Comments on the London Plan

by West London Friends of the Earth

 

 

Introduction

 

West London Friends of the Earth is a network of local Friends of the Earth groups in West London -  Brent, Ealing, Hammersmith & Fulham, Harrow, Hillingdon, Hounslow, Kensington & Chelsea and Westminster.

 

We deal with and campaign on a wide range of environmental and sustainability issues in line with the policies and remit of Friends of the Earth England, Wales and Northern Ireland.      

 

Sustainability

 

At a seminar on the London Plan, an officer from the GLA was asked if the Plan stated any environmental limits to growth, eg air pollution or greenhouse gas emissions.  The short answer was “no”.  That is, there are no sustainability criteria for London.  If it is the policy that sustainability should be sacrificed in a ‘rush for growth’ (population, construction, transport schemes, biofuel plants, incinerators, car parks, etc), this is of such fundamental importance that it should be stated clearly and debated fully.  Indeed, we consider it of such importance that the process of finalising and adopting the Plan should be deferred if that is what is necessary in order to resolve this fundamental issue.

 

Air pollution

 

Air pollution is a major issue in London. It has been estimated by the GLA that 2,900 Londoners a year die from air pollution and estimates derived by apportionment from international studies suggest the figure might be far higher.  This is a major health issue and it is also a major health equalities issues since deprived areas tend to suffer higher levels of air pollution.       

 

There are a fair number of references to air pollution – usually using the euphemism “air quality”.  These refer to the desire not to increase air pollution as a result of development schemes of various kinds.  But there is no overall plan and no intent is apparent to reduce air pollution to the extent that there are no significant health or other impacts and such that limit values and guidelines are not breached.  This is a major shortcoming of the Plan.

 

The strategy is so general and unspecific as to be useless: “The Mayor will work with strategic partners to ensure that the spatial, climate change, transport and design policies of this plan support implementation of his Air Quality Strategy to achieve reductions in pollutant emissions and public exposure to pollution.” (p183)

 

We support the Plan’s opposition to Heathrow expansion on the grounds of (among others) air pollution.

 

A number of the policies in the London Plan and also in the Mayor’s Transport Strategy are contrary to aims to reduce air pollution:

• Deferral of the Phase 3 of the Low Emissions Zone
• Scrapping the western extension of the Congestion Charge Zone
• Scrapping the planned £25 congestion charge on ‘gas-guzzling’ cars
• Relaxation of car parking standards (will encourage more car traffic)
• Relaxation of criteria for road building (will encourage more car traffic)

 

We consider that all these policies should be reversed for reasons of air pollution and some of the policies for other reasons as well.   

 

Climate change

 

London, if it seeks to be a truly world class city, should be in the vanguard of action on climate change.

 

We support the ambitious but achievable target “The Mayor seeks to achieve an overall reduction in London’s carbon dioxide emissions of 60 per cent (below 1990 levels) by 2025. It is expected that regional agencies, London boroughs and other organisations will contribute to meeting this strategic reduction target, and the GLA will monitor progress towards its achievement annually.”

 

While we support the target, we do not see sufficient evidence of a plan or of a will or determination to achieve the target.

 

While we do not disagree with the policies 5.15 to 5.46, there in no indication to what extent these policies will help achieve the 2025 target. 

 

Ground-based transport accounts for 22% of London’s carbon emissions and should be explicitly included in the 60% reduction target.  While emissions are addressed in detail in the Transport Strategy, transport ought to be addressed in the Plan as part of the climate change section. 

 

The Transport Strategy has a target of a 50% cut in CO2 emissions from the transport sector (fig 5.8, p222).  This is presumably thought to be required in order to achieve 60% cuts overall.  But the 50% cut is only ‘aspirational’.  The Strategy shows a reduction of only about 30% and - with commendable honesty - highlights a “policy gap”.

 

The great majority of the 30% reduction is due to assumed “improved vehicle efficiency” and “biofuels and low carbon electricity”.  Progress on these is largely beyond the control or remit of the Mayor/GLA.  The policies which are at least partly under the control of the GLA are “driver behaviour and operational efficiency”, “smoother traffic flow”, GLA/public sector fleet efficiency”, and “mode shift and smarter travel”.  But these make a relatively small contribution to reducing CO2.

 

Shockingly, the totality of London Plan and Transport Strategy policies, or absence of policies, makes the situation worse instead of better.  If “emission factors remain constant”, CO2 emissions would go up by about 28% (from fig 58 of the Transport Strategy).  This is far from offset by those aforementioned reductions that are at least partly under the control of the GLA. 

 

To achieve its target for cutting CO2 emissions, the national government set up a ‘Climate Change Committee’ to analyse in detail how the targets might be achieved and to report back to ministers.  Something similar will be needed for the London/GLA if the climate target is serious.  (This will require a modest number of staff which may necessitate a reversal of the Mayor’s decision to cut the numbers of staff concerned with the environment.)

 

Open spaces and biodiversity

 

Open spaces are also important for people directly, having demonstrable health and quality of life benefits.  These same spaces also harbour most of the capital’s biodiversity.  We therefore support the Mayor’s presumption against building on open spaces.

 

However, these presumptions need to be carried forward into borough’s LDFs and into planning decisions.  Despite such presumptions already existing, there are proposals to build on open land, for example on Gunnersbury Park in LB of Hounslow and on school playing fields in LB of Ealing.  This suggests stronger policies are needed rather than just continuation of existing ones.       

 

London’s people share their city with thousands of other species.  Apart from an intrinsic right to exist, loss of these species, in total or in numbers, will impoverish human life.  We therefore support measures to promote the Mayor’s Biodiversity Strategy and to specifically protect and enhance habitats as listed in 7.3. 

 

Biodiversity Action Plans (BAPs) are a key approach to protecting habitats and species.  We therefore welcome recognition of BAPs in Policy 7.10C.b.  We also welcome recognition of the London BAP habitat targets in Table 7.3, but this only recognises some of the BAP targets.  As well as habitat targets there are ‘Species Action Plans’ at a London-wide level.  There are also local BAPs for most of the boroughs, which are often even more relevant than London targets when local policies and planning applications are being considered.  We therefore submit that all London and borough BAP targets should be recognised as material considerations in planning policy.         

          

Transport    

 

In the section on climate we showed that the totality of London Plan and Transport Strategy policies on transport, or absence of policies, actually increase CO2 emissions.  This is contrary to London and national targets to cut CO2.

 

In the section on air pollution, we noted 5 specific transport policies which will make air pollution worse or will prevent desired improvements. 

 

The Transport Strategy shows that congestion on the road is forecast to increase by 14%, even after rail improvements, “better management of the road network” and “increase in cycling” are taken in account (fig 63). 

 

We disagree strongly with the change from the previous Plan – ”Tackling congestion and reducing traffic” (policy 3C.17) to Policy 6.11 “Smoothing traffic flow and tackling congestion ..”.  Dropping the policy to implement traffic reduction targets would mean worse air pollution, more greenhouse gas emissions and more congestion.  Reducing the amount of road traffic is critical.  Increased traffic undermines all the social and environmental sustainability objectives.

 

Policy 6.12 has weaker requirements for new roads than its predecessor Policy 3C.16.  It is now proposed that new road schemes should merely have to “take into account” how a net benefit to London’s environment can be provided and conditions for pedestrians, cyclists and others can be improved. Under the old policy all road schemes “should” provide a net benefit to London’s environment and improve conditions for pedestrians, cyclists and others.  We oppose the new policy, which is likely to be used to support more car traffic at the expense of pedestrians and cyclists.

 

Policy 6.9 on cycling sets a target of increasing cycling to 5% of journeys by 2026.  While it seems a big increase from the meagre 2% at present, the target is un-ambitious.  Cycling accounts for 20-30% or more of journeys in several mainland European cities and London, if it seeks to be a world-class city, should emulate them.  The cycling policy should build on the investment already made in the London Cycle Network and other cycling infrastructure.

 

One positive area of the transport strategy is that congestion on the rail network is forecast to fall slightly, following funded/programmed enhancements such as Crossrail (fig 34 of the Transport Strategy).    

 

From the above, the transport policies which form part of the London Plan (and which are elaborated in the Transport Strategy) fail on the counts of climate change, air pollution and road congestion.  We therefore consider that a fundamental re-think is required of the transport component of the Plan.

 

We are also concerned that the failure of transport policies to deal with climate change, air pollution and congestion are not apparent from reading the London Plan.  They are only apparent from the Transport Strategy.  This means that someone reading the transport chapter of the Plan and commenting on it could be seriously misled about the efficacy of the policies and thus make inappropriate comments.

 

The changes needed to London Plan (and Transport Strategy) are as follows:

• Proceed to Stage 3 of the Low Emissions Zone as soon as possible
• Keep the western extension of the Congestion Charge Zone
• Implement the planned £25 congestion charge on ‘gas-guzzling’ cars
• Constrain further rather than relax car parking standards
• Maintain or strengthen the criteria that are needed to justify road building
• Reinstate the target to reduce levels of car traffic
• Introduce a levy for business and commercial car parking
• Give active consideration to road user charging, this being the only measure identified as likely to make a large contribution to preventing congestion

 

In addition to these measures, we would wish to see more public transport schemes, particularly better buses.  We recognise that funding is probably a ’show stopper’ for rail schemes (buses are far cheaper) and we therefore do not make specific proposals.

 

We fully support 6.24 which says “.. considers that the noise problems and poor air quality at Heathrow have reached such levels that further capacity increases there are untenable.”  As noted earlier, air pollution is a major issue in London and Heathrow, being a large polluter, contributes to the death toll.  Expansion, by means of third runway or ‘mixed mode’ would prevent air pollution being brought within standards set to protect human health.  Noise is also a major issue.  It impairs the quality of life for many people, it depresses house values, it interferes with children’s learning and there is now strong evidence of health effects.

 

The statements in 6.24 is significant “[the Mayor] does recognise the need for additional runway capacity in the south-east of England.”  This statement would seem to imply support for extra runways at Stansted and/or Gatwick, the only realistic or acceptable options in the government’s aviation strategy.  It would also seem to support expansion at City airport.  The Mayor has talked about a new airport in the Thames Estuary, but there is no mention of this in the Plan.  If the policy does in fact support any of these options, this should be made clear.

 

We do not in any case agree that there is a need for additional capacity in the SE or the implication in Policy 6.6A that not providing the capacity would undermine “London’s competitive position”.  There is no evidence that not providing capacity in the SE to meet predicted would damage London’s competitive position.  There are a number of reasons for this:

• The majority of Heathrow’s and the SEs’ air traffic is leisure, not business.  Government studies show that if capacity is constrained, it will be mainly leisure, not business, travel that will be constrained.
• Much of Heathrow traffic is interchange, which does not benefit London’s businesses or economy
• The high levels of demand are largely the result of tax dodges by the aviation industry, estimated by the Aviation Environment Federation at £10 billion pa.

 

We fully support the submission by the Aviation Environment Federation which gives more detail on these points about aviation and airports.

 

We support Policy 6.4B which says “.. exploring the scope for highspeed rail services reducing the need for short- and some medium haul air travel.”  This will reduce the need for air travel which is an environmental benefit since rail travel’s impact is much less.  High speed rail could be particularly effective at dampening demand at City Airport because many flights from that airport are short-haul and within the reach of the rail network.

 

Population

 

The over-riding feature of the London Plan is that is based on and underpinned by forecasts of population (paras 1.4 to 1.14 of the Plan).  The population of London is forecast to increase hugely from the present 7.63 million to 8.89m by 2031, an increase of 16.5%.

 

This forecast increase dominates the Plan and, although not spelt out, is likely to lead to a worsening of quality of life or failure to improve it for the people who live in London.  For example, congestion on roads is forecast to increase, health-based air pollution limits will fail to be achieved and open spaces, important for health and well-being, will be threatened by ‘development’.

 

This being so, it is vital that the relevance of the population forecasts is scrutinised and debated.  We do not consider this has been adequately done in just 3 pages of a 282 page document.

 

The London Plan adopts what can be described as a ‘fatalistic’ or ‘predict and provide’ approach to population.  This is inappropriate, because London’s population is not something pre-determined.  Because people in the UK and, to considerable extent across the world, have freedom to live and work where they choose, the population of London will depend on London’s policies and plans.  If we encourage and support population growth in London it will happen - if we do not encourage and support population growth it will not happen (or not to nearly the same extent).

 

We consider that the starting point for the London Plan should be what sort of London we want to see and that must include the population we want to see.

 

Housing

 

Policy 3.3 p65 says “.. the Mayor will seek provision of at least an annual average of 33,400 additional homes [more correctly called housing units] across London which will enhance the environment ..”  It is grossly misleading to say it will enhance the environment.  Hundreds of thousands more housing units are almost certain to have an adverse effect on the environment in terms of more crowding in and overlooking of existing houses, more air pollution, more waste, more water demand, more runoff and more loss of open space.  The public recognises this as the Plan itself admits: “There is also a perceived [real!] tension between the demands of growth and the conditions for a good – and improving – quality of life, and a concern about the loss of things that have made living in London and its neighbourhoods a distinctive experience.” (para 1.42)

        

Employment

 

There is considerable emphasis in the Plan on increasing employment (jobs).  We do not consider this should be an end in itself.  Much more desirable is a decrease in unemployment.

 

Increase in employment does not necessarily equate to a decrease in unemployment unless population is static.  It is instructive to note that in the debate about Heathrow expansion, an important issue was creation of jobs.  Local authorities (LAs) were opposed to Terminal 5 for, among other reasons, increases in jobs and overheating of the local economy.  It was accepted by both LAs and supporters of expansion that the extra jobs would lead to increased population, housing and other pressures.  Thus creating jobs would not necessarily lead to a decrease in unemployment for local people.

 

As well as the number of jobs, quality is important.  Creation of low-skill, low-pay, dead-end jobs and jobs which have an adverse impact on the environment would not seem a desirable aim for London, but uncritical policies for increasing employment could result in this. 

 

 

Contact:

Nic Ferriday, 6 Boston Gardens, Hanwell, London W7 2AN

020 8357 8426

nic.Ferriday@ntlworld.com