on the Council’s website, along with the Local Development Scheme (LDS) which sets out the timetable for the production of new planning documents: http://www.lewisham.gov.uk/myservices/planning/policy/LDF/Pages/default.aspx
Lewisham Local Plan Consultation on Main Issues 2015 9 3 Sustainability Appraisal
Sustainability Appraisal
3.1 The Lewisham Local Plan will be subject to a sustainability appraisal (SA) which is an integral part of the plan preparation process. The SA involves identifying and evaluating a plan’s impacts and assessing the social, environmental and economic impacts to help ensure that the plan accords with sustainable development principles. A Scoping Report will be prepared for consultation and this will inform the scope and level of the environmental information to be included in the SA Report to accompany the next round of consultation on the Preferred Options next year.
10 Consultation on Main Issues 2015 Lewisham Local Plan Drivers for Change 4
Housing
4.1 The NPPF introduced some significant changes to the plan making process along with a strong focus on sustainable economic growth and a presumption in favour of sustainable development.
4.2 Local planning authorities are now required by the NPPF to make an objective assessment of their housing need (OAN) and ensure their local plans meet the full OAN in so far as they have sustainable capacity to do so. The NPPF states local planning authorities should prepare a Strategic Housing Market Assessment (SHMA) to identify OAN by working with neighbouring authorities within the Housing Market Area. (3) Lewisham along with the south east London boroughs of Bexley, Bromley, Greenwich and Southwark commissioned a sub regional SHMA published in 2014. (4) The SHMA identified for Lewisham, a housing need of 1,670 additional dwellings each year to meet existing and additional demand.
4.3 The Core Strategy (2011) set out to exceed the provision of new homes allocated in the London Plan (2008) by making provision for 18,000 new homes over the plan period 2011-2026. However the updated London Plan (2015) increased the housing target for Lewisham by requiring a minimum housing target of 1,385 per year. (5)
4.4 The Lewisham Local Plan will need to show how it will meet the OAN housing figure and the increased housing target required by the London Plan (2015).
Population Growth
4.5 Since the adoption of the Core Strategy, the population growth for both London and Lewisham have been higher than expected. The estimated 2013 mid-year population of the borough was 286,180 (6) an increase of 4,624 (1.6%) over the previous twelve months. This growth rate is nearly twice the national growth rate. The population is estimated to have grown by 15% since 2001, whereas the national growth in this period was only 9.6%. These two numbers show that the borough’s population growth is well above the national rate. Whilst the growth rate from 2001 to 2013 was slightly below the rate for Greater London, it is nearly a quarter higher than the metropolitan growth rate in the twelve months 2012 to 2013.
4.6 The 2014 GLA population forecasts for Lewisham show that the borough’s population will grow from 294,009 in 2015 to 333,554 by 2032. The GLA 2015 age population projections show an over all increase in the majority of the age groups between 2015 to 2032. Of particular importance is the increase in the age group of 10 to 14 years old of 23.4% and for the age group 15 to 19 years old, an increase of 17.8%. It also predicts a significant ageing of Lewisham’s population, including a 53% increase in people aged 65 plus and a 40% increase in the number of people aged 80 plus. Further details on age population projections are set out in Appendix 2.
4.7 The Lewisham Local Plan will need to manage this growth and provide for the needs of the growing population by identifying housing sites and locations for facilities and services.
3 Paragraph 47, NPPF 4 Strategic Housing Market Assessment (2014)http://www.lewisham.gov.uk/myservices/planning/policy/LDF/evidence-base/Pages/housing.aspx 5 The London Plan housing target of 1,385 per annum, therefore requires a 15 year plan period provision of 20,775 6 GLA 2013 population estimates
Lewisham Local Plan Consultation on Main Issues 2015 11 4 Drivers for Change
Transport Improvement Proposals
4.8 In September 2014, Transport for London, consulted on several options for an extension of the Bakerloo line beyond its current southern terminus at Elephant & Castle which would stop at New Cross Gate, Lewisham, Ladywell, Catford Bridge and Lower Sydenham. These transport proposals could provide opportunities to intensify housing along the Bakerloo line extension.
Picture 4.1 Location of Bakerloo Line extension proposals. Source: https://consultations.tfl.gov.uk. September 2014.
4.9 If a decision is made to progress the scheme and the necessary funding secured, it is anticipated that construction could commence in around 2023 and be completed in approximately 2030. This would fall within the latter part of the Local Plan period of 2018-2033.
12 Consultation on Main Issues 2015 Lewisham Local Plan The Spatial Strategy 5
5.1 The Core Strategy sets out the current spatial strategy for the borough by shaping how each area develops and distributes growth in housing, retail and employment in a geographical hierarchy as follows:
Regeneration and Growth Areas covering Lewisham, Catford, Deptford, New Cross/New Cross Gate; District Hubs covering the district town centres of Blackheath, Forest Hill, Lee Green and Sydenham; Local Hubs covering Brockley Cross, Hither Green and Bell Green Areas of Stability and Managed Change covering the rest of borough not included above; and Local Regeneration Areas focused on Whitefoot, Downham and Bellingham wards including the Downham district town centre and Southend village, Bromley Road.
Lewisham Local Plan Consultation on Main Issues 2015 13 5 The Spatial Strategy
Picture 5.1 Lewisham's Core Strategy Key Diagram
14 Consultation on Main Issues 2015 Lewisham Local Plan The Spatial Strategy 5
Regeneration and Growth Areas
5.2 The regeneration and growth area (RGA) in the Core Strategy was the area identified to accommodate approximately 15,000 new homes; 100,000 sqm² of new and renovated employment floorspace and 62,000 sqm² of new retail floorspace by 2026. This area coincides with the Lewisham, Catford and New Cross and Deptford Creek/Greenwich Riverside Opportunity Areas designated in the London Plan. (7)
5.3 The Regeneration and Growth Areas still represent the best opportunity for growth in housing, retail, employment floorspace and educational facilities in the borough. However, we are now faced with the challenge of finding additional sites to accommodate the additional growth. The new Local Plan will therefore identify further sites in these areas.
District Hubs
5.4 The District Hubs allocated in the Core Strategy focused on the District town centres of Blackheath, Forest Hill, Lee Green, and Sydenham. The District town centres are concentrations of local economic activity, supported by good public transport where shopping and other commercial activity is concentrated. However, the District town centres have very different characteristics and opportunities for growth. The new Local Plan will therefore have to re-examine the opportunities for growth in these centres.
Local Hubs
5.5 Local hubs were allocated in the Core Strategy at Brockley Cross, Hither Green and Bell Green. These were places that had some limited potential for redevelopment. Overall it was considered that they had the potential to deliver a small amount of residential units. Some of this development has now taken place and the new Local Plan will examine existing opportunities for growth which may included identifying new local hubs.
Areas of Stability and Managed Change
5.6 The Core Strategy defined these areas as ‘those parts of the borough which are largely residential or suburban in character and where the urban form and development pattern is established thereby limiting major physical change’. As would be expected in a well established urban area, the majority of the borough falls into this category. However, change does take place and it is thought better to simply describe this spatial category as ‘Areas of Managed Change’.
5.7 The scale and type of development anticipated in the Core Strategy was small scale and likely to consist of:
Small scale residential development mostly infill and windfall sites; Conversion of houses to flats Change of use of shops in local parades Small scale extensions and alterations to buildings
7 The London Plan identified opportunity areas across London in order to help meet the challenges of economic and population growth. These opportunity areas represent London’s largest development opportunities. The updated London Plan (2015) expects the opportunity areas to accommodate much of the capital’s growth, with capacity for approximately 575,000 jobs and 303,000 additional homes.
Lewisham Local Plan Consultation on Main Issues 2015 15 5 The Spatial Strategy
Local Regeneration Areas
5.8 The Core strategy focused this spatial category on the wards of Whitefoot, Downham and Bellingham. However, few sites for redevelopment were identified in these area and the policy approach of other areas were applied. it is therefore proposed to drop this classification in the new Local plan.
Managing Future Growth
5.9 The current spatial strategy was designed for accommodating growth and given the expected population and household growth this is likely to continue in the future. It is considered that the strategy has been working and is delivering the growth needed in the places identified. However, to meet the new targets for homes and associated infrastructure additional sites will have to be found. It is therefore proposed to continue with the growth strategy but to look more carefully for new sites to accommodate future household growth. The major contribution will continue to come from the regeneration and growth areas of Catford, Lewisham, Deptford and New Cross, whilst opportunities for new development and intensification of development in the district and local hubs will be explored. The majority of the borough is classified as an area of stability and managed change and it is proposed that this spatial category is changed to ‘Areas of Managed Change’ in the new Local Plan. This is because even small scale change like those mentioned above for households, infill development and change of use can have an impact on the character of the area and the new local plan will include policies to guide and direct these changes.
5.10 Given the level of growth that must be accommodated in the borough, and the change that this will bring with it, the key challenge is to create high quality places for people to live in, work in and visit.
5.11 If Lewisham’s places are to grow, they must do so in a way that is true to their existing locality and nature. They must grow with an appreciation of the existing quality and function of the place, including the urban form, landscapes, access, culture, topography, building types, materials and local climate, all of which is necessary to nurture local distinctiveness.
5.12 Growth should be based on an understanding of the existing situation, and what is likely to be appropriate in the future. A focus on shaping different and distinctive places has the potential to reinforce local character, protect valuable assets and create places with a real sense of identity.
5.13 However, development that delivers the needed growth should be creatively designed and not unduly constrained by existing architecture. It will be important in developing a sense of place that creative and innovative design is considered as well as responding to what already exists.
5.14 The following five principles set out how Lewisham’s places should be shaped. These principles apply to all Lewisham’s places, no matter where they are in the growth hierarchy, and no matter how much growth the place will accommodate.
1. Places are for people. They have distinctive characters and must be safe, comfortable, varied and attractive. 2. Places must add value to what already exists. The character of a place is about people and communities as well as the physical components. 3. Places are connected and overlap – boundaries, edges and transitions are important and places must be easy to get to and move around in.
16 Consultation on Main Issues 2015 Lewisham Local Plan The Spatial Strategy 5
4. Places must be economically viable. 5. Places must be flexible and respond to change.
Lewisham Local Plan Consultation on Main Issues 2015 17 6 Housing
6.1 The provision of housing is a key priority and pressure for the borough. Lewisham’ s housing policies need to be updated to respond to the recent changes in national and regional policy. The NPPF sets out the governments requirements for how local planning authorities are to plan for housing.(8) They also needs to respond to the existing and forecast increase in local housing need and population growth.
Lewisham's Housing Need
6.2 The demand for housing in the borough and across London continues to rise. The updated London Plan (2015) increased the housing target for Lewisham borough from 1,100 to 1,385 new dwellings per year. Whilst the South East London SHMA (2014) found that as a result of population growth which affects the rate at which new households are formed and immigration, 1,670 additional dwellings are required each year to meet existing and additional demand. The Council therefore needs to identify enough housing sites in the borough to accommodate this number of dwellings over the Local Plan period of fifteen years from 2018-2033, this totals 25,000 additional dwellings.
6.3 As Lewisham’s housing needs are considerably higher than previously assessed, the Council is:
Updating its Strategic Housing Land Availability Assessment (SHLAA). The SHLAA will identify available and suitable sites to accommodate housing in order to meet Lewisham’s need for housing over the plan period. This will involve research to identify possible additional sites and reviewing previously considered sites that were not progressed Quantifying committed and likely housing projects by Lewisham Homes and registered providers of social housing Carrying out a call for sites – inviting the community to nominate sites for consideration for housing development the Council’s Housing Service will be delivering new homes through the building of new homes and estate renewal where appropriate
6.4 Whilst the Council can identify sites (preferably within the borough) to meet this need, it cannot force developers or site owners to lodge applications to develop, or to act on planning permissions, or to complete the developments within any timeframe. These matters are influenced by wider economic and financial considerations, based largely on how profitable housing development is at the time.
6.5 If the borough has insufficient capacity to accommodate its housing need, then it may be able to negotiate with adjoining boroughs with spare capacity, to accommodate some of Lewisham’s need, based on the duty to co-operate as set out in the NPPF.
6.6 The Council maintains a database of a five-year supply of housing, made up of sites where permissions are granted and construction is either underway or a start date for construction is known. The capacity of sites is calculated using the sustainable residential quality density matrix in the London Plan. This database is kept up to date on a rolling basis. The Council also maintains a database of sites sufficient to meet a fifteen year demand for housing. The updates are published in the Planning Service Annual Monitoring Report.
8 Paragraph 47 to 53, NPPF
18 Consultation on Main Issues 2015 Lewisham Local Plan Housing 6
Affordable Housing
6.7 Since the Core Strategy was adopted, changes to the definition and delivery of affordable housing have been made through the NPPF(9) and the updated London Plan (2015). The NPPF requires local planning authorities to plan for a mix of housing types based on current and future demographic trends, and where they have identified that affordable housing is needed, set policies for meeting this need on site. It also changed the definition of affordable housing by introducing a new tenure called 'affordable rented housing'.(10).
6.8 The evidence presented in the South East London SHMA shows there is a pressing need for affordable housing in the borough. This is in part caused by the increasing house prices in Lewisham and the borough’s low household incomes in comparison to the London average household income. It also found that 60% of the demand for affordable housing is for three or four bedroom dwellings. The current Core Strategy policy expects the provision of family housing (3+ bedrooms) as part of any new development with 10 or more dwellings.
6.9 The current affordable housing policy in the Core Strategy seeks the maximum provision of affordable housing with a strategic target for 50% affordable housing from all sources. It also states contributions to affordable housing will be sought on sites capable of providing 10 or more dwellings. This would be subject to a financial viability assessment. To ensure a mixed tenure and promote mixed and balanced communities, the affordable housing component is to be provided as 70% social rented and 30% intermediate housing.
6.10 Given the degree of need for housing assistance, the Council believes 50% is an appropriate target for affordable housing for the borough – whether as social housing or shared ownership. Increases in house prices and rental levels mean that social rent at affordable market levels (80% of market rent) and shared ownership are both becoming inaccessible for more and more people. To make social rent more affordable the new Local Plan could incorporate a planning policy to cap social rent.
Vacant Building Credit
6.11 The ‘vacant building credit’ is a new Government policy to encourage housing development on brownfield sites by introducing a credit to offset the costs associated with bringing brownfield sites back into use. The National Planning Practice Guidance (NPPG) explains that where vacant floorspace is brought back into use for residential purposes, no affordable housing contribution need be paid on that portion of the development. This is both in terms of on-site construction of affordable units as well as financial contributions for off-site provision. (11)
6.12 The ‘vacant building credit’ is likely to reduce the amount of affordable housing that can be delivered in the borough. The Government has been recently challenged in the High Court by a local planning authority on the affordable housing threshold and the vacant building credit. The judge has ruled these policies should be withdrawn but the Government have said they will appeal so there is uncertainty over the future of this policy.
9 Paragraph 50, NPPF 10 Annex 2, NPPF - defines affordable rented housing as a form of social housing. This new tenure is let by local authorities or private registered providers of social housing to households who are eligible for social rented housing. Affordable rent is subject to rent controls that require a rent of no more than 80% of the local market rent. 11 Paragraphs 21 to 23, NPPG
Lewisham Local Plan Consultation on Main Issues 2015 19 6 Housing
Housing Standards
6.13 Following the Government’s Housing Standards Review which aimed to simplify government regulations and standards into one key set, the Building Regulations will now set the national standards for water efficiency, security, accessibility and energy.
6.14 A national internal space standard closely based on the existing London Housing Standards will be applied through the planning system. If Lewisham Council wants to require an internal space standard i.e. a minimum size for a room, it can only do so by including a reference in the new Local Plan to the nationally described space standard. The Council will not be able to require any higher internal space standards.
6.15 The new Local Plan will need to set out the Council’s approach on accessibility, by demonstrating the need for accessible and adaptable dwellings and wheelchair user dwellings. The Building Regulations set out a distinction between wheelchair accessible (a home readily useable by a wheelchair user at the point of completion) and wheelchair adaptable (a home that can be easily adapted to meet the needs of a household including wheelchair users) dwellings. The NPPG is clear that local plan policies for wheelchair accessible homes should be applied only to those dwellings where the local authority is responsible for allocating or nominating a person to live in that dwelling.
Specialist Housing
6.16 Provision will need to be made to meet the housing needs of Lewisham’s new and existing population in the new Local Plan. The short and longer term supported housing needs of vulnerable and disadvantaged groups will need to be understood and reflected in the new Local Plan. The London Plan seeks to protects against the loss of housing including hostels that meet an identified housing need, unless it can be satisfactorily re-provided. (12)
6.17 The number of older residents is increasing in the borough and many of these people have specialised housing needs which the new Local Plan must take into account. This form of housing includes care homes, sheltered accommodation and extra care accommodation.
6.18 The introduction of new housing standards on accessibility means that the new Local Plan will need to opt in to these technical standards for accessible or adapted for wheelchair users.
6.19 There is also a need for student accommodation in the borough. However, such complexes need careful management to protect the amenity of neighbours so it is important that student housing schemes are purpose-built for specific institutions, rather than being built speculatively. This form of housing needs to be built close to or located with good public transport connections to the university with which it is associated.
Infill, Backland and Back Garden Developments
6.20 The NPPF encourages Councils to set out policies to resist inappropriate development of residential gardens, for example where development would cause harm to the local area.
6.21 There are a number of sites within the borough’s residential areas that could come forward for development which require careful consideration. They are:
12 Policy 3.14 Existing Housing, The London Plan (March 2015) https://www.london.gov.uk/priorities/planning/london-plan/further-alterations-to-the-london-plan
20 Consultation on Main Issues 2015 Lewisham Local Plan Housing 6
Infill sites are sites located within street frontages such as former builders yards, gaps in terraces and gardens to the side of houses. These types of development will be permitted where they make a high quality positive contribution to the area and respect the character of existing houses. Backland sites are defined as ‘landlocked’ sites to the rear of street frontages not historically in garden use e.g. small workshops. The creation of sites for new dwellings (‘backlands’) is only supported where there is proper servicing and access, and adequate privacy and amenity are retained for adjoining dwellings. Back gardens are private amenity areas so developments on these spaces will not be supported as they are no longer considered to be previously developed land with a presumption in favour of development.
6.22 The Development Management Local Plan sets out the current policy on this and this policy approach will continue in the new local plan.
Conversion of Larger Dwellings to Flats
6.23 There is pressure in the borough for the internal subdivision of large dwellings to create a number of flats, but this reduces the number of larger dwellings (3 or more bedrooms) available. As most new dwellings built are one or two bedrooms (mostly flats) there is a need to conserve the stock of larger dwellings. Therefore current policy not to permit further such subdivisions is unlikely to change.
Conversion of Offices to Dwellings
6.24 In 2013, the Government amended the planning legislation, so that planning permissions are not required to convert empty office floorspace to housing. Although this contributes towards increasing the local housing supply, there is a risk of losing employment space and the impact this will have on town centres as well as district and local hubs. In some cases the conversion of ground floor offices is resulting in poorly designed frontages which have a negative impact upon the streetscape.
Houses in Multiple Occupation
6.25 Although there is a need for this type of occupancy(13), such dwellings need to be located close to good public transport and not cause nuisance or disturbance to neighbours or to the wider neighbourhoods in which they are located. The need for Houses in Multiple Occupation, notwithstanding other planning considerations, means that they should be built and finished to a high standard, in order to avoid the poor quality of accommodation that often characterises short-term housing.
6.26 The Council is aware of illegal and substandard houses in multiple occupation (HMOs) in some parts of the borough and is moving to have these returned to legal forms of occupation and to have illegal building work regularised or removed as appropriate.
13 Houses in multiple occupation (HMOs) are dwellings accommodating six or more unrelated persons.
Lewisham Local Plan Consultation on Main Issues 2015 21 6 Housing
Residential Design at Higher Densities
6.27 The need to achieve the maximum practical use of sites means Picture 6.1 Higher density new buildings will need to be taller. Not all locations are suited development at Lewisham to taller buildings, and the visual impact of taller buildings is High Street much greater. In particular, the view corridors to significant points such as St Pauls Cathedral are protected, and there are stringent height restrictions in these corridors.
6.28 The increase in housing need means that more attention will need to be given to the quality of residential design at considerably increased densities where residential redevelopment occurs. Higher density and taller building require an appreciation of a different relationship between building than at lower heights and densities. The Council is presently reviewing its design controls to specifically respond to these issues by developing location and design guidelines for tall buildings – these are generally taken as being more than ten storeys high.
Please provide your comments by completing the online questionnaire on the Lewisham consultation portal.
22 Consultation on Main Issues 2015 Lewisham Local Plan Employment 7
7.1 Improving the local economy is a key issue for the borough. The Lewisham Local Plan will need to support economic growth by encouraging innovation and investment, supporting new and growing businesses and ensure land is safeguarded to meet the needs of growing businesses. The borough has particular advantages for business such as good public transport and a good representation in a number of growing sectors.
7.2 The new Local Plan will need to continue to recognise the importance of creative industries to the borough’s economy, with these activities currently clustered in parts of Deptford, New Cross and Forest Hill.
7.3 The Lewisham Employment Land Study (2008) is currently being updated and will be used to prepare the next formal stage of Plan making following this consultation exercise including the possible release of some employment land for housing. The Greater London Authority (GLA) also publishes evidence about how much of this sort of land is expected to be lost over the next few years, how much office space will be required, and the number of jobs expected to be generated in the borough.
Lewisham's Economy
7.4 Lewisham has one of the smallest economies in London and has a small proportion of land occupied by these buildings. Most people in Lewisham commute to jobs elsewhere in London. It is a deprived borough with many areas suffering from higher than average levels of unemployment. Most firms in Lewisham are very small and employ few people. The major local employers are in the public sector either the National Health Service or Local Government, or other public sector providers. Many local businesses provide goods and services local to the London economy rather than to the national market, and which are complementary to the retail uses in local town centres. This includes such uses as bakers, printers, couriers, car and taxi repairs and office cleaning firms. Creative businesses have become a significant element in the Deptford New Cross area clustering around Goldsmiths College, which offers courses in the arts, and the Trinity Laban Dance Centre on Creekside. They are also represented in other parts of the borough such as Forest Hill.
7.5 In the short term, public sector employment will continue to shrink and opportunities for business and job creation and local economic initiatives might be stifled, except for shorter term jobs in the construction sector. However as more people arrive to live in the borough this will inevitably generate an increase in economic activity and hence more local jobs will be created as a result.
Employment Sites and Buildings in Lewisham
7.6 The borough has a core of heavier industrial uses at Surrey Canal Road in the north of the borough including sites used for waste transfer and waste incineration, and an area of land in Bromley Road just south of Catford which provides important warehouse facilities and a large bus garage. Both these sites are protected by policies in the London Plan and by local planning policies.
7.7 Other areas of industrial and warehousing land are smaller, are protected by local policies, and usually comprise relatively modern purpose built workshop/warehouse units.
7.8 There are also small premises in these uses scattered throughout the borough such as small builder’s yards and car repairs.
Lewisham Local Plan Consultation on Main Issues 2015 23 7 Employment
7.9 The Lewisham Employment Land Study (2008) identified a demand for modern good quality premises for small businesses, such as the purpose built units in the smaller protected industrial areas, and also that much of the borough’s stock was poor quality and did not meet this demand.
Employment Land in Lewisham - Past and Future Trends
7.10 Over the past 20 to 30 years these uses have been in competition for land from housing which can command much higher land prices. Lewisham, along with the rest of London, has faced an on-going decline in the amount of land dedicated to factories and warehouses, and now, as a result has one of the smallest economies in London. Rental yields for these properties in Lewisham are low, which make the development of new industrial buildings in most cases unviable without some form of financial support. Many of the former industrial uses have relocated to the edge of London with better access to the strategic road network. This process will inevitably continue with the pressure on land generated by increased housing targets discussed elsewhere in this consultation document. But to provide a sustainable economy within London, land will need to be maintained in these uses, otherwise these services will have to be provided from outside of London which would increase costs and generate increased traffic.
7.11 The Council has in the past succeeded in preventing some of the decline by protecting a core of better quality business sites (Strategic Industrial Locations in Surrey Canal Road and Bromley Road and Local Employment Locations (14)), while allowing a release of poorer quality large sites in the north of the borough for high density mixed use housing developments. These sites for the most part did not provide large numbers of jobs. In order to ensure the continuation of business uses on these sites the Council required that 20% of the built out floorspace should be business premises with the expectation that more jobs would be provided and the type of jobs available would be more varied. The development of the business uses was cross-subsidised from within the mixed use development, by the provision of high density housing, as noted above this provision would be unviable. The redevelopment and establishment of these mixed use sites is still at an early stage, and some of the sites have in fact not yet been redeveloped.
7.12 The Council will continue to protect the larger industrial sites at Surrey Canal Road and Bromley Road (called Strategic Industrial Locations in the London Plan), which house uses that enable the continued industrial functioning of London, but will keep the boundaries of this land under review.
7.13 The Council protects the smaller local sites of better quality industrial premises (Local Employment Locations), but has a more permissive policy on the release of smaller scattered business sites and premises in town centres and residential areas. These sites have in recent years been consistently well occupied with low vacancy rates.
7.14 The Council is also considering supporting ‘business incubator units’ that will support small business starts. This type of accommodation is being supported by Goldsmith’s College with the intention of supporting creative uses in the Deptford New Cross Area.
14 Local Employment Locations are at: Blackheath Hill, Creekside, Endwell Road, Evelyn Street, Lewisham Way, Malham Road, Molesworth Street, Stanton Square, Willow Way, and Worsley Bridge Road.
24 Consultation on Main Issues 2015 Lewisham Local Plan Employment 7
Please provide your comments by completing the online questionnaire on the Lewisham consultation portal.
Lewisham Local Plan Consultation on Main Issues 2015 25 8 Retail
8.1 Retail is an important part of the local economy and the largest employer in the private sector employing about 10,000 people locally. In addition the goods and services provided are vital to the resident, visitor and working population. It is therefore important for the borough that the planning system does what it can to protect and improve the shopping centres. The new Local Plan will need to consider changing retail trends when planning for future retail development in the borough.
8.2 The Government has introduced a number of changes to planning policy that impact on the retail sector. Most notably changes to the General Permitted Development Order (GPDO) and the Use Classes Order (UCO) which mean that a change of use of a shop to residential or some other type of business no longer requires planning permission, although prior approval is required for some change of use.
Lewisham's Retail Hierarchy
8.3 The Core Strategy (2011) sets out the planning policies in relation to retail issues. This includes defining the retail hierarchy for the borough as follows:
Table 8.1 Lewisham's Retail Hierarchy
Major town District town Neighbourhood Out of centre Parades centres centres local centres
Lewisham Blackheath Brockley Cross Ravensbourne There are about 80 Retail Park, parades scattered Bromley Road throughout the borough
Catford Deptford Crofton Park Bell Green
Downham Downham Way
Forest Hill Grove Park
Lee Green Lewisham Way
New Cross
Sydenham
8.4 The different centres perform a different role and function within the retail hierarchy. Appendix 1 gives a brief explanation of the role and function of these centres.
8.5 The Council surveys the major and district centres annually and the neighbourhood local centres and local parades every 5 years. This provides good evidence about the health of these centres. The latest retail surveys can be viewed on the Council’s website. (15)
15 http://www.lewisham.gov.uk/myservices/planning/policy/LDF/evidence-base/Pages/LDF-evidence-base-employment-and-retail.aspx
26 Consultation on Main Issues 2015 Lewisham Local Plan Retail 8
8.6 In addition to the above the Planning Service commissioned a Retail Capacity Study in 2009(16) to inform the development of the Core Strategy. This study looked at the amount of retail expenditure in the borough and the amount of retail floorspace to determine what growth might be needed to sustain the retail pattern over the 15 year plan period. This study will be updated to inform the new Local Plan and any issues raised by the study will be consulted on. In the past a growth in population has led to a demand for more retail space.
Picture 8.1 Lewisham's Town Centres
8.7 Lewisham town centre is the largest and most varied shopping centre in the borough. The town centre local plan set out an aspirational policy to raise the centre up the London hierarchy from a Major centre to a Metropolitan centre. This would require a substantial increase in shopping floorspace of between 20,000 – 40,000 square metres. A significant proportion would also have to be comparison floorspace.(17)
16 Retail Capacity Study 2009 http://www.lewisham.gov.uk/myservices/planning/policy/LDF/evidence-base/Pages/LDF-evidence-base-employment-and-retail.aspx 17 Comparison goods including clothing, shoes, furniture, household appliances, tools, medical goods, games and toys, books and stationery, jewellery and other personal effects.
Lewisham Local Plan Consultation on Main Issues 2015 27 8 Retail
8.8 Catford is our second largest centre and classified as a Major centre in the London Plan. It has a variety of retail offer including ‘out of centre’ type development opposite Catford Station (Wickes and Halfords) and at the ‘Catford island site’, formed by the one way traffic system on the A205, Plassey Road and Sangley Road; a rather old fashion 1970’s town centre based around Tesco and a linear development of shops along Rushey Green and Catford Broadway. This split in retail offer causes some problems for shoppers who have to cross busy roads to reach the different offers.
8.9 Catford town centre consists mainly of independent retailers, with very few national multiples retailers. Only five of Goad’s 31 major retailers are present in the centre. Overall, the comparison offer in the centre is weak as it has very few key attractors and consists mainly of low value and discount retailers.
8.10 The district shopping centres at Blackheath, Deptford, Downham, Forest Hill, Lee Green, New Cross and Sydenham all have a different role and function (see Appendix 1). Some like Blackheath and Downham have very low vacancy rates while Lee Green, Sydenham and Forest Hill have higher vacancy rates. Lee Green is a run down district shopping centre and the current planning policy is to recommend comprehensive redevelopment. The Council has a current planning application for large scale redevelopment of this centre anchored by an Asda store. This application is not part of this consultation.
Local Centres and Parades
8.11 The Core Strategy designated Brockley Cross, Crofton Park, Downham Way, Grove Park and Lewisham Way as neighbourhood local centres. The borough also contains about 80 local shopping parades. The current policy is to protect shops from a change of use where there is an economic demand for such services. The latest survey data shows that the overall number of shops in the smaller centres and parades has fallen. Some have high vacancy levels while others appear very successful.
Retail Vacancy Rates
8.12 Nationally, the retail sector was badly affected by the economic recession of 2007/8 with many national names going out of business. This led the government to commission the ‘Portas Review’ (2011) which found a reduction in spending in high streets and an increase in vacant property.(18) Another issue the Review highlighted was the changing nature of retailing, in particular the growth of internet shopping.
8.13 In Lewisham, the vacancy rate has been below the national average but still relatively high and hence an issue to be addressed (see graph below). However, the vacancy issue is important as it can start a spiral of decline if vacant units are not re-let quickly. The retail centres all have varying vacancy levels. It may be a better option to allow a change of use (COU) of a shop to residential rather than accept a long term vacancy. It may be appropriate to differentiate the policy approach by centre type by having a more restrictive policy on COU in the healthy retail centres and a more relaxed approach in the centres with the highest levels of vacancies.
18 The Portas Review: An Independent review into the future of our high streets (2011) https://www.gov.uk/government/publications/the-portas-review-the-future-of-our-high-streets
28 Consultation on Main Issues 2015 Lewisham Local Plan Retail 8
Picture 8.2 Vacancy Rates in lewisham Borough 2014 (Taken from Town Town and District Centre Retail Report 2014 Part I: Issues and trends)
Quality of Shopping in Lewisham
8.14 Attractive town centres not only need to have the variety of shops and services to attract customers but should also offer a pleasant environment. The design of new buildings and the urban design considerations that make town centres pleasant places will therefore need to be considered in the new Lewisham Local Plan. In order to support the viability of town centre retail, some car parking provision is needed.
8.15 Locating shopping facilities near transport interchanges will also ensure they are accessible. This will support local businesses and retain expenditure in the borough by reducing the need to travel.
8.16 There has been some concern about the type of businesses that operate in the town and local centres. The COU from a shop to a different type of business like a restaurant or housing is now allowed without the need for planning permission. This means that Core Strategy policy which designates primary and secondary frontages within major and district town centres in order to maintain essential services and contribute towards their vitality can no longer be implemented. However, protecting a variety of shops to maintain the viability of the centre is still a planning objective.
8.17 The percentage of units in the primary shopping frontage in a shop use in Lewisham, Deptford and Downham is at least 70% while Forest Hill and Lee Green have less than 50%. The definition of a shop for planning purpose is a use classified as A1 in the Use Class Order 1987 (as amended).(19) If there were no limits on the percentage of A1 units in these centres then would more vibrant centres be created?
19 Town and Country Planning (Use Classes) Order 1987
Lewisham Local Plan Consultation on Main Issues 2015 29 8 Retail
8.18 There has been community concern over the number of betting shops, pay day loan shops and fast food take away shops in some centres. The Government has changed the use class order so that betting shops are now in a separate class to other shops and this means planning policy can be used to control the number of such uses in any one centre. Due to the obesity problem in Lewisham, the current planning policy seeks to limit the extent of fast food take away shops near to schools. Planning is only part of the solution and the complex nature of obesity needs a multi agency approach.
Out of Town Retailing
8.19 Out of centre retail development has been a growth industry over the past 20 years or more. In order to protect the vitality and viability of existing shopping centres planning policy needs to direct large scale retail to the major and district town centres. The retail capacity study will be updated and this should provide evidence of need for such development but it is always possible for an opportunist planning application to be made and hence planning policy needs to address this issue. The NPPF recommends a sequential test for the location of large scale retail.(20) That is, planning policy should require applications for main town centre uses to be located in town centres, then in edge of centre locations and only if suitable sites are not available should out of centre sites be considered.
Please provide your comments by completing the online questionnaire on the Lewisham consultation portal.
20 Paragraph 24, NPPF
30 Consultation on Main Issues 2015 Lewisham Local Plan Transport 9
Delivering Transport Infrastructure
9.1 The Mayor of London, through Transport for London (TfL) manages the Transport for London Road Network (TLRN) and is also responsible for buses and the Docklands Light Railway (DLR). Network Rail is responsible for infrastructure planning for the railways. Lewisham Council is responsible for the local highway network and seeks to work in partnership with these other transport providers.
9.2 Congestion on the rail network is considered a problem by many residents. Lewisham Borough Wide Transport Study (2010)(21) found that most rail routes through Lewisham are loaded beyond crush capacity limits in the morning peak.
9.3 TfL and Network Rail plan a number of improvements to public transport that should benefit borough residents. These include, but are not limited to, the following:
capacity enhancement to the rail network the Bakerloo Line extension increase frequency of buses new Surrey Canal Road Station London Overground extension A205 Catford Town centre road improvement Picture 9.1 Improving transport infrastructure 9.4 A London Overground extension from New Cross will enhance the services through Hither Green and Grove Park. However, the local rail network currently has insufficient capacity to allow the extension to serve Lewisham station. The additional capacity created by the Bakerloo Line extension may however, allow the extension to serve Lewisham station.
9.5 There are poor levels of transport accessibility in the south of the borough and improvements are needed to improve bus service frequency. Funding for new buses will be sought through planning obligations to support these improvements.
9.6 The Catford loop is a suburban stopping service which covers the following stations: Denmark Hill, Peckham Rye, Nunhead, Crofton Park, Catford, Bellingham and Beckenham Hill. It has a poor frequency of trains running through the borough so the Council is lobbying to increase the frequency of these trains.
9.7 The new Local Plan needs to support the early implementation of these and any other schemes that can be identified.
9.8 Local transport improvements are implemented by the borough using money from the GLA for local schemes. This is set out in the Local Transport Implementation Programme (LIP). Lewisham’s LIP sets out our agreed transport priorities up until 2031, plus more detailed
21 Lewisham Borough Wide Transport Study (2010) https://www.lewisham.gov.uk/myservices/planning/policy/LDF/evidence-base/Pages/LDF-evidence-base-infrastructure.aspx
Lewisham Local Plan Consultation on Main Issues 2015 31 9 Transport
three-year delivery plans which highlight major schemes and new infrastructure projects designed to support and/or facilitate the growth and regeneration of the borough. Annual updates are submitted to TfL for review and approval.
Location of Major Developments
9.9 The London Plan and the Core Strategy both promote the location of major new development, particularly residential, in locations with good public transport or that can be improved to provide good access.
9.10 The identification of development sites and residential capacity should be considered in the light of public transport access. Related to this is the continued need for major development to provide travel plans alongside planning applications so the impact can be assessed and mitigated.
Parking
9.11 The idea of sustainable transport means that in areas of good public transport car parking provision should be limited. However, limited car parking needs to go together with limited on street car parking through controlled parking zones (CPZ). We do not currently have borough wide CPZ coverage and hence limited parking provision within development can potentially spill over into surrounding streets. An integrated approach is needed which links restricted provision with CPZ and the ability of new development residents to access residents parking permits.
9.12 For major residential developments, the incorporation of car clubs as part of the development reduces the use of the private car. The new Local Plan will only consider car limited major residential development where there is on site accessible priority parking for disabled drivers.
9.13 The Mayor of London is reviewing the parking standards in outer London and proposes to keep the standards for inner London which the borough uses (see Appendix 3). It may therefore be necessary to see how the London Mayors proposals are received and consider introducing local parking standards if necessary. Parking for disabled will always be required in new developments.
9.14 Government changes to national planning policy on parking standards are set out in the NPPF (22) and the following text also needs to be taken into account “Local planning authorities should only impose local parking standards for residential and non-residential development where there is clear and compelling justification that it is necessary to manage their local road network”. The Mayor of London does consider there is compelling justification for restrictive parking in inner London.
Promoting Sustainable Movement
9.15 New development provides opportunities to improve connectivity throughout the borough for pedestrians and cyclists, provide new accessible public spaces and contribute towards improving the relationship with the river Thames.
9.16 The borough has varied opportunities for health, leisure and recreational activities including the South East London Green Chain Walk, the Green Grid, the Waterlink Way, the Thames Path and the river and waterways network.
22 Paragraph 39, NPPF
32 Consultation on Main Issues 2015 Lewisham Local Plan Transport 9
9.17 Making places attractive for walking and cycling through public realm improvements has multiple benefits by reducing traffic congestion and greenhouse gas emissions, improving accessibility, viability of a place and contributes to the health and well-being of residents. Increasing the provision of cycle parking in town centres will encourage the use of sustainable modes of transport.
9.18 Providing safe routes for cycling and pedestrians forms part of designing safe places. Development will be expected to address these issues. Designing out crime around transport stations and ensuring good lighting will contribute towards improving the perception of safety.
9.19 The Core Strategy promotes Waterlink Way, the Thames Path and Deptford Links projects for improving cycling and walking opportunities in the borough. The North Lewisham Links Strategy is a programme of works aiming to improve walking and cycling routes across Deptford and New Cross in order to encourage residents to make better use of local amenities and public transport and to encourage more active lives. These projects are being delivered using planning obligations to fund these improvements.
9.20 The Mayor of London’s proposals for the Cycle Superhighway includes two proposed routes, one from Evelyn Street to Greenwich and Queens Road Peckham to Lewisham. The Mayor of London also proposes two Quietways routes which impact on the borough and they are Waterloo to Greenwich and Waterlink Way. These proposed cycle routes will be supported in the new Local Plan.
9.21 The use of the river Thames for sustainable transport choices, including the transport of people and freight such as the transportation of construction and waste materials from development sites will continue to be supported in the new Local Plan. As part of the Convoys Wharf redevelopment, a new river terminus will be built which will increase the number of passengers using river Thames.
Protecting Essential Transport Infrastructure
9.22 The borough has two bus garages at New Cross and at Bromley Road in Catford. The London Plan has a policy to protect essential transport infrastructure. While the Bromley Road bus garage is part of an area designated as a Strategic Industrial Location and therefore given some policy protection, the New Cross bus garage does not have any specific policy protection. The new Local Plan could protect these transport facilities and any others which come forward.
Please provide your comments by completing the online questionnaire on the Lewisham consultation portal.
Lewisham Local Plan Consultation on Main Issues 2015 33 10 The Environment
Climate Change
10.1 Local planning authorities have a statutory duty to take action on climate change and this needs to be addressed in the new Local Plan. Climate change risks are expected to intensify in London in the future to include flooding, higher and unseasonal temperatures, urban heat island effect and limited water resources.
10.2 CO2 emissions from domestic and road transport sectors are higher in Lewisham than the London and UK averages. Therefore the location of new development in areas with good public transport accessibility and the promotion of cycling and walking will be essential.
10.3 The NPPF identifies the key role planning has in the reduction of greenhouse gas emissions, providing resilience to impacts of climate change and supporting the delivery of renewable energy and local carbon development. The Government’s zero carbon policy had aimed to ensure that all new homes are zero carbon by 2016 and 2019 for new non-domestic buildings. However the Government announced as part of if its productivity plan “Fixing the Foundations” (23)that it does not intend to proceed with the zero carbon Allowable Solutions carbon offsetting scheme, or the proposed 2016 increase in on-site energy efficiency standards.
10.4 The current policies in the Core Strategy (2011) and Development Management Local Plan (2014) are supported by the Renewable Evidence Base Study (2010). It justified the adoption of the Code for Sustainable Homes (CSH) Level 4 for residential development and Building Research Establishment Environment Assessment Method (BREEAM) Very Good Standard for non residential development. This study also demonstrated that the establishment of a decentralised energy networks in Deptford and New Cross and at Lewisham and Catford town centres, without the use of South East London Combined Heat and Power plant, is feasible and commercially viable.
10.5 Up until now, the Code for Sustainable Homes (24) had allowed councils to adopt their own sustainability levels as a planning requirement for new residential development. However as part of the Government’s Housing Standards Review this is now being phased out and elements of the code will now be incorporated into building regulations. These will be known as “the new national technical standards.” So in the future new residential development will need to comply with building regulations on energy and water efficiency. The new Local Plan will need to opt-in to these national technical standards.
10.6 The Local Plan will need to ensure that growth and development in the Borough is carried out in a sustainable way. Developments will need to reduce the impacts of climate change by maximising the energy efficiency of new and existing buildings, increasing the use and supply of renewable energy and encourage the establishment of decentralised energy networks. New development will also need to incorporate design measures to manage heat gain and deliver cooling in buildings, water efficiency and urban greening.
23 Fixing the Foundations: Creating a More Prosperous Nation (HM Treasury, July 2015) https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/443898/Productivity_Plan_web.pdf 24 Code for Sustainable Homes is an environmental assessment method for rating and certifying the performance of new homes
34 Consultation on Main Issues 2015 Lewisham Local Plan The Environment 10
The Natural Environment
10.7 Lewisham has an extensive and varied network Picture 10.1 Lewisham's Natural of open space and parks. Significant areas of the Environment borough are identified as Metropolitan Open Land, notably Blackheath and Beckenham Place Park. These open spaces contribute to the attractiveness of the borough, the health and well-being of its residents. They also support a wealth of wildlife and biodiversity which is important for flood protection, improving air and water quality.
10.8 Lewisham’s open spaces and environmental assets also provide opportunities for health, leisure and recreational activities including South East London Green Chain Walk, the Green Grid, Waterlink Way,the Thames Path and river and waterways network.
10.9 Due to a limited land supply and increasing development pressures, the opportunities to create new additional open space is limited. So the new Local Plan will continue to protect and enhance Lewisham’s existing open spaces and biodiversity, recognising their importance and the multiple benefits they provide.
10.10 Although Lewisham is one of the greenest parts of inner south-east London, there are areas of open space deficiency within wards of Brockley, Catford South, Lee Green, Perry Vale and Telegraph Hill. Improving accessibility to existing green spaces by creating better connectivity to and from these spaces is therefore needed to help address this issue.
10.11 The borough contains a number of waterways including the river Thames, Deptford Creek and the Ravensbourne River network (its tributaries the Pool, Quaggy and Spring Brook). These waterways contribute towards recreation and well being and to the borough’s amenity value. The new local Plan will continue to ensure that Lewisham’s rivers are protected and restored and that their roles as heritage assets are enhanced.
10.12 Some parts of the borough fall within an area of flood risk however most of the borough is protected by flood defences, including the Thames Barrier. Properties and infrastructure are also at risk of flooding from other sources such a groundwater flooding and surface water flooding.
10.13 The Local Plan will need to ensure that the risk of flooding is considered in the location and design of new development in order to minimise the impact on people and the environment. Opportunities for development to re-naturalise the borough’s waterways should be maximised as this provides a natural buffer around watercourses, maintains the character of rivers and supports local wildlife. River restoration provides an opportunity to increase public access to the rivers by establishing or connecting up riverside walkways and cyclepaths.
Lewisham Local Plan Consultation on Main Issues 2015 35 10 The Environment
Waste
10.14 Every London borough is allocated an apportionment of waste in the London Plan that they must dispose of using appropriate facilities. For Lewisham this equates to 143,000 tonnes in 2016, increasing to 206,000 tonnes by 2036. This includes municipal, commercial and industrial waste, and a proportion of waste from central London boroughs as they have limited or no land available for waste management.
10.15 The South East London Joint Waste Technical Paper (2013) SE London Waste Technical Paper (2013) (25) was prepared with five other boroughs and sets out how the boroughs will meet the waste apportionment targets set by the London Plan. The provision of waste management sites in this borough exceeds the London Plan apportionment with the South East London Combined Heat and Power Station (SELCHP) in Deptford being able to accommodate in excess of 488,000 tonnes. Further facilities in Lewisham are capable of dealing with over 200,000 tonnes and provide support to other boroughs in south-east London.
10.16 The Site Allocations Local Plan (2013) safeguarded three waste sites in the borough, all of which are contained within the Surrey Canal Strategic Industrial Location and they are:
South East London Combined Heat and Power (SELCHP) plant, Hinkcroft Transport Ltd recycling centre, and Landmann Way recycling centre
10.17 The Lewisham Local Plan will continue to safeguard these sites for waste management. It will also continue to seek a decrease in the amount of waste generated in on-site construction and demolition waste and increasing recycling and composting. Encouraging behavioural change to ensure waste generation is reduced will also be an integral part of this process.
10.18 The consideration of waste handling is another important issue and the design of new development needs to take into account the size and location of waste and recycling stores. Bin storage areas need to be appropriately designed and must not impact upon the street scene or cause a nuisance to neighbouring properties. It is important that the volumes and types of waste which will be produced by a new development when fully occupied are properly estimated so that the bin type for the proposed development can be determined. Accessibility and the location of the bin store area are also key design considerations as there needs to be access for the waste collection crew to collect the waste containers as well as access for large collection vehicles and in some cases there needs to be a turning space for the waste collection vehicle.
10.19 In the future, new developments will need to factor in the changes taking place in the waste industry. The Council are looking at introducing new food, garden and changing refuse collection services. Therefore the design of new developments will need to ensure that they are designed to accommodate these changes, such as including space to house new waste receptacles for food and garden waste.
25 SE London Waste Technical Paper (2013) www.lewisham.gov.uk/myservices/planning/policy/LDF/evidence-base
36 Consultation on Main Issues 2015 Lewisham Local Plan The Environment 10
Air Quality
10.20 The Council’s Air Quality Action Plan identified that road traffic is the main source of air pollution in the borough, mostly in roads with a high flow of buses and/or HGVs, junctions and bus or coach stations. In 2001, Lewisham adopted five air quality management areas.
10.21 Air pollutants at high concentrations can impact upon health so there are considerable health benefits related to the improvement of air quality through the reduction of air pollution in the borough.
10.22 Addressing and improving local air quality will also influence some of the issues that contribute towards climate change. The Local Plan will continue to protect air quality in Lewisham, by only granting planning permission for major developments that have considered air quality through an air quality impact assessment. Planning permission will not be granted where air quality impacts can not be successfully mitigated against.
Water Quality
10.23 Water must meet minimal levels of quality to ensure it does not adversely effect human health, vegetation or other sensitive receptors. It is therefore necessary that when a private supply is to be included in a development that they are appropriately tested, monitored, protected and treated as required.
10.24 The new Local Plan will need to ensure that where a private supply or distribution system is proposed as part of a development, the quality of water is assessed so that any required treatment is identified and an on-going monitoring and maintenance plan is established.
Contaminated Land
10.25 In line with legislation and national and regional planning policy, the planning system must deal with contaminated land. Contaminated land can occur as a result of industry, waste disposal, chemical and oil spills. Any land known or suspected of being contaminated must be dealt with before development commences. When considering the development of such sites the Council will consider the risk of pollution arising from contamination and the impact on human health, property and the wider environment.
Noise and Light Pollution
10.26 Excessive noise can have a detrimental impact on health and on natural habitats. The Local Plan will continue to require that noise and vibration generating development are located in the Strategic Industrial Locations. Whilst new noise sensitive developments will not be allowed to locate near existing noise pollution unless no alternative location is available then appropriate mitigation measures will be sought.
10.27 Light pollution can have a detrimental impact on wildlife, local character, residential amenity and views of the night sky. The Council recognises the value of tranquil and quiet areas and will seek to protect and enhance them for the benefit of the local community and biodiversity. The Lewisham Local Plan will continue to seek that new lighting is properly design and installed. The use of energy efficient and solar powered lighting will also be encouraged.
Lewisham Local Plan Consultation on Main Issues 2015 37 10 The Environment
Please provide your comments by completing the online questionnaire on the Lewisham consultation portal.
38 Consultation on Main Issues 2015 Lewisham Local Plan Urban Design and Conservation 11
11.1 The new Local Plan will include policies that will help to create high quality new buildings and ensure that these relate well to their context and succeed in creating a sense of place and local distinctiveness. This includes sensitive and high quality design and layout, the creation of a visually interesting and coherent townscape and streetscape, design that acts to reduce the opportunity for and fear of crime, and the creation and preservation of residential amenity. The preservation or enhancement of conservation areas and listed buildings and other ’heritage assets’ will also be a major concern of the new Plan and how an understanding of this historic context also contributes to the overall urban quality and attractiveness of the borough.
11.2 In order to ensure that development meets these aims extensive evidence has been prepared on the character of the built and landscape environment of the borough as a whole. The Lewisham Borough wide Character Study (2010) examines and classifies the various forms of built development in Lewisham and makes recommendations on the key issues and pressures that might affect the unique character of these areas. The study highlights the difference between the more urban character of the north of the borough compared to the predominantly residential character of the south of the borough. The study recognises the character and quality of many residential areas that do not have conservation area status. These areas include various types and styles of terraced housing, larger ‘villa’ style housing, and more modern development styles and street layouts. The Council will consider proposing that certain parts of these areas should be adopted as ‘Areas of Special Local Character’ in order to protect their quality.
11.3 The Tall Buildings Study, updated in 2012, examines the impact of potential tall buildings on Lewisham and Catford Town Centres, and the major development sites in the Deptford and New Cross area. This includes the potential impact of tall buildings on local residential amenity and heritage assts. This document will require extensive updating as part of the preparation of the new Local Plan.
11.4 These studies provide the background information which supports the policies in the Core Strategy and the Development Management Local Plan on the design of the built environment and heritage assets, and which cover the design factors listed above.
11.5 The Planning Service also prepares Supplementary Planning Documents (SPD) which interpret and provide further guidance on policies in the borough’s Local Plan. These documents can be subject based, for example guidance on shop front design, alterations and extensions to buildings, residential standards, or area based providing detailed guidance on the urban design of a specific location.
11.6 Buildings and areas of historic and architectural importance are described as ‘heritage assets’ in NPPG. Heritage assets include conservation areas, listed buildings, archaeological remains, registered historic parks and gardens, and locally listed buildings. The Town and Country Planning (Listed Buildings and Conservation Areas) Act 1990 provides the statutory basis for the Council’s approach to preserving or enhancing these assets.
11.7 The Planning Service undertakes a continuous programme of reviewing and identifying conservation areas, and of recommending important and interesting buildings for statutory local listing. Appraisals of many of the Conservation Areas in the borough have recently been prepared which are used to guide decisions on development proposals. In order to protect features identified as being important to preserve or enhance the character of conservation area, Article 4 directions may be made which restrict the rights of property owners to alter buildings in ways that might harm their historic character. The features that
Lewisham Local Plan Consultation on Main Issues 2015 39 11 Urban Design and Conservation
are protected include for example retaining the design of traditional timber windows, fencing and other boundary treatments but can include many other elements that contribute to the historic character and quality of an area. The designation of conservation areas and the listing of buildings occurs independently of the Development Plan process. The Planning Service also has an on-going programme of ‘locally listing’ buildings and structures, such as parish boundary markers and horse troughs to suburban villas, churches and schools. A local listing does not have the status of a statutory listing but it does ensure that the significance of heritage assets is taken into account when a planning decision on a development is made.
11.8 The Council will be updating many of the evidence base documents during the preparation of the new Local Plan, and considers that these will be vital in placing high quality design and heritage assets at the centre of regeneration objectives. A high quality environment will attract business investment, (important in a borough with a small economy), create sustainable development, preserve a sense of place and history and reinforce civic pride.
The Challenge of New High Density Development
11.9 The provision of increased housing in larger or taller buildings could impact on the borough’s character areas and heritage assets. As discussed elsewhere in this consultation document, new increased housing targets for the borough will need to take advantage of what sites are available and build at a higher density than previously thought desirable or possible, particularly in the Regeneration and Growth Areas identified in the Core Strategy. This presents a challenge to architects and designers to achieve high quality environments and places where people want to live. The highest quality design, and a high quality public realm will be critical to the success of these developments. The Core Strategy sets out a framework for the location of this growth by setting out a number of spatial regeneration areas and the amount of growth and development expected for them.
Urban Design and Conservation in Regeneration and Growth Areas
11.10 The Regeneration and Growth Areas are focused on Lewisham Town Centre, Catford Town Centre, Deptford, including Deptford Creekside and New Cross/New Cross Gate. The majority of the borough’s new housing, retail and employment uses will be focused in these areas. These regeneration areas also have significant heritage assets, notably conservation areas in Lewisham, Deptford and in New Cross and New Cross Gate Town Centres and important listed buildings and structures. Extensive new development has already taken place in Deptford and Lewisham Town Centres, and the development sites near New Cross Gate station are currently being developed. The other large scale high density development in this area will take place on larger former industrial sites with few if any heritage assets and a lack of established character. Much of the current development comprises inward looking estates of social housing that are poorly connected and lack facilities.The developments are expected to bring life, new economic activity and vitality to these areas of the borough.
11.11 An example of this new development will be at Surrey Canal Road which will provide high density housing, leisure facilities and a large church. The development has an emphasis on sport, building on its location at the Millwall Football Ground. The new development of 3,500 flats at Convoys Wharf has a Scheduled Ancient Monument on site, a number of listed buildings, including the Olympia Warehouse which is more or less placed centrally on the site, and other heritage assets which will be central to the new development in providing a sense of place and continuity with the past. These assets will need to be protected, enhanced and accommodated. Developments at Marine Wharf in the north-west corner of the borough
40 Consultation on Main Issues 2015 Lewisham Local Plan Urban Design and Conservation 11
are currently on the way to completion, and a development at a large poor quality industrial site at Oxestalls Road is in the pipeline. Both of these developments take account of the local context and history, creating a sense of place. The developments will include the construction of a landscape feature that follows the line of the former Surrey Canal which was in-filled in the 1970s.
11.12 Catford town centre will face development pressures to increase the intensity of development if the proposals to extend the Bakerloo Underground Line start to become more definite. The line would travel in the borough from New Cross Gate to Lewisham underground and then use the existing network rail rail tracks through to Lower Sydenham station and beyond to the London Borough of Bromley. Catford has a distinctive character with important listed buildings at its core; Broadway Theatre and Town Hall Chambers and a number of locally listed buildings, and is surrounded by attractive low rise Victorian/Edwardian terraced housing in traditional streets, some of which has Conservation Area status.
Urban Design and Conservation in District Hubs
11.13 Some intensification of development is expected in some of the borough’s District Shopping Centres. This spatial strategy area applies to Blackheath, Forest Hill, Lee Green and Sydenham. This could refer to extra retail or residential development. In practice opportunities for development are very limited in Blackheath and Sydenham. Blackheath forms a coherent compact village centre where extra development could not be accommodated without altering in some fundamental way the established character and quality of the village. Sydenham has a coherent linear form, but has a small number of sites towards the eastern end of the shopping area where development could be accommodated. Both town centre areas have Conservation Area status.
11.14 Forest Hill Town Centre is also a Conservation Area, but it is recognised that some of the street frontage, particularly at Forest Hill Station, needs improvement and enhancement. There are also a number of small development sites at the station. Forest Hill’s characteristics as a Victorian shopping area could be enhanced by the new development, although realistic proposals have yet to emerge. These issues were discussed in the Forest Hill Urban Design Framework SPD prepared by the Council, and have recently been under discussion by the Forest Hill Society.
11.15 The purpose built shopping centre at Lee Green was constructed in the 1960s. It has a high vacancy rate and does not provide an attractive shopping environment. It is expected that the entire purpose built shopping area will be redeveloped, but is not expected to impact in any significant way on any local heritage assets.
Urban Design and Conservation in Local Hubs
11.16 Three smaller centres were identified in the Core Strategy which had clusters of sites available for development at Brockley Cross, Hither Green, and Bell Green. Much of this redevelopment has already occurred.
Urban Design and Conservation in the Areas of Stability and Managed Change
11.17 The majority of the borough’s conservation areas are located within this area which covers the residential and suburban areas. Development is expected to be small scale and infill and restricted by its largely built up character and lack of availability of large sites. The area also
Lewisham Local Plan Consultation on Main Issues 2015 41 11 Urban Design and Conservation
has many protected parks and open spaces which are preserved against development, and which are an essential element making these areas attractive and liveable and contribute to their essential character.
11.18 The Council will continue to protect the Picture 11.1 Telegraph Hil Conservation Area Conservation Areas already designated and is actively considering new ones. However, in recognition of the fact that the Lewisham Borough Wide Character Study has identified certain residential areas as having important features that could be protected but which might not meet the criteria for conservation area designation, the Council will be proposing that certain areas should be adopted as ‘Areas of Special Local Character’. An example of this could be the 1920s Bellingham Estate in the south of the borough which was designed as a garden city, and which faces unsympathetic alterations to this through opportunistic infill development which would disrupt the regularity of the development form. Other areas will also be considered for this designation.
11.19 Groups within the community are also actively preparing Neighbourhood Plans which will also be examining urban design issues and ways that local heritage assets can be enhanced and integrated into their neighbourhoods to increase a sense of place and historical continuity. Examples are the Corbett Estate Neighbourhood Forum, and the Grove Park Neighbourhood Forum.
Please provide your comments by completing the online questionnaire on the Lewisham consultation portal.
42 Consultation on Main Issues 2015 Lewisham Local Plan Community Facilities, Education and Health 12
12.1 Sustainable communities can only exist where a network of appropriately located facilities are provided within a local area. These facilities include: education, healthcare, leisure, arts, cultural, entertainment, sports and recreational facilities, emergency services, places of worship and cemeteries.
12.2 The current policies in the Core Strategy and Development Management Local Plan seek to protect and enhance community facilities, art, culture and entertainment uses. The loss of facilities is allowed only when there is no demand for it. The new Local Plan will be produced against the background of severe cuts to local government and all services will have to be reassessed against the new financial reality.
12.3 The Council has commissioned an update to its Infrastructure Delivery Plan (IDP). This evidence base document will provide an understanding of the infrastructure issues that the borough faces. The IDP will be prepared in consultation with those responsible for delivering infrastructure throughout the borough. The IDP will be accompanied by an infrastructure schedule identifying the infrastructure needs and costs (including where possible phasing of development), funding sources and responsibilities for delivery. This means delivery is often beyond the influence of the planning system itself.
Education
12.4 The Council has a legal duty to ensure there are enough school places for all children who live in the borough. Lewisham is already experiencing significant school age population growth and this will continue. There will be a very significant increase in demand for additional school places in the opportunity areas where the majority of housing growth is anticipated to take place. These areas are already under severe pressure to provide sufficient primary and other school places and in the near future secondary and special school places. It is anticipated that increased educational provision will be needed outside the growth area in the borough in response to a continued high birth rate and higher occupancy rates of rental stock across the borough.
12.5 Demand for primary school places will at least remain high and may continue to increase in the future. It is estimated that beyond the currently planned new provision, a new primary school and a new special school will be required as early as 2021.
12.6 By 2019 it is forecast that, without new provision, there will be a shortage of secondary school places in the borough. Neighbouring authorities Greenwich, Southwark and Bromley have planned for enlargements which may alleviate pressures to the end of the decade. However, it is estimated that Lewisham will have a need for up to 3 new secondary schools within the period of the plan, the earliest by 2019. The number dependant upon taking into account future provision in neighbouring boroughs.
12.7 Providing sufficient high quality places for under 5s, for children and young people of primary and secondary age including those who need special educational provision, for Further Education and Higher Education provision to support the borough’s growing population will be very challenging. This is because there is an extreme shortage of sites either for further expansion of existing schools, or for new schools, as almost all of Lewisham’s schools have already been permanently or partially expanded over the last seven years.
12.8 The following sites are safeguarded in the Sites Allocation Local Plan (2013):
Lewisham Local Plan Consultation on Main Issues 2015 43 12 Community Facilities, Education and Health
Prendergast Vale College (SA16) in Elmira Street, for a new through-school under the Building Schools Future Programme (BSF). This site has been redeveloped and is now a college. Deptford Green Secondary School Site (SA17) in Amersham Vale, is safeguarded for the redeveloped Amersham Vale/upper school site for new public open space (39%) and residential development.
12.9 Most of the borough falls within the areas of managed change, which is where most of the borough’s conservation areas are located. Therefore a more innovative approach to design will be needed in order to achieve a balance between protecting the character of an area and delivering school expansion. Higher density buildings are another option to consider for delivery of educational facilities in the borough.high quality but affordable design will be fundamental to the success of these developments.
12.10 The Lewisham Local Plan will need to ensure that there is sufficient capacity to meet the need for school places and ensure that this capacity is located in the right places. The Planning Service will need to work in partnership with the Council’s Education Service to identify the need for new school places. The new Local Plan will need to consider how this demand will be met whether it is by allocating land for new school provision or safeguarding land for schools extensions through a more general policy promoting new schools and school expansion. Delivering mixed use developments that consist of educational and other infrastructure facilities alongside housing will be essential to support growth in the borough.
Health and Wellbeing
12.11 Although there have been improvements in health, Lewisham experiences worse health outcomes than London and England. The Joint Strategic Needs Assessment (JSNA) assesses the health needs of a local population in order the to inform policies and services that will improve the health and wellbeing of individuals and communities.(26) It provides information on the health and social care needs of Lewisham’s citizens, complemented by information on the social, environmental and population trends that are likely to impact on people’s health and well-being.
12.12 The NPPF requires local planning authorities to work with public health leads and health organisations to understand and take account of the health status and needs of the local population providing accessible local services that reflect its communities needs and supports health, social and cultural wellbeing.(27) The expected growth in population means that there will be increasing demand for healthcare in the borough. The Council will support and work in partnership with health organisations in the provision of healthcare.
12.13 The Health and Social Care Act 2012 has led to significant changes in adult social care. Under this act, local authorities have a statutory duty to use their powers and resources across all sectors to improve the health of their population. The NPPF also emphasises the role that the planning system can play in facilitating social interaction and creating healthy, inclusive communities.(28) There are a whole range of planning policies that have both a direct and indirect influence on the health and wellbeing of residents and contribute towards the creation of a healthy environment. The design of new buildings can contribute towards
26 Lewisham’s Joint Strategic Needs Assessment http://www.lewishamjsna.org.uk/ 27 Paragraph 171, NPPF 28 Paragraph 69, NPPF
44 Consultation on Main Issues 2015 Lewisham Local Plan Community Facilities, Education and Health 12
improving health and promoting healthy lifestyles such as the provision of outdoor spaces and terraces adjacent to buildings to encourage mental wellbeing, activity and produce and provide healthy food.
12.14 Transport has an important role in people’s health. Transport provides access to jobs, shops, education, health and social services. Improving the transport systems to encourage more people to walk and cycle will have an impact on the health and fitness levels of residents in Lewisham.
Please provide your comments by completing the online questionnaire on the Lewisham consultation portal.
Lewisham Local Plan Consultation on Main Issues 2015 45 13 Next Steps
13.1 The council is committed to reporting back on responses to the consultation. Following each stage of public consultation the Council will:
Give full consideration to all representations received and engage in further discussions where this will assist in developing the document. Make a summary of all responses available on our website. Produce a consultation report, detailing the comments we have received and explaining how we have dealt with comments and how they have affected the development of policy, at each stage of the Local Plan process. Consultation reports will be made available to view on the Council’s website, and paper copies will be made available at Laurence House and at town centre libraries.
13.2 The Council will review the responses to this consultation and will use them to inform the Preferred Options. The Preferred Options will be published for public consultation in early 2016. Following this, the Preferred Options will be amended and a ‘Publication Plan’ will be prepared and consulted upon in early 2017.
13.3 All respondents will be notified of the submission of the plan to the Secretary of State for examination and will be notified of the examination hearings. A consultation report will be submitted to the Secretary of State showing how the Regulations and the aims of the Statement of Community Involvement have been met and describing how the plan has been influenced by consultation.
13.4 The Local Plan is expected to be adopted in late 2017 and the Council will revoke the existing Core strategy, Development Management Local Plan, Site Allocations Local Plan and Lewisham Town Centre Local Plan.
46 Consultation on Main Issues 2015 Lewisham Local Plan Appendices
Lewisham Local Plan Consultation on Main Issues 2015 47 Appendix Role and Function of the Major and District Shopping Centres 1
Introduction
The London Plan classifies town centres according to their existing role and function. The London hierarchy consists of: International centres which are London’s globally renowned retail destinations such as Knightsbridge. Metropolitan centres which serve wide catchments and typically contain at least 100,000 sq.m. of retail, leisure and service floorspace. Major centres which generally contain over 50,000 sq.m. of retail, leisure and service floorspace with a relatively high proportion of comparison goods relative to convenience goods. District centres provide convenience goods and services for more local communities and are accessible by public transport. Typically they contain 10,000 – 50,000 sq.m. of retail, leisure and service floorspace. Neighbourhood and local centres typically serve a local catchment often most accessible by walking and cycling and include local parades and small cluster of shops.
Lewisham
The role & function of Lewisham Town Centre is as the borough’s premier shopping destination. It is classified as a Major centre in the London hierarchy of shopping centres. It has by far the widest choice of comparison and convenience floorspace. It attracts customers from a wide catchment area. If the Council’s ambitions to make the centre a metropolitan centre in the London hierarchy are to be achieved it will be necessary to increase considerably both the quality and quantity of its retail offer. However, in terms of vacant property the centre is doing very well, the 2014 survey showed a vacancy rate of only 4.1%.
Catford
Catford Town Centre is the second largest centre in the borough. It is classified as a Major centre in the London hierarchy of shopping centres. It provides a wide range of services to borough residents and a more local convenience and comparison shopping offer. It performs important functions as a civic and entertainment centre attracting visitors across the borough and beyond. However there has been no notable change in the retail offer of the Town Centre in recent years. It is important that the Centre improves its retail offer in the future if it is to maintain its position in the retail hierarchy and new investment should be encouraged. The 2014 retail survey showed a vacancy rate of 7.5% for Catford.
Blackheath
Blackheath is the seventh largest of the nine major and district town centres. It can be said to have a dual role and function in that it clearly serves a local function for convenience goods and to some extent for services and comparison goods. However, the quality of the services and comparison offer is such that visitors are attracted from a wider catchment area than might be expected for a centre of this size. It plays an active role in the ‘night time’ economy of the borough. The 2014 retail survey showed a vacancy rate of 0% for Blackheath.
Deptford
Deptford is the third largest town centre in Lewisham. Its role and function is essentially as a local shopping destination. There are virtually no ‘high street’ names represented in the centre while the convenience sector is more than twice the national average and is dominated by independent traders serving a local market. Many of the local shops specialize in ‘ethnic’ goods which serve the immediate population. The centre is dominated by a street market which operates 3 days a week. However, Deptford’s strength is in the number and variety of independent traders. The 2014 retail survey showed a vacancy rate of 7.1% for Deptford.
48 Consultation on Main Issues 2015 Lewisham Local Plan Appendix Role and Function of the Major and District Shopping Centres 1
Downham
Downham is the smallest of the district town centres. Its role and function is as a local shopping centre, serving the needs of the local community. Given its location between Catford and Bromley the general nature of the centre is not surprising, with most of the shops being service and convenience oriented. However, the centre has recorded very low vacancy rates over many years and this indicates that it is a successful local shopping centre. The 2014 retail survey showed a vacancy rate of 5.3% for Downham.
Forest Hill
Forest Hill is the sixth largest of the nine major and district centres. Its role and function is as a local centre catering for the immediate population needs. This is illustrated by the small comparison goods offer and the high proportion of service uses. It contains a limited number of ‘high street’ names and they are not located in the best type of property. The dominance of the busy roads, South Circular A205 and Dartmouth Road A2216, creates a difficult pedestrian environment. The 2014 retail survey showed a vacancy rate of 11.8% for Forest Hill.
Lee Green
Lee Green is the eighth largest of the nine major and district town centres. Its role and function is as a local centre catering for the needs of the immediate population. The majority of floorspace is in convenience stores the largest being Sainsbury. In addition there are a range of service uses and a significant amount of office space within the town centre. The borough boundary runs through Lee Green and the town centre is shared with the London Borough of Greenwich. The centre has been in relative decline for a number of years and current planning policy recommends comprehensive redevelopment. The 2014 retail survey showed a vacancy rate of 13.5% for Lee Green, this was the highest of all the major and district centres.
New Cross
New Cross is the fifth largest of the nine town centres in Lewisham. Its role and function is as a local centre which provides for the needs of local people and particularly students from Goldsmiths College. It has relatively poor environment created by the linear nature along the very busy A2 road. The very high level of service uses is also influenced by the presence of the student population. The Sainsbury store at the western end of the centre is likely to have a wider draw. The 2014 retail survey showed a vacancy rate of 9.4% for New Cross.
Sydenham
Sydenham is the forth largest of the nine town centres. Its role and function is as a local centre providing for the day to day needs of the local population. The higher than average convenience floorspace and the lower than average comparison offer indicate this essentially local function. There are also relatively few ‘national name’ retailers represented in Sydenham. The 2014 retail survey showed a vacancy rate of 9.4% for Sydenham.
Lewisham Local Plan Consultation on Main Issues 2015 49 Appendix Age Population Projections 2
The predicted age-based population increases are set out in Table 2. Table 2 highlights a predicted significant ageing of Lewisham’s population, including a 53% increase in people aged 65 plus and a 40% increase in the number of people aged 80 plus.
Table 2.1 Age Population Projections (29)
Age group 2015 2022 2027 2032 % change 2015- 2032
0 to 4 22,870 22,433 22,096 21,699 -5.1
5 to 9 20,066 20,454 20,291 19,918 -0.7
10 – 14 14,957 19,012 18,666 18,464 23.4
15 - 19 15,149 15,740 18,205 17,851 17.8
20 - 24 20,443 18,552 19,157 21,054 3.0
25 - 29 28,296 27,170 25,804 26,271 -7.2
30 - 34 30,621 31,613 30,375 28,930 -5.5
35 - 39 27,521 29,594 30,284 29,062 5.6
40 -44 22,766 26,403 26,993 27,498 20.8
45 - 49 20,458 21,306 23,938 24,384 19.2
50 -54 18,930 19,218 19,693 21,935 15.9
55 - 59 14,306 18,180 17,942 18,258 27.6
60 -64 10,076 14,007 16,124 15,924 58.0
65 - 69 8,508 9,628 12,163 13,992 64.5
70 - 74 6,151 7,369 8,367 10,556 71.6
75 - 79 5,324 5,723 6,285 7,166 34.6
80 - 84 3,863 4,062 4,624 5,118 32.5
85 - 89 2,452 2,702 2,865 3,349 36.6
90 + over 1,237 1,529 1,834 2,101 69.8
Total 294,009 314,701 325,716 333,554 13.5
29 copyright of GLA 2015
50 Consultation on Main Issues 2015 Lewisham Local Plan Appendix London Plan Car Parking Standards 3
Table 3.1 Maximum parking standards
Number of beds 4 or more 3 1-2
2-1.5 per unit 1.5-1 per unit Less than 1 per unit
Notes:
All developments in areas of good public transport accessibility should aim for significantly less than 1 space per unit.
Adequate parking spaces for disabled people must be provided, preferably on-site.
20% of all spaces must be for electric vehicles with an additional 20% passive provision for electric vehicles in the future.
Lewisham Local Plan Consultation on Main Issues 2015 51 Appendix Glossary 4
Affordable housing
Social rented, affordable rented and intermediate housing, provided to eligible households whose needs are not met by market housing. Eligibility is determined with regard to local incomes and local house prices. Affordable housing should include provisions to remain at an affordable price for future eligible households or for the subsidy to be recycled for alternative affordable housing provision.
Social rented housing is owned by local authorities and private registered providers, (as defined in Section 80 of the Housing and Regeneration Act 2008), for which guideline target rents are determined through the national rent regime. It may also be owned by other persons and provided under equivalent rental arrangements to the above, as agreed with the local authority or with the Homes and Community Agency.
Affordable rented housing is let by local authorities or private registered providers of social housing to households who are eligible for social rented housing.
Affordable Rent is subject to rent controls that require a rent of no more than 80% of the local market rent (including service charges, where applicable). Intermediate housing is homes for sale and rent provided at a cost above social rent, but below market levels subject to the criteria in the Affordable Housing definition above. These can include shared equity (shared ownership and equity loans), other low cost homes for sale and intermediate rent, but not affordable rented housing.
Homes that do not meet the above definition of affordable housing, such as “low cost market” housing, may not be considered as affordable housing for planning purposes,.
Air Quality Impact Assessment (AQIA)
A technique for determining the relative contribution to ground level pollutant concentrations as a result of existing and/or future emission sources. The AQIA report enables the planning authority to determine, with a reasonable degree of certainty, the significance of any air quality impacts, and thereby the priority to be given to air quality concerns when deciding an application. The scope of an air quality assessment will depend on the nature of the proposed development and the potential impact, but is likely to include: the existing air quality in the study area (baseline) predicted future air quality without the development (future baseline) predicted future air quality with the development (with development) assessment of the impact of the construction / demolition phase consideration of the cumulative impact of permitted developments within the area.
Air Quality Management Area (AQMA)
Local planning authorities are required to review and assess the air quality in their area (see definition of AQIA above). If a local authority finds any places where the objectives are not likely to be achieved, it must declare an Air Quality Management Area there.
Amenity Areas
Communal amenity areas attached to residential development, such as, private communal gardens for small blocks of flats, landscaped spaces around taller blocks of flats and around low and medium size slab blocks.
52 Consultation on Main Issues 2015 Lewisham Local Plan Appendix Glossary 4
Article 4 Direction
A legal instrument which extinguishes specific 'permitted development rights' from buildings within a defined area i.e. the right to do some types of minor works without planning permission. The effect of an article 4 direction is to require planning permission to be obtained from the Council before such work begins. Flats and commercial premises do not have permitted development rights so article 4 directions do not apply to them.
Back gardens
Private amenity areas that were the entire back garden of a dwelling or dwellings as originally designed. Gardens used to be considered previously developed land (PDL) with a presumption in favour of development. Gardens are no longer considered to be PDL which means that there is no longer a presumption in favour of development.
Backland sites
'Landlocked' sites to the rear of street frontages not historically in garden use such as builders yards, small workshops and warehouses, and garages.
Biodiversity
Biodiversity is the variety of life, which includes mammals, birds, fish, reptiles, amphibians, invertebrates, fungi and plants and the woodlands, grasslands, rivers and seas on which they all depend including the underlying geology.
Building Research Establishment Environmental Assessment Method (BREEAM)
A national environmental assessment and rating system for buildings. It was the most widely used environmental standard in the UK, used to assess those buildings and extensions to buildings that are not rated by the Code for Sustainable Homes.
Code for Sustainable Homes
This used to be a national standard for sustainable design and construction of new homes. The Code measured the sustainability of a new home against categories of sustainable design, using a 1 to 6 rating system to communicate the overall sustainability performance of a new home.
Community Infrastructure Levy (CIL)
A levy allowing local authorities to raise funds from owners or developers of land undertaking new building projects in their area to pay for infrastructure projects identified by the Local Authority and/or the Mayor of London.
Comparison Retailing
The provision of items not obtained on a frequent basis such as clothing, footwear, household and recreational goods.
Conservation
The process of maintaining and managing change to a heritage asset in a way that sustains and, where appropriate, enhances its' significance.
Lewisham Local Plan Consultation on Main Issues 2015 53 Appendix Glossary 4
Conservation Area
Areas of special architectural or historic interest designated by local authorities under the Planning (Listed Building and Conservation Areas) Act 1990.
Contribution
Land, services, facilities and/or money given by developers of land to the local authority following negotiations, to ensure that the needs of new communities generated by the development are catered for.
Convenience Retailing
Convenience retailing is the provision of everyday essential items, including food, drinks, newspapers/magazines and confectionery.
Core Strategy
A Local Plan setting out the spatial vision and strategic objectives of the planning framework for the area, in line with the Sustainable Community Strategy.
Designated Heritage Asset
A World Heritage Site, Scheduled Monument, Listed Building, Protected Wreck Site, Registered Park and Garden, Registered Battlefield or Conservation Area designated under the relevant legislation.
Development
"The carrying out of building, engineering, mining or other operations in, on, over or under land, or the making of any material changes in the use of any building or other land." (Town and Country Planning Act (1990) Part III Section 55).
Development Plan Document (DPD)
A Local Plan that has been drawn up by the local planning authority in consultation with the community, has been subject to independent testing and has the weight of development plan status. The terminology 'Development Plan Document' has been replaced with 'Local Plan' for new documents, but remains for pre-existing documents (i.e. Lewisham Core Strategy DPD, 2011).
District Centre
A town centre that provides convenience goods and services to local communities and is accessible by public transport, walking and cycling. District centres typically contain 10,000-50,000 square metres of retail floorspace. In the London Borough of Lewisham these are Blackheath, Deptford, Downham, Forest Hill, Lee Green, Sydenham and New Cross and New Cross Gate.
Duty to Co-operate
The duty to cooperate was created in the Localism Act 2011 (30), and amends the Planning and Compulsory Purchase Act 2004. It places a legal duty on local planning authorities, county councils in England and public bodies to engage constructively, actively and on an ongoing basis to maximise the effectiveness of Local Plan preparation in the context of strategic cross boundary matters.
30 http://www.legislation.gov.uk/ukpga/2011/20/section/110/enacted
54 Consultation on Main Issues 2015 Lewisham Local Plan Appendix Glossary 4
The duty to cooperate is not a duty to agree. But local planning authorities should make every effort to secure the necessary cooperation on strategic cross boundary matters before they submit their Local Plans for examination. Local planning authorities must demonstrate how they have complied with the duty at the independent examination of their Local Plans.
Edge of Centre
For retail purposes, a location that is well connected and up to 300 metres of the primary shopping area. For all other main town centre uses, a location within 300 metres of a town centre boundary. For office development, this includes locations outside the town centre but within 500 metres of a public transport interchange. In determining whether a site falls within the definition of edge of centre, account should be taken of local circumstances.
Evidence Base
The data and information about the current state of Lewisham used to inform the preparation of Local Plan documents. Flood Risk Assessment An assessment of the likelihood of flooding in a particular area (usually a specific site) so that development needs and mitigation measures can be carefully considered.
General Permitted Development Order (GPDO)
A number of forms of telecommunications development which are permitted under the General Permitted Development Order are subject to a 56 day prior approval procedure. For such types of development the developer must apply to the local planning authority for its determination as to whether prior approval will be required for the siting and appearance of the proposed development.
Gypsy and Travellers
Persons of nomadic habit of life whatever their race or origin, including such persons who on grounds only of their own or their family's or dependant's educational or health needs or old age have ceased to travel temporarily or permanently, but excluding members of an organised group of travelling show people or circus people or circus people travelling together as such (Planning policy for traveller sites, March 2012).
Housing Need
A level of socially desirable housing, the demand for which is not reflected in the open market, normally due to a lack of income in relation to prevailing house prices or rents. It can therefore usually only be met through an element of subsidy. Independent Examination The process by which a planning inspector may publicly examine a Local Plan before issuing a report with recommendations that should be made prior to adoption of the Local Plan.
Infill Development
Development that generally takes place on sites within street frontages such as former builders yards, small workshops and garages, gaps in terraces and gardens to the side of houses. Infrastructure The utilities, transport and other communication facilities and community facilities required to support housing, industrial and commercial activity, schools, shopping centres and other community and public transport services.
Lewisham Local Plan Consultation on Main Issues 2015 55 Appendix Glossary 4
Listed Building
Buildings of special architectural or historic interest designated by the Department of Culture, Media and Sport under the Planning (Listed Building and Conservation Areas) Act 1990.
Local Development Document (LDD)
Sits within the LDF portfolio and comprises Development Plan Documents (DPDs), also called Local Plans that have been subject to independent testing and have the weight of development plan status, and Supplementary Planning Documents (SPDs) which are not subject to independent testing and do not have development plan status.
Local Development Framework (LDF)
The Local Development Framework is a portfolio, or a ‘folder', of Local Development Documents which will provide the local planning authority's policies for meeting the community's economic, environmental and social aims for the future of their area where this affects the development and use of land.
Local Development Scheme(LDS)
A public statement identifying which Local Development Documents will be produced by the Council and when.
Local Employment Location (LEL)
Land that is of local significance and provides goods and services for the local economy, which is used for business use, industrial use, storage and distribution uses, generally being those uses falling within Classes B1, B2 and B8 of the Use Class Order.
Local Plan
A Local Development Document that has been drawn up by the local planning authority in consultation with the community, has been subject to independent testing and has the weight of development plan status.
Local Shopping Parade and Corner Shop
A local shopping parade is a group of at least four contiguous shops and may continue over breaks such as streets or railways. A corner shop is a shop which is located outside of the Major centres, District centres, Neighbourhood Local centres and Local Shopping Parades. These parades and shops should provide for the day to day needs of local residents.
Localism Act 2011
National legislation from central government, partly aimed at improving the planning process and enhancing community involvement in it. Visit www.communities.gov.uk to find out more.
Major Centre
A centre that has a borough-wide catchment and typically contains over 50,000 square metres of retail floorspace with a relatively high proportion of comparison goods relative to convenience goods. Major centres may also have significant employment, leisure, service and civic functions. In the London Borough of Lewisham these are Lewisham and Catford town centres.
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Metropolitan Centre
They serve wide catchment areas covering several boroughs and offer a high level and range of comparison shopping. They typically have over 100,000 square metres of retail floorspace, including multiple retailers and department stores. They also have significant employment, service and leisure functions.
Metropolitan Open Land (MOL)
Strategic open land within the urban area that contributes to the structure of London.
Mixed Use Employment Location (MEL)
Land currently in industrial use occupied by older and poorer quality industrial uses at low densities which may be incompatible with adjacent residential areas. The sites were considered by the Lewisham Employment Land Study to require redevelopment and have been designated to ensure mixed use development incorporating reprovision of business space to ensure the regeneration of a part of the borough where the environment is poor and levels of deprivation are high.
Mixed Use Development
Development for a variety of activities on single sites or across wider areas such as town centres.
National Planning Policy Framework (NPPF)
Prepared by the Government to explain statutory provisions and provide guidance to local authorities and others on planning policy and the operation of the planning system. The NPPF explains the relationship between planning policies and other policies which have an important bearing on issues of development and land use. Local authorities must take their contents into account in preparing plans. The guidance may also be relevant to decisions on individual planning applications and appeals.
National Planning Practice Guidance
Prepared by the Government, launched in March 2014 to support the NPPF, this is online resource which enables the user to easily link guidance to the relevant NPPF policy, providing planning practice guidance on a wide range of topics.
Neighbourhood Local Centre
A centre that serves a localised catchment often most accessible by walking and cycling and typically contains mostly convenience goods and other services. In the London Borough of Lewisham these are Brockley Cross, Crofton Park, Downham Way, Grove Park and Lewisham Way. Noise and Vibration Assessment An assessment of noise and vibration that is either existing and may impact upon future development, or that would be caused by new development and could impact upon the existing environment.
Open space
All open space of public value, including not just land, but also areas of water (such as rivers, canals, lakes and reservoirs) which offer important opportunities for sport and recreation and can act as a visual amenity. Out of Centre A location which is not in or on the edge of a centre but not necessarily outside the urban area.
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Planning and Compulsory Purchase Act 2004
National planning legislation from central government aimed at improving the planning process and enhancing community involvement in it. Visit www.communities.gov.uk to find out more.
Planning Obligation
A legally enforceable obligation entered into under section 106 of the Town and Country Planning Act 1990 to mitigate the impacts of a development proposal.
Previously Developed Land
Land which is or was occupied by a permanent structure, including the curtilage of the developed land (although it should not be assumed that the whole of the curtilage should be developed) and any associated fixed surface infrastructure. This excludes: land that is or has been occupied by agricultural or forestry buildings; land that has been developed for minerals extraction or waste disposal by landfill purposes where provision for restoration has been made through development control procedures; land in built-up areas such as private residential gardens, parks, recreation grounds and allotments; and land that was previously-developed but where the remains of the permanent structure or fixed surface structure have blended into the landscape in the process of time.
Primary and secondary frontages
Primary frontages are likely to include a high proportion of retail uses which may include food, drinks, clothing and household goods. Secondary frontages provide greater opportunities for a diversity of uses such as restaurants, cinemas and businesses.
Public Transport Accessibility Level (PTAL)
A standard method used in London to calculate access level of geographical areas to public transport. The result is a grade from 1-6 (including sub-divisions 1a, 1b, 6a and 6b), where a PTAL of 1a indicates extremely poor access to the location by public transport and a PTAL of 6b indicates excellent access by public transport. More parking is generally allowed in areas with a low PTAL i.e. poor public transport and vice versa - and that also relate the allowed density of development to PTAL (i.e. areas with better public transport may have higher density housing or offices).
Regeneration
The process of putting new life back into often derelict older urban areas through environmental improvements, comprehensive development and transport proposals.
Retail Hierarchy
The role and relationship of retail centres across the borough.
Section 106 (S106)
Section 106 of the Town and Country Planning Act 1990 allows a local planning authority (LPA) to enter into a legally binding agreement or planning obligations, with a land developer over a related issue. The obligation is sometimes termed a ‘Section 106 agreement'. Such agreements can cover almost any relevant issue and can include sums of money. An example of S106 agreements could be that a developer will build a community meeting place on a development site, or the developer
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will make a financial contribution for transport improvements. S106 agreements can act as a main instrument for placing restrictions on developers, often requiring them to minimise the impact on the local community and to carry out tasks which will provide community benefits.
Sequential Approach/Sequential Test
A planning principle that seeks to identify, allocate or develop certain types or locations of land before others. For example, brownfield housing sites before greenfield sites, or town centre retail sites before out-of-centre sites.
Strategic Housing Land Availability Assessment (SHLAA)
A study aimed at identifying sites with potential for housing, assessing their housing potential and assessing when they are likely to be developed.
Strategic Housing Market Assessment (SHMA)
A study aimed at assessing the need and demand for housing within a housing market area.
Supplementary Planning Document (SPD)
Documents which add further detail to the policies in the Local Plan. They can be used to provide further guidance for development on specific sites, or on particular issues, such as design. Supplementary planning documents are capable of being a material consideration in planning decisions but are not part of the development plan.
Sustainability Appraisal (SA)
Sustainability Appraisal is a systematic and iterative appraisal process, incorporating the requirements of the European Strategic Environmental Assessment Directive. The purpose of sustainability appraisal is to appraise the social, environmental and economic effects of the strategies and policies in a Local Development Document from the outset of the preparation process.
Sustainable transport modes
Any efficient, safe and accessible means of transport with overall low impact on the environment, including walking and cycling, low and ultra low emission vehicles, car sharing and public transport.
Transport assessment
A comprehensive and systematic process that sets out transport issues relating to a proposed development. It identifies what measures will be required to improve accessibility and safety for all modes of travel, particularly for alternatives to the car such as walking, cycling and public transport and what measures will need to be taken to deal with the anticipated transport impacts of the development.
Transport Statement
A simplified version of a transport assessment where it is agreed the transport issues arising out of development proposals are limited and a full transport assessment is not required.
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Travel Plan
A long term management strategy for an organisation or site that seeks to deliver sustainable transport objectives through action and is articulate in a document that is regularly reviewed.
Use Class Order
The Town and Country Planning (Use Classes) Order 1987 (as amended) puts uses of land and buildings into various categories known as 'Use Classes'.
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Lewisham Local Plan - Consultation on Main Issues 1
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Introduction to the Survey Questionnaire
Please read the consultation document and then complete the survey form.
The questions in the survey are organised into the same topics as in the consultation document.
If you are completing the survey on-line you can navigate through the form by selecting the topics in the menu tree on the left hand side of the screen.
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We look forward to receiving your views!
Your Contact Details
If you are completing a printed version of this form, or if you have not registered on the Council's consultation portal, you can enter your contact details in the box below. Pleaser include your e-mail address if you have one.
Privacy
The Council usually publishes the results of consultation on its website. If personal details are published this will be limited to your name and post code only.
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Would you like your details to be added to the Council's consultation database so you can be notified of future stage of the preparation of the Local Plan? (please select one answer)
Yes ...... No ...... Would you like to be notified by e-mail or by letter? (please select one answer)
Letter ......
E-mail ......
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Housing Topic questions
The Council must provide more housing over the next fifteen years. The target for the borough is to provide 25,000 additional dwellings between 2018-2033.
1. Where do you think the borough should accommodate more housing?
Sites in industrial or warehousing use
Redevelopment of Council housing estates at a higher density
Sites in town centres
Redevelopment of areas of private housing
Other
No opinion
2. If you answered 'Other' to Question 1 please tell us your ideas below.
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3. Do you think there are places in the borough where additional housing should not be built? If you agree then please list these areas below and state your reasons.
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4. What can the Council do to enable housing to be more affordable, and to increase the amount of affordable housing provided by developers of private housing?
The Council requires private developers to provide a proportion of affordable housing on their housing developments. By supplying confidential viability reports they can acheive a reduction in the amount of affordable housing they provide . The reduction of affordable housing on the grounds of viability is allowed by Government planning guidance.
(please select one answer for each question) Yes No No opinion Temporary prefabricated developments similar to the proposals at the former Ladywell Leisure Centre? Provide more social housing?
New housing with lower internal space standards to help people get on to the property ladder? Support self-build housing projects? Lower affordable housing rents?
Publish the contents of viability reports submitted by private housing developers? Other suggestion?
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5. If you answered 'Other suggestion' to question 4, please let us have your ideas as to how social housing could be made more affordable.
7. The Council currently seeks to negotiate 50% of any new housing provision as affordable housing. Do you think this amount should change? (please select one answer) Remain at 50% .... Increase to 60% .... Reduce to 35% .... Reduce to 20% .... No opinion .....
8. What design controls are needed to avoid any adverse impact of new housing on existing housing and on overall townscape quality? (please select all that apply)
Borough-wide restrictions on the height of buildings ...... Allowing tall buildings only in Lewisham and Catford Town Centres and major development sites identified as suitable ......
Introducing policies to restrict large developments in residential areas ...... Policies protecting new Areas of Special Residential Character (Conservation Areas are already protected) ......
Publish more design advice ......
Other ......
No opinion ......
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9. If you answered 'other' to question 8 please give your suggestions below
10. Should part of the increased housing target be met in neighbouring boroughs? (please select one answer)
Yes ...... No ...... No opinion ......
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Employment Topic Questions
These questions relate to the future of land and buildings in office, industrial/workshop and warehousing/storage uses.
1. Do you think that the Council should continue with the current strategy of gradually allowing poorer quality surplus industrial and warehousing land to be redeveloped for housing? (please select one answer)
Yes ...... No ...... No opinion ......
2. The Borough has a number of small scattered sites such as garages, builders yards, small workshops. When the owners of these sites propose to redevelop then for housing, how should the Council react?
Allow the residential development to be built
Retain the site in business use if it continues to provide local services
Seek a mixed use with part business and part housing
No opinion
3. Do you think that the replacement of industrial and office jobs by retail and/or leisure jobs is acceptable? (please select one answer)
Yes ...... No ...... No opinion ...... 4. What actions should the Council take to ensure that new large mixed use developments, like those in the Deptford New Cross Area, succeed in offering a variety of new jobs? (please select all that apply)
Provide subsidised business space ......
Make sure that the units are flexible and can be used by a variety of businesses ......
Ensure that business units are designed and fitted out to be attractive to new businesses ......
No opinion ......
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5. Do you have any further suggestions as to how to ensure these mixed use developments are attractive to new businesses?
6. Do you support the creation of business incubator uses which are premises provided at low rents, and flexible terms, to support starter businesses? (please select one answer)
Yes ...... No ...... No opinion ......
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7. How do you think the Council should continue to support creative industries which often rely on premises with cheaper rents which are vulnerable to rising residential land values?
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Retail and Town Centres Topic Questions
These questions relate to the borough's shopping facilities and how to keep them viable in the future.
1. The retail sector is facing various challenges including from the internet and changing shopping habits. What should the Council do in response to maintain the viability of the Major and District Town Centres?
Allow units at the edge of town centres to change to other uses
Promote uses in town centres according to their character and particular strengths
Maintain a core of convenience shops in a centre
Allow a wider range of entertainment and leisure uses including short term 'pop-up' lets such as art galleries No opinion
2. The Council can now limit the numbers of new betting shops and hot food take away shops. Should they be limited in: (please select one answer)
All areas of the borough? ......
In the larger shopping centres only? ......
In the smaller parades only? ......
No opinion ...... 4. In view of the changes to the retail sector, do you think there will be a need to plan for an orderly decline in the number of shops in the smaller centres and local parades? (please select one answer)
Yes ...... No ...... No opinion ...... 5. If your answer to question 4 is yes how should the Council go about this process? (please select all that apply)
Always maintain corner shops in retail use where there is an under provision ......
Allow losses at the edges of shopping parades in order to maintain a core of viable shops ......
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Council policy currently seeks to protect A1 shops in the borough's town centres and shopping parades. Examples of A1 shops are grocery shops, newsagents, and clothes shops.
2. Do you think that the Council should adopt a more flexible aproach to the change of use of A1 shops in town centres and shopping parades with high vacancy rates? (please select one answer)
Yes ...... No ...... No opinion ...... 6. Ideally, what sort of uses would you like to see maintained in local shopping parades?
7. The Council sets a size limit, currently 1,000 sq. m., for supermarkets close to local shopping centres in order to protect the viability of town centres. Proposals for larger new supermarkets must provide evidence that they woud not have a negative effect on the functioning of a town centre. To give an idea of the floorspace sizes the Lidl and Aldi Stores in Catford are each about 1,000 square metres (1,000 sq.m). The Tesco store in Catford is 3,364 sq.m. Should this size limit change or should the 1,000 sq.m limit be retained? (please select one answer) Retain 1,000 sq.m Increase to 2,000 sq. m. Increase to 3,000 sq. m. No opinion ...... threshold ...... 7. The Council sets a size limit, currently 1,000 sq. m., for supermarkets close to local shopping centres in order to protect the viability of town centres. Proposals for larger new supermarkets must provide evidence that they woud not have a negative effect on the functioning of a town centre. To give an idea of the floorspace sizes the Lidl and Aldi Stores in Catford are each about 1,000 square metres (1,000 sq.m). The Tesco store in Catford is 3,364 sq.m. Should this size limit change or should the 1,000 sq.m limit be retained? (please select one answer) Retain 1,000 sq.m Increase to 2,000 sq.m. Increase to 3,000 sq.m. No opinion ...... threshold ......
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Lewisham Town Centre is currently a Major Centre. These centres generally contain over 50,000 sq.m of retail, leisure and service floorspace. A Metropolitan Centre typically contains at least 100,000 sq.m of floorspace, and has a greater variety of shops providing goods such as clothes, furniture and electrical equipment.
8. Should Lewisham Town Centre aspire to become a Metropolitan Town Centre? (please select one answer)
Yes ...... No ...... No opinion ...... 9. The Council intends to improve and redevelop Catford Town Centre. What approach do you think should be taken? (please select one answer)
Large scale comprehensive redevelopment to provide more shops at a modern standard ......
Seek incremental improvements as opportunities arise ......
No opinion ......
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Transport Topic Questions
These questions relate to how development should be located in relation to transport facilities.
1. Do you think that we should direct higher density development to places where good public transport is available, and restrict development in places with poor public transport? (please select one answer)
Yes ...... No ...... No opinion ...... 2. Should the Council require transport assessments/travel impact statements for all new developments or only for developments larger than a certain size threshold? (please select one answer)
For all new developments ......
For developments that are expected to generate a significant amount of traffic ......
For new developments of more than ten dwellings, ......
No opinion ...... 3. Should the Council require a Travel Plan to be provided for all large developments or only for those that will generate a 'significant' amount of traffic? (please select one answer)
For all large scale developments ......
For large developments that will generate a 'significant' amount of traffic ......
No opinion ...... 4. Should the Council adopt car parking standards from the London Plan or adopt local standards? (See Appendix 3 in the Consultation Document) (please select one answer)
Adopt the London Plan car parking standards ......
Adopt local car parking standards which restrict parking ......
Adopt local standards which allow more car parking ......
No opinion ...... 5. Should reduced parking provision for new developments be limited to areas or locations with controlled parking zones? (please select one answer)
Yes ...... No ...... No opinion ......
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Environment Topic Questions
These questions relate to how Town Planning can help address climate change, and how open space should be protected.
1. Do you think that the consultation paper deals adequately with climate change issues?
(please select one answer for each question) Yes No No opinion Flood risk
Higher and unseasonal temperatures
Urban heat island effect/urban greening Renewable energy and decentralised energy networks Heat gain and cooling within buildings
Water resources and efficiency
CO2 emissions
2. The borough is facing increased pressures from population growth, the need to expand school provision and budget pressures. Should the Council continue to protect all open space in the borough from pressures for development? (please select one answer)
Yes ...... No ...... No opinion ......
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3. Please give your reasons for your answer to question 2.
4. Should under-used communal green areas in housing estates be developed to create new housing, where this can be achieved without harming existing residential amenity? (please select one answer)
Yes ...... No ...... No opinion ......
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5. Do you know of any areas of open space that are not currently formally protected in the Local Plan and should be considered for designation? Please list them below:
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6. Do you know of any areas of open space that you think should be developed for other uses? Please list them below.
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7. What elements do you think will be important to consider when designing developments that minimise negative impacts from noise and light pollution, waste handling and impacts on air quality? Please let us have your ideas below:
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Urban Design and Conservation Topic Questions
These questions relate to the design quality of new built development, and to the preservation or enhancement of local heritage assets such as conservation areas and listed buildings.
1. Do you think the Council is taking the right approach to achieving high quality design, by varying the approach depending on the character of the area? (See Chapter 11 of the Consultation Paper) (please select one answer)
Yes ...... No ...... No opinion ...... 2. Do you think that the Council should create policies to protect the special characteristics of residential areas which are not designated as Conservation Areas? (please select one answer)
Yes ...... No ...... No opinion ......
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Community Facilities, Education and Health Topic Questions
These questions cover how the Council can ensure there are enough community faciities to both cater for existing residents and for new residential development.
1. How should the Local Plan address the need for community facilities and services including schools and health provision? (please select all that apply)
Safeguard sites for the future ......
Promote mixed use developments e.g. schools and housing on one site ......
Require the provision of facilities necesary to support new housing developments ......
Prevent the loss of facilities unless there is no demand ......
Policy promoting schools or the expansion of existing schools ......
No opinion ......
2. In order to provide new schools for the future and to maximise the use of available sites in the residential areas where new school places will be needed, do you agree that:
(please select all that apply) Yes No No opinion Innovative use of design should be allowed in order to deliver school expansion The development of school sites to a higher density (school and housing on one site) is acceptable where there is good public transport access 3. Should the Local Plan encourage facilities that could be used by more than one community group to maximise their value to the community? (please select one answer)
Yes ...... No ...... No opinion ......
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4. How do you think the Local Plan should support culture, health and well-being and leisure in Lewisham?
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The future of Lewisham?
We hope that you found the consultation document interesting and that it gave you an idea of the issues that Lewisham borough will need to plan for in the coming fifteen years. If you have any views on this future please let us have your comments below.
Thank you for the time you have taken to complete this questionnaire.
Your views are much appreciated, and will be reported to the Council who will consider them fully as part of the preparation of the new Local Plan for Lewisham.
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26 Lewisham Local Plan - Consultation on Main Issues
MAYOR AND CABINET
Report Title A New Lewisham Local Plan: consultation on main issues
Key Decision Yes Item No.
Ward All
Contributors Executive Director for Resources and Regeneration
Class Part 1 Date: 15 July 2015
1. Summary 1.1 The Planning Service is undertaking a first round of public consultation on the production of a new Lewisham wide Local Plan. There are statutory requirements which specify the process for adopting a Local Plan. These involve an early round of public consultation on the main issues to be addressed in the Local Plan. This round of consultation seeks to meet the requirements for initial consultation. As part of the development plan process the Lewisham constitution requires the consultation document be approved by Full Council.
2. Purpose 2.1 This report seeks the Mayor’s agreement to undertake public consultation on the main issues to be addressed in the new Lewisham Local Plan.
3. Recommendations 3.1 The Mayor is recommended to approve the Lewisham Local Plan: Consultation on Main Issues for public consultation and recommend the Full Council do the same. The consultation document is set out as Appendix 1 to this report.
3.2 The Mayor is recommended to delegate authority to the Executive Director of Resources and Regeneration to make any minor alterations to the consultation document prior to the start of the formal consultation.
4. Policy Context
4.1 The contents of this report are consistent with the Council's policy framework. The new Lewisham Local Plan will replace in time the current statutory plans for the borough. When adopted it will become part of the Lewisham policy framework and will contribute to the implementation of each of the Council’s ten priorities as follows:
• community leadership and empowerment • young people’s achievement and involvement
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• clean, green and liveable • safety, security and a visible presence • strengthening the local economy • decent homes for all • protection of children • caring for adults and older people • active, healthy citizens • inspiring efficiency, effectiveness and equity
4.2 The new Lewisham Local Plan will help give spatial expression to the Sustainable Community Strategy (Shaping Our Future) (SCS), which was prepared by the Local Strategic Partnership and adopted by the Council in May 2008. The new Borough Local Plan will also play a central role in the implementation of the SCS vision ‘Together we will make Lewisham the best place to live, work and learn’ and all of the six strategic priorities, which are:
• Ambitious and achieving – where people are inspired and supported to fulfil their potential • Safer – where people feel safe and live free from crime, antisocial behaviour and abuse • Empowered and responsible – where people are actively involved in their local area and contribute to supportive communities • Clean, green and liveable – where people live in high quality housing and can care for their environment • Healthy, active and enjoyable – where people can actively participate in maintaining and improving their health and well-being • Dynamic and prosperous – where people are part of vibrant communities and town centres, well connected to London and beyond
4.3 The new Lewisham Local Plan will help implement a range of other Council policies and strategies.
5. Background
5.1 The new Lewisham Local Plan, when adopted, will be part of Lewisham’s statutory planning framework. The National Planning Policy Framework (NPPF) 2012 changed the old development plan system which encouraged local planning authorities to produce a suite of development plan documents to one which encourages the production of a single local plan for the area. Paragraph 153 of the NPPF states ‘each local planning authority should produce a Local plan for its area….Any additional development plan documents should only be used where clearly justified’.
5.2 Lewisham has already produced and adopted a suite of development plan documents including the Core Strategy (2011); Site Allocations Local Plan (2013); Lewisham Town Centre Local plan (2014) and the Development Management Local Plan (2014). The Core Strategy is the key planning document and set out the spatial
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strategy to deliver growth over the period 2011 – 2026 and is the document all the other development plan documents seek to implement.
5.3 There are three basic reasons why we need to update and replace our development plan documents. Firstly, the many Government changes to national planning policy means there is a danger of our policies being considered out of date. The Core Strategy was adopted prior to the NPPF and our policies are required to be in conformity with national policy. The Government have also made a number of other policy changes that impact on our current policies and therefore need to be revised. For example, there have been changes to national policy relating to affordable housing, residential space standards and change of use of retail units and these and other changes need to be reflected in Lewisham planning policy.
5.4 Secondly, the London Plan (2011) has been changed three times since the Core Strategy was adopted. The borough development plan is required to be in general conformity with the London Plan. Our policies could therefore be considered out of date regarding the London Plan. In particular, the latest Further Alterations to the London Plan adopted May 2015 has set new minimum housing targets for the borough. These are new challenging minimum targets for Lewisham and have risen from 1,100 to 1,385 new homes per annum. The new plan will have to say how Lewisham intends to deliver these and possibly higher targets identified from the objectively assessed need methodology.
5.5 Thirdly, there have been many social and economic changes since the Core Strategy was adopted in 2011. The household and population growth in London has been much higher than predicted. The 2011 Census showed that London’s population had already exceeded 8 million yet the prediction had been that it would not reach this level until 2016. This growth has multiple consequences included demand for housing and health and education infrastructure. The global economic recession of 2008 had impacts on many sectors of the economy, for example, some house building programmes were stalled and many high street shops went out of business. The current evidence shows that Lewisham is doing relatively well on house building and in relation to vacant shop units but nevertheless there have been impacts which need to be addressed in the new plan.
5.6 The NPPF, paragraph 213 states ‘Plans may, therefore, need to be revised to take into account the policies in this framework. This should be progressed as quickly as possible, either through a partial review or by preparing a new plan.’ If the development plan for the borough is not kept up to date planning decisions will be challenged and Inspectors will give the policies less weight in decisions on planning appeals. These factors all indicate the need for a new local plan for the borough.
5.7 The process for adopting a development plan is prescribed by legislation and government guidance. Of particular importance are the Planning and Compulsory Purchase Act 2004 (as amended); the Town and Country Planning (Local Planning) (England) Regulations 2012 and the National Planning Policy Framework (NPPF) which was introduced in March 2012.
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5.8 In summary, the regulations and guidance indicate that a new Lewisham Local Plan will need to address the following stages: • Consultation on Issues and Options (regulation 18) • Consultation on Preferred Options (regulation 18) • Consultation on Proposed Submission and Submission Plan (regulations 19-22) • Independent Examination in Public (regulation 24) • Inspectors report on ‘soundness’ (regulation 25) • Adoption by Council (regulation 26)
6. New Lewisham Local Plan – First Stage Public Consultation
6.1 As indicated above the regulations require an early round of consultation with the public and other stakeholders. This initial round of consultation must notify interested people about the intention to produce a new borough local plan and identify the main issues that the local plan will address and invite representations on these topics. Officers propose to meet this statutory requirement by consulting on the proposed spatial strategy and the main issues the new Lewisham local plan will address. The first stage public consultation document is set out as Appendix 1 to this report.
6.2 The NPPF and National Planning Policy Guidance (NPPG) make clear that Local Planning Authorities should work with infrastructure providers and other authorities to assess the quality and capacity of existing infrastructure, identify future needs and set out what infrastructure is required to deliver the development plan. The Council prepared an Infrastructure Delivery Plan (IDP) in 2010 to inform and support the current Core Strategy and, subsequently, the development of Lewisham’s Community Infrastructure Levy (CIL). Work has started on revising the scope and content of the IDP to inform the new Lewisham Local Plan and revised CIL. It is proposed to consult on the baseline study for the new IDP alongside the consultation on the new Lewisham Local Plan. This document will establish a baseline of existing infrastructure facilities, key relevant strategies and plans and current committed and planned infrastructure projects.
6.3 The Regulations and the Council’s adopted Statement of Community Involvement (SCI) require the Planning Service to consult the public and other stakeholders at regular intervals during the preparation of the new Borough Local Plan. This first round of public consultation will run for a minimum period of 6 weeks and will involve a number of different techniques of consultation. This will involve, but is not limited to, display on the council web site; placing copies in all libraries; mail out to all those on the planning policy database and a series of targeted meetings with the community and business interests. The details are set out in the Consultation Strategy attached as Appendix 2 to this report.
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7. Summary of Main issues consultation document
7.1 The new ‘Lewisham Local Plan: Consultation on Main Issues’ is set out as Appendix 1 to this report. The document is structured as follows: • Introduction • Drivers for Change • The Spatial Strategy • Housing • Employment • Retail • Transport • The Environment • Urban Design and Conservation • Community Facilities, Education and Health • Next Steps
7.2 The introduction sets the scene and explains why a new Local Plan is needed and that a Sustainability Appraisal will be produced alongside the Local Plan to ensure it is the most sustainable plan we can achieve. The Drivers of Change section sets out the extent of the challenge given by the population growth and housing need. The Spatial Strategy section reviews the strategy set out in the Core Strategy and finds it generally fit for purpose but acknowledges that new sites and further intensification will be required.
7.3 The bulk of the document then addresses subject topics to identify the main issues that the new Lewisham Local Plan will need to deal with. Each section provides a summary of the national and regional policy requirements; reviews the evidence available, sets out the main issues to be addressed and then asks some consultation questions on the approach proposed. A summary is given below.
7.4 Housing is probably the biggest challenge the new Local Plan must address. This section sets out the planning policy requirements for Lewisham to meet including the objectively assessed need for 25,000 new homes in the Local Plan period 2018-2033. It reviews the need for affordable housing; the governments new national housing standards which mean Lewisham must op- in to these higher standards through its Local Plan. Other issues the Local plan will address include the need for older people and student housing; development in back gardens and infill sites; conversion of lager dwellings into flats; houses in multiple occupation and residential design and density.
7.5 The Employment section discusses the land and buildings in the borough that are used for employment, that is, employment in offices, industry and warehouses. The trends in these uses are discussed and the current policy to classify employment land as strategic industrial land, local employment land, mixed use employment land and other employment land, is described. The current policy is to protect the best quality sites while allowing redevelopment
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on poorer quality sites. Some consultation questions are asked concerning future policy direction.
7.6 The Retail section sets out the current retail hierarchy for planning purposes and discusses some of the issues that face the different centres. The Major centres at Lewisham and Catford and the district centres at Blackheath, Deptford, Downham, Forest Hill, Lee Green, New Cross and Sydenham, all perform a different role and function. The main issues are how to maintain vibrant town centres; dealing with the variety and type of uses and vacant properties. At the local shopping level the main issue is economic viability and change of use away from a shop to other uses such as residential or take away uses.
7.7 The Transport section considers the delivery of large scale transport infrastructure such as the proposed Bakerloo Line extension and improvements to the A205 South Circular at Catford. These schemes are delivered by strategic providers such as Transport for London or Network Rail and the Council has a promotional role to influence early provision. Other transport issues considered are the location of large scale development in areas of good public transport provision; Parking in new development; promoting walking and cycling and protecting essential transport infrastructure such as bus garages from redevelopment.
7.8 The Environment section deals with issues relating to climate change, sustainability, open space, waste and environmental protection. Current policy in relation to sustainable development refers to the Code for Sustainable Homes which the Government has abolished so a new approach will be required. The increased population will put extra pressure on the use of Lewisham’s open spaces and policy will need to protect these valuable assets. The London Plan directs the Borough to find sites to deal with waste and this will need to be reviewed. Other issues concerning environmental protection relating to air quality, land contamination and noise will also need to be addressed.
7.9 The Urban Design and Conservation section deals with issues relating to high quality design, the creation of visually interesting and coherent townscape, the creation and preservation of residential amenity and the preservation or enhancement of conservation areas and listed buildings. The issue of increased density while maintaining quality and a ‘sense of place’ is covered as is the issue of maintaining the character of certain areas which might experience rapid change and growth.
7.10 The Community facilities, Education and Health section deals with the social infrastructure necessary for a sustainable community. These facilities include: education, healthcare, leisure, arts, cultural, entertainment, sports, emergency services, places of worship and cemeteries. The main issue for community facilities is protecting those which are needed from inappropriate
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redevelopment. In education, it is providing enough school places for the growing population and in health it is how to use the planning system to help improve the general health of the population.
7.11 The Next Steps section sets out the process for delivering the new Local Plan. The comments made at this early consultation will be taken into account to inform a more detailed consultation on policy options for early next year. Following that consultation a draft Local Plan will be prepared for submission to the Planning Inspectorate for an independent review. The Inspector will make recommendations about changes which the Council must make before it can go onto adopt the new Local Plan.
8. Financial Implications 8.1 There are no direct financial implications arising from this report. The consultation will be delivered within the agreed Planning Service budget.
9. Legal Implications 9.1 The procedures which the Council is required to follow when producing a new local plan derive from the Planning and Compulsory Purchase Act 2004 and the Town and Country Planning (Local Planning) (England) Regulations 2012.
9.2 This report seeks authority to consult on the Council’s proposed intention to create a new local plan.
9.3 The Equality Act 2010 (the Act) introduced a new public sector equality duty (the equality duty or the duty). It covers the following nine protected characteristics: age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation. In summary, the Council must, in the exercise of its functions, have due regard to the need to:
• eliminate unlawful discrimination, harassment and victimisation and other conduct prohibited by the Act. • advance equality of opportunity between people who share a protected characteristic and those who do not. • foster good relations between people who share a protected characteristic and those who do not.
9.4 The duty continues to be a “have regard duty”, and the weight to be attached to it is a matter for the decision maker, bearing in mind the issues of relevance and proportionality. It is not an absolute requirement to eliminate unlawful discrimination, advance equality of opportunity or foster good relations.
9.5 The Equality and Human Rights Commission provides Technical Guidance on the Public Sector Equality Duty and statutory guidance entitled “Equality Act 2010 Services, Public Functions & Associations Statutory Code of Practice”. The Council must have regard to the statutory code in so far as it relates to the duty and attention is drawn to Chapter 11 which deals particularly with the equality duty. The Technical Guidance also covers what public authorities
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should do to meet the duty. This includes steps that are legally required, as well as recommended actions. The guidance does not have statutory force but nonetheless regard should be had to it, as failure to do so without compelling reason would be of evidential value. The statutory code and the technical guidance can be found at: http://www.equalityhumanrights.com/legal-and-policy/equality-act/equality-act- codes-of-practice-and-technical-guidance/
9.6 The Equality and Human Rights Commission (EHRC) has previously issued five guides for public authorities in England giving advice on the equality duty:
1. The essential guide to the public sector equality duty 2. Meeting the equality duty in policy and decision-making 3. Engagement and the equality duty 4. Equality objectives and the equality duty 5. Equality information and the equality duty
9.7 The essential guide provides an overview of the equality duty requirements including the general equality duty, the specific duties and who they apply to. It covers what public authorities should do to meet the duty including steps that are legally required, as well as recommended actions. The other four documents provide more detailed guidance on key areas and advice on good practice. Further information and resources are available at: http://www.equalityhumanrights.com/advice-and-guidance/public-sector- equality-duty/guidance-on-the-equality-duty/
10. Crime and Disorder Implications 10.1 There are no direct implications relating to crime and disorder issues.
11. Equalities Implications
11.1 The Council’s Comprehensive Equality Scheme for 2012-16 provides an overarching framework and focus for the Council's work on equalities and helps ensure compliance with the Equality Act 2010. The proposals set out in this report accord with the Council’s Comprehensive Equalities Scheme; particularly as they relating to: ‘increasing participation and engagement’ .
11.2 The process of producing the new Local Plan will include an equalities appraisal to identify equalities impacts and implications of emerging policy options.
12. Environmental Implications 11.1 There are no direct environmental impacts arising from this report.
13. Conclusion 13.1 The Planning Service will be consulting on the first stage of preparing a new Lewisham Local Plan this year. This early round of consultation is intended to notify the public and other specified bodies about the Councils intention to
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produce a new Local Plan and identify the main issues that the new Plan will seek to address. There are formal regulations that specify what consultation must take place and as a minimum these will be met.
14. Background documents and originator
Short Title Date File File Contact Exempt Document Location Reference Officer Planning & 2004 Laurence Planning Brian No Compulsory House Policy Regan Purchase Act 2004 Localism 2011 Laurence Planning Brian No Act 2011 House Policy Regan National 2012 Laurence Planning Brian No Planning House Policy Regan Policy Framework (NPPF) 2012 Town and 2012 Laurence Planning Brian No Country House Policy Regan Planning (Local Planning) (England) Regulations 2012
If you have any queries on this report, please contact Brian Regan, Planning Policy Manager, 3rd floor Laurence House, 1 Catford Road, Catford SE6 4RU – telephone 020 8314 8774.
Appendix 1: New Lewisham Local Plan – Consultation on Main Issues
Appendix 2: Borough Local Plan – consultation strategy
9 Council
Title Byelaws for Parks and Open Spaces
Key decision Yes Item no
Wards All
Contributors Executive Director for Customer Services
Class Part 1 23 September 2015
1. Summary
1.1 The Council is responsible for various parks, open spaces and gardens in the Borough. The conduct of the public in these locations is regulated by byelaws, which aim to ensure that everyone is reasonably able to use the spaces without unreasonably inconveniencing other users. The byelaws were last updated in 1980 and over time the nature of park usage has altered and the expectations of park users have also changed. The updated byelaws reflect the way in which the Borough’s parks and open spaces are used today and the reasonable expectations of users. The updating also ensures that they are easier for park users to understand.
2. Policy Context
2.1 Shaping the Future – the Councils Sustainable Community Strategy sets out the broad themes that describe a ‘sense of place’ that all Council services aspire to. It has six priority areas to which open space contributes to:
Ambitious and Achieving – where people are inspired and supported to fulfill their potential Celebrate local achievement so people feel proud of their area and eager to be a part of its success Safer – where people feel safe and live free from crime, anti-social behaviour and abuse Tackle antisocial behavior and ensure that people feel confident and safe throughout the borough Keep our children and young people safe from harm, abuse and criminal activity Empowered and responsible - where people are actively involved in their local area and contribute to supportive communities -Empower citizens to be involved in their local area and responsive to the needs of those who live there. -Champion diversity and the contribution everyone makes to the borough’s quality of life Clean, green and livable – where people live in high quality housing and care for and enjoy their environment - protect and enhance our parks, open spaces and local biodiversity
Healthy, active and enjoyable – where people can actively participate in maintaining and improving their health and well-being -improving the well-being of our citizens by increasing participation in healthy and active lifestyles
2.2 Alongside the above the Corporate Strategy sets out the specific contribution of the Council to the delivery of Shaping our future. The strategy has 10 corporate priorities including “clean green and liveable” which has a commitment to “maximise access to and use of our open spaces by all communities and organisations, making them feel safe and open to all”.
2.3 The Council’s Open Space Strategy 2012-17 sets out as one of its key themes to promote a safe and secure environment. 2.4 The Mayor approved at Mayor and Cabinet 15th July 2015 the report for Council to make the new byelaws for parks and open spaces in the form attached to this report and that they revoke the existing byelaws made in 1980.
3. Recommendations
It is recommended that Council
3.1 makes the new byelaws for parks and open spaces in the form attached to this report, and that they revoke the existing byelaws made in 1980.
4. Purpose
4.1 The purpose of this report is for Council to approve the making of the new set of parks Byelaws, and the revocation of the existing set which were made in 1980.
5. Narrative
5.1 The Council is responsible for public parks, open spaces and gardens in the Borough. The conduct of the public in these locations is currently regulated by byelaws, which aim to ensure that everyone is reasonably able to use the spaces without unreasonably inconveniencing other users.
5.2 The byelaws were last updated in 1980 although an attempt was made in 2004 to introduce new ones but they were never confirmed by the Secretary of State and therefore did not replace the 1980 byelaws. Over time the nature of park usage has altered as has the expectations of users. In addition, the penalties which may be imposed in serious cases of breach are insufficient to act as a deterrent. 5.3 The Open Space Strategy 2012-17 sets out as a key theme to promote a safe and secure environment and has an objective (6.1) to tackle antisocial behaviour and reduce fear of crime. The updated byelaws therefore are required to reflect the way in which the Borough’s parks and open spaces are used today and the responsible expectations of users. The updated byelaws, which are based upon model wording published by the Department for Communities and Local Government (DCLG), also ensures that they are easier for park users to understand. Because certain of the model byelaws have been amended to address specific Lewisham requirements, provisional approval had to be sought from DCLG, who have now given their provisional approval for the byelaws to be made in the form attached to this report.
5.4 Officers from Green Scene have liaised with the Lewisham Parks Forum, made up of members of all the friends and user groups, to garner their views and take comments. Responses are available in the Background paper attached.
5.5 The adoption of clearly set out and updated byelaws will assist the agencies involved with park policing (Glendale, Community Safety team, Police, Environment Enforcement officers etc), to enforce these rules and regulations, principally through persuasion. These groups will help co-ordinate future enforcement of the byelaws and other associated Acts of Parliament which apply to the parks environment, for example the Environmental Protection Act 1990 and Clean Neighbourhood and Environment Act 2005 (Dog Control Order). Enforcement is likely to take place at targeted enforcement sessions rather than on an ad-hoc basis. Members of the public who contravene a byelaw will be given a written caution for a first offence. However, any person offending against any of these byelaws shall be liable on conviction at the Magistrates Court to a fine not exceeding level 2 on the standard scale (currently up to £500.) An effective deterrent will therefore exist to deal with serious contraventions of the byelaws.
5.6 The draft set of byelaws attached to this report has been subject to discussion with the Lewisham Parks Forum (Friends and User Groups). As a result of that process several recurring themes have emerged which include issues covered by existing criminal law. The point to note is that where the existing criminal law deals with a problem, the Council is unable to duplicate that in a byelaw. The existing criminal law covers issues such as dog fouling, littering and fly-tipping and in most cases imposes a higher maximum penalty than would apply under the byelaws. Some members of the Lewisham Parks Forum felt that the Council should not ban the climbing of trees or the use of BBQ’s. Both these matters are included in the model byelaws for health and safety and environmental reasons.
5.7 A certain amount of training will be required for Glendale’s parks services team, to carry out informal enforcement duties. This will be undertaken within the terms of the current parks contract. 5.8 The new byelaws must be displayed and or be available for the public to read and a number of signs highlighting specific clauses must be erected. The cost of signage, or amendments to signage is anticipated to be in the region of £1000.
6. Financial implications
6.1 The cost of adopting the new byelaws is limited to the cost of signage, or amendments to signage which is anticipated to be in the region of £1000. This will be contained within the Green Scene budget.
6.2 The training required for Glendale’s parks services team to carry out informal enforcement duties will be undertaken within the terms of the current parks contract, at no additional cost to the Council.
7. Legal implications
7.1. Section 164 of the Public Health Act 1875 and Section 15 of the Open Spaces Act 1906 enable local authorities to make byelaws for the regulation of public walks and pleasures grounds and of open space and burial ground respectively. Section 12 of the Open Spaces Act 1906 extends the types of land for which byelaws can be made under section 15 of that Act.
7.2. The Local Authorities (Functions and Responsibilities) (England) Regulations 2000 provides that the power to make, amend, revoke, re-enact or enforce byelaws shall not be the responsibility of the Council’s executive. Furthermore the Council’s constitution reserves the making altering and revoking of byelaws to full council.
7.3. The procedure for making byelaws is set out in Section 236 of the Local Government Act 1972. That section provides that byelaws must be made under the common seal of the authority making them. The authority must then apply to the relevant Secretary of State, which in this case is the Secretary of State for Communities and Local Government, for confirmation. At least a month before seeking such confirmation the Council must publish a notice in a local newspaper indicating its intention to do so. During this month a copy of the byelaws must be made available at all reasonable hours at the Council’s offices for public inspection. There is no legal requirement for a formal consultation process for new byelaws.
7.4 Any objections to the byelaws should be sent to the Secretary of State for Communities and Local Government. The Secretary of State may confirm, or refuse to confirm, any byelaw submitted for confirmation, and may fix the date on which the byelaws are to come into operation and if no date is so fixed the byelaw shall come into operation at the expiration of one month from the date of its confirmation.
8. Crime and disorder implications 8.1 The byelaws will facilitate and enhance reasonable use of the Borough’s parks and open spaces, while at the same time providing a more effective deterrent to serious instances of park misuse.
9. Equalities implications
9.1 The adoption of the new byelaws will clearly set out rules and regulations, which aim to ensure that all members of the community are able to use parks without unreasonably inconveniencing other users.
10. Environmental implications
10.1 A number of byelaws specifically set out to protect the environment, for example protection of flower beds, trees and grassland and the protection of lakes and water courses. Byelaws also include for the protection of fish and other wildlife.
11. Conclusion
11.1 The adoption of the new set of byelaws will provide the community with clearly set out rules and regulations as to how members of the public should conduct themselves in parks and open spaces.
12. Background documents and originator
12.1 There are no background documents to this report.
12.2 If you require further information please contact Martin Hyde, Green Space Regeneration Manager on 020 8314 2034. Appendix
1. LONDON BOROUGH OF LEWISHAM
BYELAWS FOR PLEASURE GROUNDS, PUBLIC WALKS AND OPEN SPACES
ARRANGEMENT OF BYELAWS
PART 1 GENERAL 1. General interpretation 2. Application 3. Opening times
PART 2 PROTECTION OF THE GROUND, ITS WILDLIFE AND THE PUBLIC 4. Protection of structures and plants 5. Unauthorised erection of structures 6. Climbing 7. Grazing 8. Protection of wildlife 9. Gates 10. Camping 11. Fires 12. Missiles 13. Interference with life-saving equipment PART 3 HORSES, CYCLES AND VEHICLES 14. Interpretation of Part 3 15. Horses - Horse riding prohibited (subject to any bridleway, etc) 16. Cycling 17. Motor vehicles 18. Overnight parking
PART 4 PLAY AREAS, GAMES AND SPORTS 19. Interpretation of Part 4 20. Children’s play areas 21. Children’s play apparatus 22. Skateboarding, etc - Skateboarding, etc permitted but must not cause danger or annoyance 23. Ball games - Prohibition of ball games 24. Ball games - Ball games permitted throughout the ground but designated area for ball games also provided 25. Ball games - Rules 26. Cricket 27. Archery 28. Field sports 29. Golf - Prohibited except on golf course 30. Golf - Permitted where part of ground is set aside as a golf course
PART 5 WATERWAYS 31. Interpretation of Part 5 32. Bathing 33. Ice skating 34. Model boats 35. Boats - To prohibit use of boats, etc without permission except in designated area 36. Fishing 37. Blocking of watercourses PART 6 MODEL AIRCRAFT 38. Interpretation of Part 6 39. Model aircraft - General prohibition
PART 7 OTHER REGULATED ACTIVITIES 40. Provision of services 41. Excessive noise 42. Public shows and performances 43. Aircraft, hang-gliders and hot air balloons 44. Kites 45. Metal detectors
PART 8 MISCELLANEOUS 46. Obstruction 47. Savings 48. Removal of offenders 49. Penalty 50. Revocation - General
SCHEDULE 1 - Grounds to which byelaws apply generally SCHEDULE 2 - Grounds referred to in certain byelaws SCHEDULE 3 - Rules for playing ball games in designated areas Byelaws made under section 164 of the Public Health Act 1875 section 15 of the Open Spaces Act 1906 sections 12 and 15 of the Open Spaces Act 1906 by the LONDON BOROUGH OF LEWISHAM with respect to pleasure grounds, public walks and open spaces.
PART 1 GENERAL General Interpretation 1. In these byelaws:
“the Council” means the London Borough of Lewisham;
“the ground” means any of the grounds listed in Schedule 1;
“designated area” means an area in the ground which is set aside for a specified purpose, that area and its purpose to be indicated by notices placed in a conspicuous position;
“invalid carriage” means a vehicle, whether mechanically propelled or not,
(a) the unladen weight of which does not exceed 150 kilograms,
(b) the width of which does not exceed 0.85 metres, and
(c) which has been constructed or adapted for use for the carriage of a person suffering from a disability, and used solely by such a person.
Application
2. These byelaws apply to all of the grounds listed in Schedule 1 unless otherwise stated.
Opening times
3. (1) No person shall enter or remain in the ground except during opening hours.
(2) “Opening hours” means the days and times during which the ground is open to the public and which are indicated by a notice placed in a conspicuous position at the entrance to the ground.
(3) Byelaw 3(1) applies only to the grounds listed in Schedule 2 Part 1.
PART 2
PROTECTION OF THE GROUND, ITS WILDLIFE AND THE PUBLIC
Protection of structures and plants 4. (1) No person shall without reasonable excuse remove from or displace within the ground:
(a) any barrier, post, seat or implement, or any part of a structure or ornament provided for use in the laying out or maintenance of the ground; or
(b) any stone, soil or turf or the whole or any part of any plant, shrub or tree.
(2) No person shall walk on or ride, drive or station a horse or any vehicle over:
(a) any flower bed, shrub or plant;
(b) any ground in the course of preparation as a flower bed or for the growth of any tree, shrub or plant; or
(c) any part of the ground set aside by the Council for the renovation of turf or for other landscaping purposes and indicated by a notice conspicuously displayed.
Unauthorised erection of structures
5. No person shall without the consent of the Council erect any barrier, post, ride or swing, building or any other structure.
Climbing
6. No person shall without reasonable excuse climb any wall or fence in or enclosing the ground, or any tree, or any barrier, railing, post or other structure.
Grazing
7. No person shall without the consent of the Council turn out or permit any animal for which he is responsible to graze in the ground.
Protection of wildlife
8. No person shall kill, injure, take or disturb any animal, or engage in hunting or shooting or the setting of traps or the laying of snares.
Gates
9. (1) No person shall leave open any gate to which this byelaw applies and which he has opened or caused to be opened.
(2) Byelaw 9(1) applies to any gate to which is attached, or near to which is displayed, a conspicuous notice stating that leaving the gate open is prohibited.
Camping 10. No person shall without the consent of the Council erect a tent or use a vehicle, caravan or any other structure for the purpose of camping.
Fires
11. (1) No person shall light a fire or place, throw or drop a lighted match or any other thing likely to cause a fire.
(2) Byelaw 11(1) shall not apply to the lighting of a fire at any event for which the Council has given permission that fires may be lit
Missiles
12. No person shall throw or use any device to propel or discharge in the ground any object which is liable to cause injury to any other person.
Interference with life-saving equipment
13. No person shall except in case of emergency remove from or displace within the ground or otherwise tamper with any life-saving appliance provided by the Council.
PART 3
HORSES, CYCLES AND VEHICLES
Interpretation of Part 3
14. In this Part:
“designated route” means a route in or through the ground which is set aside for a specified purpose, its route and that purpose to be indicated by notices placed in a conspicuous position;
“motor cycle” means a mechanically-propelled vehicle, not being an invalid carriage, with less than four wheels and the weight of which does not exceed 410 kilograms;
“motor vehicle” means any mechanically-propelled vehicle other than a motor cycle or an invalid carriage;
“trailer” means a vehicle drawn by a motor vehicle and includes a caravan.
Horses
15. (1) No person shall ride a horse except:
(a) in any of the grounds listed in Part 2 of Schedule 2; or
(b) in the exercise of a lawful right or privilege.
(2) Where horse-riding is permitted in any ground by virtue of byelaw 15(1)(a) or a lawful right or privilege, no person shall ride a horse in such a manner as to cause danger to any other person. Cycling
16 No person shall without reasonable excuse ride a cycle in the ground except in any part of the ground where there is a right of way for cycles
Motor vehicles
17 (1) No person shall without reasonable excuse bring into or drive in the ground a motor cycle, motor vehicle or trailer except in any part of the ground where there is a right of way or a designated route for that class of vehicle.
(2) Where there is a designated route for motor cycles, motor vehicles or trailers, it shall not be an offence under this byelaw to bring into or drive in the ground a vehicle of that class for the sole purpose of transporting it to the route.
Overnight parking
18 No person shall without the consent of the Council leave or cause or permit to be left any motor vehicle in the ground between the hours of 10 p.m. and 6 a.m..
PART 4
PLAY AREAS, GAMES AND SPORTS
Interpretation of Part 4
19 In this Part:
“ball games” means any game involving throwing, catching, kicking, batting or running with any ball or other object designed for throwing and catching, but does not include cricket;
“golf course” means any area within the ground set aside for the purposes of playing golf and includes any golf driving range, golf practice area or putting course;
“self-propelled vehicle” means a vehicle other than a cycle, invalid carriage or pram which is propelled by the weight or force of one or more persons skating, sliding or riding on the vehicle or by one or more persons pulling or pushing the vehicle.
Children’s play areas 20 No person aged 13 years or over shall enter or remain in a designated area which is a children’s play area unless in charge of a child under the age of 13 years.
Children’s play apparatus
21 No person aged 13 years or over shall use any apparatus stated to be for the exclusive use of persons under the age of 13 years by a notice conspicuously displayed on or near the apparatus.
Skateboarding, etc
22 No person shall skate, slide or ride on rollers, skateboards or other self- propelled vehicles in such a manner as to cause danger or give reasonable grounds for annoyance to other persons.
Ball games
Prohibition of ball games
23 No person shall play ball games in the grounds listed in Schedule 2 Part 3.
24 No person shall play ball games outside a designated area for playing ball games in such a manner:
(a) as to exclude persons not playing ball games from use of that part;
(b) as to cause danger or give reasonable grounds for annoyance to any other person in the ground; or
(c) which is likely to cause damage to any tree, shrub or plant in the ground.
25 It is an offence for any person using a designated area for playing ball games to break any of the rules set out in Schedule 3 and conspicuously displayed on a sign in the designated area when asked by any person to desist from breaking those rules.
Cricket
26 No person shall throw or strike a cricket ball with a bat except in a designated area for playing cricket.
Archery
27 No person shall engage in the sport of archery except in connection with an event organised by or held with the consent of the Council.
Field sports 28 No person shall throw or put any javelin, hammer, discus or shot except in connection with an event organised by or held with the consent of the Council or on land set aside by the Council for that purpose.
Golf
29 No person shall drive, chip or pitch a hard golf ball except on the golf course.
30 (1) No person shall play golf on the golf course unless he holds a valid ticket issued by or on behalf of the Council entitling him to do so, which ticket shall be retained and shown on demand to any authorised officer or agent of the Council.
(2) No person shall enter on to or remain on the golf course unless:
(a) taking part in the game of golf or accompanying a person so engaged; or
(b) doing so in the exercise of a lawful right or privilege.
(3) No person shall offer his service for hire as an instructor on the golf course without the consent of the Council.
PART 5
WATERWAYS
Interpretation of Part 5
31 In this Part:
“boat” means any yacht, motor boat or similar craft but not a model or toy boat;
“power-driven” means driven by the combustion of petrol vapour or other combustible substances;
“waterway” means any river, lake, pool or other body of water and includes any fountain.
Bathing
32 No person shall without reasonable excuse bathe or swim in any waterway except in a designated area for bathing and swimming.
Ice skating
33 No person shall step onto or otherwise place their weight upon any frozen waterway.
Model boats 34 No person shall operate a power-driven model boat on any waterway except in a designated area for model boats.
Boats
35 No person shall sail or operate any boat, dinghy, canoe, sailboard or inflatable on any waterway without the consent of the Council except in a designated area for the sailing or operation of boats.
Fishing
36 No person shall in any waterway cast a net or line for the purpose of catching fish or other animals except in a designated area for fishing.
Blocking of watercourses
37 No person shall cause or permit the flow of any drain or watercourse in the ground to be obstructed, diverted, open or shut or otherwise move or operate any sluice or similar apparatus.
PART 6
MODEL AIRCRAFT
Interpretation of Part 6
38 In this Part:
“model aircraft” means an aircraft which weighs not more than 7 kilograms without its fuel;
“power-driven” means driven by:
(a) the combustion of petrol vapour or other combustible substances;
(b) jet propulsion or by means of a rocket, other than by means of a small reaction motor powered by a solid fuel pellet not exceeding 2.54 centimetres in length; or
(c) one or more electric motors or by compressed gas.
.
General prohibition
39 No person shall cause any power-driven model aircraft to:
(a) take off or otherwise be released for flight or control the flight of such an aircraft in the ground; or (b) land in the ground without reasonable excuse.
PART 7
OTHER REGULATED ACTIVITIES
Provision of services
40 No person shall without the consent of the Council provide or offer to provide any service for which a charge is made.
Excessive noise
41 (1) No person shall, after being requested to desist by any other person in the ground, make or permit to be made any noise which is so loud or so continuous or repeated as to give reasonable cause for annoyance to other persons in the ground by:
(a) shouting or singing;
(b) playing on a musical instrument; or
(c) by operating or permitting to be operated any radio, amplifier, tape recorder or similar device.
(2) Byelaw 42(1) does not apply to any person holding or taking part in any entertainment held with the consent of the Council.
Public shows and performances
42 No person shall without the consent of the Council hold or take part in any public show or performance.
Aircraft, hang gliders and hot air balloons
43 No person shall except in case of emergency or with the consent of the Council take off from or land in the ground in an aircraft, helicopter, hang glider or hot air balloon.
Kites
44 No person shall fly any kite in such a manner as to cause danger or give reasonable grounds for annoyance to any other person.
Metal detectors
45 No person shall without the consent of the Council use any device designed or adapted for detecting or locating any metal or mineral in the ground.
PART 8 MISCELLANEOUS
Obstruction
46 No person shall obstruct:
(a) any officer of the Council in the proper execution of his duties;
(b) any person carrying out an act which is necessary to the proper execution of any contract with the Council; or
(c) any other person in the proper use of the ground.
Savings
47 (1) It shall not be an offence under these byelaws for an officer of the Council or any person acting in accordance with a contract with the Council to do anything necessary to the proper execution of his duty.
(2) Nothing in or done under these byelaws shall in any respect prejudice or injuriously affect any public right of way through the ground, or the rights of any person acting lawfully by virtue of some estate, right or interest in, over or affecting the ground or any part of the ground.
Removal of offenders
48 Any person offending against any of these byelaws may be removed from the ground by an officer of the Council or a constable.
Penalty
49 Any person offending against any of these byelaws shall be liable on summary conviction to a fine not exceeding level 2 on the standard scale.
Revocation
50 The byelaws made by the London Borough of Lewisham on 5th March 1980 and confirmed by Secretary of State for the Home Office on 18 August 1980 are hereby revoked. SCHEDULES SCHEDULE 1 GROUNDS TO WHICH BYELAWS APPLY GENERALLY The grounds referred to in byelaw 2 are: Baxter Field Beckenham Place Park Bellingham Green Bellingham Play Park Blythe Hill Fields Bridghouse Meadows Broadway Fields Brookmill Park Chinbrook Meadows Cornmill Gardens Deptford Memorial Gardens Deptford Park Downham Playing Fields Downham Woodland Walk Durham Hill Eckington Gardens Edith Nesbit Gardens Evelyn Green Ferranti Park Folkestone Gardens Fordham Park Forster Memorial Park Friendly Gardens Frendsbury Gardens Grove Park Library Gardens Hatcham Gardens Hilly Fields Home Park Horniman Play Park (Triangle) Kirkdale Green Ladywell Fields Ladywell Green Lewisham Memorial Gardens Lewisham Park Luxmore Gardens Manor House Gardens Manor Park Margaret McMillian Park Mayow Park Mountsfield Park Northbrook Park Pepys Park Ravensbourne Park Gardens River Pool Linear Park Riverdale sculpture park Riverview Walk Sayes Court Park Southend Park St. Andrew’s Churchyard (disused) St. Bartholomew’s Churchyard (disused) St. Margaret’s Churchyard (disused) St Mary’s Churchyard (disused) St Paul’s Churchyard (disused) (including Mary Ann Gardens) Sue Godfrey Nature Reserve Sydenham Wells Park Telegraph Hill Park SCHEDULE 2 GROUNDS REFERRED TO IN CERTAIN BYELAWS PART 1 OPENING TIMES BYELAW 3 (1) Beckenham Place Park Deptford Park Downham Woodland Walk Eckington Gardens Edith Nesbit Gardens Forster Memorial Park Frendsbury Gardens Grove Park Library Gardens Horniman Play Park (Triangle) Lewisham Park Luxmore Gardens Manor House Gardens Manor Park Mayow Park Mountsfield Park Northbrook Park St Paul's Churchyard disused (including Mary Ann Gardens) Sayes Court Park Southend Park Sydenham Wells Park Telegraph Hill Park (lower section)
PART 2 HORSE RIDING PROHIBITED EXCEPT IN CERTAIN GROUNDS (SUBJECT TO BRIDLEWAY, ETC) BYELAW 15 (1) Hilly Fields
PART 3 GROUNDS WHERE BALL GAMES ARE PROHIBITED BYELAW 24 Downham Woodland Walk Frendsbury Gardens Sayes Court Park St Paul’s Churchyard (disused) (including Mary Ann Gardens) Lewisham Memorial Gardens Deptford Memorial Gardens St Mary’s Churchyard (disused) St. Andrew’s Churchyard (disused) St. Bartholomew’s Churchyard (disused) St. Margaret’s Churchyard (disused) SCHEDULE 3 RULES FOR PLAYING BALL GAMES IN DESIGNATED AREAS (BYELAW 26)
Any person using a designated area for playing ball games is required by byelaw 26 to comply with the following rules:
(1) No person shall play any game other than those ball games for which the designated area has been set aside. (2) No person shall obstruct any other person who is playing in accordance with these rules. (3) Where exclusive use of the designated area has been granted to a person or group of persons by the Council for a specified period, no other person shall play in that area during that period. (4) Subject to paragraph (5), where the designated area is already in use by any person, any other person wishing to play in that area must seek their permission to do so. (5) Except where they have been granted exclusive use of the designated area for more than two hours by the Council, any person using that area shall vacate it if they have played continuously for two hours or more and any other person wishes to use that area. (6) No person shall play in the designated area when a notice has been placed in a conspicuous position by the Council prohibiting play in that area. Council
Title Byelaws for Blackheath (Lewisham section)
Key decision No Item no
Wards Blackheath
Contributors Executive Director For Customer Services
Class Part 1 23 September 2015
1. Summary
1.1 The Council is responsible for the section of Blackheath that lies within the borough boundary, that is the land to the south of the A2 trunk road. The conduct of the public in this location is regulated by byelaws, which aim to ensure that everyone is reasonably able to use the space without unreasonably inconveniencing other users. The byelaws, were made in 1932 by the London County Council and over time the nature of park usage has altered and the expectations of park users have also changed. The updated byelaws reflect the way in which Blackheath is used today and the reasonable expectations of users. The updating also ensures that they are easier for users of the Heath to understand.
2. Policy Context
2.1 Shaping the Future – the Councils Sustainable Community Strategy sets out the broad themes that describe a ‘sense of place’ that all Council services aspire to. It has six priority areas to which open space contributes to:
Ambitious and Achieving – where people are inspired and supported to fulfill their potential Celebrate local achievement so people feel proud of their area and eager to be a part of its success Safer – where people feel safe and live free from crime, anti-social behaviour and abuse Tackle antisocial behavior and ensure that people feel confident and safe throughout the borough Keep our children and young people safe from harm, abuse and criminal activity Empowered and responsible - where people are actively involved in their local area and contribute to supportive communities -Empower citizens to be involved in their local area and responsive to the needs of those who live there. -Champion diversity and the contribution everyone makes to the borough’s quality of life Clean, green and livable – where people live in high quality housing and care for and enjoy their environment - protect and enhance our parks, open spaces and local biodiversity
Healthy, active and enjoyable – where people can actively participate in maintaining and improving their health and well-being -improving the well-being of our citizens by increasing participation in healthy and active lifestyles
2.2 Alongside the above the Corporate Strategy sets out the specific contribution of the Council to the delivery of Shaping our future. The strategy has 10 corporate priorities including “clean green and liveable” which has a commitment to “maximise access to and use of our open spaces by all communities and organisations, making them feel safe and open to all”.
2.3 The Council’s Open Space Strategy 2012-17 sets out as one of its key themes to promote a safe and secure environment. 2.4 The Mayor approved at Mayor and Cabinet 15th July 2015 the report for Council to make the new byelaws for parks and open spaces in the form attached to this report and that they revoke the existing byelaws made in 1980.
3. Recommendations
It is recommended that Council
3.1 makes the new byelaws for Blackheath in the form detailed in the Appendix to this report, and revoke the existing byelaws for Blackheath made in 1932.
4. Purpose
4.1 The purpose of this report is for Council to approve the making of the new set of Byelaws for Blackheath, and the revocation of the existing set.
5. Narrative
5.1 The Council is responsible for the management and maintenance of Blackheath that lies to the south of the A2 trunk road. The section to the north of the A2 is managed and maintained by the Royal Borough of Greenwich who have their own set of byelaws. Officers attempted on numerous occasions to try to make joint byelaws with Greenwich but they chose to go their own way. The conduct of the public in this location is currently regulated by byelaws, which aim to ensure that everyone is reasonably able to use the space without unreasonably inconveniencing other users.
5.2 The byelaws were made in 1932 and over time the nature of park usage has altered as has the expectations of users. In addition, the penalties which may be imposed in serious cases of breach are insufficient to act as a deterrent. 5.3 The Open Space Strategy 2012-17 sets out as a key theme to promote a safe and secure environment and has an objective (6.1) to tackle antisocial behaviour and reduce fear of crime. The updated byelaws therefore are required to reflect the way in which the Borough’s parks and open spaces are used today and the responsible expectations of users. The updated byelaws, which are based upon a model set published by the Department for Environment, Food and Rural Affairs (DEFRA), also ensures that they are easier for users of the Heath to understand. Because certain of the model byelaws were amended to address specific Lewisham requirements, provisional approval had to be sought from DEFRA, who have now given their provisional approval for the byelaws to be made in the form attached to this report.
5.4 Officers from Green Scene have liaised with the Blackheath Joint Working Party, made up of members of amenity groups, local interest groups and ward councillors, to garner their views and take comments. Responses are available in the appendix attached.
5.5 The adoption of clearly set out and updated byelaws will assist the agencies involved with policing Blackheath (Glendale, Community Safety team, Police, Environment Enforcement officers etc), to enforce these rules and regulations, principally through persuasion. These groups will help co-ordinate future enforcement of the byelaws and other associated Acts of Parliament which apply to the parks environment, for example the Environmental Protection Act 1990 and Clean Neighbourhood and Environment Act 2005 (Dog Control Order). Enforcement is likely to take place at targeted enforcement sessions rather than on an ad-hoc basis. Members of the public who contravene a byelaw will be given a written caution for a first offence. However, any person offending against any of these byelaws shall be liable on conviction at the Magistrates Court to a fine not exceeding level 2 on the standard scale (currently up to £500.) An effective deterrent will therefore exist to deal with serious contraventions of the byelaws.
5.6 The draft set of byelaws attached to this report has been subject to discussion with the Blackheath Joint Working Party. As a result of that process a number of points were raised including the removal of pond planting etc. in relation to the Hare and Billet Pond where this practice is allowed with the approval of the Council in order to maintain the pond environment. The new byelaws would not affect maintenance by approved volunteer groups in relation to the nature site. Other concerns were raised about the ability of the Council to impose fines for breaches the response to which is set out in section 5.5. It was also explained to the BJWP that where the existing criminal law deals with a problem, the Council is unable to duplicate that in a byelaw. The existing criminal law covers issues such as dog fouling, littering and fly-tipping and in most cases imposes a higher maximum penalty than would apply under the byelaws. 5.7 A certain amount of training will be required for Glendale’s parks services team, to carry out informal enforcement duties. This will be undertaken within the terms of the current parks contract.
5.8 The new byelaws must be displayed and or be available for the public to read and a number of signs highlighting specific clauses must be erected. The cost of signage, or amendments to signage is anticipated to be in the region of £500.
6 Financial implications
6.1 The cost of adopting the new byelaws is limited to the cost of signage, or amendments to signage which is anticipated to be in the region of £500. This will be contained within the Green Scene budget.
6.2 The training required for Glendale’s parks services team to carry out informal enforcement duties will be undertaken within the terms of the current parks contract, at no additional cost to the Council.
7 Legal implications
7.1 The Council maintains Blackheath Common under a management scheme pursuant to the Metropolitan Commons Act 1866 and confirmed by the Metropolitan Commons Supplemental Act 1871. That scheme requires the Council to make byelaws for the regulation and preservation of the common. Section 15 of the Open Spaces Act 1906 enable local authorities to make byelaws for the regulation of an open space for whose management they are responsible..
7.2 The Local Authorities (Functions and Responsibilities) (England) Regulations 2000 provides that the power to make, amend, revoke, re-enact or enforce byelaws shall not be the responsibility of the Council’s executive. Furthermore the Council’s constitution reserves the making altering and revoking of byelaws to full council.
The procedure for making the byelaws is set out in Section 236 of the Local Government Act 1972. That section provides that byelaws must be made under the common seal of the authority making them. The authority must then apply to the relevant Secretary of State, which in this case is the Secretary of State for Environment Food and Rural Affairs, (DEFRA), for confirmation. At least a month before seeking such confirmation the Council must publish a notice in a local newspaper indicating its intention to do so. During this month a copy of the byelaws must be made available at all reasonable hours at the Council’s offices for public inspection. There is no legal requirement for a formal consultation process for new byelaws.
7.3 Any objections to the byelaws should be sent to the Secretary of State for DEFRA. The Secretary of State may confirm, or refuse to confirm, any byelaw submitted for confirmation, and may fix the date on which the byelaws are to come into operation and if no date is so fixed the byelaw shall come into operation at the expiration of one month from the date of its confirmation.
8 Crime and disorder implications
8.1 The byelaws will facilitate and enhance reasonable use Blackheath while at the same time providing a more effective deterrent to serious instances of park misuse.
9 Equalities implications
9.1 The adoption of the new byelaws will clearly set out rules and regulations, which aim to ensure that all members of the community are able to use Blackheath without unreasonably inconveniencing other users.
10 Environmental implications
10.1 A number of byelaws specifically set out to protect the environment, for example protection of trees and grassland and the protection of lakes and water courses. Byelaws also include for the protection of fish and other wildlife.
11 Conclusion
11.1 The adoption of the new set of byelaws will provide the community with clearly set out rules and regulations as to how members of the public should conduct themselves at Blackheath.
12 Background documents and originator
12.1 There are no background documents to this report.
12.2 If you require further information please contact Martin Hyde, Green Space Regeneration Manager on 020 8314 2034. Appendix
Draft Byelaws
THE LONDON BOROUGH OF LEWISHAM
BLACKHEATH OPEN SPACE, LONDON SE3
Byelaws made by THE LONDON BOROUGH OF LEWISHAM under paragraph 5 of the Scheme for Blackheath confirmed by the Metropolitan Commons Supplemental Act 1871 and section 15 of the Open Spaces Act 1906, with respect to the Blackheath open space.
Interpretation
1. In these byelaws:
"the Council" means the London Borough of Lewisham or where the context requires it its nominated contractor;
"the ground" means the Blackheath open space, Blackheath, London SE3 (including any new name subsequently given to it) as shown edged red on the plan attached to these byelaws;
“Schedule” followed by a number, or a number and a letter, means the Schedule to these byelaws bearing that number, or that number and letter
Words implying the singular shall include the plural and vice versa
Application
2 These byelaws shall apply to the ground
Motor Vehicles
3. (1) No person shall without reasonable excuse bring onto or drive in the ground a motor cycle, motor vehicle, trailer except in any part of the ground where there is a right of way for that class of vehicle.
(2) In these byelaws:
"cycle" means a unicycle, bicycle, a tricycle, or a cycle having four or more wheels, not being in any case a motor cycle or motor vehicle; "motor cycle" means a mechanically propelled vehicle, whether or not intended or adapted for use on roads, not being an invalid carriage, with less than four wheels and the weight of which unladen does not exceed 410 kilograms;
"motor vehicle" means a mechanically propelled vehicle, whether or not intended or adapted for use on roads, not being an invalid carriage.
"trailer" means a vehicle drawn by a motor vehicle, and includes a caravan.
Cycling
4 No person shall without reasonable excuse ride a cycle in the ground except in any part of the ground where there is a right of way for cycles or on a designated route for cycling
Overnight parking
5. No person shall without the consent of the Council leave or cause or permit to be left any vehicle in the ground between the hours of 10 pm and 6 a.m.
Horses
6. (1) No person shall ride a horse except in the exercise of any lawful right or privilege.
(2) Where horse-riding is permitted by virtue of a lawful right or privilege no person shall ride a horse in such a manner as to cause danger to any other person .
Climbing
7. No person shall without reasonable excuse climb any wall or fence in or enclosing the ground, or any tree, or any barrier, railing, post or other structure.
Removal of structures
8. No person shall, without reasonable excuse, remove from or displace on the ground any barrier, railing, post or seat, or any part of any structure or ornament, or any implement provided for use in the laying out or maintenance of the ground. Erection of structures
9. No person shall in the ground, without the consent of the Council, erect any post, rail, fence, pole, tent, booth, stand, building or other structure.
Camping
10. No person shall in the ground, without the consent of the Council, erect a tent or use any vehicle, including a caravan, or any other structure for the purpose of camping.
Fires
11. (1) No person shall in the ground intentionally light a fire, or place, throw or let fall a lighted match or any other thing so as to be likely to cause a fire.
(2) Byelaw 11(1) shall not apply to any event held with the prior written consent of the Council.
Games
12. (1) Where the Council has, by a notice placed in a conspicuous position in the ground, set apart an area in the ground for the playing of such games as may be specified in the notice, no person shall:
(a) play in such an area any game other than the game for which it has been set apart;
(b) use any such area so as to give reasonable grounds for annoyance to any person already using that area for any purpose for which it has been set apart; or
(c) play any game so specified in any other part of the ground in such a manner as to exclude any person not playing the game from the use of that part.
(2) No person shall, in any area of the ground which may have been set apart by the Council for any game, play any game when the state of the ground or other cause makes it unfit for use and a notice is placed in a conspicuous position prohibiting play in that area of the ground.
(3) (i) No person shall in the ground play any game: (a) so as to give reasonable grounds for annoyance to any other person in the ground; or
(b) which is likely to cause damage to any tree, shrub or plant in the ground.
(ii) This Byelaw shall not extend to any area set apart by the Council for the playing of any game.
Trading
13. No person shall in the ground, without the consent of the Council, sell, or offer or expose for sale, or let to hire, or offer or expose for letting to hire, any service commodity or article.
Grazing
14. No person shall without the consent of the Council turn out or permit any animal for which he is responsible to graze in the ground.
Protection of flower beds, trees, grass, etc
15. No person shall walk on or ride drive or station a horse or any vehicle over:
(a) any flower bed, shrub or plant
(b) any ground in the course of preparation as a flower bed or for the growth of any tree, shrub or plant; or
(c) any part of the ground set aside by the Council for the renovation of turf or for other landscaping purposes indicated, by a notice conspicuously displayed.
Removal of substances
16. No person shall remove from or displace in the ground any stone, soil or turf, or the whole or any part of any plant, shrub or tree. Archery
17. No person shall engage in the sport of archery except in connection with an event organised by or held with the consent of the Council.
Field Sports
18. No person shall throw or put any javelin, hammer, discus or shot except in connection with an event organised by or held with the consent of the Council,
Golf
19. No person shall in the ground drive, chip or pitch a hard golf ball except in connection with an event organised by or held with the consent of the Council
Cricket
20. No person shall throw or strike a cricket ball with a bat except in a designated area for playing cricket.
Skateboarding and roller skating
21. No person shall in the ground skate, slide or ride on rollers, skateboards or other self-propelled vehicles, wheels, mechanical contrivances or other equipment in such a manner as to cause danger or give reasonable grounds for annoyance to other persons .
Missiles
22. No person shall in the ground, to the danger or annoyance of any other person in the ground, throw or discharge any missile. Bathing
23. No person shall without reasonable excuse, bathe or swim in any waterway comprised in the ground except in an area where a notice exhibited by the Council permits bathing and swimming
Watercourses
24 No person shall knowingly cause or permit the flow of any drain or watercourse in the ground to be obstructed or diverted, or open, shut or otherwise work or operate any sluice or similar apparatus in the ground.
Ice Skating
25. No person shall step onto or otherwise place their weight upon any frozen waterway.
Boats
Model boats
26. (1) No person shall operate a power-driven model boat on any waterway.
(2) No person shall operate a non power-driven model boat on any waterway except in a designated area for non power-driven model boats.
(3) In byelaw 26(1), "power-driven" means driven by the combustion of petrol vapour or other combustible vapour or other combustible substances.
Boats 27. No person shall sail or operate a boat dingy canoe sailboard or inflatable in any waterway without the consent of the Council except in a designated area for the sailing or operation of boats
Interference with life-saving equipment
28. No person shall, except in case of emergency, remove from or displace in the ground or otherwise tamper with any life-saving appliance provided by the Council.
Aircraft
29. No person shall, except in case of emergency or with the consent of the Council, take off from or land in the ground in an aircraft, helicopter, hang-glider, hot-air balloon, helium or hydrogen filled airships and balloons.
Power-driven model aircraft
30. (1) In these Byelaws
(i) "model aircraft" means
(a) a power-driven aircraft which either weighs between 500 grams and 7 kilograms without its fuel or
(b) a power-driven aircraft which weighs more than 7 kilograms and up to 20 kilograms without its fuel and is regulated by the Air Navigation Order Clause 87 or
(c) a power-driven aircraft which weights over 20 kilogram without it fuel and which is exempt from the Air Navigation Order
(ii) “power-driven” means driven by the combustion of petrol vapour or other combustible vapour or other combustible substances and subject to the Code of Practice on Noise from Model Aircraft 1982
(iii) The “Noise Code” means the Code of Practice issued by the Department of the Environment in pursuance of the approval given by the Control of Noise (Code of Practice on Noise from Model Aircraft) Order 1981
(2) No person shall
(i) in the ground release any power-driven model aircraft for flight or control the flight of such an aircraft.
(ii) cause any power-driven model aircraft to take off or land in the ground.
Kites
31. No person shall in the ground fly any kite or cause or permit to be flown or ride or drive any vehicle powered by a kite in such a manner as to cause danger, nuisance or annoyance to any other person in the ground. .
Metal detectors
32. No person shall on the land without the consent of the Council use any device designed or adapted for detecting or locating any metal or mineral in the ground.
Protection of Wildlife
33. (1) No person shall in the ground intentionally kill, injure, take or disturb any animal or fish or engage in hunting, shooting or fishing, or the setting of traps or nets or the laying of snares.
(2) This byelaw shall not prohibit any fishing which may be authorised by the Council.
Noise
34. (1) No person shall in the ground, after being requested to desist by an officer of the Council, or by any person annoyed or disturbed, or by any person acting on his behalf:
(a) by shouting or singing;
(b) by playing on a musical instrument; or (c) by operating or permitting to be operated any radio, CD player or other device capable of emitting sound
cause or permit to be made any noise which is so loud or so continuous or repeated as to give reasonable cause for annoyance to other persons in the ground.
(2) This byelaw shall not apply to any person holding or taking part in any entertainment held with the consent of the Council.
Public Shows, Exhibitions and Structures
35. No person shall in the ground, without the consent of the Council, place or take part in any public show or exhibition or set up any swing roundabout or other like thing.
Children’s play areas
36. No person aged 13 years or over shall enter or remain in a designated area which is a children’s play area unless in charge of a child under the age of 13 years.
Children’s play apparatus
37. No person aged 13 years or over shall use any apparatus stated to be for the exclusive use of persons under the age of 13 years by a notice conspicuously displayed on or near the apparatus."
Obstruction
38. No person shall in the ground:
(a) intentionally obstruct any officer of the Council in the proper execution of his duties; or
(b) intentionally obstruct any person carrying out an act which is necessary to the proper execution of any contract with the Council; or of the ground
Savings 39. (1) An act necessary to the proper execution of his duty in the ground by an officer of the Council, or any act which is necessary to the proper execution of any contract with the Council, shall not be an offence under these byelaws.
(2) Nothing in or done under any of the provisions of these byelaws shall in any respect prejudice or injuriously affect any public right of way through the ground, or the rights of any person acting legally by virtue of some estate, right or interest in, over or affecting the ground or any part thereof.
Removal of offenders
40. Any person offending against any of these byelaws may be removed from the ground by an officer of the Council or a constable.
Penalty
41. Any person offending against any of these byelaws shall be liable on summary conviction to a fine not exceeding level 2 on the standard scale.
Revocation
42. The byelaws referred to in Schedule 1 are hereby revoked. SCHEDULE 1
Existing byelaws to be revoked
The following byelaws relating to the ground made by:
1. the London County Council on 1 November 1932 as confirmed by the Secretary of State for the Home Department on 14 December 1932 (insofar as they apply to that part of the ground within the Borough of Lewisham); are hereby revoked. COUNCIL
Report Title Action taken by the Council Urgency Committee
Key Decision n/a Item No.
Ward Rushey Green
Contributors Chief Executive
Class Part 1 Date: September 23 2015
Action taken by the Urgency Committee under Rule 7 of Section C of the Constitution
Date Title Reason for Urgency
August 3 2015 Milford Towers Leasing An extension to the leasing Scheme scheme was agreed by the Mayor on July 15. The existing leasing arrangement was to expire in December and sufficient time was required to apply to the Secretary of State for permission to extend. Meeting urgently after the Mayoral consideration greatly reduced the risk that permission would not be received in time.
RECOMMENDATION that the action taken by the Council Urgency Committee be noted.
BACKGROUND PAPERS
Agenda papers and minutes for the Urgency Committee can be viewed at: http://councilmeetings.lewisham.gov.uk/ieListDocuments.aspx?CId=284&MId=402 4
d:\moderngov\data\agendaitemdocs\0\5\0\ai00012050\$rvsp1pw3.doc COUNCIL
Report Title Action Taken by the Chair of the Overview and Scrutiny Committee Under Rule 19 of Section G of the Constitution Key Decision no Item No.
Ward n/a
Contributors Chief Executive (Head of Business & Committee)
Class Part 1 Date: September 23 2015
. ACTION TAKEN BY THE CHAIR OF THE OVERVIEW & SCRUTINY COMMITTEE UNDER RULE 19 OF SECTION G OF THE CONSTITUTION
1. The Chair of the Overview & Scrutiny Committee agreed under the urgency procedure set out in Rule 16(c) of Section G of the Constitution, that the matters listed below should be treated as a matter of urgency despite not having been included in a Notice of Intention giving the public 28 clear days notice of a proposal to consider executive business in closed session.
Date Title Reason for Urgency
June 30 2015 ICT Infrastructure The confidential report was Procurement Update considered by Mayor & Cabinet Contracts on July 6 2015. Following receipt of legal advice further authorisations were required to give effect to decisions on ICT first made at Mayor & Cabinet on June 15 2015. Therefore this matter was not included in the Council’s Key Decision Plan or in Notice of Intention giving notice of a proposal to consider executive business in closed session. The report was urgent and could not wait for correct notice to be given as members were advised each week of delay increased the risk of a major costly systems failure before an intended migration could be achieved.
RECOMMENDATION that the actions taken by the Chair of the Overview and Scrutiny Committee be noted.
d:\moderngov\data\agendaitemdocs\3\5\0\ai00012053\$03ab5gmk.doc COUNCIL
Report Title Recommendations arising from the Public Spending in Lewisham Working Group final report Key Decision Item No.
Ward
Contributors Chief Executive (Interim Overview and Scrutiny Manger)
Class Part 1 Date: 23 September 2015
1. Summary
1.1 Following a request from the Overview and Scrutiny Business Panel, the Public Spending in Lewisham Working Group was set up by Full Council on 24 June 2015 to investigate the way in which other public sector organisations deploy expenditure across the borough. This report informs Council of the recommendations arising from the Working Group’s final report.
2. Recommendation
2.1 Council is asked to receive the recommendations of the Public Spending in Lewisham Working Group and note that the final report will be provided to Council on 25 November 2015.
3. Summary
3.1 The recommendations arising from the draft final report of the Public Spending in Lewisham Working Group are due to be agreed at a meeting of the Working Group on 22 September 2015. They will be tabled at Council on 23 September 2015.
3.2 The draft final report due to be considered on 22 September can be found here.
4. Financial Implications
4.1 There are no financial implications arising out of this report per se; but there may be financial implications arising from carrying out the actions proposed by the Working Group.
5. Legal Implications
5.1 The Constitution provides for scrutiny bodies to refer reports to the Mayor and Cabinet, who are obliged to consider the report and the proposed response from the relevant Executive Director; and report back to the relevant scrutiny body within two months (not including recess). The recommendations of the Working Group will be provided to the Mayor and Cabinet in due course; and also to those organisations spending public money in Lewisham, that contributed to the review. If you have any queries on this report, please contact Charlotte Dale, Interim Overview & Scrutiny Manager (0208 3149534). COUNCIL
Report Title Recommendations arising from the Public Spending in Lewisham Working Group final report – TO BE TABLED Key Decision Item No. 13
Ward
Contributors Chief Executive (Interim Overview and Scrutiny Manger)
Class Part 1 Date: 23 September 2015
1.1 Council is asked to receive the agreed recommendations (Appendix 1) of the Public Spending in Lewisham Working Group and note that the final report will be provided to Council on 25 November 2015.
1.2 The draft final report, including the recommendations and conclusion, can be found here.
http://councilmeetings.lewisham.gov.uk/documents/s38827/Draft%20Report%20Pu blic%20Spending%20September2015.pdf
1.3 A link to an earlier draft of the report was provided when the agenda papers for this meeting were dispatched, as shown below.
http://councilmeetings.lewisham.gov.uk/ieListDocuments.aspx?CId=351&MId=4012
If you have any queries on this report, please contact Charlotte Dale, Interim Overview & Scrutiny Manager (02083149534). Appendix 1
Final recommendations arising from the Public Spending in Lewisham Scrutiny Review
The Council
1. This review has highlighted both the steep reductions in spending being made by a wide range of organisations spending public money in Lewisham and the potential impact they may have on services to Lewisham residents. When agreeing its own budget and any proposals for savings, the Council must take into account the impact of the savings being made by other organisations and how these link to its own programme of expenditure reduction.
2. The Council and the other organisations that took part in this review should provide the following financial information to the Overview and Scrutiny Committee on an annual basis (at the July meeting) in order to enable meaningful monitoring and comparison:
- Actual gross revenue expenditure and gross capital spend for the last three complete financial years - Gross budgeted revenue expenditure and gross budgeted capital expenditure for the current financial year and following two years. (Recommendation for contributing organisations in addition to the Council)
3. The Council needs to make sure it fully understands the complex public finances of the NHS and healthcare delivery when considering the changes that will be put forward as part of the Our Healthier South East London Strategy.
4. The formal partnership arrangements between the Mayor, Executive Members and Officers should be reviewed to ensure that they are robust enough to recognise the potential conflicts and solutions required to address the scale of the challenges that this review has identified.
5. The Council should reiterate its support for public consultation where major service changes are under consideration to ensure public confidence in our public services especially emergency services.
6. The Council should review the Housing Strategy to ensure proposed legislative, financial and regional policy changes are fully reflected.
7. If proposals for devolution in London are accepted by the Government, the Mayor and Executive Members should share their proposals with Overview and Scrutiny Committee as soon as possible to facilitate constructive scrutiny and the most effective constitutional arrangements.
Business Panel
8. Business Panel is asked to consider the overall scrutiny work programme in light of the review findings, with a view to considering whether further work should be carried out; and request that the relevant select committees incorporate this work into their work programmes as a matter of priority. London Ambulance Service (LAS)
9. The performance figures for Lewisham (Category A calls) are below target and below the figures being achieved in neighbouring boroughs including Southwark, Lambeth and Greenwich. The LAS should focus its attention on understanding and addressing the reasons behind this discrepancy, and report their findings to the Overview and Scrutiny Committee.
10. In 2014, police vehicles were used on 39 occasions to transport patients to hospital in Lewisham and 13 times so far this year (up to 21 August 2015). This puts an unnecessary strain on the Metropolitan Police Service (MPS) and the LAS should look into the reasons behind this, consider ways in which the impact on the MPS can be reduced and report their findings to the Overview and Scrutiny Committee.
London Fire Brigade (LFB)
11. The Mayoral Direction requiring the 13 appliances from across London currently being held for contingency purposes, to not be returned pending decisions on 2016/17 savings proposals, which could include their permanent removal, is of grave concern. The Mayor has already been asked to request a full briefing on Forest Hill Station’s second fire appliance and the relevant Mayoral Direction, from the London Fire Brigade, to be shared with the Overview and Scrutiny Committee. (Recommendation for the Mayor)
12. In 2014/15 and in 2015/16 (to date) the six minute target for getting a first appliance to an incident has not been met in the Bellingham, Downham and Grove Park wards of Lewisham. The LFB should focus its attention on understanding and addressing the reasons behind this failure. This should include considering any impact caused by the removal of Forest Hill’s second appliance and the closure of Downham Fire Station; and considering what mitigating action might be taken to improve attendance times in these areas. The findings should be reported to the Overview and Scrutiny Committee.
Metropolitan Police Service (MPS)
13. Police Community Support Officers (PCSOs) are valuable to the Community. However recruitment is currently on hold and the number of PCSOs in Lewisham is going down due to natural attrition. In light of the cuts over the last five years, plans to potentially abolish the PCSOs in safer neighbourhood teams are of particular concern and the Mayor is asked to request a full briefing on the future of PCSOs in Lewisham from the MPS. It is expected that the Council will be fully consulted prior to any decisions being taken on this issue. (Recommendation for the Mayor)
14. The Metropolitan Police Service Commissioner has publically stated that the projected £800m of savings scheduled for the MPS over the next four years may put public safety at risk. The Mayor is asked to request a full briefing on any modelling that has been done to date to assess the likely impact that the savings will have on the borough of Lewisham. (Recommendation for the Mayor)
15. As soon as specific savings proposals are developed, the Borough Commander is asked to share these with the Council, highlighting the specific impact on the borough. The briefing should be shared with the Overview and Scrutiny Committee. Goldsmiths
16. Higher Education Institutions offering “high teaching quality” will be able to increase their tuition fees in line with inflation from 2017-18. Goldsmiths is asked to share any plans to increase its fees with the Council at the earliest opportunity, together with information on any schemes it operates to encourage students from deprived backgrounds to apply, including the excellence scholarships available for students from Lewisham.
17. The Council should develop a closer working relationship with Goldsmiths University, for example around community development issues.
Lewisham Southwark College
18. An Ofsted rating of 4 (inadequate) is not good enough for the approximately 740 Lewisham 16-18 year olds studying at the College. However, the establishment of a new senior management team and the recent Ofsted monitoring visit which revealed improvements across all areas is heartening. The College needs to focus on achieving at least a Grade 3 when it is next inspected.
19. Plans to rationalise the number of campuses in Lewisham should be shared with the Council at the earliest opportunity.
20. The Overview and Scrutiny Committee should convene an Inquiry into post-16 education. (Recommendation for the Overview and Scrutiny Committee)
______
Overview and Scrutiny
Public Spending in Lewisham
A report by the Public Spending in Lewisham Working Group
September 2015
______
Membership of the Public Spending Working Group
Councillor Alan Hall (Chair) Councillor Gareth Siddorn (Vice-Chair) Councillor Liam Curran Councillor Brenda Dacres Councillor Carl Handley Councillor Jim Mallory Councillor Jamie Milne Councillor Hilary Moore Councillor Pauline Morrison Councillor John Muldoon
Contents
1. Chair’s introduction xx
2. Executive summary xx
3. Recommendations xx
4. Purpose and structure of review xx
5. The context xx
6. The findings xx
7. The London Ambulance Service xx 8. The London Fire Brigade xx 9. The London Metropolitan Police Service xx 10. Goldsmiths University xx 11. Lewisham Southwark College xx 12. Other Organisations xx
13. Analysis xx
14. Conclusion xx
15. Monitoring and ongoing scrutiny xx
16. Appendices xx
1. Chair’s Introduction
To be inserted.
Councillor Alan Hall Chair of the Public Spending in Lewisham Working Group and Chair of the Overview and Scrutiny Committee
2. Executive Summary
To be inserted
3. Recommendations
3.1 The Working Group would like to make the following recommendations:
The Council
1. This review has highlighted both the steep reductions in spending being made by a wide range of organisations spending public money in Lewisham and the potential impact they may have on services to Lewisham residents. When agreeing its own budget and any proposals for savings, the Council must take into account the impact of the savings being made by other organisations and how these link to its own programme of expenditure reduction.
2. The Council and the other organisations that took part in this review should provide the following financial information to the Overview and Scrutiny Committee on an annual basis (at the July meeting) in order to enable meaningful monitoring and comparison:
- Actual gross revenue expenditure and gross capital spend for the last three complete financial years - Gross budgeted revenue expenditure and gross budgeted capital expenditure for the current financial year and following two years. (Recommendation for contributing organisations in addition to the Council)
3. The Council needs to make sure it fully understands the complex public finances of the NHS and healthcare delivery when considering the changes that will be put forward as part of the Our Healthier South East London Strategy.
4. The formal partnership arrangements between the Mayor, Executive Members and Officers should be reviewed to ensure that they are robust enough to recognise the potential conflicts and solutions required to address the scale of the challenges that this review has identified.
5. The Council should reiterate its support for public consultation where major service changes are under consideration to ensure public confidence in our public services especially emergency services.
6. The Council should review the Housing Strategy to ensure proposed legislative, financial and regional policy changes are fully reflected.
7. If proposals for devolution in London are accepted by the Government, the Mayor and Executive Members should share their proposals with Overview and Scrutiny Committee as soon as possible to facilitate constructive scrutiny and the most effective constitutional arrangements.
Business Panel
8. Business Panel is asked to consider the overall scrutiny work programme in light of the review findings, with a view to considering whether further work
should be carried out; and request that the relevant select committees incorporate this work into their work programmes as a matter of priority.
London Ambulance Service (LAS)
9. The performance figures for Lewisham (Category A calls) are below target and below the figures being achieved in neighbouring boroughs including Southwark, Lambeth and Greenwich. The LAS should focus its attention on understanding and addressing the reasons behind this discrepancy, and report their findings to the Overview and Scrutiny Committee.
10. In 2014, police vehicles were used on 39 occasions to transport patients to hospital in Lewisham and 13 times so far this year (up to 21 August 2015). This puts an unnecessary strain on the Metropolitan Police Service (MPS) and the LAS should look into the reasons behind this, consider ways in which the impact on the MPS can be reduced and report their findings to the Overview and Scrutiny Committee.
London Fire Brigade (LFB)
11. The Mayoral Direction requiring the 13 appliances from across London currently being held for contingency purposes, to not be returned pending decisions on 2016/17 savings proposals, which could include their permanent removal, is of grave concern. The Mayor has already been asked to request a full briefing on Forest Hill Station’s second fire appliance and the relevant Mayoral Direction, from the London Fire Brigade, to be shared with the Overview and Scrutiny Committee. (Recommendation for the Mayor)
12. In 2014/15 and in 2015/16 (to date) the six minute target for getting a first appliance to an incident has not been met in the Bellingham, Downham and Grove Park wards of Lewisham. The LFB should focus its attention on understanding and addressing the reasons behind this failure. This should include considering any impact caused by the removal of Forest Hill’s second appliance and the closure of Downham Fire Station; and considering what mitigating action might be taken to improve attendance times in these areas. The findings should be reported to the Overview and Scrutiny Committee.
Metropolitan Police Service (MPS)
13. Police Community Support Officers (PCSOs) are valuable to the Community. However recruitment is currently on hold and the number of PCSOs in Lewisham is going down due to natural attrition. In light of the cuts over the last five years, plans to potentially abolish the PCSOs in safer neighbourhood teams are of particular concern and the Mayor is asked to request a full briefing on the future of PCSOs in Lewisham from the MPS. It is expected that the Council will be fully consulted prior to any decisions being taken on this issue. (Recommendation for the Mayor)
14. The Metropolitan Police Service Commissioner has publically stated that the projected £800m of savings scheduled for the MPS over the next four years
may put public safety at risk. The Mayor is asked to request a full briefing on any modelling that has been done to date to assess the likely impact that the savings will have on the borough of Lewisham. (Recommendation for the Mayor)
15. As soon as specific savings proposals are developed, the Borough Commander is asked to share these with the Council, highlighting the specific impact on the borough. The briefing should be shared with the Overview and Scrutiny Committee.
Goldsmiths
16. Higher Education Institutions offering “high teaching quality” will be able to increase their tuition fees in line with inflation from 2017-18. Goldsmiths is asked to share any plans to increase its fees with the Council at the earliest opportunity, together with information on any schemes it operates to encourage students from deprived backgrounds to apply, including the excellence scholarships available for students from Lewisham.
17. The Council should develop a closer working relationship with Goldsmiths University, for example around community development issues.
Lewisham Southwark College
18. An Ofsted rating of 4 (inadequate) is not good enough for the approximately 740 Lewisham 16-18 year olds studying at the College. However, the establishment of a new senior management team and the recent Ofsted monitoring visit which revealed improvements across all areas is heartening. The College needs to focus on achieving at least a Grade 3 when it is next inspected.
19. Plans to rationalise the number of campuses in Lewisham should be shared with the Council at the earliest opportunity.
20. The Overview and Scrutiny Committee should convene an Inquiry into post-16 education. (Recommendation for the Overview and Scrutiny Committee)
4. Purpose and structure of review
4.1 The work of other public sector organisations, alongside that of the Council, is critical to the wellbeing of local people; and the Council often works in partnership with these organisations to achieve the best possible outcomes for those who live and work in the borough. Particularly in times of austerity it is critical that the Council understands how resources are deployed by other public organisations in the borough. This enables the Council to make its views known to those organisations and make informed choices about the nature of its own service provision. Following a request from the Overview and Scrutiny Business Panel, the Public Spending in Lewisham Working Group was set up by Full Council on 24 June 2015 to investigate the way in which other public sector organisations deploy expenditure across the borough.
4.2 The timetable for the working group was as follows:
7 July 2015 – meeting of the Working Group to receive core data on public spending in Lewisham.
13 July 2015 – meeting of the Overview and Scrutiny Committee to receive verbal evidence from the London Ambulance Service, the London Fire Brigade and the Metropolitan Police Service on the implications of any reductions in spending that had taken place or were due to take place, any impact on performance and any mitigation being put in place to combat the worst effects.
28 July 2015 - meeting of the Working Group to receive verbal evidence from a further organisation - Goldsmiths University.
8 September 2015 – meeting between the Chair and the Principal and Vice Principal of Lewisham Southwark College to gather further evidence for the review.
22 September 2015 - meeting of the Working Group to consider its final report presenting all the evidence taken and agree recommendations for submission to Mayor & Cabinet / Full Council / relevant public organisations operating in Lewisham.
4.3 For the purposes of this review, the following information, if available, was requested from organisations spending public money in Lewisham.
1. Actual gross revenue expenditure for 2012/13, 2013/14 and 2014/15 2. Gross budgeted revenue expenditure for 2015/16 3. Actual gross capital spend for 2012/13, 2013/14 and 2014/15 4. Gross budgeted capital expenditure for 2015/16 5. Gross budgeted revenue expenditure for 2016/17 and 2017/18 (including estimated savings to be found for those respective years). 6. Capital budgeted spend for 2016/17 and 2017/18.
Those organisations not invited to attend a meeting of the Working Group or Overview and Scrutiny Committee were also asked to comment on:
The implications of the figures. Their spending plans for the future, especially given any further savings which they might be expected to make. Any areas of collaboration or interdependencies with Lewisham Council services (and in particular on any plans in the next three years to stop / change service arrangements in these areas) so that any direct impact on the Council arising from reductions in spending can be assessed.
Those organisations invited to attend a meeting commented on the above at the relevant meeting.
4.4 The Working Group concluded its review and agreed its recommendations on 22 September 2015.
5. The Context
Public Spending
5.1 Analysis by the Chartered Institute of Public Finance and Accountancy (CIPFA) shows that since 2009-10 the per capita spending of local authorities in England will have decreased by 17.2 per cent in cash terms by the end of this financial year (2015-16). When adjusted for inflation this represents a drop of 32 per cent.1 Recent analysis by the Financial Times2 suggests that this drop in spending is having a huge impact in areas such as adult social care and children’s services, with PwC’s annual local government survey (2014) revealing that the vast majority of Chief Executives and Council Leaders believe that some local authorities will get into serious financial crisis within the next five years and will fail to deliver the essential services that residents require.3 A recent report prepared by the Centre for Local Economic Strategies for the Trade Union Congress argues that the current deep and prolonged period of austerity is weakening service provision and undermining many aspects of the universal welfare state that plays an integral part in sustaining communities and social cohesion4.
5.2 The financial outlook for councils, and the public sector as a whole, is likely to remain extremely challenging in future years. The Office for Budget Responsibility (OBR) provides independent analysis of the UK’s public finances and the most recent forecasts, released in July 20155, are for the period to 2020/21. Although the new Government’s summer budget has loosened, somewhat, the squeeze on public services spending that had been pencilled in by the Coalition Government in March 2015, by delaying the expected return to a budget surplus by a year to 2019-20, a slightly bigger surplus is aimed for in the medium term.
5.3 On the basis of the Government’s provisional plans, it is likely that the forthcoming Spending Review will still see the Government having to identify further real cuts in public services spending, rising to a peak of £17.9 billion in 2019-20. Thereafter spending is assumed to rise again in real terms. Public services spending will need to fall by an average of 1.5 per cent a year in real terms over the 2015-20 Parliament as a whole, only slightly less than the 1.6 per cent a year cuts over the last.
1 See: http://www.cipfa.org/about-cipfa/press-office/latest-press-releases/council-spending-in-england-falls-by-32-per-cent 2 See: http://www.ft.com/cms/s/2/88198dd2-2948-11e5-8db8-c033edba8a6e.html#axzz3igkC4LXP 3 See: http://www.pwc.co.uk/local-government/publications/the-local-state-we-are-in-2014/index.jhtml The Local State we’re in, 2014, p6 4 See: https://www.tuc.org.uk/sites/default/files/TUC%20Final%20Report%20Dec'14_1.pdf 5 See: http://cdn.budgetresponsibility.independent.gov.uk/July-2015-EFO-234224.pdf
65 Current receipts 60
Total managed expenditure Forecast 55
50
45
40 Per cent of GDP of cent Per 35
30
25
20 1920-21 1930-31 1940-41 1950-51 1960-61 1970-71 1980-81 1990-91 2000-01 2010-11 2020-21 Source: Bank of England, O NS, OBR
5.4 The steep drop in public services expenditure that has occurred from 2009/10 is highlighted in the graph below:
5.5 The Government proposed two new fiscal targets in the Summer Budget: to achieve a surplus on public sector net borrowing in 2019-20 (and then every year in ‘normal times’) and for public sector net debt to fall as a share of GDP every year up to 2019-20.
5.6 Although the Government's Summer Budget made it clear that reducing public sector spending would remain a priority in this parliament, it also made clear that certain areas of spend would remain protected or receive additional
investment. The protected areas are Health, Education (5-15 year olds), Defence, Overseas Aid, and Pensions. These represent approximately 62 per cent of total annual Departmental spending of £315 billion. The savings are to be found by reducing welfare spend by £12 billion and taking a further £20 billion of other public spend out.
5.7 The £12 billion of welfare cuts will impact all local areas and those with higher levels of deprivation will be most affected. Lewisham is the 17th most deprived local authority in the country. In the local context that this review covers, the £20 billion of public spending reductions to fall on the unprotected areas of public spending will therefore likely impact the local authority, police and fire services, housing services, and all arts and voluntary organisations in particular.
5.8 In preparation for the Comprehensive Spending Review to be announced on 25 November 2015, the Chancellor has asked Departments to model 25 per cent and 40 per cent reductions to 2019/20 in their budgets.
The impact of demographics
5.9 Existing and forecast demographic pressures are adding to the significant financial pressures being felt by public agencies. The attraction of London as a major world city means that the capital’s population is expected to grow significantly over the next two decades. Lewisham’s population currently stands at 292,000, an increase of 16 per cent over the past 10 years. In terms of size, Lewisham is the fifth most populous borough in Inner London and the 13th most populous in London. Lewisham’s population is forecast to reach 318,000 by the time of the 2021 Census and rise by a further 34,000 to reach 352,000 by the 2031 Census.
5.10 The 2014 MYE (Mid-Year Estimate) reveals that over the last year, Lewisham’s population growth has been particularly notable in the age group of 35 to 39 which saw a net increase of 1,283 residents on the year. Also of note is the 50 to 54 age group, which saw a net increase of 841 residents over the period 2013-14 and five to nine year olds, which saw a net increase of 721 residents. There were however decreases for certain ages, for example those aged 20 to 24 years declined by 525 residents over the period 2013-14. Table 1 below presents the data by broad age band, whilst Table 2 illustrates the composition of this change.
Table 1: ONS 2014 Mid Year Population Estimates for Lewisham
All ages Children Residents Older people 0-19 20 to 64 65 and over
291,933 72,782 191,776 27,375
Table 2: Components of Change since Mid 2013
Net migration Mid-2013 Live Natural & Total Mid-2014 population births Deaths change other changes change population
286,180 4,753 1,461 3,292 2,461 5,753 291,933
5.11 The ongoing rapid growth in population across London, including in Lewisham, has placed, and will inevitably continue to place, great pressure on the capital’s infrastructure and services, particularly:
Schools and children’s services Health and social care Affordable housing.
Schools and Children’s Services
5.12 The impact of the increasing birth rate was highlighted in a recent report published by London Councils, which forecast that London needed 133,000 more primary and secondary school places by 2018 to meet current demand6. More children also means more demand for children’s services but local authority spending in this area is being reduced. Children’s services (and adult social care) form the biggest part of a council’s budget, so budget reductions necessarily have a large impact in this area. As an example, recent analysis of section 251 data held by the Department for Children, Schools and Families by the Financial Times suggests that council spending per child (0-4 years old) fell from £446 in 2010/11 to £319 in 2013/14, a real terms cut of 28 per cent7.
Health and Social Care
5.13 Pressures on social care and health care services continue to increase as people live longer, health treatments and interventions grow and expectations rise for care in older age. Life expectancy is increasing in Lewisham: 10 years ago life expectancy in the borough for women was 79.1 (2001-2003) and 74.5 for men (2001-2003). According to the Office for National Statistics, life expectancy at birth for female residents of the London Borough of Lewisham is now 83 years (2011-13), and for males life expectancy is 78.7 years (2011-13). This is an increase in life expectancy for women of nearly four years and for men an increase of over four years8. This demographic pressure is particularly concerning given the cuts to council spending on adult social care that have taken place over recent years. As noted in a recent Local Government Association (LGA) report, since 2013/14, the adult social care funding gap has continued to grow by at least £700 million a year due to demographic pressures, inflation and reduction in grants9. Recent analysis of NHS Health
6 See: https://www.londoncouncils.gov.uk/sites/default/files/Who%20runs%20London/London_Briefing_Web_Spreads.pdf 7 See: http://www.ft.com/cms/s/2/5fcbd0c4-2948-11e5-8db8-c033edba8a6e.html#axzz3j4ZEIarU 8 See: http://www.ons.gov.uk/ons/rel/subnational-health4/life-expectancy-at-birth-and-at-age-65-by-local-areas-in-england-and- wales/index.html 9 See: http://www.local.gov.uk/documents/10180/6869714/L15-252+Spending+Review_WEB_new.pdf/3101e509-1e22-4c26- 91ac-8fd8a953aba5
and Social Care Information Centre data (Referrals, Assessments and Packages of Care returns and Personal Social Services Expenditure and Unit Costs returns) by the Financial Times suggests that council spending on adult social care services has fallen from £15.2bn in 2009/10 to £14.4bn in 2013/14 (spending calculated at 2013/14 prices)10. John Jackson, a council social services director who speaks for the Association of Directors of Adult Social Services, has said that years of reductions have seen councils forced to slash services that are seen as “very desirable but not absolutely essential”11.
5.14 Furthermore, the Department of Health has recently been asked to deliver savings of £200 million in 2015/16 through reductions to the Public Health Grant to local authorities. The Council’s response to the consultation on the proposed grant reduction notes that: “The Chancellor’s plans to reduce public health spending in year contradicts his statement in the NHS plan that “the future health of millions of children, the sustainability of the NHS, and the economic prosperity of Britain all now depend on a radical upgrade in prevention and public health”. Imposing public health savings of this order within year will undermine our effectiveness and reduce our capacity to work with our NHS partners in prevention and public health and so will damage the long-term partnership needed to achieve public health goals.”12
5.15 A motion going to Lewisham’s full Council on 23 September will note that “This Council expresses serious concern about the proposed £200 million in year cut to local public health budgets. The Council notes that within days of the General Election the Chancellor of the Exchequer published the public health cuts and therefore cuts to the NHS. The Council further notes that the Prime Minister in his first major speech13 since returning to Downing Street made a commitment to "a completely new approach to public health and prevention. A real focus on healthy living."14
Housing
5.16 Data collected by CIPFA and the Department for Communities and Local Government, shows that the overall drop in local authority spending has hit housing particularly hard, with housing estimated to experience the biggest loss in its budget over the next few years15. This will be particularly keenly felt in London and follows a number of years in which legislative changes have negatively impacted the housing sector.
5.17 The Localism Act 2011 brought in a number of changes that had a significant impact on housing: Discharge into the private rented sector to end the homeless duty Changes to housing register – no Band 4
10 See http://www.ft.com/cms/s/2/88198dd2-2948-11e5-8db8-c033edba8a6e.html#axzz3igkC4LXP 11 Ibid. 12 See: http://councilmeetings.lewisham.gov.uk/documents/s38094/150821%20Response%20to%20Department%20of%20Health%20 Consultation%20on%20Public%20Health%20Funding%20-%20Draft%20for%20OSC%20Busin.pdf 13 See: https://www.gov.uk/government/speeches/pm-on-plans-for-a-seven-day-nhs 14 See: http://councilmeetings.lewisham.gov.uk/ieListDocuments.aspx?CId=138&MId=3689 15 See: http://www.cipfa.org/about-cipfa/press-office/latest-press-releases/council-spending-in-england-falls-by-32-per-cent
5 year fixed term tenancies Grant rates for new housing supply reduced by 70% New ‘Affordable’ rents at up to 80% of local market rents on new supply and in a percentage of relets Welfare Benefit Changes including the overall cap, the ‘bedroom tax’ and setting the local housing allowance at the 30th percentile Increase in the Right to Buy discount from £16k to £103k Introduction of HRA self financing.
5.18 This has resulted in: A chronic shortage of housing, including a large reduction in new supply A reduction in the turnaround of available social hosuing properties to let A large increase in acute housing demand / homelessness Affordability problems across all tenures A massive growth in the private rented sector People being encouraged into low pay work.
5.19 Further changes since 2011 have exacerbated these effects. For example, the new Government has introduced a Housing Bill that will extend the right-to-buy scheme to housing association tenants (and require local authorities to dispose of high-value vacant council houses to help fund the extension). It has also indicated that it will reduce the overall benefit cap to £23,000, freeze the majority of working age benefits for two years and remove automatic entitlement to housing support for 18-21 year olds.
New Legislation: A Summary Housing Bill • Right-to-buy extended to housing association tenants • Local authorities to sell most valuable vacant homes • Starter homes scheme • Local authorities to help custom builders identify plots • Statutory register for brownfield land • Simplifying/speeding up planning system Welfare reform and work bill • Removes ‘automatic entitlement’ to housing benefit for 18-21 year olds • Benefit cap lowered to £23k in London (£20k outside – in Summer Budget) • Four year freeze on working age benefits from 2016/17 Immigration Bill: • Full roll-out of West Midlands ‘Right to Rent’ pilot of private rented sector landlords checking immigration status of new tenants (also affects social tenants taking in lodgers) Cities & Local Government Devolution Bill: • Legislative framework for Greater Manchester deal and similar agreements in other areas Summer Budget • Rate of £12bn reduction in welfare spending ‘slowed’ over 3 years • Reduced income threshold for Universal Credit and tax credits • Tax credit/ Universal Credit support limited to 2 children for new claimants from April 2017
• New claimants in Employment and Support Allowance work-related activity group will be paid same rate as those on Job Seekers Allowance • Social rents reduced by 1per cent for next 4 yrs: • Average 12per cent reduction by 2020/21 • Consultation on ‘pay to stay’ (market rate rents for social housing tenants on £40k pa in London – raises affordability and administration issues) • Use of lifetime social tenancies to be reviewed (detail awaited) Source: Presentation by Terrie Alafat, the Chief Executive of the Chartered Institute of Housing, to Phoenix Community Housing, September 2015
5.20 The National Housing Federation represents housing associations in England. In its response to the Queen’s speech16 it stated that it does not support the extension of the right-to-buy scheme to housing association homes as it will mean that housing associations will need to focus on building replacement homes rather than homes for the large number of people on waiting lists17. The Federation also has concerns about the proposal to reduce the overall benefit cap to £23,000, freeze the majority of working age benefits for two years and remove automatic entitlement to housing support for 18-21 year olds as “a blanket withdrawal of support, that takes no account of personal circumstances or where you are in the country and will remove vital safety nets that prevent families and young people from becoming homeless”.
5.21 The Charted Institute of Housing is a registered charity and the professional body for the housing sector. It is also concerned about the extension to the right-to-buy scheme stating that “extending right to buy to housing associations…would have a huge impact both on housing associations and on local authorities, as councils would have to sell off their most valuable homes to fund replacements.” 18 It has conducted research19 which indicates that most local authorities only expect to be able to replace half or fewer of the homes they sell under right to buy. Like the National Housing Federation, it also has concerns about the Government’s announcement on freezing working age benefits for two years, lowering the benefit cap and removing automatic entitlement to housing benefit for 18-21 year olds20.
New Legislation: Potential Implications • Sale of ‘high value’ vacant local authority homes: - Significant impact in London - Unlikely to deliver the receipts needed to replace all HA homes sold –
16 See: http://www.housing.org.uk/media/press-releases/response-to-the-queens-speech/ 17 The Federation believes that “this policy does nothing for the 11 million private renters and three million adult children living at home with their parents. If there is £22.5 billion of public money available for housing, we should use it to build the homes the next generation needs, not just gift it to the lucky few already housed in housing association homes.” They have also suggested that the policy could cost up to £5.8bn a year because compensation would have to be paid to housing associations for forcing them to offer stock to tenants at below-market rates. 18 See: http://www.cih.org/news-article/display/vpathDCR/templatedata/cih/news-article/data/CIH_responds_to_the_Queens_Speech 19 See: http://www.cih.org/news-article/display/vpathDCR/templatedata/cih/news- article/data/New_government_should_adopt_a_more_flexible_approach_to_right_to_buy 20 The Institute believes that: “freezing working age benefits for two years fails to reflect the reality of the housing crisis. We are not building enough homes, which means the cost of housing and therefore the housing benefit bill is going up. Millions of people have no choice but to rely on housing benefit to secure a roof over their head. That includes an increasing number of people in work – the number of people in work who still have to claim housing benefit has more than doubled from around 445,000 to just over a million in the last five years. Cutting housing benefit for under 21s fails to take into account the reality of many young people’s lives. It could have a serious impact on vulnerable young people who have left home, including those who have been rough sleeping and may be forced to return to it. It could also mean that young people would be unwilling to take risks such as moving for work because there would be no safety net for them.”
and will receipts from London sales stay in London? • Tougher times ahead for tenants, residents, and communities - 33% of people experienced poverty between 2010-2013 (ONS) • Income collection challenges • Prospective tenants on benefits increasingly unable to afford rents - Void rent loss issues - Professional and moral dilemmas? - Who will house the poor? • Increased tensions for choice based lettings schemes: welfare reform/ affordable rents/ nominations • Increased pressure on front-line staff • A tougher financial environment may bring some difficult discussions and decisions: - What is your role and purpose? - Development/regeneration plans: maintained, reduced or ended? - Provide only essential/ basic landlord services e.g. repairs? - To merge or not to merge? Source: Presentation by Terrie Alafat, the Chief Executive of the Chartered Institute of Housing, to Phoenix Community Housing, September 2015
Councillor Alan Hall giving evidence to a meeting of the GLA’s Housing Committee on 16 July 2015, on the impact of recent Government housing announcments including the extension of ‘Right To Buy’.
5.22 Recent data published by the Land Registry indicates that the average house price in London is now £481,820. This represents the highest as well as fastest rising house price increase of any region in the country. Whilst this is undoubtedly a particular and pressing challenge for London, the effects are most acute in Inner London, which is home to more than one in three of the capital’s 8.5 million residents.The impact of the buoyant London housing market has, in recent years, meant that comparatively affordable boroughs such as Lewisham have also seen significant house price rises. In July 2015, the Land
Registry reported that the average house price in Lewisham was £402,861 up 13.2 per cent on the year21.
5.23 Aside from the fact that rising house prices make home ownership increasingly unaffordable, instability in the housing economy is also driving up the cost of private sector rents. According to the 2011 Census, 25 per cent of Lewisham residents now reside in the private rented sector (up from 14 per cent in 2001). The sector is now the fastest growing in the borough.
Key housing facts
• London needs 80,000 new homes every year to meet demand but less than 18,000 each year were delivered in 2010-2014 • Over the last 20 years average house prices have increased by 350% in London and 330% in Lewisham • In Lewisham, the numbers in temporary accommodation (currently almost 1,800) have increased by 76% over the last 5 years • In Lewisham, the number of properties to let (currently 1,100) has decreased by 44% over the last 5 years and there are 8500 households on the Housing Register • In Lewisham, the private rented sector (PRS) has doubled in size in the last ten years and 50% of all homeless acceptances come from the PRS.
5.24 In Lewisham, work is being done to mitigate the worst effects of the housing crisis and the Council’s new Housing Strategy includes the following four policy and delivery priorities:
Helping residents at times of housing need Greater security and quality for private renters Improving our residents’ homes Building the homes our residents need.
5.25 In particular, the Council has worked to change the role of its Arms Length Management Organisation (ALMO), Lewisham Homes, so that it focuses more broadly on operational delivery, including infill development. Lewisham is also using the PRS for temporary accomodation pressures; providing enhanced sheltered housing management, working more at a Sub Regional level to address issues relating to placing homeless families and clients with No Recourse to Public Funds (NRPF); and introducing PRS Licensing to improve standards in this growing sector. The Council is also developing its role in providing local strategic focus, setting the direction for partners on supply and affordability.
Affordable housing definitions
Social rented – This covers homes owned or managed by registered providers such as councils and housing associations which are let at below market rents at levels set using a national formula (known as target rents).
21 See: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/447551/June_2015_HPI.pdf
Affordable rented – This covers homes owned or managed by registered providers such as councils and housing associations (and managed and maintained in the same way as social rented homes) but which are let at up to 80% of local market rents, rather than at the social rented level. Intermediate housing – this covers homes let above social rented levels but below market levels (and includes affordable rented homes) but also covers homes that can be bought at less than market prices through shared ownership or shared equity arrangements.
Welfare Reform
5.26 The Council has undertaken much activity to mitigate the impact of Welfare Reform especially around the abolition of council tax benefit (the responsibility for providing relief has passed to councils who have been required to develop their own schemes); the introduction of the ‘bedroom tax’; and the introduction of the benefit cap. Actions taken by the Council have included:
The establishment of various welfare reform groups both internally to the Council and with external partner eg housing associations The holding of a Jobsfair, the promotion of English for Speakers of Other Languages (ESOL) courses and joint work with Jobcentre+ to try to support capped households into work The Trading Places project to encourage mutual exchanges and support households affected by the bedroom tax to downsize to the appropriate accommodation A Council tax hardship fund to support those experiencing financial hardship as a result of a reduction in council tax support Make money advice appointments for households suffering financial hardship and having difficulty managing financially.
5.27 Since the introduction of welfare reform, Lewisham’s housing and council tax benefit caseloads have increased, although recent months have seen a small decrease:
Caseload Year 34,950 2010/11 37,368 2011/12 38,558 2012/13 39,223 2013/14 39,212 2014/15 38,583 2015/16
5.28 The impact this has had on the total benefit spend for the schemes administered within Lewisham – housing benefit (HB) and council tax benefit (CTB) - is shown below:
Financial HB - HB - Private Year CTB Council rented HB - RSL Total 2010/11 £29m £49m £94m £62m £234m 2011/12 £30m £48m £100m £69m £247m
2012/13 £29m £52m £104m £74m £259m 2013/14 £25m £66m £98m £77m £266m 2014/15 £23m £61m £96m £82m £262m
5.29 Jobcentre+ has provided the information overleaf on other benefits administered within Lewisham (all figures are expressed as £m).
5.30 The Department for Work and Pensions (DWP) provides a fund to councils to enable them to make Discretionary Housing Payments (DHP) to assist those affected by welfare reforms where there is a shortfall in the housing benefit received. It can only be awarded as a top-up to households already receiving housing benefit.The table below shows the number of cases affected by the Benefit Cap and Bedroom Tax and the DHP awarded for the previous two years. For 2015/16 the Council received £1.2m and is projecting to spend all of it. Bedroom Benefit Cap 2013/14 2014/15 Tax 2013/14 2014/15 Number Number affected 632 605 affected 3523 2635 DHP DHP awarded 252 329 awarded 508 772 DHP DHP Total £588,386 £1,258,220 Total £417,273 £687,527
5.31 As part of the on-going welfare reform programme, the DWP has confirmed that £800m of DHP funding will be available nationally over the next 5 years. Assuming the same apportionment arrangements are used to share out the £800m and that the £800m is apportioned evenly over the 5 years, it is likely Lewisham will receive around £1.7m per year, an increase in the region of £500k per year. However, the likely impacts of the additional welfare reforms will far exceed this and could result in either the Council being unable to help, amending its policy on Bedroom Tax cases, reviewing how it could limit DHP spend or using its general fund.
5.32 Lewisham is currently participating in a Pathways to Employment (PTE) project with the London boroughs of Southwark and Lambeth which is designed to take individuals from their universal credit/welfare application through to employment using a key worker approach. The pilot is funded through a blend of DWP grant, Jobcentre+ flexible support fund and borough contributions. The three councils’ intention is to explore, through the pilot, the possibilities for greater integration and joint commissioning in order to achieve savings to the public purse, better outcomes for priority residents and demonstrate to central government that devolving responsibility to local areas can achieve better results. For the second phase of the PTE pilot, the three councils have successfully bid for £1.1m of Transformation Challenge Award funding, awarded by the Department for Communities and Local Government to proposals which are designed to transform the delivery of public services. This may rise to £2.2m through a match funding bid to the European Social Fund, with a decision expected in the autumn.
Jobcentre+ administered benefits
Bereavement Disability Employment Job Severe State Attendance Benefit/ Carer's Incapacity Income Pension Winter Fuel Year Total Living and Support Seekers Disablement Retirement allowance Widow's Allowance benefit Support Credit Payments allowance allowance allowance allowance pension Benefit 2009/10 £396 £12 £2 £6 £46 £6 £19 £64 £27 £38 £3 £163 £8 2010/11 £402 £12 £2 £7 £48 £11 £17 £59 £29 £39 £3 £168 £8 2011/12 £417 £12 £2 £8 £51 £19 £16 £51 £34 £38 £3 £176 £6 2012/12 £432 £13 £2 £9 £55 £36 £12 £40 £35 £36 £3 £186 £6 2013/14 £430 £13 £2 £9 £56 £51 £7 £28 £29 £34 £3 £191 £6
N.B. There are currently two Jobcentre+ offices in the borough of Lewisham, one in Catford and one in Forest Hill. It is difficult to gauge the imminent impact of welfare reform on counter services as the government’s approach of “digital by default” is likely to shift much more activity on-line and reduce the need for traditional face to face delivery. Lewisham, along with Southwark and Lambeth, continue to pilot a process within local Jobcentre+ offices, using a triage process to identify those with support needs and ensure these needs are met. While it is hoped the findings from this pilot feed into the longer term delivery model, it makes it very difficult at this stage to comment on what this model may look like or what it will deliver.
Other organisations spending public money
5.33 The impact of the cut in public spending initiated by the Coalition Government and continued by the current government on local councils is well known, well documented and has been scrutinised in depth by Lewisham councillors. The purpose of this review was to consider the impact beyond the local authority, on the organisations that work in partnership with the Council to serve the needs of those who live, work and study in the borough. As noted earlier, the public spending reductions announced in the Summer Budget and scheduled to fall on “unprotected” areas of public spending will have a significant impact not just on the local authority but also on police and fire services, housing services, and arts and voluntary organisations in particular. Two of the areas that councillors were particularly interested in were the emergency services and higher education.
The Emergency Services
5.34 Over the past few years, whilst the capital’s population has grown, there have been unprecedented cuts to the emergency services. There are now fewer paramedics, fewer fire stations and fewer police officers and police community support officers.
5.35 The London Ambulance Service was required to make £53m of savings between 2011 and 2015 which put pressure on the service it provides22. The service aims to reach 75 per cent of calls within 8 minutes. However this target has not been met since March 2014, reaching a low of 48 per cent in December 2014. Although response rates have improved recently, reaching 67 per cent in May 2015, this is still below the 75 per cent target.
Category A* response times: target 75% within eight minutes
Dec- Jan- Feb- Mar- Apr- May- 14 15 15 15 15 15 Enfield 40% 54% 52% 52% 61% 62% Haringey 40% 54% 50% 52% 58% 62% Islington 52% 61% 60% 62% 67% 68% Barking & Dagenham 43% 57% 59% 60% 64% 70% City & Hackney 53% 63% 62% 63% 67% 68% Havering 46% 60% 64% 65% 68% 74% Newham 49% 62% 63% 63% 68% 71% Redbridge 42% 58% 58% 56% 61% 62% Tower Hamlets 55% 67% 66% 63% 70% 73% Waltham Forest 38% 50% 53% 52% 58% 60% Westminster 57% 70% 63% 65% 70% 70% Bexley 50% 61% 60% 62% 64% 69% Bromley 46% 58% 53% 58% 59% 64% Greenwich 56% 63% 63% 66% 72% 69% Lambeth 53% 65% 66% 63% 69% 69%
22 See: http://www.bbc.co.uk/news/uk-england-london-13051798
Lewisham 47% 57% 56% 56% 64% 62% Southwark 54% 67% 62% 65% 71% 74% Croydon 46% 56% 56% 56% 61% 60% Kingston 56% 69% 65% 66% 70% 73% Merton & Sutton 55% 65% 66% 69% 70% 70% Wandsworth 54% 64% 60% 62% 68% 70% Brent 46% 56% 55% 54% 60% 66% Ealing 41% 56% 53% 51% 56% 58% Hammersmith & 49% 63% 62% 58% 65% 68% Fulham Harrow 39% 57% 56% 54% 63% 65% Hillingdon 51% 61% 58% 60% 67% 69% Hounslow 41% 54% 57% 49% 61% 58% Kensington & Chelsea 50% 66% 60% 61% 68% 70% Barnet 39% 51% 48% 50% 58% 58% Camden 59% 66% 69% 67% 74% 73% Richmond & 46% 61% 60% 57% 65% 65% Twickenham
LAS Total 48% 60% 59% 59% 65% 67% * Data about response times for Category A (immediately life-threatening) calls, broken down by local area). Source: London Ambulance Service NHS Trust (2015) 23
5.36 As outlined in the Fifth London Safety Plan 2013-16,24 the London Fire Brigade has closed 10 fire stations, retired 14 appliances and cut 552 fire station staff in order to meet the budget savings targets it was set for 2013-15 (£45 million over the two years 2013/14 to 2014/1525). The LFB is now being asked to make £18.6m of further savings over the next two years.
5.37 Uniformed police officers have been cut in every London Borough26. This reduction in police numbers, combined with increased demand is having an impact on the number of crimes the Metropolitan Police Service can solve27. However, more savings are planned: a possible £800m over the next four years28. The Metropolitan Police Service Commissioner has stated that this may put public safety at risk29.
Higher Education
5.38 The higher education sector has also suffered from the squeeze on public spending, with universities and further education colleges experiencing significant reductions to some of their funding.
5.39 Although the Department for Education has sought, over the past 5 years, to protect funding for pupils up to the age of 16, post-16 funding has been excluded from the ringfence. When the Coalition Government ringfenced the schools budget in 2010, protecting it from the funding cuts that affected many other service areas and
23 See: http://www.londonambulance.nhs.uk/about_us/how_we_are_doing/meeting_our_targets/latest_response_times.aspx 24 See: http://www.london-fire.gov.uk/Documents/LSP5-authority-version-18-july-following-september-authority-meeting.pdf 25 See: http://www.london-fire.gov.uk/news/AC1B4F18D05A4D82B52979C6465BBFE5_Londonerswillstillbesafe.asp#.VcyVftIzbGg 26 See: http://data.london.gov.uk/dataset/metropolitan-police-service-recorded-crime-figures-and-associated-data 27 Ibid 28 See: http://www.bbc.co.uk/news/uk-england-london-30696052 29 See: http://www.theguardian.com/commentisfree/2014/dec/14/reform-cuts-public-risk-police-emergency-services-austerity
departments, pupils over the age of 16 were not included. As a result, a recent IPPR report has suggested that funding for 16-18 education fell from £7.7bn to £7bn over the course of the parliament30. A recent Institute for Fiscal Studies report notes that “the area of Department for Education spending that has suffered the largest cuts has been 16–19 education, where spending has fallen by 14 per cent in real terms between 2010–11 and 2014–15.”31
5.40 Between 2009/10 and 2010/11 direct public funding for university teaching provided by the Higher Education Funding Council for England (HEFCE) fell by 11.2 per cent in real terms. However, this was balanced by a rise in tuition fee income (supported by publically funded loans) of 14 per cent32. Although, overall, the net result was a rise in the income universities receive for teaching, the effect has been highly variable between different institutions and the expectations and demands of students, now funding their own courses, has risen dramatically. In addition, the rise in university income is now dropping as the level at which home and EU student fees can be set is capped by the government and declining in real terms. As announced in the Summer budget, only Higher Education Institutions offering “high teaching quality” will be able to increase their tuition fees in line with inflation from 2017-1833. HEFCE funding is also continuing to drop with the teaching grant for universities in England due to be cut by £150 million in the 2015-16 financial year affecting allocations to institutions for the academic years 2014-15 and 2015-1634.
30 See: http://feweek.co.uk/wp-content/uploads/2015/03/moving-on-up.pdf 31 See: http://www.ifs.org.uk/uploads/publications/bns/BN168.pdf 32 See: http://www.universitiesuk.ac.uk/highereducation/Documents/2013/WhereStudentFeesGo.pdf 33 See: https://www.kpmg.com/UK/en/IssuesAndInsights/ArticlesPublications/Documents/PDF/Tax/summer-budget-2015-implications-for- education-v2.pdf 34 See: http://www.hefce.ac.uk/pubs/year/2015/CL,192015/
6. The Findings
Meeting of the Overview and Scrutiny Committee, 13 July 2015
6.1 The Working Group decided to focus its evidence collection on the emergency services and higher education sectors. Representatives from the London Ambulance Service, the London Fire Brigade, the Metropolitain Police Service, Goldsmiths University and Lewisham Southwark College were all invited to attend formal meetings of the Council. Unfortunately the representative from Lewisham Southwark College was unable to attend the scheduled meeting due to illness, so the Chair of the Working Group met the College’s Principal and Vice Principal (Resources and Finance) on a separate occasion.
Comments received from Len Duvall, London Assembly Member
“Londonwide, public services are changing and they will do so too at the local level. It seems to me that where these changes affect local people and communities directly, there should be a high level of transparency and public engagement. As I write to you, there is a possibility that Lewisham may lose a further fire appliance and face a major reorganisation of policing services which will almost certainly result in a very different delivery of services to residents. This may well be done on the back of reduced finances from central government but this should not stop local people having a say around the delivery of those services”.
7. The London Ambulance Service (LAS)
Graham Norton, Andrew Bell, Councillor Alan Hall Public Spending
7.1 Graham Norton, Assistant Director of Operations (South East) and Andrew Bell, Deputy Director of Finance, from the LAS, attended the meeting of the Council’s Overview and Scrutiny Committee held on 13 July 2015 and provided the following spending figures for their organisation:
The organisation’s actual gross revenue expenditure for 2012/13 was £303.5m; for 2013/14 was £302.3m; and for 2014/15 was £317.7m. The gross budgeted revenue expenditure for 2015/16 was £325.6m. The actual gross capital spend for 2012/13 was £9.7m; for 2013/14 was £6.9m; and for 2014/15 was £15.9m. The gross budgeted capital expenditure for 2015/16 was £20.7m. Capital investment had increased as the service was investing in its fleet to ensure it had the right number of vehicles that were the right average age. Capital funding was also sometimes rolled forwards. The gross budgeted revenue expenditure for 2016/17 and 2017/18 and the capital budgeted spend for the same years was not yet available as it was still being finalised.
Ambulance on a call Performance
7.2 The LAS has experienced a large reduction in staff recently (due to high attrition rates) and a recruitment programme is currently taking place. There has been a loss of qualified paramedics by ambulance services across the country, as demand for paramedics has increased due to the wide range of work areas they are now employed in. This is presenting some performance challenges as demand for ambulance services is continuing to rise. Paramedics do not receive comparable grants to nurses to cover the costs of training (paramedics need a paramedic science degree) but a case was being made to Health Education England in relation to this.
7.3 The current recruitment programme is focussing on Australia and New Zealand in particular. Australasia is a good source of new recruits as there is an oversupply of paramedics, their qualifications are recognised here, they speak English and they are very keen. This means that the cost of the recruitment exercise is worth it. The Committee was informed that 200 new paramedics had recently been recruited in this way. The recruitment process in Australia and New Zealand is as rigorous as in the UK and all recruits are tested before starting work. Staff retention is a key focus of the Trust in a bid to reduce attrition rates. Following the meeting it was confirmed that staffing was significantly improving which would have a positive impact on patient care within Lewisham.
7.4 In response to questions from members of the Overview and Scrutiny Committee the following key points were noted:
The LAS currently has no concerns about the A&E Department at Lewisham Hospital. Many hospitals are under pressure at the moment but Lewisham is still
delivering and there have been fewer diversions recently, possibly as a result of campaigns to reduce inappropriate 999 calls and the provision of telephone advice to turn away less appropriate calls.
The 111 service is run separately from the 999 service with a separate control room in Beckenham although the control rooms are linked enabling effective triage.
7.5 The service has a target of reaching 75 per cent of Category A calls (the most serious) within 8 minutes. Up-to-date performance figures for Lewisham and neighbouring boroughs was provided following the meeting which showed that by July 2015 performance in Lewisham for Category A calls had reached 65.31 per cent but this was still below the target and below the figures being achieved in neighbouring boroughs including Southwark (69.77 per cent); Lambeth (71 per cent); and Greenwich (71.65 per cent). Croydon was, however, lower (61.4 per cent).
Lewisham CCG
Month Cat A 8Min% R1 8Min% R2 8Min% C1 20Min% C2 30Min% Jul-14 63.55% 68.89% 63.35% 47.37% 52.59% Aug-14 61.74% 69.23% 61.49% 55.61% 54.47% Sep-14 56.83% 60.00% 56.73% 42.49% 52.39% Oct-14 58.15% 55.81% 58.23% 45.79% 53.31% Nov- 14 58.44% 71.79% 58.01% 44.51% 57.76% Dec-14 46.79% 60.47% 46.40% 37.87% 44.59% Jan-15 57.06% 72.73% 56.51% 57.76% 62.12% Feb-15 56.05% 55.88% 56.05% 47.24% 55.84% Mar- 15 55.95% 62.22% 55.72% 53.30% 60.75% Apr-15 63.76% 59.52% 63.91% 49.13% 66.32% May- 15 62.46% 31.11% 63.61% 56.70% 70.25% Jun-15 61.04% 66.67% 60.90% 47.25% 60.03% Jul-15 65.31% 58.54% 65.53% 58.14% 67.73% Total 58.80% 60.80% 58.73% 49.45% 58.20%
Southwark CCG
Month Cat A 8Min% R1 8Min% R2 8Min % C1 20Min% C2 30Min% Jul-14 69.29% 70.45% 69.26% 55.91% 54.75% Aug-14 69.33% 75.00% 69.19% 50.22% 57.30% Sep-14 63.11% 65.96% 63.02% 42.86% 50.79% Oct-14 66.23% 77.08% 65.90% 53.53% 52.23% Nov- 14 62.76% 71.79% 62.53% 54.41% 57.05% Dec-14 53.73% 71.43% 53.21% 43.52% 47.97% Jan-15 66.96% 79.17% 66.55% 57.59% 68.89%
Feb-15 62.14% 64.58% 62.06% 47.16% 56.44% Mar- 15 65.29% 67.35% 65.23% 45.16% 58.84% Apr-15 70.75% 68.75% 70.80% 58.58% 67.93% May- 15 73.69% 70.00% 73.76% 58.17% 69.87% Jun-15 70.56% 67.19% 70.70% 50.44% 63.37% Jul-15 69.77% 67.44% 69.83% 51.29% 65.64% Total 66.32% 70.36% 66.20% 51.56% 59.35%
Bromley CCG
Month Cat A 8Min% R1 8Min% R2 8Min% C1 20Min% C2 30Min% Jul-14 64.97% 64.10% 64.99% 52.45% 49.64% Aug-14 61.98% 78.13% 61.52% 46.81% 51.33% Sep-14 54.98% 71.74% 54.31% 50.67% 52.14% Oct-14 59.19% 55.00% 59.32% 44.91% 52.33% Nov- 14 56.72% 64.44% 56.44% 45.96% 54.96% Dec-14 46.34% 45.61% 46.37% 34.01% 40.19% Jan-15 58.30% 50.00% 58.57% 46.62% 62.99% Feb-15 53.18% 61.76% 52.94% 46.21% 54.70% Mar- 15 57.91% 50.00% 58.19% 44.22% 60.47% Apr-15 59.49% 79.07% 58.80% 56.17% 67.28% May- 15 64.50% 62.07% 64.55% 51.85% 66.20% Jun-15 62.62% 66.67% 62.47% 49.39% 62.38% Jul-15 65.93% 65.38% 65.94% 56.21% 68.47% Total 58.77% 61.79% 58.67% 48.20% 57.13%
Greenwich CCG
Month Cat A 8Min% R1 8Min% R2 8Min% C1 20Min% C2 30Min% Jul-14 68.34% 68.89% 63.35% 47.37% 52.59% Aug-14 68.52% 69.23% 61.49% 55.61% 54.47% Sep-14 59.04% 60.00% 56.73% 42.49% 52.39% Oct-14 59.37% 55.81% 58.23% 45.79% 53.31% Nov- 14 62.07% 71.79% 58.01% 44.51% 57.76% Dec-14 56.43% 60.47% 46.40% 37.87% 44.59% Jan-15 63.00% 72.73% 56.51% 57.76% 62.12% Feb-15 62.74% 55.88% 56.05% 47.24% 55.84% Mar- 15 65.50% 62.22% 55.72% 53.30% 60.75% Apr-15 71.53% 59.52% 63.91% 49.13% 66.32% May- 15 68.99% 31.11% 63.61% 56.70% 70.25%
Jun-15 70.48% 66.67% 60.90% 47.25% 60.03% Jul-15 71.65% 58.54% 65.53% 58.14% 67.73% Total 65.11% 60.80% 58.73% 49.45% 58.20%
Lambeth CCG
Month Cat A 8Min% R1 8Min% R2 8Min% C1 20Min% C2 30Min% Jul-14 67.89% 80.36% 67.45% 51.34% 55.11% Aug-14 68.28% 71.93% 68.14% 50.49% 56.50% Sep-14 62.70% 64.10% 62.67% 42.93% 51.67% Oct-14 64.46% 78.05% 64.08% 47.46% 57.63% Nov- 14 63.78% 77.78% 63.29% 45.62% 54.54% Dec-14 53.04% 66.67% 52.54% 42.50% 48.55% Jan-15 64.76% 67.74% 64.63% 56.52% 67.32% Feb-15 65.57% 77.78% 65.19% 47.76% 59.02% Mar- 15 63.30% 62.50% 63.33% 45.15% 57.46% Apr-15 68.83% 76.92% 68.54% 52.61% 69.90% May- 15 69.14% 67.27% 69.21% 56.39% 71.65% Jun-15 70.05% 70.69% 70.03% 56.28% 61.31% Jul-15 71.00% 70.21% 71.02% 61.04% 65.56% Total 65.55% 71.53% 65.34% 50.67% 59.75%
Croydon CCG
Month Cat A 8Min% R1 8Min% R2 8Min% C1 20Min% C2 30Min% Jul-14 62.46% 66.07% 62.34% 48.68% 47.60% Aug-14 61.83% 62.16% 61.83% 47.08% 48.46% Sep-14 51.50% 53.85% 51.42% 42.27% 47.17% Oct-14 53.83% 47.62% 53.98% 45.95% 49.21% Nov- 14 51.76% 58.06% 51.55% 44.12% 44.13% Dec-14 45.92% 51.85% 45.76% 32.77% 39.37% Jan-15 55.96% 63.27% 55.75% 46.81% 58.25% Feb-15 55.64% 66.67% 55.31% 48.33% 52.58% Mar- 15 56.30% 56.00% 56.31% 45.19% 51.36% Apr-15 61.01% 60.00% 61.03% 50.68% 60.76% May- 15 59.62% 63.64% 59.49% 51.48% 60.02% Jun-15 57.08% 75.93% 56.47% 36.00% 56.43% Jul-15 61.40% 47.73% 61.74% 48.98% 63.27% Total 56.31% 59.72% 56.21% 45.20% 52.29%
8. The London Fire Brigade(LFB)
Keeley Smith and Councillor Alan Hall Public Spending
8.1 Keeley Smith, Lewisham Borough Commander, attended the meeting of the Council’s Overview and Scrutiny Committee held on 13 July 2015 and provided the following spending figures for the LFB:
2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 Outturn Outturn Forecast Budget Budget Budget (£000s) (£000s) Outturn* (£000s) (£000s) (£000s) (£000s)
Revenue 408,210 400,720 390,946 382,400 382,400 not Expenditure available Capital 7,807 10,288 54,427 56,683 19,492 not Expenditure available *the 2014/15 Forecast Outturn is as reported to the LFB Resources Committee in March 2015.
8.2 The following key points were noted by the Committee:
Due to saving requirements 10 fire stations across London had closed last year with some appliances removed. Further savings would need to be made next year but nothing had been approved for 2016/17 yet. The Commissioner would be making recommendations and a decision was not expected until November 2015.
The LFB’s fleet was leased from Babcocks as part of a long standing contract whereby they supplied and promptly maintained the vehicles. At the time the contract was entered into, the LFB’s fleet was failing and expensive to maintain and this contract was felt to be the best proposal financially.
Fire engine on a call Forest Hill Fire Station
8.3 The Committee heard that Forest Hill fire station’s second appliance was currently being held elsewhere in order to provide emergency fire cover whilst there was the possibility of industrial action. The Fire Brigade Union only needed to give seven days’ notice in relation to strike action and this was not sufficient time to fit out an alternative appliance, hence the need to take 13 second appliances for emergency cover. However, there had now been a Mayoral Direction requiring the 13 appliances from across London currently being held for contingency purposes, to not be returned pending decisions on 2016/17 savings proposals, which could include their permanent removal.
8.4 The Committee heard that options on the budget savings proposals would be presented towards the end of the year and that it had not yet been confirmed that all 13 appliances would be permanently removed. Should such a saving be taken, modelling would be carried out to determine which 13 appliances should be removed based on impact on response times.
8.5 In response to questions from members of the Committee on this issue it was noted that:
A public consultation on the loss of the Forest Hill second appliance was not planned as it had not yet been confirmed that the appliance would be permanently lost. The actual physical location of Forest Hill fire station’s second appliance could not be revealed for security reasons, but all 13 emergency cover appliances were being held together in South East London.
The crew of the removed second appliance had use of a non-response vehicle and was engaged in other LFB activity including community liaison work such as fitting smoke alarms and visiting schools. They also still trained with the crew of the active appliance. Fire appliances were normally staffed by 4 or 5 crew members but could take 6 and the active Forest Hill appliance did take 6. Keeley Smith met regularly with senior officers, spoke up on behalf of the borough and provided her views on upcoming issues. She had been very vocal about wanting Forest Hill’s second appliance returned. Although it might be difficult to argue the case for the return of Forest Hill’s second appliance given that the station has managed relatively well for so long without it, Orpington Fire Station had been given a second appliance recently on the basis of response time data. In the event of any appliances being permanently decommissioned to save money, modelling would be carried out to determine which appliances should be removed based on impact on response times.
Keeley Smith giving evidence to the Overview and Scrutiny Committee, 13 July 2015
Performance
8.6 The map overleaf shows local fire station grounds (in pink) compared to borough wards. Although appliances from the home station are likely to be the first mobilised to an incident in their area, pumps will sometimes come from other stations. The attendance time data for Lewisham wards (see paragraph 8.9) is for incidents in that ward regardless of which station appliance attends. Another station may attend if the appliance normally nearest is already attending a different incident. When Downham Fire Station was closed, computer modelling was carried out to split the ground it covered between existing stations. Lewisham, Eltham and Bromley Fire
Stations are now covering the ground formally covered by Downham Fire Station and attendance times are better than were predicted during the consultation period, although they are sometimes outside the 6 minute target.
Fire station grounds / ward boundaries
8.7 The Committee heard that a new mobilising system would be rolled out shortly which would use GPS to ensure that the nearest appliance was always used to respond to a call out and that this should have a positive impact on response times.
8.8 Appendix 1 shows the number of incidents that occurred within the Borough of Lewisham from 2011/12 to 2014/15.
8.9 The LFB aims to get the first fire engine to an incident within an average of six minutes; to get the second fire engine to an incident within an average of eight minutes and to get a fire engine anywhere in London within 12 minutes on 95 per cent of occasions. The LFB has the fastest attendance times in the Country. The chart below shows first and second appliance attendance times in Lewisham for the four years 2012/13 to 2015/16 (at 20 July 2015). 2012/13 is a ‘base year’ with no pumps removed for cover in the event of industrial action and was prior to the closing of Downham fire station. Forest Hill’s second appliance was removed in August 2013 (2013/14 year) and Downham was closed in January 2014 (also 2013/14 year). The 2014/15 and 2015/16 (to date) years show the combined impacts of Downham closing and the temporary removal of Forest Hill’s second appliance.
8.10 In 2014/15 and in 2015/16 (to date) the six minute target has not been met in the Bellingham, Downham and Grove Park wards.
9. The London Metropolitan Police Service (MPS)
Kate Halpin, Councillor Pauline Morrison and Councillor Alan Hall Public Spending
9.1 Information on the MPS budget, provided via a letter from the Mayor's Office for Policing and Crime (MOPAC) is attached at Appendix 2.
9.2 Kate Halpin, Lewisham Borough Commander, attended the meeting of the Council’s Overview and Scrutiny Committee on 13 July 2015 to discuss the spending outlook for the MPS and the following key points were noted:
The MPS had to save around £550m over the period 2012-2016 and around £800m over the period 2016-20. However, the first phase of savings (2012-2016) would not involve a reduction in police numbers as the Mayor had promised to keep numbers at or around the 32,000 level. Options were still being considered as to how to make the next round of savings (2016-2020). Savings had and would result from restructuring; centralising or regionalising the custody, criminal justice, CID, finance, HR, Rape and Trident services; selling some buildings (including Scotland Yard); and making better use of technology. A large part of capital expenditure was being spent on ICT to ensure that vehicles could, in effect, become mobile police stations and officers could be supplied with hand held devices. There would also be a flattening of the rank structure. Police Community Support Officers (PCSOs) were valuable but the numbers were going down due to attrition and the fact that new recruitment was on hold. No decisions had been taken on the future of PCSOs and there would be consultation prior to any decisions being taken.
Councillor Hall meets local police officers
Performance
9.3 The Committee heard the following in relation to MPS performance:
MOPAC had set the MPS a target of reducing crime in seven priority categories by 20 per cent by 2016. The priority crimes were crimes felt to have a high impact on victims: burglary, criminal damage, robbery, theft from a motor vehicle, theft from a person, theft of a motor vehicle and violence with injury. Lewisham was a leading borough in terms of this challenge. Kate Halpin felt that Lewisham needed to focus more on targeting the right criminals (especially crime generating families) and on crime prevention (including the marking of property). The target for responding to 999 calls was 12 minutes if the need was ‘immediate’ and 60 minutes if the need was ‘soon’. Following the meeting the Committee was informed that the current rolling 12 months ‘immediate’ call performance was 93.2% of calls responded to within the target response time (88.9% for ‘soon’ calls) . The previous 12 months figures were 93.% for ‘immediate calls’ and 91.% for ‘soon’ calls. The average call response time was nine minutes. Figures for staff absence were below average. Following the meeting it was reported that the figures since April 2015 were as follows: April - 489 days across 62 employees; May - 480 days across 52 employees; June - 440 days across 70 employees; and July - 619 days across 76 employees. These figures include everything including injuries on duty and maternity related sickness.
Police and PCSO figures
The Borough Commander reported at the meeting that she thought there were 670 police officers stationed in Lewisham at present, which was above the target of 647 by the end of 2015.
However, figures obtained by the Working Group from the GLA suggested that Lewisham had 654 police officers (down from 696 police officers in 2010), representing a cut of 6 per cent. The figures also indicated that Lewisham had 46 PCSOs (down from 118 PCSOs in 2010), representing a cut of 61 per cent. The MPS confirmed, after the meeting, that in July 2015 there were 623 officers and 41 PCSOs compared to 627 officers and 50 PCSOs in July 2014.
9.4 Following the meeting it was announced that, at its Management Board meeting on 29 September 2015, the Met would be reviewing the role, and future, of all PCSOs in neighbourhood policing, deciding whether to retain, reduce or remove the 629 dedicated ward PCSO posts. Mark Serwotka, the general secretary of the Public and Commercial Services Union, which represents PCSOs, has commented that: "PCSOs provide a link between communities and the police that is crucial to developing and maintaining trust. We don't believe this is in the best interests of Londoners and we are calling on the Met to halt the plans and allow for proper negotiations around the alternatives."35
9.5 A motion to Lewisham’s Council on 23 September 2015 will oppose any reduction in PCSO numbers, stating that “Proposals to scrap all of London's neighbourhood PCSOs would have a profound impact on the shape of London's police force and should be subject to full public consultation if approved by the Met Management Board”.36
9.6 In response to questions from members of the Committee regarding MPS performance in Lewisham, the following points were noted:
Child Sexual Exploitation (CSE) was being taken very seriously and the police service was working closely with the eight secondary schools in the borough and was considering how best to engage with primary schools. Serious youth crime was down in the borough with 319 cases in 2012 compared with 239 in 2014. However, there had been a spike last month which had been replicated across London and the MPS was looking into the reasons behind this. Following the fatality in Sydenham High Street in June 2015, additional resources had been deployed and the gangs matrix reviewed. Targeted stop and search had a greater impact than random stop and search and from next year all stop and searches would be filmed by body worn video cameras, which should improve public confidence in the method. Most wards had one dedicated officer but the top one hundred most challenging wards in London had two; and five of these wards were in Lewisham (New Cross, Evelyn, Brockley, Lewisham Central and Rushey Green). Every borough had a counter-terrorism officer including Lewisham. A number of officers were involved in the prevent strategy, which aimed to stop people becoming terrorists or supporting terrorism, and they worked closely with the Council, local youth groups and local schools. Events had been held at Sedgehill and Deptford Green secondary schools to expose the reality of joining or supporting organisations such as Islamic State.
35 See: http://www.pcs.org.uk/en/news_and_events/news_centre/news_centre.cfm/cutting-pcsos-will-damage-met-s-link-to-london-s- communities 36 See: http://councilmeetings.lewisham.gov.uk/ieListDocuments.aspx?CId=138&MId=3689
The borough made best use of its vehicle fleet and sometimes accessed the fleets of other units based within the borough. Time and motion studies had been carried out to ensure the use of vehicles was maximised. Local knowledge was important to policing and there was a current initiative which encouraged Lewisham recruits to be based in Lewisham.
9.7 Following the meeting, a Freedom of Information request revealed how many times the police had to utilise police vehicles to transport patients to hospital in a) the London Borough of Lewisham and b) London, in 2014 and so far in 2015:
Number of police vehicles to transport patients to hospital for Lewisham in 2014: 39 Number of police vehicles to transport patients to hospital in London in 2014: 851 Number of police vehicles to transport patients to hospital for Lewisham for year 2015 up to 21 August 2015: 13 Number of police vehicles to transport patients to hospital in London for year 2015 up to 21 August 2015: 378
[It was noted that the figures were reliant on (a) the Met actually being told that a patient is being conveyed to hospital in police transport and (b) that fact then being recorded on the CAD message and Met staff then applying the 'LAS' tag to the relevant CAD messages, highlighting this has happened and allowing the collation of figures.]
10. Goldsmiths University
Sally Townsend giving evidence to the Working Group, 28 July, 2015
10.1 Sally Townsend, Director of Finance at Goldsmiths, attended the meeting of the Working Group held on 28 July 2015 and provided the following spending figures:
2012-13 2013-14 2014-15 2015-16 2016-17 2017-18 Notes £'000 £'000 £'000 £'000 £'000 £'000 Staff costs (2012-13 50,822 55,684 not excludes one off available Actual gross provision write back revenue and 3 year pension expenditure costs liability) Non-staff expenditure 27,873 29,844 not available Gross Staff costs (forecast 59,625 budgeted for 2014-15) Confidential revenue expenditure Non-staff expenditure 32,529 Confidential (forecast for 2014-15) Actual gross 6,065 11,699 not capital available expenditure Gross 12,305 Confidential budgeted capital expenditure Gross Staff costs (forecasts) Confidential Confidential budgeted
revenue expenditure Non-staff expenditure Confidential Confidential (forecasts) Capital forecasts Confidential Confidential budgeted spend N.B. Data marked confidential was made available to working group members on a part 2 basis at the meeting of the working group to be held on 28 July 2015
The Ben Pimlott Building, Goldsmiths University
10.2 Sally highlighting the following key points to the Working Group:
The overall position for Goldsmiths University was very positive with growing numbers of students and therefore income. The University had successfully managed the change in the funding regime which had reduced the levels of funding from the Higher Education Funding Council for England (HEFCE), replacing it with loans. There had been a positive effect on the university’s finances as there was strong demand for places. Future plans for Goldsmiths University forecasted a growth in expenditure and income, driven by an increased capacity to attract students. There was an overall objective to increase students within the five-year timeframe which would be beneficial financially for the university but also positive for Lewisham as a whole, as it could increase spending power within the borough. The new financial arrangements meant that there was no longer a student number cap meaning there was potential to increase the number of students. The government was currently considering permanently removing the student number cap for universities with strong teaching records. (Following the meeting, it was announced in the Summer budget that Higher Education Institutions offering “high
teaching quality” would be able to increase their tuition fees in line with inflation from 2017-1837). The Goldsmith University growth strategy was also based on increasing numbers of international students. Capital expenditure had been significantly increased since 2010 and estate and infrastructure spending including IT infrastructure was an important part of the growth strategy.
10.3 In the discussion that followed, the following key points were raised:
The number of students studying in Goldsmith who were from Lewisham was not as high as the university would like. There were excellence scholarships available for students from Lewisham and the university was looking to strengthen relationships with local schools and sixth forms and to improve their outreach to ensure students consider these options. In terms of the size of the campus and managing additional students; there was currently a space utilisation group who checked and monitored room usage and capacity to optimise space available. Capital works across the campus were also being undertaken such as fitting out the former St James Hatcham Church for additional teaching space and refurbishing the theatre to increase the floor space available. The methodology for student funding had changed in 2012 and the fees were raised from around £3000 per annum to £9000 per annum. At the same time annual HEFCE teaching grant to the university was reduced from approximately £15 million to approximately £5 million per year. This had resulted in a net financial benefit to the university in the first year as the additional student fees had more than compensated the reduction in HEFCE funding, in light of the increased student intake.
37 See: https://www.kpmg.com/UK/en/IssuesAndInsights/ArticlesPublications/Documents/PDF/Tax/summer-budget-2015-implications-for- education-v2.pdf
The change also meant that the university was less vulnerable to changes to central government funding as this made up a proportionally much smaller percentage of overall budget. Comparatively, other universities that currently benefitted from additional government funding to encourage uptake in Science Technology Engineering and Maths (STEM) subjects, were more exposed if there were sudden cuts to these funding streams. Research grant funding had reduced by £2 million from over £7.5 million in the financial year 2014/15 to £5.5 million in 2015/16. This was an issue and Goldsmiths was aiming to focus on increasing the number of successful research grant applications to counteract the reduction from central government. Currently less than 20 per cent of students were international (non EU) students, and the strategy would be to increase the number of international students, as the overall student population grows, over the next few years. An additional challenge that Goldsmiths was facing was the current government targets for schools and local authorities to increase the numbers of students going to Russell Group Universities (as Goldsmiths was not a Russell Group member). There would be increased demand for accommodation with increasing student numbers. Goldsmiths had expanded nomination agreements with private providers including residences in Greenwich, Stratford and Shadwell. The university had a good professional working relationship with the Lewisham planning department. Goldsmiths were currently going through an Official Journal of the European Union (OJEU) procurement process for tenders for improvements to the halls of residences. The Goldsmiths Livery Company still donated to Goldsmiths University and provided funding for the Hoggart building.
University Funding
Between 2009/10 and 2010/11 direct public funding for university teaching provided by the Higher Education Funding Council for England (HEFCE) fell by 11.2 per cent in real terms. This was balanced by a rise in tuition fee income (supported by publically funded loans) of 14 per cent across the university sector. Although, overall, the net result was a rise in the income universities receive for teaching, the effect has been highly variable between different institutions. The rise in university income is now dropping as the level at which home and EU student fees can be set is capped by the government and declining in real terms. However, Higher Education Institutions offering “high teaching quality” will be able to increase their tuition fees in line with inflation from 2017-18. HEFCE funding is continuing to drop with the teaching grant for universities in England due to be cut by £150 million in the 2015-16 financial year affecting allocations to institutions for the academic years 2014-15 and 2015-16. Source: See pargraph 5.40 of this report
11. Lewisham Southwark College
The College’s new logo
11.1 The following information was supplied to the Working Group at its first meeting on 7 July 2015:
Year ending July 31 2013 2014 2015 2016 2017 2018
Actual Actual Forecast Budget Estimate Estimate Notes
£m £m £m £m £m £m Not requested but sets NB Total Revenue Funding 49.1 43.7 35.7 32.3 30.0 29.7 context 1. Actual gross revenue Includes expenditure for 2012/13, redundancy/reorganisation 2013/14 and 2014/15 54.1 50.8 42.0 costs 2. Gross budgeted Includes revenue expenditure for redundancy/reorganisation 2015/16 33.3 costs 3. Actual gross capital spend for 2012/13, 2013/14 and 2014/15 1.7 7.6 15.8 Waterloo phases 1 & 2 4. Gross budgeted capital expenditure for Waterloo project complete 2015/16 19.2 summer 2016 5. Gross budgeted revenue expenditure for 2016/17 and 2017/18 (including estimated savings Includes to be found for those redundancy/reorganisation respected years). 31.2 30.7 costs Campus development in 6. Capital budgeted Lewisham may increase spend for 2016/17 and these figures, subject to 2017/18. 1.0 1.0 funding being identified
11.2 At the meeting of the Working Group held on 28 July 2015, the Council’s Executive Director for Children and Young People provided the following update on the College:
The demand for Further Education (FE) places was challenging to predict because, although overall numbers of students had increased in recent years, so too had the number of providers and spaces available. Nationally FE funding from central government had been reduced. The role of the FE Commissioner was introduced in 2013 to act quickly to deal with poor performing further education providers. There was potential for FE to be part of the devolution agenda with, for example, sub-regional groupings and management. The London Borough of Lewisham had been in discussion with the FE Commissioner, Dr David Collins, concerning the future of the college. Lewisham Council would take a very keen interest in the sixth form area based reviews which were being undertaken as part of the Departments for Education and Business Innovations and Skills review process following pilots including in Norfolk and Suffolk.
11.3 Following the meeting, it was noted that Southwark Council’s proposal to demerge Lewisham Southwark College and bring half of it under its control had been rejected by the FE Commissioner. A statement from the College said that “the College has been given time to work on its planned recovery which has recently been praised by both the FE Commissioner and received positive comments towards changes made by Ofsted.”38
11.4 The Chair of the Working Group met Carole Kitching, the Chief Executive and Principal of the College and Jeremy Cook, Vice Principal (Finance and Resources) on 8 September 2015. The following points were noted in discussion on the College’s finances:
The finances of the College are challenging as a result of (a) the year on year reduction in revenue funding for adults and the fact that funding for 16-
38 See: http://feweek.co.uk/2015/08/03/bis-confirms-ruling-on-local-authority-plan-to-split-troubled-lewisham-southwark-college/
18 year olds had not increased with inflation in recent years and (b) some other challenges specific to the College including the decreasing number of students. Although education funding is ringfenced for 5-15 year olds, 16-18 year olds falls outside of the ringfence. Funding for 16-18 year olds is 20 per cent less than funding for under 16s and has not been increased for many years. Pay is the biggest cost for the College and to help contain this expenditure there has been no pay awards in recent years. Non-pay costs are between one quarter and one third of total expenditure. Unlike schools, FE Colleges are unable to reclaim VAT. As shown in the chart at paragraph 11.1 above, the College’s expenditure had exceeded its revenue in recent years but this was now being tackled. A staffing review had resulted in a rationalisation of the number of staff, bringing it in line with sector norms. A rationalisation of college campuses would also help bring expenditure down. The old Southwark Campus in Bermondsey had been sold and the money raised used to develop the Waterloo Campus which had a greater capacity but would be cheaper to run and maintain. The Camberwell Campus was on the market and eventually there would be a single campus in Lewisham. The Breakspears building is very expensive to run and addressing this is part of the longer term strategy of the college. Developing new sources of income is an avenue currently being explored by the College and achieving at least a grade 3 at the next Ofsted inspection (due by the end of the academic year) will assist in this. It is projected that the College’s gross budgeted revenue expenditure for 2016/17 and 2017/18 will be in line with its income. The College has no borrowings which gives it flexibility in terms of the future.
11.5 Following the meeting, the Vice Principal (Finance and Resources) provided the following information on the College’s finances:
Financially the College continues to face challenges both locally and nationally. Turnover has fallen from almost £50m in 2012/13 when Lewisham College merged with Southwark College to £36m in 2014/15. Further reductions are anticipated as a result of government cuts to adult skills funding.
Excluding inflation the National Audit Office identified a fall before inflation of 11 per cent in grant funding paid to further education colleges between 2010/11 and 2014/15. The Association of Colleges estimates that over the life of the Coalition government spending in real terms on further education fell by 27 per cent. As a consequence of government policy changes over recent years the per capita funding on a 16 or 17 year old studying full-time in a college is approximately 17 per cent less than the amount spent on a 15 year old at school. Per capita expenditure on 18 year olds in colleges is more than 30 per cent less than on a 15 year old and less than half the funding for a 19 year old undergraduate.
The funding squeeze is further compounded by VAT which colleges, unlike schools and academies, are unable to recover. For Lewisham Southwark College it is estimated that VAT amounts to £1.5m per annum.
The Conservative government is accelerating the reduction of adult skills funding in 2015/16 having announced a further 3.9 per cent in July on top of the 24 per cent that had already been announced as well as withdrawing mandated funding for the delivery of English for Speakers of Other Languages (ESOL). This has hit Lewisham Southwark College particularly hard as it has proportionally more adult activity than many general further education colleges and has historically offered substantial ESOL provision.
11.6 In terms of performance, the following points were noted:
The College had received two Ofsted inspections rating it as Grade 4 (inadequate) but a recent monitoring visit in July 2015 had found progress in every area39. An interim team had been in place at the College in the two years leading up to the Sumer of 2015, but there was now a new permanent Principal and management team; and a new Chair of the Governing Body and it was envisaged that this would help instil confidence in the future of the College. A full review of the curriculum had recently taken place and improvements to the offer were continuing to be made. The College was looking to embed itself in the local community to a greater extent and better engage with its stakeholders. 36 per cent of the College’s 16-18 students were from Lewisham and 25 per cent of its adult learners.
Lewisham Southwark College Main Entrance, Lewisham Way
39 See: http://reports.ofsted.gov.uk/inspection-reports/find-inspection-report/provider/ELS/130415
11.7 Following the meeting between the Chair and the Principal and Vice Principal of the College, the following statement on the College’s view of its future was provided:
Lewisham Southwark College has faced a number of challenges over the past three years, both in terms of quality of some provision and financially. An interim senior management team led the college for some 18 months up to July 2015. A new permanent senior management team has been in post since early summer with a trackrecord of leading some of the best performing and most innovative and entrepreneurial colleges in the sector. The new Principal and CEO, Carole Kitching, was previously Principal of Newcastle College (£65 million turnover, Grade 1 and 2 provision) and has also had successful college turnaround experience. A major Organisational Review was concluded in July and has resulted in pay to income ratios in line with sector norms and a structure that will drive ownership, responsibility and accountability focussed on students and employers in partnership with key stakeholders. A further review of the curriculum offer is in place to align it more closely with unmet skills demands locally and regionally. The Principal brings significant experience in both 14-16 provision and higher education provision which will be core to the College’s strategy moving forwards. There is clearly a lot of work to do but an increased confidence locally that the College will rapidly become a college that is the pride of the communities that it serves.
12. Other Organisations
Lewisham and Greenwich NHS Trust
12.1 The following data was received from the Trust:
Actual gross revenue expenditure for 2012/13, 2013/14 and 2014/15
FY12- FY13- FY14- 13 14 15 £'000 £'000 £'000 239,328 372,096 510,137 Note that increase is driven by the merger with QEH in October 2013.
Gross budgeted revenue expenditure for 2015/16
FY15-16 £'000 513,880 Source: FIMS Plan – May 2015
Actual gross capital spend for 2012/13, 2013/14 and 2014/15
FY12- FY13- FY14- 13 14 15 £'000 £'000 £'000 5,453 15,654 23,285 Source: Statutory Accounts
Gross budgeted capital expenditure for 2015/16
FY15-16 £'000 33,483 Source: FIMS Plan – May 2015 – adjusted for delayed QEH expenditure
Gross budgeted revenue expenditure for 2016/17 and 2017/18 (including estimated savings to be found for those respected years). - Not available
Capital budgeted spend for 2016/17 and 2017/18.
FY16-17 FY17-18 £'000 £'000 39,464 23,605 Source: FIMS Plan – May 2015 – adjusted for delayed QEH expenditure
12.2 The Trust reported a deficit of £8.4m in 2014/15. The Independent Auditor’s report notes that “The Trust delivered a deficit of £8.4m in 2014/15, having
previously planned to deliver a surplus. It has also submitted a deficit budget of £38m for 2015/16 to the Trust Development Authority. The actual and planned deficits are evidence of weakness in arrangements in respect of the Trust’s strategic financial planning.”40
12.3 According to the annual accounts, the deterioration in the financial position has been driven by reductions in transitional support related to the merger with the Queen Elizabeth Hospital in the London Borough of Greenwich in 2013, increases in Clinical Negligence Scheme for Trusts (CNST) contributions and reductions in non-recurrent items. In the short term, action is being taken to improve the performance of the cost improvement programme and reduce the amount of agency spend through the recruitment of permanent staff. In the medium term, the Trust is actively working to develop strategies to reduce and then eliminate the deficit.
King’s College Hospital NHS Foundation Trust
12.4 Although King’s College Hospital sits outside the borough and was not asked to contribute any data to the working group, the Trust plays an important part in the life of the borough treating a number of patients from Lewisham postcodes. The Trust has a very serious ongoing deficit. At the end of the last financial year this stood at £47m. Its savings target for this year is £86m and it has, to date, identified £57m of savings which leaves it with a £29m gap.Reasons behind the deficit included the following:
Almost two years ago King’s acquired the Princess Royal University Hospital (PRUH), Orpington Hospital, and some services at Beckenham Beacon and Queen Mary’s Sidcup following the dissolution of South London Healthcare NHS Trust on 1 October 2013. There were long-standing financial and quality related issues at the PRUH which were found to be far greater than anticipated and urgent investment was required by the Trust in the interests of quality and patient safety such as the use of agency staff to fill vacant nursing positions while permanent staff were recruited. Emergency care pressures and the resulting impact on planned care - the demand for services locally is a major challenge with record levels of attendance and admissions at the Emergency Departments. This has also led to longer waiting times for patients and cancellations of planned operations due to the lack of beds. These cancellations have increased waiting lists for patients needing surgery as emergency patients are prioritised. Difficulty in discharging patients fit-for-discharge either back into the community or to their referring hospital. This has led to a significant proportion of elective procedures being undertaken offsite in the private sector or out of hours, which costs more than in-house treatment during normal working hours.
12.5 The Trust’s savings targets are very challenging. The Trust has been working for some time with Monitor and earlier this year the health regulator launched a formal investigation that aimed to find a solution to the long standing problems
40 See: https://www.lewishamandgreenwich.nhs.uk/important-documents
at the PRUH. The findings of Monitor’s investigation recognised the significant progress King’s had made but that further work was required to achieve financial sustainability. King’s has since prepared one and two year recovery plans and is developing a five year strategy focused on sustainability which will be completed in the autumn.
12.6 A recent King’s Fund briefing notes that deficits are increasing across the sector. It concludes that “If last year’s deficit among NHS providers was unprecedented, this year will be much worse… There are significant opportunities to improve productivity in the NHS, and efforts to deliver better outcomes at lower cost must be redoubled. However, exhortations and initiatives to increase financial control will not be enough to close the black hole in NHS finances. It is clear that if more funding is not forthcoming for the current year, the consequences will be significant – either patient care will suffer as staff are cut, waiting times rise and the quality of care deteriorates, or the Department of Health will overspend its budget.”41
12.7 The King’s Fund has also reported that a total of 77 foundation trusts reported a deficit for 2014/15, totalling £636 million; and for NHS trusts, the NHS Trust Development Authority reported deficits in 40 trusts and an overall net deficit of £472.6 million.42
Lewisham Clinical Commissioning Group (LCCG)
12.8 Lewisham CCG has no current plans to reduce spending on Health Services and remains committed to deliver the CCG and Borough Joint Commissioning Intentions43; its five year Strategy – ‘A Local Health Plan for Lewisham 2013 – 2018’; and the ‘Our Healthier South East London Strategy’ (OHSELS)44 to improve the outcomes, quality and sustainability of local services for local people. The NHS is required to make Quality, Innovation, Productivity and Prevention (QIPP) efficiency savings due to increasing demand for services. The CCG has begun the process of identifying a number of ways, in partnership with the Council and other partners, in which it can improve the quality of services using an integrated approach through the Adult Integrated Care Programme. The table below provides some indicative figures as income is not known for 2016/17 and 2017/18 and therefore assumes allocation growth of 2.4% in 2016/17 and 2.33% in 2017/18 for Programme Expenditure.
Actual Actual Actual Planned Planned Planned 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 £000 £000 £000 £000 £000 £000 Revenue Expenditure - n/a 6,395 6,152 6,552 6,552 6,552 Administrative Revenue Expenditure - n/a 369,273 377,160 392,949 402,380 411,755 Programme
41 See: http://www.kingsfund.org.uk/sites/files/kf/field/field_publication_file/Budget%20briefing%20July%202015%20final_0.pdf 42 See: http://qmr.kingsfund.org.uk/2015/16/survey 43 See: https://www.lewisham.gov.uk/myservices/socialcare/health/improving-public- health/Documents/Summary%20commissioning%20Int%20V8.pdf 44 See: http://www.ourhealthiersel.nhs.uk/news/latest-update-august-2015/9965
Total Revenue n/a 375,668 383,312 399,501 408,932 418,307 Expenditure Total Capital Spend n/a 0 0 0 0 0 Total Savings Required n/a (12,250) (9,990) (6,770) (11,600) (10,172)
12.9 The stated outcomes of the Our Healthier South East London Strategy (OHSELS) are improving the quality and sustainability of local services for local people. The OHSELS advocates new models of care focussing on community- based care initiatives, designed to deliver more care in the community. In terms of services based in acute hospitals, all hospitals must meet the London Quality Standards, and reconfigurations of services may be required as a result, requiring public consultation.
Lewisham Homes
12.10 The following spending figures were received from Lewisham Homes, an Arms Length Management Organisation which manages a number of social housing tenancies and leasehold properties within the borough, on behalf of the Council:
Outturn Outturn Outturn Budget Forecast Forecast 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 £m £m £m £m £m £m LH Management Fee 18.9 18.9 18.6 18.7 18.7 19.0 includes cost saving efficiencies 1.1 0.9 1.0 0.5 0.4 0.2 Capital Programme 36 43 49 39 41 65 Repairs and Maintenance 15 14 13 15 15 17 N.B. HRA planning assumptions, and consequent financial forecasts, are currently being reviewed and agreed with the Council.
12.11 Lewisham Homes has:
Reduced its management fee from £22.5m in 2007 to £18.6m in 2014/15. Increased its capital investment in the property stock, rising from £20m in 2007m to almost £50m in 2014/15. Invested £156m in the past 4 years to increase the number of homes meeting the Decent Homes standard from 40% to 80%. Made service improvements so that, at the same time as reducing costs, significant improvements in customer satisfaction have been made, as shown in the graph below:
12.12 Lewisham Homes is working closely with the Council on how it can work in partnership to use its resources to support the Council’s policy aims. Key initiatives it is currently planning and/or delivering are:
500 new Council homes taking on and investing in Grounds Maintenance and paying the living wage taking on sheltered housing support using a loan to provide better quality temporary accommodation properties for the Council providing apprenticeship and training opportunities.
Phoenix Community Housing
12.13 The following data was received from Phoenix Community Housing, a community gateway housing association, where residents can become shareholding members and play a central role in decision making. Phoenix owns and manages more than 6,000 properties following a stock transfer from the Council.
Actual gross revenue expenditure for 2012/13, 2013/14 and 2014/15:
All figures in £’000 2012/13 2013/14 2014/15 Gross revenue 26,650 25,303 26,926 expenditure
Actual gross capital spend for 2012/13, 2013/14 and 2014/15:
All figures in £’000 2012/13 2013/14 2014/15 Gross capital 29,360 17,783 13,692 expenditure
Gross budgeted revenue expenditure for 2015/16; Gross budgeted capital expenditure for 2015/16; Gross budgeted revenue expenditure for 2016/17 and 2017/18 (including estimated savings to be found for those respected years); and Capital budgeted spend for 2016/17 and 2017/18: Confidential
12.14 Phoenix Community Housing is maintaining revenue expenditure at similar levels as it continues to provide its core housing service as well as community regeneration work. Capital expenditure has reduced from 2012/13 which reflected the peak of the post transfer major works it was required to undertake. The majority of the increase in capital expenditure in 2016/17 relates to building new homes.
12.15 Phoenix Community Housing’s financial plan includes a commitment to current services and completion of the major works programme, as well as the building of 100 new homes during the period to 2017/18. Phoenix has spent over £140 million on a programme of works to bring the housing stock up to decent homes standard over the period 2008 to 2015. A programme of external major works is continuing in 2015/16 on which Phoenix are spending £8 million. Earlier this year Phoenix received planning permission for our first residential development – a 60-home extra care scheme in south Lewisham.
12.16 In 2013 Phoenix opened a new community building at in the heart of our area – The Green Man – including a café, a training kitchen for the Council, credit union branch and venue space as well as offices for Phoenix staff. The Green Man won the Community Achievement award at the national 24housing Awards in 2014 and received more than 20,000 visitors in its first 12 months. It has also been shortlisted for a number of architectural awards.
12.17 Phoenix is committed to playing a leading role in the regeneration of the local area, perhaps best exemplified by therestoration of the Fellowship Inn in Bellingham. The organisation plans to bring a cinema, live music venue and restaurant to the pub, along with around 70 jobs, following a successful £3.8million bid to the Heritage Lottery Fund.
12.18 Phoenix recognises the need for the Government to manage public finances effectively and in particular the welfare benefit bill. Housing associations are long term businesses and reinvest their surpluses into new homes and services to their residents. The previous Government agreed a ten-year rent framework commencing in April 2015, providing certainty over future revenue steams and enabling housing associations to plan and agree future development programmes and additional added-value services. There is a serious shortage of affordable housing, particularly acute in London, and Phoenix were finalising plans for an expanded programme of development of new homes which would help to address this.
12.19 Phoenix is now having to review its plans following the requirement to reduce rents announced in the 8 July 2015 Budget. The required 1 per cent rent reduction each year over the next four years means Phoenix’s rental income will be £4million lower by 2019/20, a reduction of 13 per cent compared to the
level Phoenix had previously assumed based on the current formula (CPI +1 per cent). Over the longer term, Phoenix estimates a total loss of some £150million in rent over 30 years.
12.20 While Phoenix remains viable, it will clearly have to make significant savings and is already looking at ways of attracting additional income, building on existing partnerships with other housing associations and service providers. Whilst the reduction is good news for existing tenants, Phoenix’s ability to borrow additional finance to develop new homes will be significantly reduced. This frustrates its desire to address housing need, which in turn will potentially add to the welfare benefit bill as people remain in more expensive private rented accommodation or bed and breakfast.
The Council
12.21 Over the course of the last parliament, local authorities' grants and spending power fell substantially. The following graph, taken from the Parliament website, shows the real-terms change from 2010/11 in departmental expenditure limits, local authority spending power and local authority grant45.
45 See: http://www.parliament.uk/business/publications/research/key-issues-parliament-2015/economy-public-finances/local- government/
12.22 The following data was submitted to the Working Group in relation to Lewisham Council’s spending:
Gross Spend
Gross Spend Other Revenue Year Capital Spend Spend HRA Revenue Spend £m £m £m 2012/13 104.4 960.6 108.6 2013/14 114.4 982.0 117.5 2014/15 122.6^ 975.2^ 130.9^ 2015/16 132.7* 985.2* 128.9* 2016/17 113.1* 951.4* 123.9* 2017/18 116.8* 920.1* 149.4* ^ As at June 2015 * These are forecast figures
Breakdown of the Gross Other Revenue Spend
Year General Fund Housing School Total Benefit Spend £m £m £m £m 2012/13 503.3 227.6 229.7 960.6 2013/14 499.7 234.5 247.8 982.0 2014/15 474.3^ 238.2^ 262.7^ 975.2^ 2015/16 478.1* 239.6* 267.5* 985.2* 2016/17 439.8* 239.6* 272.0* 951.4* 2017/18 404.7* 239.6* 275.8* 920.1*
12.23 However, in 2013 the Government changed the way local authorities were funded, removing the formula grant and rolling a number of different grants into the main allocation. The rolling in of additional grants has distorted the figures, meaning that the actual percentage reduction in spending is larger than the figures suggest. Between 2013/14 and 2015/16 the Council has experienced a 13.5 per cent reduction in net spend.
12.24 The Council is now in the sixth year of an expected ten year long period of resource reduction. In the period 2010 to 2015 the Council made savings of over £120m. Then Council is currently considering £12m of new savings proposals for 2016/17 and a further £14m for 2017/18, which leaves a gap of £19m if the target of £45m of savings over the next two years is to be met.
The Horniman Museum
12.25 The following information was received from the Director of Finance at the Horniman Museum:
12.26 The Horniman Museum receives core funding from the Department for Culture, Media and Sport (DCMS) and from Arts Council England (ACE) as
one of its Major Partner Museums. In 2014/15 the Trust received £4,064k from DCMS, a reduction of 4.5 per cent on 2013/14 and £967k from ACE.
12.27 The Horniman’s funding from the DCMS has been cut by circa 20 per cent in real terms since 2010/11. This equates to over £1m less core funding in real terms per annum. This is set to continue to decline with £3,820k agreed for 2015/16 representing a further 6 per cent cut from 2014/15. Funding beyond this will be agreed as part of the next comprehensive spending review (CSR) but cuts of 5 per cent per annum for 2016/17 and 2017/18 have been assumed for the purposes of the museum’s corporate plan for this period. Similar cuts are expected in relation to funding from ACE.
Drop in Funding for Horniman Museum
6000
5000
4000 DCMS 3000 ACE £000's Total 2000
1000
0 2013/14 2014/15 2015/16 2016/17 2017/18 Year
12.28 Over recent years the Trust has been engaged in a significant change programme to reduce costs, to enable it to be more enterprising, and to allow it to grow and diversify its sources of income. The museum has had considerable success in this regard and now generates in excess of £1.5m through its own commercial, fundraising and charitable activities. It is the museum’s intention to continue to grow and develop this self-generated income to become more resilient and less vulnerable to future changes in public funding. However, should government funding be cut more significantly or rapidly than current assumptions, there will undoubtedly be a detrimental impact on the development of these income strands as well as the museum’s service to the public and care of its collections and estate.
13. Analysis
13.1 Comparison of the financial information on public spending in Lewisham received by the Working Group shows that, as the wider economy continues to recover and growth returns, the impact of further public sector spending cuts will be doubly felt (graph 1). Almost all areas of public spending in Lewisham have been reduced, and are expected to continue to reduce, year on year to 2017/18 (graph 2). The impact of these reductions on services across the borough will likely be most significant in respect of Council services (graph 3).
13.2 The Lewisham and Greenwich NHS Trust (the Hospital) also submitted their spending numbers. However, due to the changes as a result of their merger to form a single Hospital, including this information in the graphs presented would have skewed the analysis of year on year resourcing changes. In summary the Hospital’s revenue expenditure was:
Lewisham and Greenwich NHS 2012/13 2013/14 2014/15 2015/16 Trust Revenue spend £m £239.3m £372.1m £510.1m £513.9m Annual change £m £132.8m £138.0m £3.8m Annual change % 55% 37% 1% Annual inflation % 2.64% 2.31% 1.05% 0.60% Total change % including 52.36% 34.69% -0.05% resourcing and inflation
13.3 As inflation returns to the economy through 2015/16, further public sector spending reductions will be felt more significantly in terms of services due to the combination of rising costs and funding reductions. Graph 1 and Table 1 below show the inflation rate between 2012/13 and 2017/18 (predicted). Projected inflation rates have been taken from the Bank of England's website.
Graph and Table 1: The Inflation Rate [Source - Bank of England, actual and forecasts]
Graph Showing The Rate of Inflation
4.00%
3.50%
3.00%
2.50%
2.00%
1.50% Inflation Rate
1.00%
0.50%
0.00% Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2
2012 2012 2012 2012 2013 2013 2013 2013 2014 2014 2014 2014 2015 2015 2015 2015 2016 2016 2016 2016 2017 2017 2017 2017 2018 2018 Period
Financial Year Average inflation rate 2012/13 2.64% 2013/14 2.31% 2014/15 1.05% 2015/16 0.60% 2016/17 1.65% 2017/18 2.09%
13.4 Graph 2 shows that, for nearly all the public sector areas of spending in Lewisham, recent annual reductions in funding in real terms are forecast by all organisations to continue in future years. Over time these annual reductions compound to produce significant culmulative impacts on the community.
Graph 2: Annual percentage change in gross revenue expenditure adjusted for the inflation rate [Source - Individual organisation expenditure submissions and Bank of England inflation numbers (graph 1)] Percentage Change in Expenditure taking into Account the Effects of Inflation
10.00% MOPAC (all) MOPAC (Lew isham) 5.00% London Fire Brigade
0.00% London Ambulance Service 2013/14 2014/15 2015/16 2016/17 2017/18 Goldsmiths -5.00% Lew isham Southw ark College
-10.00% Lew isham Clinical Commissioning Group
Lew isham Homes -15.00% Phoenix Community Housing
-20.00%
Percentage Change in ExpenditurePercentage Lew isham Council
The Horniman Museum -25.00% Year
13.5 Adding the dimension of population to the analysis but excluding inflation in Graphs 3 (spend per person) and 4 (culmulative percentage change in spend per person) below shows that most areas of public spending in Lewisham per person are declining, with a couple of exceptions. The exceptions are spending by Goldsmiths University and Clinical Commissioning Group spending, which are both growing.
13.6 The decline in Council spending per person is steeper when excluding the spending on the two large nationally set areas of schools and housing benefits. Taking only the Council’s General Fund into consideration, the revenue expenditure per person
falls from £1,824 in 12/13 to £1,327 in 2017/18, a fall of 27.2 per cent, compared to £3,482 in 12/13 to £3,017 in 17/18 for the Council as a whole. Add to this the 10.4 per cent impact of inflation over the same period and the spending power of the Council’s General Fund activities from 2012/13 to 2017/18 will have reduced by 37.6 per cent.
Graph 3 – revenue expenditure per person (excluding inflation) [Source - Individual organisation expenditure submissions. Lewisham population is from the 2011 census data and information from the Corporate Policy and Governance Team within Lewisham Council. London population is from the 2011 census data, the Office for National Statistics and BBC news; Where organisations have provided Lewisham expenditure data the Lewisham population data has been used. Where London wide expenditure is provided London population data has been used.]
Revenue Expenditure per Population MOPAC (all)
3,500.0 MOPAC (Lewisham)
London Fire Brigade 3,000.0
London Ambulance 2,500.0 Service Goldsmiths 2,000.0 Lewisham Southwark 1,500.0 College
Lewisham Homes Expenditure Expenditure (£'s) 1,000.0 Phoenix Community Housing 500.0 Lewisham Council (GF only) - Lewisham Council 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 Year Lewisham Clinical Commissioning Group
Graph 4 – culmulative change in expenditure per person (excluding inflation) from 2012/13 [Source - Individual organisation expenditure submissions. Lewisham population is from the 2011 census data and information from the Corporate Policy and Governance Team within Lewisham Council. London population is from the 2011 census data, the Office for National Statistics and BBC news; Where organisations have provided Lewisham expenditure data the Lewisham population data has been used. Where London wide expenditure is provided London population data has been used.] MOPAC (all) Cumulative Percentage Change in Expenditure per Population MOPAC (Lewisham) 10.00% London Fire Brigade
0.00% London Ambulance 2013/14 2014/15 2015/16 2016/17 2017/18 Service
-10.00% Goldsmiths
Lewisham Southwark -20.00% College Lewisham Clinical
Percentage Commissioning Group -30.00% Lewisham Homes
-40.00% Phoenix Community Housing Lewisham Council -50.00% Year Lewisham Council (GF only)
14. Conclusion
14.1 The work of other public sector organisations, alongside that of the Council, is critical to the wellbeing of local people; and in times of austerity it is important that the Council understands how resources are being deployed by other public organisations in the borough to help maximise overall benefit to the community. The Working Group’s review into public spending in Lewisham has found that most areas of public spending in Lewisham have seen a drop in expenditure and that, for nearly all the organisations surveyed, recent annual reductions in funding in real terms are forecast to continue in future years. To some degree, inflation, cost pressures and changes to the way funding is delivered are masking the reductions. For example, in 2013 the Government changed the way local authorities were funded, removing the formula grant and rolling a number of different grants into the main allocation. The Working Group found that the rolling in of additional grants has distorted the Council’s expenditure figures, meaning that the actual percentage reduction in spending was larger than the figures were suggesting.
14.2 Over time annual reductions compound to produce significant cumulative impacts on the community. It is therefore crucial that the public money still being spent in Lewisham is being spent in the most efficient way possible, to secure the best possible outcomes for those that live, work and learn in the borough. The Working Group therefore calls on the Council to work with its partners to ensure that there is proper public consultation on any upcoming ambulance, fire, police and NHS reconfigurations or changes; so the combined impact on Lewisham’s residents can be fully assessed and taken into consideration by the Council when planning its own service changes.
14.3 All three emergency services are clearly under some degree of strain as they struggle to meet the ambitious savings targets they have been set and their performance is often below target in Lewisham. The Working Group has therefore asked the London Ambulance Service to investigate why their response time performance (Category A calls) is below that being achieved in neighbouring boroughs; and the Fire Brigade to investigate why their six minute target for getting a first appliance to an incident is not being met in three of the borough’s wards. It is the Working Group’s opinion that the recent Mayoral Direction requiring an appliance from Forest Hill Fire Station to not be returned, pending decisions on 2016/17 savings proposals, is not helping the situation. In terms of the Metropolitan Police Service, the Working Group notes with concern that the Metropolitan Police Service Commissioner has publically stated that the projected £800m of savings scheduled for the MPS over the next four years may put public safety at risk.The decline in numbers of Police Community Support Officers (PCSOs) and plans to potentially abolish PCSOs in safer neighbourhood teams are particularly worrying, and a detailed briefing has been urgently requested.
14.4 Many parts of the Further Education sector are suffering from the squeeze on public spending, with universities and further education colleges experiencing significant reductions to some of their funding. Although the Department for
Education has sought to protect funding for pupils up to the age of 16, post-16 funding has been excluded from the ringfence. The Working Group was particularly alarmed to discover that 16–19 education has suffered from a 14 per cent reduction in funding, in real terms, between 2010–11 and 2014– 15.”46
14.5 Although Goldsmiths University has, so far, benefitted from the change in the funding regime from Higher Education Funding Council for England (HEFCE) funding to loans, many other universities have experienced the opposite, with the effect of the change being highly variable between different institutions. The poor state of the finances of the borough’s major FE provider, Lewisham Southwark College, are well documented, with turnover falling from almost £50m in 2012/13 when Lewisham College merged with Southwark College to £36m in 2014/15. Further reductions are anticipated as a result of government cuts to adult skills funding. The funding squeeze is further compounded by VAT which colleges, unlike schools and academies, are unable to recover. For Lewisham Southwark College it is estimated that VAT amounts to £1.5m per annum. The College is pushing very hard to improve its Ofsted rating from 4 (inadequate) but its financial situation is clearly a barrier to achieving this that will be difficult to overcome.
14.6 The housing crisis in the capital is well documented and Lewisham is not immune. Proposed legislative changes will exacerbate the situation when enacted and minimising the impact on vulnerable residents will be a key challenge for the Council and its partners.
14.7 Devolution is on the agenda in London and the Working Group notes the publication of the London Proposition47 by London Councils and the GLA, which advocates London government working closely with central Government to agree a devolution package focussing on six key areas: employment and complex dependency; skills; business support; crime and justice; health; and housing. The Council supports devolution, recognising that fiscal devolution in particular will reduce local government’s dependency on central government and allow it to deliver services more flexibly, generating the funds it needs to fulfil its priorities, itself. In the meantime the restoration of needs- based central funding would assist local government in meeting local priorities. In February 2015 the Council agreed a motion expressing its support for the Core Cities’ Modern Charter for Local Freedom48; and agreed to campaign for further devolution and greater localism and a fairer distribution of resources based on the restoration of needs-based central funding49. However, the Working Group would like to be reassured that this is not used as a mechanism to implement more HM Treasury top sliced cuts.
46 See: http://www.ifs.org.uk/uploads/publications/bns/BN168.pdf 47 The London proposition: Devolution and public service reform, Congress of Leaders meeting, 14th July 2015 48 See: http://www.corecities.com/what-we-do/publications/modern-charter-local-freedom 49 See: http://councilmeetings.lewisham.gov.uk/documents/s33998/Motion%203%20Proposed%20by%20the%20Mayor%20Seconded %20by%20Councillor%20Hall.pdf
14.8 On 25 November 2015 the Chancellor will set out departmental funding allocations and related changes to public service delivery for the next four years (2016/17 to 2019/20). The Working Group notes that while the extent of the funding cuts will not be known until the Chancellor’s announcement, London boroughs are preparing for at least the same scale of cuts experienced over the last parliament and notes London Councils’ submission to Government that advocates devolution as one of three broad solutions that might ease the burden on London.
London Councils’ Spending Review submission
London Councils’ Spending Review submission was submitted on 4 September 2015. It proposes three broad solutions to meet the challenge of re-designing local public services in London so that they better match the needs of London and the UK: Devolution and public service reform – supporting the London Proposition Reform of the local government finance system – including delivering a four year local government finance settlement; agreeing a fixed definition of spending power with local government for the 2016/17 finance settlement; and giving local government greater autonomy over the setting of fees and charges. Greater financial autonomy through fiscal devolution – including fully devolving business rates, exploring retention-sharing mechanisms for funding public services as part of the Spending Review process, and over the course of the parliament; and maintaining an open dialogue on a fully devolved London settlement.
14.9 Lewisham is the 17th most deprived local authority in the country and spending cuts that impact on the local authority; police, ambulance and fire services; higher education; and housing services have the potential to have a devastating cumulative impact on local people. It is therefore imperative that all organisations spending public money in Lewisham work together to ensure that limited and declining financial resources are used holistically and in the most efficient way possible, to ensure that the consequences of austerity are minimised wherever possible.
15. Monitoring and ongoing scrutiny
15.1 Business Panel will consider the Council’s overall scrutiny work programme in light of the review findings, with a view to considering whether further work should be carried out. If it feels that further work should be carried out, the relevant select committees will be asked to incorporate this work into their work programmes as a matter of priority.
16. Appendices
Appendix 1 – Chart showing the number of London Fire Brigade incidents that occurred within the Borough of Lewisham from 2011/12 to 2014/15
Appendix 2 – Letter from MOPAC received on 2 July 2015
ReportArea (All) ReportBorough Lewisham ReportStation (All)
Count of CallID DDFinYear FRS IncidentGroup IncidentType WOSIncidentGroup 2010/11 2011/12 2012/13 2013/14 2014/15 London incident Fire Primary Fire Dwelling 281 256 249 241 245 Other residential 15 23 16 12 16 Non residential 61 80 47 54 46 Outdoor 22 32 13 17 9 Road Vehicle 101 69 63 64 59 Other Transport 1 1 Primary Fire Total 480 460 389 389 375 Secondary Fire Dwelling 1 Non residential 3 1 1 2 Outdoor 435 406 231 320 266 Road Vehicle 4 1 2 Secondary Fire Total 443 408 232 322 268 Chimney Fire Dwelling 3 3 3 Chimney Fire Total 3 3 3 Late Call Dwelling 1 1 Late Call Total 1 1 Fire Total 923 871 625 711 647 Special ServiceSpecial Service Advice Only 14 18 23 17 11 Animal assistance incidents 19 22 17 18 22 Assist other agencies 34 28 14 20 21 Effecting entry/exit 339 335 322 339 341 Evacuation (no fire) 8 14 13 4 10 Flooding 318 334 356 308 358 Hazardous Materials incident 17 9 4 11 17 Lift Release 228 194 201 149 117 Making Safe (not RTC) 42 35 29 59 36 Medical Incident 15 16 15 24 15 No action (not false alarm) 74 80 53 67 65 Other rescue/release of persons 17 15 10 13 15 Other Transport incident 4 9 15 18 9 Removal of objects from people 7 7 11 10 9 Rescue or evacuation from water 2 2 1 RTC 100 109 132 117 133 Spills and Leaks (not RTC) 54 43 58 45 39 Stand By 2 2 2 Suicide/attempts 5 5 3 4 4 Water provision 1 Special Service Total 1,295 1,276 1,280 1,226 1,224 Flood call attended - Batch mobilised 1 1 10 5 Flood call attended - Batch mobilised Total 1 1 10 5 Special Service Total 1,296 1,277 1,280 1,236 1,229 False Alarm AFA Dwelling 512 542 574 555 558 Other building 545 492 533 555 526 Other location 1 1 AFA Total 1,057 1,034 1,108 1,111 1,084 False alarm - Good intent 549 551 544 430 432 False alarm - Malicious 104 98 71 60 83 False Alarm Total 1,710 1,683 1,723 1,601 1,599 Grand Total 3,929 3,831 3,628 3,548 3,475
COUNCIL
Report Title Motion 1 in the name of Councillor Morrison to be seconded by Councillor Daby
Key Decision No Item No.
Ward
Contributors Chief Executive (Head of Business & Committee)
Class Part 1 Date: September 23 2015
This Council notes: - Since May 2010, as a result of Government cuts London has lost 3,170 dedicated neighbourhood PCSOs, a cut of over 70% compared with May 2010.
- As a result of the spending review in 2010 the Metropolitan Police have faced cuts of almost £600m, totally 20% of its budget. At the upcoming Spending Review it is widely expected that the Met will face a minimum of another £800m in cuts with the Guardian reporting the budget could be cut by as much as 43%.
- The ‘Safer Neighbourhood Team’ (SNT) model introduced by the previous Labour Government was widely welcomed by communities and saw each ward allocated a dedicated team of six officers (1 sergeant, 2 PCs and 3 PCSOs).
- The introduction of Boris Johnson's Local Policing Model dismantled SNTs reducing them to just a single dedicated PC and PCSO per ward.
- On the 29th September the Metropolitan Police's Management Board will consider proposals to scrap neighbourhood PCSOs all together, resulting in a loss of over 1,000 officers if approved.
- That whilst PCSOs have been informed of the Met's intention to make this decision there has been no meaningful consultation with boroughs, the public or PCSOs about the impact of scrapping PCSOs.
This Council believes: - Scrapping neighbourhood PCSOs would be the final nail in the coffin for neighbourhood policing as SNTs would be reduced to just a single dedicated PC. - The £600m of cuts handed down from Government have devastated the police service in the capital despite promises from the Mayor of London and Home Secretary that they would not hit the frontline.
- That the introduction of neighbourhood policing teams transformed local policing, increased public confidence and provided a integral link between communities and the police.
- Proposals to scrap all of London's neighbourhood PCSOs would have a profound impact on the shape of London's police force and should be subject to full public consultation if approved by the Met Management Board.
This Council resolves: - To write to the Home Secretary in opposition to further cuts to the Metropolitan Police Budget in the spending review.
- To oppose any Metropolitan Police decision to scrap neighbourhood PCSOs.
- To condemn attempts to reshape London's police force by stealth and call on the Mayor and Metropolitan Police to set out the true impact of Government cuts and engage in meaningful consultation with Londoners about the future of policing in the capital. COUNCIL
Report Title Motion 2 in the name of Councillor Hall to be seconded by Councillor Muldoon
Key Decision No Item No.
Ward
Contributors Chief Executive (Head of Business & Committee)
Class Part 1 Date: September 23 2015
“This Council expresses serious concern about the proposed £200 million in year cut to local public health budgets.
The Council notes that within days of the General Election the Chancellor of the Exchequer published the public health cuts and therefore cuts to the NHS.
The Council further notes that the Prime Minister in his first major speech since returning to Downing Street made a commitment to "a completely new approach to public health and prevention. A real focus on healthy living."
This Council endorses the response agreed at Business Panel on 25th August 2015.” COUNCIL
Report Title Motion 3 in the name of the Mayor to be seconded by Councillor Reid
Key Decision No Item No.
Ward
Contributors Chief Executive (Head of Business & Committee)
Class Part 1 Date: September 23 2015
“This Council wishes to continue London's proud history of providing a safe haven for refugees of war and conflict. We note the response by our community to provide aid and assistance to refugees in recent weeks.
This Council agrees that, while the root cause of the conflict in Syria and current refugee crisis in Europe needs to be resolved, we cannot abdicate our moral responsibility to help those affected now.
This Council reaffirms its commitment to stand ready to help with the Syrian refugee crisis, and welcome the commitment by the Mayor and other London Boroughs to ensure refugees are welcomed to London as part of the UK playing a full role in the international humanitarian response to the current crisis.”
This Council welcomes the Government’s announcement that it will increase the number of the most vulnerable Syrian refugees who will be allowed into Britain from 20 a month to 400 a month directly from the refugee camps but we do not consider this alone to be an adequate response.
This Council therefore calls on the Government to reverse its position and immediately join the EU scheme to accept 160,000 refugees across Europe.”