Haringey Federation of Residents Associations
Planning & Development in Haringey
- A Residents’ Conference (April 2010)
On April 17th 2010 at Hornsey Vale Community Centre, N8, 40 Haringey residents from many local organisations and groups from all over the borough took part in a residents' conference on planning and development issues. Participants included residents associations, 'friends of parks' groups, conservation societies, local campaigns, environmental organisations, political groups as well as individual residents.** The conference was organised by The Haringey Federation of Residents Associations, supported by Haringey’s Friends of Parks Forum, Sustainable Haringey network, Haringey's Conservation Area Advisory Committees, Tottenham Civic Society and other local community organisations and networks.
The conference had been called to mobilise concerned community groups and residents to influence the borough's planning and development policies - known as the Local Development Framework - currently being re-written. The consultation documents set out very important policy proposals on how the borough will manage issues of housing, climate change, transport, employment, leisure, retail, open space, and design from 2011 to 2026. The documents were about to undergo 6 weeks public consultation from May 10th to June 21st, following which they would be examined at a long and formal public hearing at the Civic Centre, presided over by a Planning Inspector.
Concerns were expressed about over-development and skyscrapers, advertising hoardings, loss of Haringey's heritage and character, threats to some green spaces, the selling off of community facilities and local pubs, and too much traffic. There were strong feelings that what Haringey's communities actually need, but are rarely getting, is genuinely affordable housing, well-designed buildings, good quality local jobs, community-led regeneration, safer, greener and more friendly local streets and better public transport, more green space and allotment sites, protection of public land and community facilities, safeguarding of small independent shops, and the long term sustainability of our society.
In the final session entitled 'Community Involvement and Empowerment In Planning - what we can do as residents', there were riveting and often inspirational presentations from some of the local campaigns around Haringey where local residents are standing up for their communities against unpopular and inappropriate development, and sometimes creating their own alternative community plans for contested sites. These included Alexandra Palace, Wards Corner, Hornsey Town Hall, various local parks, and certain backland sites.
Participants pledged to continue to work together to ensure residents' voices will be heard loud and clear throughout the official consultation, and beyond.
Special webpages have been set up to help as a reference point and to promote communication and co-ordination: www.des-con-hgy.org.uk
** Members and reps of the following organisations attended:
Selby Trust, Selby Wood Recycling Project, Pedro Achata Trust, Noel Park North Area Residents Association, Haringey Green Party, Bounds Green & District Residents Association, Chestnuts Northside Residents Association, Friends of Lordship Rec, Haringey Solidarity Group, Sustainable Haringey (including reps from a number of the SH working groups), Woodlands Park Residents Association, Tynemouth Area Residents Association, Alexandra Palace & Park Conservation Area Advisory Committee, Methuen Park Association, Haringey Living Streets, Warner Estate Residents Association, Hornsey Conservation Area Advisory Committee, Hawthorn Road Residents, West Green Residents Association, Muswell Hill & Fortis Green Association, Haslemere Road Residents Association, Tottenham Civic Society, InHaringey.co.uk, Wards Corner Community Coalition, Tottenham & Wood Green Friends of the Earth, Muswell Hill Friends of the Earth, Ferry Lane Action Group, Gladwell Landrock Cecile Park Residents Action Group, Jesus Hospital Estate Residents Association / Columbia Rd E2 Residents Association (Tower Hamlets), Bruce Grove Residents Network, Noel Park Conservation Area Advisory Committee, Stroud Green Residents Association, Stroud Green Conservation Area Advisory Committee, Save Ally Pally campaign
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DETAILED REPORT OF THE PROCEEDINGS
[Based on notes taken by Colin Marr]
Part 1. Introduction and background
Dave Morris, of the Haringey Federation of Residents Associations, chaired and opened the conference by welcoming participants. He went on to explain why the Local Development Framework (LDF), which replaces the Unitary Development Plan, is important and how in the past property developers (often with support from the council) had managed to exploit it to the detriment of local communities. In the last few years residents groups around Haringey have been increasingly taking up development issues, sharing their experiences and are increasingly aware of the need to speak out loud and clear. The HFRA had held a well-attended seminar about the LDF for over a dozen groups in June 2009 where it had been agreed a more substantial conference was needed.
The main purpose of the conference was:
1. To explain what the LDF is and what is involved
2. To outline the key issues what needs to be changed?
3. How to respond to ensure we are taken notice of?
Officers from Haringey Council had agreed to attend in order to help participants understand the new and complex LDF procedures, but they had unfortunately been told to pull out at the last minute because of the forthcoming local Council elections. The coming 6 weeks consultation due to start on April 19th had also just been postponed - until May 10th. The revised start date is 10th May up to 21st June. A new schedule provided to the event organisers the day before (by Ciara Whelehan, Team Leader Planning Policy for the Council) explained some of the new LDF consultation timetable, and that in May/June the formal focus would be on the Core Strategy and not on the accompanying, related Development Management Policy document and the Sites Allocation Development Plans document. [See Appendix 1 below - provided to all attendees]. Consultation on the latter documents will be late 2010 - early 2011. The HFRA had been able to get 4 copies of the relevant documents in advance of printing so that the conference could view them.
Dave listed a few key planning questions identified by a pre-meeting of those helping organise the event. Issues included:
- Heritage, and character of neighbourhoods - are we protected, or are we going backwards?
- Tall buildings - are residential skyscrapers unacceptable, and if so what policies are needed?
- Affordable Housing - is the affordable % of new build homes too low, and in any case are they really ‘affordable’ to those who most need homes?
- Sustainability and climate change - this is crucially important, but do the policies impose strict enough conditions on all development?
- Open space provision - how do we protect open space of all kinds and ensure the deficiencies are addressed?
- Community facilities in local neighbourhoods - what policies would halt the loss of local shops, POs, local pubs, community centres, public land and other amenities etc etc.
- Town centres and regeneration - how can we prevent over-development and ensure that commercial interests do not undermine the needs of local communities?
- The ‘Sites Allocation’ document maps - need to be carefully scrutinised and specific sites or site boundaries challenged where inappropriate development is being proposed
Lucy Rogers, from Jesus Hospital Estate Residents Association / Columbia Rd E2 Residents Association in Tower Hamlets, spoke about their experiences there with the LDF, where they are further into the process than at Haringey. Tower Hamlets is currently involved with the stage where their LDF is subject to public hearings where the Council has to justify its plans to the Planning Inspector this is the stage beyond setting the core strategy, which is what Haringey is now involved with. Key points from Lucy’s presentation included:
- The public hearings are well attended by well prepared hired reps of property developers they keep an eye on these things to ensure their views are prominent.
- ‘Opportunities for growth’ generally means opportunities for developers! Residents need to work out ways to ensure other aspects of policy are strong, so as to resist the developers.
- Residents need to work in issue-based groups to submit their statements in a way that questions what the Council is doing beware the Council’s gobbledegook! The Inspector needs to be prompted to ask the council do you really need this particular phrase or policy?
- The council’s ‘sustainable community strategy’ is important and should be looked at closely, with a legalistic mind, and try to ensure that the core policies are tightly worded.
- To ensure residents have a voice at the public hearings they have to put in their written submission at the core strategy stage (which in Haringey is now).
- She praised Haringey’s residents groups for being well organised and co-ordinated compared to Tower Hamlets, and urged everyone to continue to support each other and work together.
Chris Mason, from Hornsey Conservation Area Advisory Committee (CAAC) and chair of the Haringey Joint CAACs, explained the background to the national introduction of the new LDF process, a result of the 2004 Planning Act, which replaces UDPs. Chris’s key points included:
- The LDF includes both strategic ‘core strategies’, and the more detailed day-to-day policies, which are known as “Development Management Policies” (DMPs).
- The draft core strategies are in the main glossy document that Haringey is about to put out for consultation - we need to focus on the draft strategies that are in the ‘blue panels’.
- The DMPs are in the second, less glossy document, which is incomplete and less well developed.
- The concept of democracy in planning has been built into the planning process since the rise of ‘people power’ aspirations and community groups from the 1960s onwards. There is now the need for a ‘Statement of Community Involvement’. This is crucial to the process and there is a ‘Test of Soundness’ to see if the public has been consulted, that the policies are backed by evidence and are effective. [See Appendix 3 below - provided to all attendees].
- The LDF is wider in scope than the old UDP and includes other, more social, issues than just physical buildings / land development.
- Guidance on the LDF process and issues is on the Joint CAAC website: www.des-con-hgy.org.uk
Part 2. Key issues - discussion groups / workshops, and feedback
Discussion groups were arranged and separate break-out meetings held with the following feedback reports from note takers:
A. Sustainability and response to climate change
Quentin Given’s report included the following points:
- Review of the old UDP revealed weaknesses, e.g. transport policies
- Population and economic growth the models used are poorly considered, but dominate current policies
- Need to have stronger evidence-base to influence policy decision-making
- The high ‘churn-rate’ of people needs to be considered
- Friends of the Earth and Sustainable Haringey have been pushing for better policies generally
- Should we form a working group to progress this subject area?
B. Transport and street scene
Chris Barker’s report included the following points:
- Overall aims of the policy are good, e.g. promote cycling, walking and public transport
- A night time lorry ban is good, but could also go for lighter vehicles for deliveries
- Policy to restrict/ban ‘crossovers’ (the turning of front gardens in parking spaces) needs to be tightened it’s not specific enough
- 20 mph speed limit should be the ‘default’ for all the borough’s residential streets
- Need for more cycle storage, routes and lanes
- More mixed residential and commercial development could reduce the need to travel. We need ‘localisation of the economy’
- Plus there was a comment (afterwards from the floor): re-activate ex-Mayor Ken Livingstone’s idea of a hierarchy of travel preferences?
C. Open space and community facilities
John Oakes’ report included the following points:
- The policies need to adequately define the deficiency in open space (parks, nature reserves, allotments, playgrounds etc) in areas around Haringey - and policies put in place to ensure such deficiencies are properly addressed by development. Now is the time to lobby for open space protection to be increased by re-designating many sites currently defined as ‘Significant Local Open Land’ to be upgraded to ‘Metropolitan Open Land’
- Community facilities (e.g. pubs and community centres) need to be better protected and increased in neighbourhoods.
- Section 106 agreements (financial payments and conditions on development) should be more demanding.
- There is a need for community audits to ensure community needs are defined and met
- Where land is unused pending development there could be a policy promoting the implementation of “meanwhile leases” to encourage temporary community use, e.g. for allotments, community gardens, play areas etc.
- Plus there was a comment (afterwards from the floor): Regarding s106 payments, beware big developer’s money being used to persuade the Council to accept otherwise inappropriate development.
D. Housing and development
Joyce Rosser’s report included the following points:
- There is a need to improve social infrastructure (local community facilities and amenities) to support existing residents - growth will put even further stress on infrastructure.
- A map in the LDF documents shows that the areas in the east of Haringey are the most heavily stressed, but are still being earmarked for even more dense development
- There are currently insufficient resources to provide the community facilities needed
- Section 106 agreements need to be strengthened
- Properties being taken up as buy-to-let investments is still a problem
- Key workers accommodation needs to be better provided for
- More affordable homes for poorer families are needed.
E. Design and conservation
Chris Mason’s report included the following points:
- Need to focus on Core Strategies SP10, 11 and 12 in the draft document
- SP10 includes a reference to further development at Tottenham Hale, which could hasten the demise of other ‘heritage shopping centres’, such as Tottenham High Road
- There are lots of ‘fine words’ that need to be tightened up e.g. references to ‘all new development’, which might better be ‘all development’. [See Appendix 2 below].
- The consultation documents are in a muddle over monitoring indicators and other procedural irregularities.
Part 3. Community Involvement and Empowerment In Planning- what can we do as residents?
Practical proposals coming out of the discussions included:
- Working groups communicating over specific subject areas are possible, convened by experienced activists eg Sustainability, Open Spaces, Heritage & Design.
- The www.Des-Con-Hgy.org.uk website is a community resource for all LDF information and liaison
- Need to look at the maps given in the ‘Sites Allocation’ document to consider and challenge some of the ‘areas for change’ designations - and to identify additional sites all over Haringey to lobby for positive community uses that will otherwise be overlooked
- The need for good Guidance Notes on how to make an effective submission - look for this on the Des-Con-HGY site. The Council should be circulating these, but it seems that the draft Haringey advice is poor compared to Camden’s [See Appendix 3 below].
- The LDF documents that are being consulted on will shortly be available from the council. All interested groups should try to ensure they obtain copies
- We possibly need a further conference or meeting at end of May to review all of this and finalise inputs.
- A letter could be sent to the Planning Team seeking to address some of our procedural concerns
The conference ended with brief reports from a few of the many inspirational local campaigns:
- Wards Corner / Seven Sisters: Carlos explained how the Latin American and other market stall holders, local family shops and members of residents associations in the area were working together to challenge the Council’s plans for demolition and evictions, including holding large public meetings, protests and a forthcoming Judicial Review. They have created an alternative Community Plan for renewal and restoration of the site and are applying for planning permission. They have also made a film about their struggle. http://wardscorner.wikispaces.com
- Ally Pally: campaigners prevented a property developer from buying the site. The issue of governance of the Park and Palace is still being debated with the possibility of it eventually being taken over from the Council by an independent trust. www.saveallypally.com
- Backlands development: report of a 10yr long residents’ battle to prevent property developer Paul Simon building on a backland site in Crouch End www.greenn8.org.uk/campaigns
- Hornsey Town Hall: local campaigners had campaigned successfully to save the Town Hall, but there are continuing controversies eg over the lack of a cinema, and the council promoting some private residential development on the site to pay for conservation of the main building. www.crouchendforpeople.org/index
- Tottenham Hale: local residents groups formed an alliance to influence the massive development proposed in the area. Some of the plans have been put on hold by the recession, but may soon re-emerge. www.webjam.com/ferry_lane_action_group
- Lordship Rec: The Friends group have spent 6 years lobbying for the community-led regeneration of a neglected park, and in partnership with the Council are on the verge of implementing £7m of improvements (depending on a successful lottery bid). There are many examples of other Friends Groups also improving their parks. www.lordshiprec.org.uk
The closing message from the Chair was that residents want to ensure that the policies which are meant to protect the interests of communities need to strengthened and enforced, and that other policies favouring developers should be changed. Those who live and work in Haringey should have the maximum possible say over planning and development policies and practices that affect our lives, our communities and our neighbourhoods. As the Council prepares to consult over these matters let’s call on everyone to raise their voices, together.
Notes by CM, 21 April 2010
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The next stages / timetable of the Core Strategy
1. Public consultation on the proposed submission: 10th May 21st June 2010
2. Analyse representations received from consultation and prepare for Submission: June August 2010
3. Report to Cabinet: September 2010
4. Report to Full Council: October 2010
5. Submit Core Strategy to the Secretary of State: October 2010
6. Pre-Examination Hearing: Nov/Dec 2010 (this meeting will be held in the borough, the Inspector and Programme Officer attend setting out the programme for the Examination. Consultees can also attend)
7. Examination: January 2011 (to be confirmed)
8. Adoption: March/April 2011 (approx)
Please note that the timetable dates from point 6 onwards have yet to be confirmed. Once we submit the Core Strategy to the Secretary of State it is in the hands of the Planning Inspectorate (PINS), and they decide when the Pre-examination meeting and Examination takes place. Depending on the number of representations received will determine how long the Examination lasts. We normally allow 6 months from the time of submission to adoption which means March 2011 for adoption.
Important note: Regarding the Sites and Development Management policy documents, these are at the very first stage of consultation. A second round of consultation on these will take place later this year / early 2011.
Ciara Whelehan - LBH Team LeaderPlanning Policy
It is very important to understand the jargon and the words used in drafting management plans. An explanation, what to look out for, and what to propose in its place can be found at: www.des-con-hgy.org.uk Click on ‘Local Development Framework’ then scroll down to grey link: Policy drafting notes.
Or at: http://web.me.com/chrisbarbary/des-con-hgy/Local_Development_Framework_files/How policies should be written.doc
RESPONDING TO THE COUNCIL’S LDF DOCUMENTS
Extract from Camden's Proposed Submission Representation Form Guidance Note
Soundness [The key test of the policies!]
Soundness is explained fully in Planning Policy Statement 12: Local Spatial Planning in paragraphs 4.36 4.47, 4.51 and 5.52 and the boxed text . The Inspector has to be satisfied that the document is justified, effective and consistent with national policy.
To be sound an LDF document should be:
• Justified This means that the document should be founded on a robust and credible evidence base involving:
o Evidence of participation of the local community and others having a stake in the area
o Research/fact finding: the choices made in the plan are backed up by facts
The document should also provide the most appropriate strategy when considered against reasonable alternatives. These alternatives should be realistic and subject to sustainability appraisal. The document should show how the policies and proposals help to ensure that the social, environmental, economic and resource use objectives of sustainability will be achieved.
• Effective This means the document should be deliverable, embracing:
o Sound infrastructure delivery planning
o Having no regulatory or national planning barriers to delivery
o Delivery partners who are signed up to it
o Coherence with the strategies of neighbouring authorities
The document should also be flexible and able to be monitored.
The document should indicate who is to be responsible for making sure that the policies and proposals happen and when they will happen.
The LDF documents should be flexible to deal with changing circumstances, which may involve minor changes to respond to the outcome of the monitoring process or more significant changes to respond to problems such as lack of funding for major infrastructure proposals. Although it is important that policies are flexible, the document should make clear that major changes may require a formal review including public consultation.
Any measures which we have included to make sure that targets are met should be clearly linked to an Annual Monitoring Report. This report must be produced each year by all local authorities and will show whether the document needs amendment.
• Consistent with national policy The document should be consistent with national policy. Where there is a departure, we must provide clear and convincing reasoning to justify our approach. Conversely, you may feel we should include a policy or policies which would depart from national or regional policy to some degree in order to meet a clearly identified and fully justified local need, but we have not done so. In this instance it will be important for you to say in your representations what the local circumstances are that justify a different policy approach to that in national or regional policy and support your assertion with evidence.
If you think the content of a document is not sound because it does not include a policy where it should do, you should go through the following steps before making representations:
Is the issue with which you are concerned already covered specifically by any national planning policy or in the London Plan? If so it does not need to be included.
Is what you are concerned with covered by any other policies in the document on which you are seeking to make representations or in any other document in Camden’s Local Development Framework (LDF). There is no need for repetition between documents in the LDF.
If the policy is not covered elsewhere, in what way is the document unsound without the policy?
If the document is unsound without the policy, what should the policy say?
Legal Compliance Consider the following before making a representation on legal compliance (as set out in s20(5)(a) of the 2004 Act):
The document in question should be within the Council’s current Local Development Scheme (LDS) and the key stages should have been followed. The LDS is effectively a programme of work which sets out the documents we propose to produce for the Local Development Framework over a 3 year period. It sets out the key stages in the production of any documents which we propose to bring forward for independent examination. If the document is not in the current LDS it should not have been published for representations. The LDS is available on our website www.camden.gov.uk/ldf
The process of community involvement for the document in question should be in general accordance with the our Statement of Community Involvement. The Statement of Community Involvement (SCI) sets out our strategy for involving the community in the preparation and revision of LDF documents and the consideration of planning applications.
The document should comply with the Town and County Planning (Local Development) (England Regulations) 2004 (as amended) . On publication, we must publish the documents prescribed in the regulations, and make them available at our principal offices and on our website. We must also place a local advertisement and notify the specific bodies (as set out in the regulations) and any persons who have requested to be notified.
We are required to provide a Sustainability Appraisal Report when they publish a document. This should identify the process by which the Sustainability Appraisal has been carried out, and the baseline information used to inform the process and the outcomes of that process. Sustainability Appraisal is a tool for appraising policies to ensure they reflect social, environmental, and economic factors.
The document should have regard to national policy and conform generally to the London Plan. The London Plan sets out the region’s policies in relation to the development and use of land and forms part of our development plan.
The document must have regard to the Sustainable Community Strategy.
Further detailed guidance on the preparation, publication and examination of LDF documents is provided in PPS12 and in The Plan Making Manual .
How to set out consultation responses - Camden’s Guidance
Question 1 Please indicate which document your representation relates to either the Core Strategy or the Development Policies. The Core Strategy and the Development Policies documents will be examined separately, so please do not combine your comments. Question 2 Please indicate which part of the document your representation refers to. You are required to fill in this section, whether your representation is in support of the document or not.
Question 3 To answer this question, you first need to decide whether the document is ‘sound’ or legally compliant (see sections 4 and 5 of this note for more information).
Question 4 If you consider the document unsound, please tick the option(s) to which your representation relates.
Question 5 Please give as much detailed information as possible regarding the reason why you think the document is unsound or not legally compliant. You should try to support your representation by evidence showing why the document should be changed. It will be helpful if you also say precisely how you think the document should be changed. Representations should cover succinctly all the information, evidence and supporting information necessary to support/justify the representation and the suggested change, as there will not be a subsequent opportunity to make further representations. After this consultation, further submissions will be only at the request of the Inspector, based on the matters and issues he/she identifies for examination.
Question 6 Please provide details of what change(s) you consider necessary to make the document legally compliant or sound, having regard to the option you have identified in question 4 where this relates to soundness and the reasons provided in your answer to question 5. If possible please provide your suggested revised wording of the identified section in a concise manner to help the Council review and respond to your suggested alteration(s).
Question 7 Please indicate how you would like your representation be dealt with at the independent examination, i.e. by written representations or by exercising the right to attend and be heard. Written or oral participants will be given the same weight. The appointed independent inspector will determine the procedure to be adopted at the examination. The procedures by which the inspector can consider representations are by: Written representations, Round table discussions, Informal hearing sessions or Formal hearing sessions
Question 8 Please justify why you believe it is important to participate at the oral part of the examination.
1 View the 2004 Act at: http://www.opsi.gov.uk/acts/acts2004/ukpga_20040005_en_1
View the amending 2008 Act at: http://www.opsi.gov.uk/acts/acts2008/pdf/ukpga_20080029_en.pdf
2 View at http://www.communities.gov.uk/publications/planningandbuilding/pps12lsp
3 View the 2004 Regulations at: http://www.opsi.gov.uk/si/si2004/20042204.htm
View the 2008 amending Regulations at: http://www.opsi.gov.uk/si/si2008/pdf/uksi_20081371_en.pdf
View the 2009 amending Regulations at: http://www.opsi.gov.uk/si/si2009/pdf/uksi_20090401_en.pdf
4 View at http://www.pas.gov.uk/