Appendix 1
London Assembly Planning Committee – 30 January 2018
Transcript of Agenda Item 4 – Mayoral Consultation – Draft London Plan
Nicky Gavron AM (Chair): As I said earlier, this Committee is responding on behalf of the whole Assembly to the Mayor’s consultation draft. This is the second of two meetings that we are having, although we have a whole body of evidence from many, many previous Planning Committee meetings, and of course the other Committees are going to give us evidence because they are also looking at the draft London Plan.
Our first panel today is on London’s heritage, its historic fabric, its views, its built environment and its conservation areas. Also, we might touch on its natural heritage and the river. The second panel is on open space, which of course also overlaps with the natural heritage.
Before we go into our questioning, panel, it would be a good idea for each of you to introduce yourselves so that those people who are watching can know who you are. Could you give us just one line about what you do and who you represent, starting at that end?
David English (Historic Places Principal, Historic England): My name is David English. I am Historic Places Principal at Historic England. I lead a team of planners involved with the London Plan for about the last 18 months. We have also have been involved with the United Nations Educational, Scientific and Cultural Organisation (UNESCO) mission to Westminster last February and I work with the boroughs, looking at their planning policy.
Nicky Gavron AM (Chair): Very succinct. Thank you.
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): I am Chloe Clay. I am Team Lead for Urban Design and Development at Kingston Council. I lead up a team of six different specialists, advising on planning applications and also delivering in-house supplementary planning guidance (SPG).
Charles Wagner (Co-Chair, Spatial Planning Advisory Group, Heritage Alliance): I am Charles Wagner. I am a heritage and planning consultant. I am Co-Chair of the Spatial Planning Advisory Group of the Heritage Alliance. The Heritage Alliance is England’s largest coalition of independent heritage interests. It was set up to promote the central role of the non-governmental movement in the heritage sector. We unite 113 organisations, which together have over seven million members, volunteers, trustees and staff. Indeed, the vast majority of England’s historic environment is owned, managed and cared for by Heritage Alliance members.
Nicky Gavron AM (Chair): Thank you.
Michael Coupe (Planning and Transport Committee, London Forum): My name is Michael Coupe. I used to be Head of Planning and Regeneration at the former English Heritage. I am now so distant from that job that I am practically listable myself. I am a freelance consultant. I work mainly pro bono, I like to think on the side of the good guys. Otherwise, I sell antiquarian books.
Nicky Gavron AM (Chair): We are also interested in your role on the London Forum.
Michael Coupe (Planning and Transport Committee, London Forum): Yes, sorry. I am part of the --
Nicky Gavron AM (Chair): It is very important because we want to have a spread of expertise, including people who are meeting and working with people who are extraordinary citizens.
Michael Coupe (Planning and Transport Committee, London Forum): Yes. I am on the Planning and Transport Committee of the London Forum, which represents all the civic societies around London.
Nicky Gavron AM (Chair): Thank you.
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): Good morning. I am Nairita Chakraborty. I am the Principal Conservation Officer at Haringey Council. I have been working in the field of conservation and urban design for over 11 years. I have worked in three different local authorities, two of which have been within London.
Nicky Gavron AM (Chair): Thank you all for that. All right. Now we are going to have two panels and we want to close this session at about 11.30am, just so that you are aware of the time. We have to be. We have a lot of questions, but we want everyone to be very succinct. Today, we are not having general statements about things. What we are trying to do is to look at the Plan and say what is good about it, but particularly the meeting is mainly about whether there are areas that we want to improve. Our experience has been that if something is very important, it ought to be in the policy box. If it is in the text, however good it is, if it is not reflecting a policy, it does not have anything like the material consideration or weight of a policy in a box, just so everyone is aware of that.
We are going to start with the World Heritage Sites and Tony Devenish, who is a Councillor for Westminster [City Council] and so who better?
Tony Devenish AM: Thank you, Chair. If we start with Mr English and work our way down, please, in relation to London’s World Heritage Sites, how do you view UNESCO’s concerns that there are challenges from incremental developments that will put them at risk, potentially?
David English (Historic Places Principal, Historic England): Fundamentally, we agree that incremental development is a challenge. The policies in the new London Plan make reference to cumulative impacts and the need to assess them, which is really welcome. That is a positive step, responding directly to the recommendations of the monitoring mission.
However, there are one or two points, if you read across the Plan, which are particularly relevant to World Heritage Sites. As I am sure you will know, at Westminster, a lot of the problems which drew the mission there in the first place related not to Westminster itself but to Opportunity Areas in Vauxhall Nine Elms and at Waterloo. It is the Opportunity Area Policy that we have particularly picked up on as being a bit of a concern for the treatment of World Heritage Sites and where we think there needs to be perhaps some changes to the policy.
This is particularly relevant with the Opportunity Area near the Great West Corridor in Hounslow, which is very close to Kew. There is likely to be a public inquiry later this year for a tall building, which is in that area and could affect the World Heritage Site at Kew. Within the Opportunity Area --
Nicky Gavron AM (Chair): Is this the Curve?
David English (Historic Places Principal, Historic England): It is the Curve, yes. Within the Opportunity Area Policy, there is a line which says about Opportunity Areas being allowed to define their own character and density, which seems quite a strong push towards very tall buildings that pay no regard to their context. That is something from our perspective that we would want to see adapted or changed so that there is some recognition of context so that you do not get situations where you have very tall buildings in the setting of World Heritage Sites which spoil their outstanding universal value.
Nicky Gavron AM (Chair): You think we need to look at that part of the London Plan?
David English (Historic Places Principal, Historic England): Yes.
Nicky Gavron AM (Chair): All right.
Tony Devenish AM: Do you have any wording for that? Not now, but the point the Chair did not make but we are going to make: if you can provide short written evidence afterwards, that will be really helpful.
Nicky Gavron AM (Chair): Well done, Tony. Yes, I should have said that.
David English (Historic Places Principal, Historic England): I would be very happy to do that.
Tony Devenish AM: Thank you. Ms Clay, do you want to comment?
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): Kingston does not have any World Heritage Sites within it and so we --
Nicky Gavron AM (Chair): I do not think everyone needs to comment.
Tony Devenish AM: No, OK. I will move on to my second question, which is fairly similar to number one. What is your view on UNESCO’s fears that, despite the London Plan and borough plan policies, there is, I quote, “a disconnect between the good intentions of the policies and the buildings that are being constructed”, end quote, which negatively impact on London’s heritage? It is similar to the first question but, Mr English, do you have anything else to add?
David English (Historic Places Principal, Historic England): This is really about implementation and it definitely applies across the built environment for London’s heritage and so it is one which is relevant to everyone. In terms of improving implementation, that was an issue with the previous or the existing Plan. We commissioned various pieces of research, one of which said that some of the policies in the current Plan are not that bad, but the implementation has not been very good.
In terms of improving that implementation, having a clearer steer from the Mayor about the types of development he wants to see would be helpful. There are some really great words in the Plan about heritage, but there are places where he could be clearer. Mayoral decisions, again, send a very clear signal to the industry about what will be acceptable and what will not be acceptable. We will get on to later the key performance indicator (KPI), but that is a very positive thing, potentially, to help with implementation and making sure that that is monitored.
From our perspective, having something like an SPG or a Heritage Strategy would be really helpful with implementation because, again, it will let boroughs know, it will let neighbourhood forums know, it will let civic
groups know and it will let developers know what the Mayor’s position is in a bit more detail and how he thinks people should be approaching the historic environment, not just in the kind of overview that you can get in a plan like this, but in the everyday.
Nicky Gavron AM (Chair): Would it help the boroughs for the Mayor to have a heritage SPG?
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): From Kingston’s point of view, it would do, yes.
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): Definitely, yes. An SPG on heritage would really help us because we are suffering from severe resource cuts and we just do not have the resources to make a heritage SPG for ourselves. We are struggling just to update the conservation area appraisals, to be honest, and we are starting to add design guidance to each and every appraisal that we are making, just as short guidance to give residents, developers, etc, an idea about what kind of development may be acceptable on what sites. However, that is just part of the appraisal. That is not something that we can then take to an appeal, for example. It does not have as much weight. An SPG would be really helpful, I think.
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): Yes, and if it covered small sites as well. Incremental changes are one of the -- I know we are going to cover small sites, but for Kingston in particular half of our housing is on small sites --
Nicky Gavron AM (Chair): We are getting on to small sites.
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): -- but it is the impact on the heritage assets of those small sites. It is not just about doing something for a new site or one next to a heritage site, but it also the smaller sites. Guidance on that is also important to have within that.
Nicky Gavron AM (Chair): Guidance on that. I will move on to my question.
Tony Devenish AM: Please, go ahead.
Nicky Gavron AM (Chair): The question I was going to ask was about - and I will come back to the Heritage Strategy on this - the Mayor’s strategic objectives. He calls them ‘Good Growth’ policies. How do they correlate, in a way, with the National Planning Policy Framework (NPPF) on heritage?
David English (Historic Places Principal, Historic England): That is a big question.
Nicky Gavron AM (Chair): Is it a useful question?
David English (Historic Places Principal, Historic England): It is a very key question, actually.
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): Yes.
David English (Historic Places Principal, Historic England): From Historic England’s perspective, there has been some really good progress on bringing good growth together with sustainable development. When we did our report on good growth, that was one of the things we wanted brought out: this very strong link between the two.
The key thing in the NPPF is that heritage has a very clear place and a very strong level of protection as part of sustainable development. It is tied through and then, every time you read things like ‘environmental’ in the Plan, you understand exactly what that means.
At the moment, in this London Plan the glossary has a definition of ‘sustainable development’ which is just very slightly different to that in the NPPF. The NPPF has one for planning specifically and so it talks about economic, social and environmental, including the historical environment, and it makes reference to a 2005 document that the Department for Environment, Food and Rural Affairs (Defra) put out. The London Plan makes reference only to the 2005 document that Defra put out, which focuses more on the natural environment. Therefore, in terms of changes, one of the things we would like to see is a change to that glossary definition, from which lots of other things flow.
In relation to the good growth policies, there is a reference to’ local character’ in Good Growth Policy 2. There is a reference to the economic value of heritage in Good Growth Policy 5. Perhaps the bit which is missing is a reference to the social value and what heritage means to Londoners, to their identity and to the identity of the city, which you might be able to get into Good Growth Policy 1, something about identity, something about sense of place. These are things about why Londoners want to live here, why they care about their city and why people visit from all over the world. That is maybe not brought out as much as it could be at the moment.
We would say that the links are there, but they just need tweaking and tightening up so that you have everything covered robustly going forward.
Nicky Gavron AM (Chair): That is interesting. The social value point has been brought up to me, really in relation to other topics, too. Does the NPPF say there should be a Heritage Strategy?
Charles Wagner (Co-Chair, Spatial Planning Advisory Group, Heritage Alliance): Paragraph 126 [NPPF] says:
“Local planning authorities should set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats. In doing so, they should recognise that heritage assets are an irreplaceable resource and conserve them in a manner appropriate to their significance.”
Nicky Gavron AM (Chair): “Irreplaceable resource” is a nice phrase. That is for the Local Development Plans, but do you think the Mayor should also have a heritage SPG at a strategic level?
Charles Wagner (Co-Chair, Spatial Planning Advisory Group, Heritage Alliance): Indeed, as the Government has done with its own Heritage Statement issued last December [2017], which was one designed to be taken on board by all Government departments. The Government is expecting the next level down at the strategic planning level to do it and then local authorities to do it.
Nicky Gavron AM (Chair): All right. Does anyone else have a comment on this? You do not have to have one. OK. The other thing is KPIs. They are very important for monitoring. Is the KPI what you would like to see? Do you want to kick off, David?
David English (Historic Places Principal, Historic England): I can answer that one again. Generally, yes. The new KPI will do something that the existing one, which relates to heritage, will not. The existing one relates only to heritage at risk, which is about 5% of heritage assets in London, and those which are most at
threat. It is something that we at Historic England monitor every year. It does not make any calls on the Greater London Authority (GLA) or on the Mayor in terms of what he does and what the Authority does.
The new KPI will look at the trend in terms of whether applications are generally making positive impacts on heritage or if they are generally making negative impacts on heritage and assessing, essentially, how the GLA is reviewing heritage and the decisions it is making on it. That is --
Nicky Gavron AM (Chair): Will it mean that strategic planning applications which are considered by the Mayor as well as local --
David English (Historic Places Principal, Historic England): It is only ones being looked at by the Mayor to start with. However, we are doing some work on developing a similar performance measure with our advice and so, if you then have the two sets of advice, you can see how GLA decisions compare to the Government’s advisor on heritage. That is quite a powerful tool, then, to see if you are getting the right types of decision on this issue from City Hall.
Nicky Gavron AM (Chair): All right. Do any other members of the panel want to make a comment?
Michael Coupe (Planning and Transport Committee, London Forum): Could I make a general comment about the whole of the World Heritage side of the Plan? It seems to me that from the outside that there is quite a bit of satisfaction about the policies and we thought they were generally good and in the last Plan as well, but the problem has always been implementation and enforcement. When it comes down to it, particularly with the previous administration, the interventions were generally to overturn refusals rather than actually to be more restrictive. So it seems to me that this administration has to set an example to show that the Mayor is prepared to intervene when the boroughs are intending to do something that is contrary to policy.
What I would like to see is a tightening up of the wording. There are a lot of ‘shoulds’, shall I say, in this Plan and I wonder whether they should not be ‘musts’ or ‘be required to’ or that sort of thing. I would like to see the wording tightened up. Indeed, quite a lot of us feel that the NPPF is a bit weak: ‘sustain’ and ‘enhance’. The word ‘preserve’ appears in the legislation. Remember that in the 1990 [Planning (Listed Buildings and Conservation Areas)] Act, with the duties for listed buildings and conservation areas, the wording is very different. It is ‘preserve’ or ‘enhance’. Now we have gone through and in some cases, it is ‘conserve’ and in some cases it is ‘sustain’. I noticed that the definition in the glossary is a good one, but I just feel that there is a perception that is a bit weaker than it might have been in the past.
Nicky Gavron AM (Chair): That is interesting. Which trumps which? The legislation is 1990, is it?
Michael Coupe (Planning and Transport Committee, London Forum): Yes, the 1990 Act [Planning (Listed Buildings and Conservation Areas) Act].
Nicky Gavron AM (Chair): Does that trump the NPPF?
Michael Coupe (Planning and Transport Committee, London Forum): Yes.
Charles Wagner (Co-Chair, Spatial Planning Advisory Group, Heritage Alliance): That puts a duty on local authorities to have special regard to the desirability of preserving the building or its setting and, for conservation areas, it is about special attention that should be paid to the desirability of “preserving or enhancing the character or appearance of that area”.
Michael Coupe (Planning and Transport Committee, London Forum): That is right. I have set this out in an email to Paul [Watling, Scrutiny Manager, GLA] and so I have explained and perhaps I will do something else afterwards to make it even more --
Nicky Gavron AM (Chair): Do send us in extra wording if you want to.
Michael Coupe (Planning and Transport Committee, London Forum): Yes. The wording in the [1990] Act should trump, really, what is appearing at the moment in guidance.
Andrew Boff AM (Deputy Chair): Are you saying that it is contradictory at the moment or just not strong enough?
Michael Coupe (Planning and Transport Committee, London Forum): It is not strong enough.
Nicky Gavron AM (Chair): No. It is ‘sustain’ and ‘conserve’ rather than ‘preserve’ and ‘enhance’, which is rather stronger, is it not?
Michael Coupe (Planning and Transport Committee, London Forum): Yes. There is a plus in that the wording in the London Plan has ‘and’ so it is “conserve and enhance”. If you look at the legislation, it is ‘or’ and so you could say that that is a little bit weaker. It is swings and roundabouts, really.
Nicky Gavron AM (Chair): It is hard to enhance if you are not preserving, but still.
Michael Coupe (Planning and Transport Committee, London Forum): Yes, but you know what I mean.
Nicky Gavron AM (Chair): I am not quite sure! Anyway, we get the message.
Michael Coupe (Planning and Transport Committee, London Forum): ‘Preserve’ means to prevent from causing harm. That is what it actually means.
Nicky Gavron AM (Chair): Yes. I might ask it now, actually. Any of you who have compared the language in other parts of the Plan, do you think then that the historic heritage, historic fabric, etc, is not quite as strongly protected or preserved or enhanced as other parts of the Plan? Does anyone want to comment on that?
Michael Coupe (Planning and Transport Committee, London Forum): I think ‘should’ appears pretty consistently throughout the Plan. You might want to consider where you want to have a bit more of an emphasis and say ‘must’ or ‘shall’.
David English (Historic Places Principal, Historic England): Even just looking at the green environment policies, almost every one is ‘should’ be protected. If you go through it, in policy after policy it is very clear. In the Good Growth policies at the beginning - I think it is Good Growth Policy 2 - with the historic environment, the wording in itself is good:
“... understand what is valued about existing places and use this as a catalyst for growth and placemaking, strengthening London’s distinct and varied character.”
That is a positive approach to heritage. With the green environment, “protect London’s open spaces”, and then a list of things, which is very straightforward and very clear. We want heritage to be engaged with
positively, but a tightening up of words is the type of thing that sends a clear sign about how the administration wants to use this issue.
Nicky Gavron AM (Chair): Would you send us in examples of where you think the wording should be stronger in terms of protection?
Michael Coupe (Planning and Transport Committee, London Forum): Can I make a general point, Chair? It seems to me that throughout this chapter --
Nicky Gavron AM (Chair): The heritage chapter?
Michael Coupe (Planning and Transport Committee, London Forum): Yes, the heritage chapter. Heritage is seen as a civilising element to development proposals produced from elsewhere. What I would like to see in the Plan also is a recognition that heritage-led regeneration is a tool that should be used, particularly when you are looking at intensification in the suburbs, because the historic environment provides some sort of a template for showing you how you can get mixed uses, people living and working and playing within a short compass, and all those sorts of things, squares, terraces, mansion blocks, the sort of fairly dense development you get in areas like North Kensington, which are still civilised urban living and might just be more palatable to the boroughs, which are of course gearing up at the moment to have a revolt against the GLA because they feel that their houses and gardens are going to be threatened by intensification. I think if you look at a heritage-led approach, you might be able to have a little bit more acceptance.
Charles Wagner (Co-Chair, Spatial Planning Advisory Group, Heritage Alliance): Indeed, that is what is in the present Plan [2016] in Policy 7.9, heritage-led regeneration, which, I think, has been diluted by taking parts of it and moving them around. It is not a policy at the moment. It is just a paragraph, is it not?
Michael Coupe (Planning and Transport Committee, London Forum): What we are suggesting is --
Nicky Gavron AM (Chair): In the previous Plan, was it a policy?
Michael Coupe (Planning and Transport Committee, London Forum): We are suggesting converting that into a policy, yes --
Nicky Gavron AM (Chair): Heritage-led regeneration. That is really important. We will come to it when we talk about small sites and one of you is going to ask questions about this. Since small sites include conversion and demolition, I think a case has to be made - not in every case - for refurbishment. I do not know. We ought to get on to that.
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): It should, yes.
Michael Coupe (Planning and Transport Committee, London Forum): Yes. Sustainability, let us face it, means making the best use of the existing urban fabric. Perversely, of course, the value-added tax (VAT) rules at the moment say that if you want to repair or maintain your building you pay 20% VAT, but if you knock it down and build something new it is zero-rated. That has been a bone of contention for many years. We would quite like the Mayor to help the rest of us take this up with the Government.
Nicky Gavron AM (Chair): It overlaps also with the environment because it means then, until we have policies on embodied energy and embodied carbon, we are not going to really be able to see the value sometimes of refurbishing. Anyway, shall we park that and maybe come back to it?
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): I have a small point to make about that. In the design policies, the Plan does actually talk about the circular economy. That is where we can talk about refurbishing buildings and reusing them. They do not have to be listed; they do not have to be in the conservation area. The idea should be that if there is a building that I can use, my first priority should be how I can retrofit it rather than demolishing it because I want a very big building here. That needs to come out clearly, perhaps not in the heritage policies, but definitely there is scope to put that in the design policies because it is already talking about reusing fabric, the circular economy and using materials that have longevity, etc. That is one place that this can be included, perhaps.
Nicky Gavron AM (Chair): It is not sufficiently joined up. Which is the policy you mentioned?
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): Yes, I was just looking at it. It is the design policies and ...
Nicky Gavron AM (Chair): If you would let us know?
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): It is somewhere between D1 and D2. It does talk about the circular economy and how buildings should have a longer life and --
Nicky Gavron AM (Chair): I see. You are linking it to the circular economy?
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): Yes, because I do feel that heritage is not just about designated assets; it is also about industrial warehouses and other buildings that have historical value but are not necessarily designated. Local character perhaps we will come back to, but local character is much made of those kinds of buildings. That could be included in the designing section of the Plan.
Nicky Gavron AM (Chair): We have that. That is good. Thanks. I am done with my question.
Navin Shah AM: This is a question primarily aimed at Nairita since it refers to the boroughs. How can boroughs manage the need to increase densities even in areas that may be within conservation areas and town centres with historic local character?
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): Thank you. On one hand, the Plan is quite thorough in terms of recognising that every borough needs to understand its local context and character, but then it contradicts itself by talking about intensification of small sites and town centres. Whilst theoretically and ideally that is the right way forward - because I know in my borough the west of the borough is so saturated that we do not have any big sites and we would be looking for smaller sites there for development – but the way the Plan is set out is quite dangerous to the local character. It talks about one to 25 sites that could be seen as a licence to subdivide gardens and sell them for profit just for one small unit.
We have already struggled with it. In our Local Plan that we have, the Development Management Development Plan Document (DM DPD) when we did our urban characterisation study, we realised that most of our town centres are Victorian and most of the residential areas - I would not call them ‘suburbs’ - are made of Victorian terraces or Edwardian terraces with really long deep gardens. That is the main characteristic feature of Haringey as a borough. If we start subdividing each of those gardens randomly, then that is going
to have a very negative impact on the character. However, if you were to look for negative sites, particularly in town centres where you may be able to go taller, or within residential areas where you perhaps have a small garage site or a parking site that has been abandoned and you identify that at a very early level, then you can probably go ahead and talk about how you can develop that site in the future. I am just saying that one to 25 is actually quite dangerous.
The other thing is that there is a presumption towards demolition. It says you have to be sensitive in the conservation areas, but I know for a fact that in Highgate, for example, which is a part of Haringey, the main character is large buildings in very large gardens. Now how am I going to justify the demolition against the provision of, say, 35 new flats? That means that you are kind of agreeing with the London Plan because you are optimising the land there and you are providing 35 new homes instead of one big mansion house, but what is there for me to say? That demolition of one house does not necessarily mean harm to the whole of the conservation area, even if it is a conservation area. Therefore, I will struggle in an appeal situation to protect the character of that protected designated asset.
That is my fear. I am really worried about the small sites and --
Nicky Gavron AM (Chair): Sorry, Navin. I was just thinking. I actually live in Highgate and so I know but --
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): -- with the Bishops [Wood Court], for example.
Nicky Gavron AM (Chair): I was just wondering. The thing is that you have a conflict here, do you not? You have sometimes large buildings of absolutely no character whatsoever, so to speak, with large gardens and what you are looking at, really, is the loss of open space there. They could certainly take 20 houses.
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): Yes, and that can have an impact further on the diverse natural habitats as well because that is also not designated. When you have back-to-back rear gardens, then you have this area where --
Navin Shah AM: Also, on a larger scheme, how it will fit in with the rest of the character? It cannot be historic in terms of conservation-related, but certainly something which is very local and something which the community wants to see maintained.
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): Exactly, yes. That is like when we come back to the social value point that we were discussing before. If I were to then connect it to the local character bit that the policy includes on the design side of it, where it talks about the boroughs identifying area codes and design codes, again, I am really worried about that. Having done the urban characterisation study, there were three of us, two urban designers and me, who did that. It was work for two-and-a-half years when we did that. It was very onerous and we did only a neighbourhood-level plan. We gave only broad place principles for areas which we thought could be done better, which then informed our site allocations and other DPDs). However, if the onus is now on local authorities to go into the fine-grain detail of what densities should be going where and where the small sites would be, that is extremely onerous and extremely resource consuming. I am not sure whether any borough has the skill because it is a skill-based thing. You have to employ specific urban designers, architect urban designers actually. I am not sure whether any borough would be able to deliver that.
Navin Shah AM: I have a supplemental here. I think I know what your answer is, but I will pose it anyway and then we will open it up for any comments from any of the panel members. Does the new presumption in
favour of developing smaller sites, including conservation and demolitions in conservation areas, pose a risk to local heritage?
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): Yes, definitely. I definitely think that.
Navin Shah AM: Any comments?
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): Yes, I would agree with everything that is being said, particularly - and I know David [English] is probably going to bring them up - the Opportunity Areas, which tend to be around stations. In Kingston, all of our stations are going to be Crossrail 2 stations and a lot of those areas have not seen a lot of change. There are a lot of Victorian and a lot of heritage assets around there, which will mean huge swathes of change. In favour of development and housing numbers, you are always going to have that favour to knock it down and build something high because it is optimising the site and it is doing all of the things that the new London Plan is saying what we need to be doing and not giving enough weight to heritage.
On the flip side, with the garden aspect, whilst you may not notice it from the street - that tends to be the public viewing place and, therefore, if the impact is at the back, there is no impact because you cannot see it from the street - the impact on the natural space. Particularly with storm water and surface water, all of those issues are going to be huge and they impact on our urban environment. Some connection there needs to be made, which I do not feel is ever made within the London Plan.
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): Agreed.
Navin Shah AM: Moving away from small sites, how will the focus on increasing densities in town centres - often, as you will see, through London Plan designation, Opportunity Areas in outer London boroughs, for example, and areas around stations - impact on protecting local significant heritage? David, you might --
David English (Historic Places Principal, Historic England): I would say that the approach taken in this version of the Plan, particularly to town centres, is far more coherent and far more sensitive to heritage than in the current London Plan, particularly after the last set of revisions, which talked about wholesale redevelopment and was potentially very harmful. In relation to town centres, the approach here is a good one, one that could do to be picked up with the Opportunity Areas Policy, thinking about densification around rail hubs and stations.
However, my colleagues here are right to put their finger on the Small Sites Policy. That is perhaps the biggest threat to heritage. The plan-led approach that this document is encouraging is a good one, from our perspective. There are issues to do with resources and that is where good guidance from the GLA will be really helpful but there are specific parts of the small site policy where it talks about demolition, where it talks about how all applications can have a certain amount of harm to heritage and that is automatically OK, and where it talks about only excluding statutory-listed buildings: these are things which are not in line with the Planning Act on listed buildings and conservation.
Nicky Gavron AM (Chair): They are not?
David English (Historic Places Principal, Historic England): They are not.
Nicky Gavron AM (Chair): Which policies are those?
David English (Historic Places Principal, Historic England): This is in the Small Sites Policy. It is parts E and F of H2 that are of particular concern.
Nicky Gavron AM (Chair): E and F?
David English (Historic Places Principal, Historic England): It is also not in line with the NPPF. There are some bits of this policy which, if we were to prioritise changes that would be for heritage - those would be the changes that we would really focus on.
Navin Shah AM: Do you think there are enough measures within the policies to protect local heritage within those areas which will have much intensification within town centres? Because I can give you an example now. I represent the Borough of Harrow. Town centre development is quite right, obviously, in terms of that being an Opportunity Area, but then the controversy comes about when it is a landmark building which is up in the air, such as St Mary’s Church. It becomes a major issue of contention when you start looking at 20-storey buildings coming up.
Do you think that there is enough divergence, so to say, within the new Plan to give that extra emphasis to make sure that local buildings or local landscapes of value are protected? They may not be of architectural, conservation or heritage significance, although that is arguable in itself, but things which are important in terms of the local fabric. Do you think that there is enough in here to protect or additionally protect?
David English (Historic Places Principal, Historic England): There are some additional protections for things like landmark churches if boroughs do the work on things like views. There are some good words in the Plan - which could be slightly stronger, but they are definitely a step in the right direction - about the weight given to local view protection. If you think about London strategically, the key things in the views are St Paul’s Cathedral and the Palace of Westminster. If you were to do that at a borough level, it could be St Mary’s Church in Harrow or an equivalent building. It need not necessarily be listed --
Navin Shah AM: Unfortunately, it is not done because, when you look at local landmarks of character, they are not just strategic views and, therefore, they do not take on the same strategic importance.
David English (Historic Places Principal, Historic England): I know that Kingston is certainly doing some great work on this --
Navin Shah AM: I have that coming up later on. If we can move on, I am mindful of the time --
Nicky Gavron AM (Chair): Kingston has done some great work.
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): On the views side of things, but I think you want to wait until later, but --
Navin Shah AM: No, you might as well go on.
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): We are currently using a three-dimensional (3D) model done by VU.CITY and Wagstaffs. We have analysed all of our current views that we have locally that we see as locally important. There were roughly 900 views that we looked at across the entire borough and we used a 3D model alongside that to look at those, as well as doing site visits. We have come up with 13 highly important views. We use the same language that has come out in the London
Plan, which is lucky. We have been working with Historic England on it. The GLA has been invited to join in on this but has not been as active as Historic England.
What we are planning on doing is having all of these views put into the VU.CITY model. That allows developers or us to put developments in place and highlight those buildings and take views from all across the borough and outside of the borough. I know that VU.CITY is currently working with, I think, the GLA or Transport for London (TfL) to build a London-wide model. That way, you will be able to see impacts from buildings outside of your borough. It is allowing us to have a greater understanding of the impacts of new buildings or changes to buildings. At the moment, it is just a massing model, but the more detail we can put into that - such as materials and things like that - it will make a huge difference to those longer, locally important views.
David English (Historic Places Principal, Historic England): Heritage is a key part of that with local landmarks --
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): Absolutely.
Navin Shah AM: Yes. I have a policy-related question here. We have Design Policies D1 and D2 and Heritage Policy HC1 of the Plan, which promote an evidence-led approach to identifying growth areas and appropriate types of development. The question is: can character analysis help deliver good growth?
Michael Coupe (Planning and Transport Committee, London Forum): Yes, definitely.
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): Definitely.
Michael Coupe (Planning and Transport Committee, London Forum): Can I just make a general point? I know we are talking about heritage here, but for a long time only conservation areas had character appraisals and, therefore, politicians - particularly national politicians - say, “If it is outside the red-lined area, then the rules of the jungle apply and we do not need to worry about anything really at all”.
Kingston set a fantastic example by characterising the whole of their borough and what we would like the GLA to do is to try to make sure that all the rest of the London boroughs have borough-wide characterisations. That will help because that gives you some guidance, particularly with the 3D models, as to what you can do in terms of intensification.
Nicky Gavron AM (Chair): That is quite interesting because then you could isolate, sometimes, way outside of conservation areas, a street or three streets that are places --
Michael Coupe (Planning and Transport Committee, London Forum): Yes, absolutely.
Nicky Gavron AM (Chair): -- the sorts of places that people really do identify with that are part of the historic fabric. That would do that. Is there not another tool in the London Plan that would do that, the area density or the area design codes?
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): The area design codes, but, then again, that was the point I was making before. The urban characterisation study - like Kingston - that we did talked about place principles and advice on block patterns that could be appropriate for certain sites where we thought they could be improved in a way, especially in terms of permeability and movement and circulation patterns.
The problem, however, was that we worked at a neighbourhood level. What this Plan tends to suggest is to go at the finer, street-by-street level of detail and that is quite resource-consuming. That is where my worry is, that, before we can come up with that characterisation study, there will be a queue of developers outside who would want to do there development first. That is my biggest worry with this Plan. It is really idealist and I am really glad that the London Plan requires that characterisation study, which up until now we were doing because Historic England asked us to do it. We did not do it because the London Plan asked us to do it. It, in a way, strengthens it but, on the other flip side, it puts too much onus on the local authority and I just do not know whether it is practicable.
Nicky Gavron AM (Chair): Can I just clarify? Does the Plan actually ask for characterisation studies?
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): Yes. Policy D2 talks about initial evaluation. It talks about:
“To identify an area’s capacity for growth and understand how to deliver it in a way which strengthens ……”, etc, and it goes into details:
“In preparing Development Plans and area-based strategies, which covers the following elements ...”
Your development plan is the DPD. That is a borough-wide development plan. We did – Nicky Gavron AM (Chair): Can I just ask? Does it actually say in that evaluation list “characterisation studies”?
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): The things that it has picked up will be part of your characterisation study; for example:
“... urban form and structure ... transport networks ... open space ... historical evolution and heritage assets ...”
These are the elements that we studied for the characterisation study --
Nicky Gavron AM (Chair): It does not use the words --
Navin Shah AM: Should it actually say it?
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): Perhaps, yes.
Michael Coupe (Planning and Transport Committee, London Forum): It does not specifically ask.
Nicky Gavron AM (Chair): Should it not say it?
Michael Coupe (Planning and Transport Committee, London Forum): No, it does not, not specifically for borough level.
Nicky Gavron AM (Chair): Should it say that?
Michael Coupe (Planning and Transport Committee, London Forum): Yes.
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): Yes, it should, yes.
Nicky Gavron AM (Chair): That is what we want to know.
Charles Wagner (Co-Chair, Spatial Planning Advisory Group, Heritage Alliance): It should say it because it is set out in the NPPF at paragraph 170:
“Where appropriate, landscape character assessments should also be prepared, integrated with assessment of historic landscape character, and for areas where there are major expansion options assessments of landscape sensitivity.”
Nicky Gavron AM (Chair): That is text?
Navin Shah AM: Yes.
Michael Coupe (Planning and Transport Committee, London Forum): Could I just say? There is only one good thing about small sites because, generally speaking, what has happened with housing policy nationally is that it is the big battalions that have done all the development. The reason for that is that they are big enough to be able to offer some affordable housing. The small stuff does offer an opportunity for local developers and local architects who live in the area and have to live with the consequences of what they produce to maybe do rather better developments than you might have had otherwise. That is the only plus, I think.
Nicky Gavron AM (Chair): Also, there are sites like garage sites and there are open sites that would take housing.
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): Absolutely, yes.
Michael Coupe (Planning and Transport Committee, London Forum): Yes.
Nicky Gavron AM (Chair): Also, there are 800,000 households with two or more bedrooms spare. Often people want to downsize in their area but cannot and it offers that opportunity, too. You can stay in your community, perhaps. There are quite a lot of pluses about this. It is just that we want to examine the threats and the risks as well. We do not want unintended consequences.
Michael Coupe (Planning and Transport Committee, London Forum): No, we want the heritage elements to be a lead in a regeneration process rather than targets for demolition.
Nicky Gavron AM (Chair): Sure.
Tony Devenish AM: I just wanted to ask the Haringey officer. Are there particular pinch-points in terms of resourcing some of this work you are trying to do on heritage? Is there something that you would say to the GLA where you are particularly struggling to resource, particularly on the small sites side?
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): Yes, in terms of design. At the moment, I am the only Principal Conservation Officer. We have an Urban Design Officer. To do the characterisation study, we asked Neil Double [Urban Planner, Inner Circle Consulting], a guy who had worked for Hounslow as well. We asked him to come in and he was the lead on the urban characterisation
study. The work that we did was in addition to my and Richard’s [Truscott, Urban Design Officer, London Borough of Haringey] regular work. Whilst Neil was fulltime on this, Richard and I already had a really busy work schedule and on top of that we had to do that. It was two-and-a-half years. The worry is also that, with us, we did it at a neighbourhood level. We did it at maybe a 1:50,000 scale, but the Plan requires it look at 1:500 scale, which is --
Tony Devenish AM: Are you going to write to the GLA and say, because they have made that change, there will be an additional cost of having one more fulltime equivalent at least? Are you pushing these points back to the GLA? It is very good at pushing everything down to the boroughs. I do hope that Kingston, Haringey and the others are pushing stuff back up.
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): Yes, definitely. This resource is definitely an issue that I will raise.
Navin Shah AM: On this whole capacity issue, which is a big concern, to be honest, I can see in a sense where you want boroughs to take that leading role because it is to do with local character and all of that, but the question is, given that there is a capacity issue already, how can both the London Plan as well as the GLA help the boroughs?
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): Guidance. When we talked about -- sorry, David wants to say something. I was just going to say guidance.
David English (Historic Places Principal, Historic England): I would say, in addition to guidance, which would be very helpful --
Navin Shah AM: Yes.
David English (Historic Places Principal, Historic England): -- there is a huge resource and Charles [Wagner] touched on this in his introduction. There are hundreds of thousands of people who really care about heritage, millions of people who care about heritage. There are some programmes - and these could be boosted and encouraged - to help residents, help civic groups, help neighbourhood forums get involved. They can do character assessments. It is not rocket science. It takes a lot of time on the ground, but it is something that absolutely everyone can get involved in, and that can --
Navin Shah AM: Local amenities societies and the like.
David English (Historic Places Principal, Historic England): Yes. That could be a really good way to embed them in the process and put them at the beginning of the plan-making process, rather than only coming in at the end and being consulted on proposals.
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): Yes. I know Croydon did this with its conservation areas and locally listed Local Areas of Special Character, but it did take them five or six years. By the time you have done it, it is going to be out of date and then another one is going to come in. There is the timing issue. It is great and that is what should be done, getting local people to buy into this and have their own respect for their own areas. One of the things with small changes is you have permitted development rights, things like people putting in crossovers and taking out their front gardens, which is all OK. They can do that. They do not really need planning for that. That will change the character of an area in a decade - gone - and so what was a conservation area for a reason is now no longer. Even the incremental changes that are allowed can destroy areas.
Charles Wagner (Co-Chair, Spatial Planning Advisory Group, Heritage Alliance): Can I just give an example of the local work you can do in this area? I live in Hammersmith and I sit on the Hammersmith Residents Working Group. We have been brought in to work with the planners on a masterplan for Hammersmith. That has involved looking at the historic environment. A big firm of consultants was involved and identified every listed building and then said how the place had changed, but they did not evaluate the buildings that are there, the ones that are partially in conservation areas and not in conservation areas.
We said from the start, as the laypeople on this group, that surely the answer is to go through King Street - the main street in Hammersmith - and look at every building, look at its history, look at what is left of it and say, “This one is worth keeping”, or, “This one is not worth keeping”, or, “This one has this amount of local significance”. The Council has not done that, but we as the Hammersmith and Fulham Historic Buildings Group are now endeavouring to walk down King Street and use the local archive and what resources we have to produce a study of King Street so that we are informed and the Council is informed about the local importance of a number of the buildings. We are not that listed buildings here; we are talking about buildings of local interest, Victorian terraces. Are they worth keeping? Have they been so badly altered that maybe you should be thinking about redevelopment? That then gives you the answer to take back to the masterplan and to the developers about their sites.
Michael Coupe (Planning and Transport Committee, London Forum): It would be a great reassurance, particularly to the outer London boroughs, for the GLA to acknowledge that intensification does not necessarily mean tall buildings. There is a lot of concern about tall buildings and how this would change character. As I have said already, you can get quite high densities, looking at historic areas, with the pattern that traditionally we have: mansion blocks, squares, terraces and all the rest of it. It is perfectly possible to do that. Look at the centre of Paris, for instance, which is much higher density than London and no high-rise --
Nicky Gavron AM (Chair): Do you get many mansion blocks in the outer London suburbs?
Michael Coupe (Planning and Transport Committee, London Forum): No, but we could do. That is what I am suggesting.
Nicky Gavron AM (Chair): We could?
Michael Coupe (Planning and Transport Committee, London Forum): Yes. What I am suggesting is that we look at the model or the template of the historic environment and think about how we could apply it to certain parts of the outer London boroughs. It would not be high-rise. It would be civilised urban living, which I think would be satisfactory. Of course, it is much more sustainable, with mixed uses, with everything attainable in a short compass.
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): One of the things that we have had in Kingston recently was a mansion block put forward for Tolworth but on steroids. It was 11 storeys, which is not --
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): That is not a mansion block!
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): And they take the typology of a mansion block and say, “This is a mansion block. This is optimising a site”, and so you have to then balance that. It is not a mansion block but is a --
Michael Coupe (Planning and Transport Committee, London Forum): It needs to fit into the character.
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): Yes, and this is one of the issues. You will have typologies that people will try to take from central London and plonk into a suburb where it does not work, and there must be a different way of densifying that site.
We will see a lot of house extensions and a lot of splitting of houses, which traditionally people have bought because they want a four-bedroom house but then they do not want to move out because it costs too much and, therefore, they will convert. Then you have a lot more strain on that house and the services within that area, things like bins. You have one house that had one family in it having two sets of bins or three sets of bins or four sets of bins now because you have to recycle and everything else. If you split that into two, you now have eight sets of bins. All of those little things then also change the character of that street.
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): Yes, and parking as well. There are old streets just covered with parking and you cannot even see the terrace. You cannot see front gardens. You cannot see front boundaries.
Michael Coupe (Planning and Transport Committee, London Forum): You have the drives and you have the bins and --
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): Yes, exactly. It is the incremental changes, as you were saying before, absolutely.
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): Yes. They have a huge impact on --
Andrew Boff AM (Deputy Chair): Can I ask Mr Coupe whether or not you think the London Plan should make a requirement that developers should come forward with a low-rise proposal first before they produce a high-rise one?
Michael Coupe (Planning and Transport Committee, London Forum): Yes, I think I probably do. I would defer to my colleagues who have more working knowledge now. I am speaking --
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): Now it is the other way around, though. They always come up with a bigger building and then we negotiate it down.
Andrew Boff AM (Deputy Chair): The problem is of course that those negotiations sometimes are not successful.
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): Yes, and then we end up here.
Navin Shah AM: This this question is very important and it comes up every time on London Plan issues --
Andrew Boff AM (Deputy Chair): Mr English, you were about to --
David English (Historic Places Principal, Historic England): I was just going to say on the tall buildings Policy D8 that there is part C(1)(d). That justification. It says:
“Proposals resulting in harm [and this is purely to heritage] will require clear and convincing justification, demonstrating that alternatives have been explored and there are clear public benefits that outweigh that harm.”
I think what you are suggesting is that that test - that alternatives have been explored - should be applied across the board. It is quite possible that that type of approach, where people can see that there is a justification for why it has to be this way in this location to produce these benefits, would help convince communities that that was the right solution in terms of built form for that site. On a lot of sites, the density that you get is relative to how you draw the boundary and you can tweak that more or less.
Andrew Boff AM (Deputy Chair): What we are trying to get to, really, is that developers of tall buildings will always say, “That is the only way we could get that kind of density”, without trialling any other alternative. That is my concern.
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): For me, what I see coming is all about viability. The first thing I say is, “I do not care how much you have paid for your site”, but something like that should be in there: that viability to the historic environment or any built environment does matter. That is your issue. If you have overpaid for that site, then the built environment should not pay the price for that. That is what happens a lot and that is what it comes down to. It comes down to viability and affordable housing, and then it is a balancing act and effects that always result in housing winning. That is a problem that we see.
Navin Shah AM: We collectively see this London Plan as yet another opportunity to make sure that high densities or intensification does not mean automatically tall high-rise buildings. That is where this sequential test or an ability to prove or a requirement to prove that they have explored other options before coming to a high-rise solution. There is enough evidence. Sunand Prasad [Penoyre & Prasad Architects], for example, an architect on the panel, consistently said the same thing: we would like to see alternatives produced before promoting high-rise buildings.
Nicky Gavron AM (Chair): The whole Assembly has put that forward as a recommendation.
Navin Shah AM: Yes. That is what you would call a cross-party kind of approach here. That is what we would like to see happen. That is what we have heard from panellists as well. I would certainly want to see that this London Plan does carry that through.
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): Yes, I would agree with that. It just goes back to the viability and the balancing.
Navin Shah AM: Sure. Of course.
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): That is always going to be the point. They will come in and they will say, “Yes, you can have a four-storey building, but you are going to get no affordable housing”.
Navin Shah AM: You can accommodate it. You can in many instances have medium-rise blocks that deliver the same --
Nicky Gavron AM (Chair): Yes, eight or ten storeys.
Navin Shah AM: Exactly.
Andrew Boff AM (Deputy Chair): The less consensual position is that you should ban the lot of them, but --
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): Even eight to ten storeys medium-rise for suburbs is still quite high.
Nicky Gavron AM (Chair): Can I just call us to order for a moment and just say? None of you have said what is actually new in this Plan, which is that local authorities are able to decide what a tall building is. Last week, we had the [constituency] Assembly Member covering Richmond [Tony Arbour AM] saying, “Does that mean I can have five storeys as my tall building?” It does allow for that. It is going to be on an area-by-area basis, but it does give enormous freedom to them.
Navin Shah AM: There is a question coming up on that.
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): We are probably very supportive of that but depending on different Members in different areas and residents. That is a positive. Also, you still have the optimisation and all of those other things, removing the density matrix but also retaining standards. As a minimum standard, if you cannot have any pocket living or any of those types of things, they go against each other and you going to end up with a taller building.
Michael Coupe (Planning and Transport Committee, London Forum): If you give the developers a clear message they are not necessarily going to be allowed their own development, then they should not pay too much for the site. That is when it comes down to it. It is all a question of what they pay for the site.
Nicky Gavron AM (Chair): That is a very good point, which means that boroughs have to get on with defining what the range is going to be in different areas; that is if we do not have a density matrix.
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): Yes. In Haringey, based on the characterisation study, we are now working towards a tall building SPG. The main parameter is that if your building is two storeys taller than the rest of the area, then you are looking at a ‘tall’ building - or a ‘taller’ building - because, technically, you would be able to see it from various views, whether you are in a conservation area or other conservation areas. We have said that if you are --
Tom Copley AM: When you say “the rest of the area”, do you mean the tallest building in the area or do you mean the average?
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): The average height. For example, if you are looking at a Victorian suburb, it is about three storeys with Georgian townhouses or Victorian townhouses. If you are proposing a six-storey building, then you will qualify that as a ‘taller’ building. That is the approach we have proposed. We have not adopted the SPG yet. We are still working on it, but that is the approach that we have.
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): That is quite interesting because, in places like New Malden, we have areas around the station which have 16 storeys and then next door is a two-storey residential road. You then ask, “What is in between?” Then you start to get this mini Manhattan right around the station. In terms of the London Plan, you are optimising your site and
you are working on your Crossrail 2 stations and all of those things, but it is a huge change to the character of that area, which is literally next to a conservation area. You are impacting on the setting of that conservation area. Yes, they sort of work together but also work against each other in a lot of the policies in it.
Michael Coupe (Planning and Transport Committee, London Forum): Also, if you are a developer and you get your application refused, let us say, you will want to take a view as to whether you are going to be able to get away with it on appeal. We need to have policies couched in such a way that there is more strength, as it were, for the boroughs in fighting a case on appeal.
Navin Shah AM: You can defend it on appeal?
Michael Coupe (Planning and Transport Committee, London Forum): Yes.
Navin Shah AM: Chair, we have done my questions thoroughly now. Thank you.
Andrew Boff AM (Deputy Chair): Most of my questions are about small sites, but a lot has been covered. The terminology in the London Plan is that you can turn down a development on a small site where there is an “unacceptable level of harm”. What does that mean, do you think? What is an acceptable level of harm?
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): This is what I struggled with. I highlighted that word when I was writing my notes. Yes. Does that mean that less substantial harm is permissible and substantial harm is not going to be permissible? That is a very weak word, I would say.
Andrew Boff AM (Deputy Chair): I sometimes think that the London Plan is just an employment project for planning lawyers so that they --
David English (Historic Places Principal, Historic England): You have put your finger on a problem there. An unacceptable level of harm in a conservation area where the local authority has a duty to preserve or enhance? You cannot have an unacceptable level of harm. Fundamentally, that part of the policy needs to be changed or the following bit where it talks about the presumption should not be applied to. It needs to say “all heritage assets” so that you are not automatically building in this slippage of the levels of protection which exist in national legislation and in national planning guidance.
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): Yes. It also would give more weight to local listings, which I feel are lost here. We struggle to hold on to those because it is always outweighed by the benefit of more housing or whatever it would be.
Michael Coupe (Planning and Transport Committee, London Forum): Does it mean that if it is not a heritage asset and therefore has no significance in terms of this policy, the rules of the jungle apply? You have to be careful. We are talking about heritage here, but we are talking about the character of London as a whole. There is too much of a contrast there. If you cannot argue significance in terms of particular designated assets, then in fact you have no defence.
Andrew Boff AM (Deputy Chair): Without you all going into a huddle now to decide an alternate form of words, it is a sustainable objective to build on small sites and to use those small sites. Can you think of better wording that might enable small sites to be delivered or a certain degree of presumption in favour of development? How would you also at the same time protect --
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): You could probably say the presumption should be in favour of development where it does not harm heritage assets.
Andrew Boff AM (Deputy Chair): A nice and clear binary position, “Where it does not”?
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): Yes, “Where it does not harm”, and then I do not know --
Michael Coupe (Planning and Transport Committee, London Forum): Character as well.
Nicky Gavron AM (Chair): In fact --
Andrew Boff AM (Deputy Chair): Sorry, I missed that, Mr Coupe.
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): Yes, “Where it does not harm heritage assets or the local character”.
Nicky Gavron AM (Chair): You have to add that because it already does include the heritage assets. It does not include conservation areas.
Navin Shah AM: Local character.
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): Local character, yes.
Andrew Boff AM (Deputy Chair): It is about this ‘unacceptable’.
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): Yes, “Where it does not harm the --
Andrew Boff AM (Deputy Chair): Am I right in saying that there is a consensus that the word ‘unacceptable’ is unacceptable?
Nicky Gavron AM (Chair): Yes.
David English (Historic Places Principal, Historic England): In relation to heritage assets, definitely. Just taking a slight step back with this policy, where it talks about local character evolving, in some places that is probably fine, and it does say “in appropriate locations”. Where you then get the slippage is in the supplementary text where, conservation areas having been taken out of the actual policy box, paragraph 4.2.7 has some wording to try to soften the slippage in terms of the conservation areas being made targets for the small sites policy, for the demolition, for the conversions and for the infill.
You could, if you take designated heritage assets out of this policy, have something quite positive. Nicky [Gavron AM] picked up on this. You do have back-land sites; you do have buildings which have been left to rack and ruin which become eyesores in conservation areas. You could have something in that paragraph which is quite positive that local authorities should seek out opportunities in conservation areas where they can enhance character through this type of development.
Andrew Boff AM (Deputy Chair): I have experienced too many instances where landowners have deliberately derelicted their own sites and so I am not sure. Well, it is your evidence, not mine.
Michael Coupe (Planning and Transport Committee, London Forum): It is very important for people to understand that a conservation area is something where change is permissible provided that it is, as it were, enhancing. If you have an element that detracts from the character, it is a positive advantage to change that and, therefore, there is always scope for change in conservation areas. People like to characterise it. The famous politician’s remark is ‘preserving in aspic’. Every politician, it seems to me, when they talk about heritage also mentions aspic. There is always scope for change.
Andrew Boff AM (Deputy Chair): You are saying that this general thrust of the Plan that development needs to take place everywhere except the Green Belt is not necessarily a threat to conservation areas?
Michael Coupe (Planning and Transport Committee, London Forum): No.
Andrew Boff AM (Deputy Chair): Is that what you are saying?
Michael Coupe (Planning and Transport Committee, London Forum): Yes.
David English (Historic Places Principal, Historic England): If you can get the wording right, you can use it as a positive tool. The need to exclude heritage, particularly conservation areas in this case, because it is very relevant to these policies which talk about demolition and infill. These are areas where they have a special character. In terms of the whole of London, it is a very small proportion of London which is conservation areas.
Nicky Gavron AM (Chair): It looks huge on the map.
Andrew Boff AM (Deputy Chair): It is not really. There are gaps in between.
Nicky Gavron AM (Chair): I know.
Andrew Boff AM (Deputy Chair): It is like the gaps between atoms: inconceivable. Anyway, yes, I have covered my questions. Does anybody else want to say anything about small sites before we move on?
Charles Wagner (Co-Chair, Spatial Planning Advisory Group, Heritage Alliance): Just principally that the NPPF does recognise that every part of a conservation area is not of the same value and does encourage local authorities to look at parts of the conservation area where they could carry out development that could potentially enhance the conservation area. That is in paragraphs 137 and 138. There is an encouragement that we should be looking at conservation areas in terms of development to get good development in there that could potentially enhance the special interest of that.
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): There would be work to be done on conservation area appraisals and the management of those areas, and then it goes back to the resources.
Charles Wagner (Co-Chair, Spatial Planning Advisory Group, Heritage Alliance): Yes, but that is where the gap is in the resources. So many London boroughs do not have up-to-date conservation area appraisals. In fact, many of them still rely on the designation document that they did in the beginning, which is often very scant.
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): If you can find it as well, because we could not find ours.
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): Yes.
Michael Coupe (Planning and Transport Committee, London Forum): It is exactly the same for listed buildings because you do not even need listed building consent if the alteration you are making does not affect the special interest of the building.
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): Yes, the special interest.
Michael Coupe (Planning and Transport Committee, London Forum): People do not understand that. They think, if it is a listed building, you cannot do anything to it. That is not true.
Charles Wagner (Co-Chair, Spatial Planning Advisory Group, Heritage Alliance): That is why you have listed building consents: so that you can make changes.
Michael Coupe (Planning and Transport Committee, London Forum): That is right.
Andrew Boff AM (Deputy Chair): Thank you very much. Thanks, Nicky.
Nicky Gavron AM (Chair): All right.
Navin Shah AM: I have a question pertinent to strategic views. We have already touched upon this during our discussions. The strategic views policy is largely similar to what we currently have, but should the strategic views policy be firmer than what it is now? David, would you start?
David English (Historic Places Principal, Historic England): There is a new paragraph which has been put in in response to the development referred to in the question, which is the one in Stratford, which affects a view from Richmond Park.
Navin Shah AM: Yes.
David English (Historic Places Principal, Historic England): This paragraph is good. It clarifies about development in the background of views, whether it is in the assessment area or not. That is welcome. That is slightly firmer.
We have talked about implementation before and that is the key thing. It is making sure that the next version of the London View Management Framework, which is the SPG which flows from the London Plan, has the right words.
Again, it touches on things like 3D models. You spoke at your last Planning Committee about 3D models. There are mentions of 3D models in the Plan, including in relation to World Heritage Sites. We are a little way off them being common practice, but the Plan could take a bolder position and really push this as a very useful resource if that was considered helpful.
Navin Shah AM: Are boroughs the right bodies to define what a tall building is? We are going back to, again, the conversation we had before, pretty much. Should the Mayor be doing more and be setting a strategic vision for the London skyline?
David English (Historic Places Principal, Historic England): I will kick that one off as well, if that is all right, and just say that the views policy is not a skyline policy. By defining where development is not permissible, it effectively says that there are lots of areas where development is permissible in terms of the skyline. To manage the skyline, you would need an urban design approach rather than a heritage approach.
The one point that I would make on that from a heritage perspective is that at the moment the views policy really focuses on the visibility of St Paul’s Cathedral and the Palace of Westminster. These are the key defining features of London to the nation and to the world. If you were to have an urban design-led policy, regardless of how you got it to work on the ground in terms of tall buildings or large buildings, how would that present London to the world in terms of the skyline? Would you still make those key landmark features the defining features?
Navin Shah AM: When we talk about London, it is so much more than just inner London, where one generally talks about skyline protection, enhancement, call it what you like. You have outer London areas. You have the large mayoral development corporations - Old Oak Common, for example - coming along.
Should the skyline approach or urban design approach cover those suburban outer London boroughs as well? Fine, yes, boroughs are being asked to look at what their definition and their policies for tall buildings are, but should there not be a strategic vision that is reflected in the London Plan for all of London from the Mayor’s side of things?
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): I was going to say that it should be locally decided.
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): Yes, I agree. The London Plan already talks about the Opportunity Areas; for example, Old Oak Common, Tottenham, Wood Green. It has already identified the areas it sees as Opportunity Areas. We expect at a borough level that those Opportunity Areas will change in character immensely. We are already looking at Tottenham Hale as a cluster of lots of tall buildings. We are already looking at Wood Green as a cluster of tall buildings, two mini Manhattans, actually, stepping down to the residential suburbs. We have given that in our area action plans. Our urban characterisation study highlighted places which could be suitable for tall buildings, right opposite main railway stations, future Crossrail railway stations, where it would be possible to accommodate really tall landmark buildings, but just the one. In places we have identified just one tall building and in other places we have identified a cluster of tall buildings. At the borough level, up until now it has worked.
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): For me, with Opportunity Areas, it goes back to them not having to be tall buildings. They just have to be a higher density. That is something that could probably be drawn out more. The issue that we will face is, by having an Opportunity Area, people will put land values on that because there can therefore be a tall building. However, if there is more pressure on it being high density rather than being a tall building, a tall building is not necessarily the answer.
Charles Wagner (Co-Chair, Spatial Planning Advisory Group, Heritage Alliance): Mid-rise high density.
Nicky Gavron AM (Chair): Yes. I find it very interesting listening to Haringey. Unless you are going to go above 30 storeys or something, you do not necessarily have to have a tall building, do you? You could get just as good density out of the site by going for a different configuration.
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): It is not very --
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): I know you are going to answer, but, in the suburbs, you have a lot of landowners and so you do not have that site there and one person owns quite a big site to be able to do that on. People do not want to sell their sites to someone else and so you end up having more tall buildings. That is something that we see.
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): In Haringey at least, we have managed in Tottenham Hale for developers to work together for a masterplan in a land assembly way so that we can put a cluster of tall buildings on a particular site and more open spaces and a mansion block-style typology in others. Then there has been a cross-subsidy, which, at least in Tottenham Hale, has been partly successful. I know it can be very difficult to achieve that practically because there are always developers saying, “Why are you allowing 35 storeys there in the masterplan and not on my site? Why is there a big park on my mind on my site?” I guess it all comes down to how you then work with the developers in making sure that the area-based masterplan goes down to those details.
No, I definitely did not mean that opportunity areas mean tall buildings. Opportunity areas definitely mean higher densities, but it is about achieving. In Wood Green, in Tottenham the land values are really poor and you do not get a good, viable scheme like King’s Cross did, I guess. At King’s Cross, the land values were so high that they were able to achieve without going to that level of high buildings.
Michael Coupe (Planning and Transport Committee, London Forum): Borough-wide characterisation and 3D modelling are great exercises for councillors when they are looking at proposals anyway because it is so easy, if you do not have those devices to hand, to be seduced by the architects’ drawings of people enjoying cocktails under striped umbrellas and all the rest of it.
Navin Shah AM: This is the GLA and the Mayor’s 3D of --
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): That is really important, but the only place that I see the 3D model being mentioned within the heritage stuff is within the World Heritage Sites. It does not form part of a policy. Every borough should have the 3D model and they should have to look at it when they are assessing applications.
Navin Shah AM: Indeed, if it does not, that is something we need to pick up, yes.
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): It does in the design policies for area-based masterplans, etc, but, as we were talking before, perhaps it needs to be strengthened to a borough-wide characterisation --
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): Absolutely.
Nairita Chakraborty (Principal Conservation Officer, London Borough of Haringey): -- along with a 3D model. That needs to be --
Navin Shah AM: Absolutely, yes.
Nicky Gavron AM (Chair): Yes, borough-wide characterisation. I am going to have to wrap up in a moment.
Navin Shah AM: Yes. I just need to move on to a question topic we have not discussed at all and that is a question to Michael Coupe. The Thames blue-ribbon policies have a lower profile in this plan than previously. Is the River Thames being adequately protected in the new waterways policies?
Michael Coupe (Planning and Transport Committee, London Forum): I have a particular point that I made to Nicky [Gavron AM] before. It is that it seems to me that the Thames is a very important part of London’s unique selling point. There is no question. A lot of the character and appearance of the river is not just to do with the buildings on either side; it is to do with the river traffic, and that river traffic needs to be serviced and looked after. What has tended to happen is that policies for building alongside the river have obliterated quite a lot of the framework of the small sites that used to service and repair the river traffic. Riverine activities need to be looked at very carefully. That is what I am saying.
Nicky Gavron AM (Chair): Does anyone have a view on what has been a policy, more or less, which is to have very tall buildings alongside the Thames, particularly in central parts of London?
Michael Coupe (Planning and Transport Committee, London Forum): The real problem of course is that if you look at them, half the buildings have no lights on at night because they are just not occupied. You think to yourself, “Here is an opportunity that is being wasted”, but that is just a personal view.
Nicky Gavron AM (Chair): Do you think the policies are strong enough on the river in relation to the built environment alongside it?
Michael Coupe (Planning and Transport Committee, London Forum): They have not been strong enough as far as World Heritage Sites are concerned, have they? It seems to me that developers have run rings around certainly the statutory bodies that are meant to advise like Historic England. UNESCO has been - rightly - threatening for many years dire consequences; it always seems to just disappear. However, it is a problem. I am absolutely sure that what has happened in the setting of the Westminster Palace World Heritage Site has been pretty outrageous.
David English (Historic Places Principal, Historic England): As an observation, in terms of the position that the Thames is getting in this Plan, what is in the box in terms of the policy and what is not in the box is really interesting. Paragraph 9.14.4 [Policy SI14), “The River Thames is a strategically important and iconic feature of London”. That is not in the policy box.
Nicky Gavron AM (Chair): Which policy box would it be in?
David English (Historic Places Principal, Historic England): It would be in SI14, which is about waterways and their strategic role. There is something there which is an opportunity for the Mayor potentially to show some leadership. It talks about the Thames policy areas. It talks about the things which need to go into the strategies for the different Thames policy areas. There are various strategies from Hampton to Kew and from Kew to Chelsea.
Then you have a gap in central London - and this has existed for a very long time - where there is not that detailed work that has ever been done. You have to go back to the 1990s when John Gummer [former Secretary of State for the Environment] was at the Department of the Environment. There was some quite clear guidance on things like tall buildings next to the river and the effects that you should try to avoid in
terms of good design. A lot of that was swept away in the early days of trying to promote a few tall buildings in central London to show that London was open to the world.
Nicky Gavron AM (Chair): There are the thresholds.
David English (Historic Places Principal, Historic England): Exactly.
Nicky Gavron AM (Chair): There are strong thresholds about heights in central London, but they are overshot all the time.
David English (Historic Places Principal, Historic England): There is something there in terms of that work which could be a really positive contribution to how the river is managed and how the area around the river is managed. As we think about London becoming a 24-hour city, the river is one of its best assets. There are projects like the Illuminated River project where they are looking to bring people to the river at night. That is fantastic, but marrying up that cultural activity, how it relates to the built environment and how the built environment relates to this wonderful resource, which is full of nature and full of heritage; there is an opportunity there for the strategic authority to bring people together because you need to bring people together to make it work. It is so complicated with so many different interests and it is such a big space that a borough cannot do it and a civic group cannot do it.
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): I do not know much about this policy, but one thing that it does not talk about is opening it up to public access, which should probably be within that policy. It is about the accessibility to that riverside. Regardless of whether it is a tall building or not, it is the accessibility to that asset that should be within that policy. That is not drawn out at all and that is one of the most important things.
Nicky Gavron AM (Chair): This is all helpful.
Tom Copley AM: On that, I am told that at Nine Elms, the promenade along the Thames is, basically, as small as they can get away with.
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): Yes --
Tom Copley AM: -- which is a tragedy, really.
Chloe Clay (Urban Design and Development Lead, Royal Borough of Kingston): Yes. The thing that we found there - we went on a site visit there - was that the tall buildings have created a lot of wind around them and so the enjoyment of that public space, which is already very narrow, needs to be dealt with in terms of the wind tunnelling and the enjoyment of those spaces.
Nicky Gavron AM (Chair): The Plan does talk somewhere about a canyon effect, which has happened in central London, and I do not want - none of us want - that to set a precedent for further developments. I would just urge you to write in if you can - because we have to close this panel now - if you can spot ways that we can strengthen the policies in the Plan on the Thames. To a certain extent, London has turned its back on the Thames.
Andrew Boff AM (Deputy Chair): Also, you are saying all the right stuff, which helps us.
Nicky Gavron AM (Chair): Yes. If you could do that? As I said earlier on and as Tony Devenish [AM] said, if there is evidence you want to give us to tighten up policies, then do send it in to us. I presume that you will all be making your own individual responses anyway.
Tony Devenish AM: Chair, can I make a very quick comment?
Nicky Gavron AM (Chair): Yes.
Tony Devenish AM: It is particularly to English Heritage [Historic England]. Will you have on your website the fact that we have this London Plan consultation going on? Will you be able to push this out to your members to get more people and more stakeholders to really get involved in the process?
David English (Historic Places Principal, Historic England): I would say we have been actively promoting this consultation for about 18 months or two years now. We have put lots of information up on our website that people can look at and engage with. We are working with other partners in the sector to make sure that everyone is aware of it.
Tony Devenish AM: Thank you.
Nicky Gavron AM (Chair): Thank you very much to our panel of experts. We are now going to bring up our second panel on open spaces. You are very welcome to stay if you want to.