Comments on Draft Local Plan
CONSULTATION FEB/MARCH 2020
COMMENTS FROM FEDERATION OF RESIDENTS ASSOCIATIONS IN BARNET (FORAB)
In this submission we have limited our comments to a number of major themes that we have identified and have not addressed minor issues or the detail of the drafting.
We are mindful that the 15 year target for the Borough is not necessarily settled and could be any one of 33,460, 46,000 or 62,000. We are however quite sure that the Inspectors recommendation that the target set in the Draft London plan should be reduced by 20% was soundly based. We are not proposing to examine here the viability of all the agreed and potential schemes identified by the council, but we are persuaded that 46,000 let alone 62,000 is unrealistically ambitious.
In trying to assess what might reasonably be delivered we find the figures presented in the draft as unhelpful, indeed confusing. The only information on overall new homes delivery is the table 5 at 4.7.6. This serves to confuse rather than illuminate. The council does have specific data on schemes under construction, approved, or with planning applications submitted, which in total amount we understand amount to over 30,000 homes. This information should be presented in the document in tabular form as Appendix 1. Featuring 67 potential sites in the appendix is indeed misleading when many other more advanced and significant projects are not identified. Further, some of the 67 projects have approval or planning applications in and should be included in group above. We reckon maybe 9,000, not 16,000 homes should form an Appendix 2 of sites for which no proposals for development yet exist. We also consider that many of these sites are speculative to the extent that they are unlikely to proceed to redevelopment, and this is especially unhelpful as those locations will effective now suffer planning blight with owners lacking any incentives to effect improvements.
For potential sites the London Plan encourages Boroughs to set out acceptable height, scale, massing and indicative layouts. In the draft Local Plan we simply have indicative volume based on the density matrix. This is most unhelpful for communities who may rightly be concerned about what might happen on these sites. It is also an opportunity to get ahead of developers who might otherwise come forward with unpalatable proposals. We recognise that undertaking a comprehensive assessment as suggested by the Mayor would be demanding, but we do consider that more effort should be made to assess the potential of any development other than just indicative numbers, some of which could turn out to be very misleading. The site descriptions at the end of the document could perhaps be expanded without too much difficulty to set down some principles for development.
Table 6 (5.5.8) indicates the assessed need by number of bedrooms. We understand the overall need for one and two bedroom properties is 38%, with the rest three bedrooms or more. But as we know, as stated at 5.5.6, that 78% of what has been built is just one or two bedrooms, and that proportion is being perpetuated. and possibly increased in anticipated schemes. Whilst two bedroom properties are being described as family homes we consider this is unrealistic as an expectation of public acceptability except for those with low incomes who will have to put up what is on offer. Indeed reality is recognised in policy HOU02(a) identifying three bedroom properties as the highest priority for market homes, though there is a complete absence of measures that might achieve this.
If the desired larger homes are not going to be built what alternatives are there? Again the plan falls short on ideas. There are no robust proposal to persuade singles and couples living in family homes to downsize. So as a minimum it is imperative that the existing stock of family homes is protected. Unfortunately the Plan is inadequate on mechanisms to do this, as we discuss later.
Housing in town centres (Policy GSS08)
There is elsewhere in the document a welcome commitment to supporting the economic well-being of town centres, but achieving this is set to conflict with the aim to create 6100 homes within 400 yards of town centres. The thinking around town centres appears somewhat muddled. We are aware of the ambitious concept for North Finchley to rebuild much of the town centre combining replacement shops with increased provision of flats above. But there must be doubts about whether this or similar ambitious schemes will ever materialise given the complexity and capital required just to buy out the existing owners. What we have seen in and around town centres is the conversion of floors above shops to residential, which is ok, and the redevelopment of office and industrial workplaces to residential, resulting in loss of local employment, which is not ok. It should be possible to do more to convert secondary retail space to residential and we are surprised the Plan does not encourage this. Indeed the opposite is the case as the Plan appears to be committed to protecting all retail A1 space. More thought is needed to reconcile this Policy and Policy TOW01.
Of concern to us is that the one way to deliver these extra homes around town centres would be to pursue intensification by converting wholesale existing family homes within 400 metres to flats or demolishing them and replacing with new blocks of flats, which indeed the plan as drafted is encouraging. Such an approach would destroy the existing community structure and would inevitably lead to a net loss of family homes, the protection of which we have already said should be essential to maintain the stock of these homes. There would be considerable public resistance to such wholesale redevelopment and given that the vast majority of new housing is already identified for dense high-rise developments, the comparative gains from town centre intensification would probably result in overkill in the provision of small flats. The Plan should draw back on this concept.
Homes and new transport infrastructure (Policy GSS09)
This policy suggests aspiration ignoring reality. We have more to say later on transport infrastructure and the doubts whether the ambitious schemes mentioned will be realised. Moreover, even if these schemes do happen they are more likely than not to be delivered at the very end of the Plan period or later. Any housing should follow, not precede these schemes, and so at best housing proposals directly linked to new transport infrastructure should be expressed in the Plan in very conditional terms.
Homes on car park sites (Policy GSS12)
We note the intention to maintain car parking as part of any redevelopment, but it will be inescapable that a car park would have to be closed for a considerable period of time whilst redevelopment takes place. Such is the fragile state of our town centre economies that we view this idea with some foreboding. Pedestrianisation schemes and other changes to the public realm to make the experience better for visitors to town centres, which are being encouraged, do often lead to some loss of parking. We do not wish to see any more parking spaces lost than necessary. Whilst some car parks may lend themselves to redevelopment without disruption, we consider this policy needs to be approached with extreme caution, and the need to do this should be reflected in the text.
Residential conversions (Policy HOU03)
We welcome the initiative to bring some order to this area where consistency in allowing or refusing applications for conversion has not been evident. The Policy as drafted is based on the assumption that a larger family home of 3 – 5 bedrooms may be converted to flats if ‘family’ sized accommodation of 74m2 or more is provided at ground floor level. This means that two bedroom accommodation would be acceptable. This is not what is said in the text - 5.6.4 says at line 8 “providing 3 bedrooms”. The requirement to provide a minimum of three bedrooms should appear in the Policy.
And indeed, even with this qualification we remain concerned about the implications. Housing in streets characterised by family homes, irrespective of size, have largely been protected using existing policies. But this new definition will explicitly encourage conversions in certain areas which have larger family homes close to a town centre, e.g. East Finchley, North Finchley and Underhill. These areas overwhelmingly consist of family homes and we consider it essential they should remain that way to maintain the quality of life in the neighbourhood and ensure the stock of larger family homes is not diminished. We do not understand the argument why the existing defence in DM01 may not remain and ask that it be reinstated: “Conversions in roads characterised by houses will not normally be permitted”.
Demolish and Redevelop
The Plan seeks to be explicit on conversions and extensions to provide appropriate protection, but is silent on proposals to demolish a detached family home or a pair of semis and replace with a small block of flats. Many such applications have been made in recent years and, as with conversions, planning decisions have not been consistent. We anticipate that without explicit controls such applications will increase. We suggest a policy similar to that for conversions is needed. With the presumption that such proposals will normally need to conform to the same clauses (a) to (g) along with the limitation on roads characterised by houses.
The draft policy CDHO4 is almost wholly concerned with the parameters for tall building within the areas where they are considered to be appropriate, whilst saying nothing about the rest of the Borough other that the implication that as a tall building is defined as 8 storeys or more, up to seven storeys will be the default for what is acceptable elsewhere. The London Plan says at 3.8.2 that “tall buildings are those that are substantially taller than their surroundings and cause a significant change to the skyline”. This is a clear statement that could be used to protect low rise areas and something along these lines should be in the Local Plan tall buildings policy. Further, the London Plan offers flexibility to tailor what height is acceptable in specific locations, which indicates that the Barnet blanket definition of tall buildings as eight storeys or more applying across the Borough is far too rigid. We have large areas where there is little or nothing above 2/3 storeys and here five, six or seven storeys would clearly be considered a tall building. We suggest the default position should be that a building of five storeys or more would be considered as tall except in defined areas where variable higher limits could be set.
We are also aware that in many localities developers have used the pressure to include more affordable housing as a reason to increase the height of buildings way beyond what was initially agreed. Such a situation is currently in discussion in relation to the New Barnet gas works site. We are alarmed that it has proved so easy for developers to press for much taller buildings in areas where they are at odds with the surroundings. So we ask for a statement in the policy that the maximum height allowed for particular areas may not be varied.
The current Local Plan anticipated a significant increase in comparison retail space A1 at Brent Cross and a modest increase elsewhere, much of it expected by 2021. Although none of this space has materialised the draft Plan surprisingly largely repeats this expectation. Given the difficulties experienced by retailers over the years since the current plan was adopted in 2012, we suggest it is unrealistic to expect to defend all the existing A1 space, as the Plan aims to do, let alone maintain the expectation of expansion. We would instead wish to see encouragement to convert space in secondary retail areas to residential or other uses.
This whole area is most troubling. The dependence on the two branches of the Northern Line for travel to work is acknowledged as is the reality that these lines are currently overloaded. Whilst some capacity increase is possible, which will include the necessitate for rebuilding at Camden Town, financial constraints indicate it is likely to be many years before plans come to fruition. Even worse is the prospect that with a change in emphasis by the Govt to HS2 and transport infrastructure in the north, there is considerable doubt whether Crossrail 2 and WLO will ever see the light of day, and certainly they would not arrive before the timescale of much of the planned additional housing. Though orbital services bus links are a legitimate concern we doubt they are anything other than marginal in the overall picture and any improvements will only have limited impact. More important is finding ways to reduce bus travels times, the decline of which is cited as a major reason for the fall in bus usage,
So the notion of major improvements to public transport in the Borough is little more than fanciful and the Plan should reflect the impact of this reality rather than dwell on aspiration. And linked to this, it is evident the plan is very weak on curbing car usage where much more imaginative solutions are needed e,g some form of road pricing, particularly vehicles entering the Borough from the motorways to the north. We do however support ideas such as priority for buses, banning parking close to schools and to increase 20mph zones.
From the above we have identified five major areas of concern:
1. The increasing in housing numbers, aspiring to 46,000, is unlikely to be wholly achievable in the timescale, but from the sites identified we recognise that delivery could certainly exceed 30,000. We do conclude that the lower target of 33,460 is what is realistic and that figure should properly form the basis of the Plan.
2. What is evident is that the vast majority of these planned new homes will be in high rise blocks on densely developed sites, with the majority of homes just one or two bedrooms. Faced with this reality the Plan should ensure that the existing stock of three to five bedroom homes is robustly protected against losses. This is not the case with the policies as currently presented, and in particular the notion of major intensification in and around town centres is ill-conceived in this respect.
3. A more robust tall buildings policy is required to protect existing low rise areas.
4. The proposals for town centres are outdated and need revising to reflect the current reality of retailing.
5. There is a major mismatch between population growth and a largely unrealistic transport strategy.