Hammersmith and Fulham Liberal Democrats

LIB DEM SUBMISSION to LOCAL DEVELOPMENT FRAMEWORK CORE STRATEGY REVIEW

Core Strategy June 2009

The Local Development Framework provides the guidelines for developers to follow when constructing new or refurbished buildings in the borough. It also sets out the Council's vision for major changes in the borough (transport, schools, shopping areas etc.). It is a long and sometime technical document. Below are the comments made by the Liberal Democrats.

They are short and follow the format of the LDF itself. If you want further details or to discuss particular aspects of our submission, please e-mail us.

Comments to submitted by the H&F Liberal Democrats.

D: Reducing deprivation and polarisation Para 4.9 pg 14: The paragraph seems to conflate home-ownership with increasing levels of employment. It is not housing that affects employment but skills and training. Agreed that housing policies can aggravate dependency and exacerbate levels of deprivation but they do not "build out opportunity."

E: We recommend removing this paragraph or altering so that skills and training are recognised as means to increase employment; not home-ownership.

D: Improving Quality of Housing Para. 4.20 pg 16: Agree "planning policies can help to ensure new housing is built to meet higher standards of energy efficiency and accessibility" but planning policy can also affect redevelopment or modifications to existing buildings.

E: Add the words "and redevelopment of existing buildings" to the last sentence.

D: Mitigating the impact of climate change Para 4.81 pg 23: We agree that Climate Change needs to be addressed in the Core Strategy. However, the document rarely refers to Climate Change issues. For example, the description of "Decent Neighbourhoods" in various places does not include any references to sustainability.

E: Ensure mitigating the impact of climate change is considered throughout the document, not just in paragraph 4.81.

D: Spatial Vision Para 5.1 and 5.3 pg 31: "Promoting home ownership" as a goal conflicts with comments made in paragraphs 3.1, 3.2 and 3.3. If the borough is young, diverse and mobile and, as stated in para 5.9, the goal is to provide a "broad range of options to suit different lifestyles and life stages", then promoting home ownership is severely limiting. Home ownership is suitable for many people but certainly not all. The Key Priorities should reflect this.

E: Change "Promoting home ownership" to "Promoting a broad range of housing and ownership options"

D: From Decent Homes to Decent Neighbourhoods Para 5.8 pg 31: The vision is to create "decent and aspirational neighbourhoods." "Aspirational" is not defined and conflicts with the sentence that follows. How can the residents be expected to be "happy to continue living" in them if they are supposed to be aspiring to be something else!

E: Shorten the two sentences to simply: Our vision is to transform deprived areas in the borough and make the entire borough a place where people want to live and in which they are happy to continue living if they wish to do so as their circumstances change.

D: "What makes a decent Neighbourhood" pg 32 Section 5: No mention is made of sustainability issues. A decent neighbourhood should also be one that does not waste resources or encourage unsustainable living.

E: Change the fifth point to: Well designed buildings that incorporate the latest principles of sustainability, encourage active streets and respect their surroundings.

D: Regenerating the local economy Para 5.13 pg 33: Given the excellent transport links described elsewhere in the document, there is no need for the local economy to be "growing". Growth in the borough brings many of the problems needing to be addressed (traffic, expensive housing, lack of open space, climate change, etc.) by the document. Rather, the Strategy should be to provide residents with a place to live from which they can take advantage of growth in other areas of London.

E: The sentence needs to be written so that residents benefit from regeneration and not suffer from growth: "Regeneration initiatives will also have impacted on our local economy which will be thriving and able to make an important contribution to, and take advantage of, the wider London and west London economy."

D: Strategic Objectives Paragraph 6.1 pg 37: Item 19 only mentions transport schemes that help east-west travel or travel by commuters through the borough. No mention is made of schemes that will improve north-south travel or reduce car travel within the borough.

E: Change Item 19 to "Ensure there is high quality transport infrastructure, including roads designed to provide more space for bus routes, cycle lanes and pedestrian areas."

D: Town Centres Paragraph 7.37ff pg 47: The statement is made that the Council "will look towards ensuring greater variety of uses" of local centres and neighbourhood parades. But all examples deal with increased shopping or commercial uses. Buildings in local centres can be used to meet community needs as well. Youth centres, child care, libraries, art centres, etc. can all add to the vitality and success of a neighbourhood.

E: The paragraphs need to make clear that a "greater variety of uses" includes community facilities.

D: Council Housing Estates Paragraph 7.46 pg 49: Again, "What makes a decent Neighbourhood" makes no mention of sustainability issues. A decent neighbourhood should also be one that does not waste resources or encourage unsustainable living.

E: Change the fifth point to: Well designed buildings that incorporate the latest principles of sustainability, encourage active streets and respect their surroundings.

D: Options for each Regeneration Area Paragraph 8.1 pg 57: No mention is made of sustainability issues. Council housing estates should be energy efficient with low environmental impact. In fact, new council housing should aspire to incorporate the latest sustainable building methods and practices.

E: Change the fifth point to: Well designed buildings that incorporate the latest principles of sustainability, encourage active streets and respect their surroundings.

D: Housing, mixed and sustainable communities and decent neighbourhoods Paragraph 8.6 pg 59: The word "sustainable" is mentioned in the title of the paragraph but not referred to anywhere in the actual text.

E: A point should be added that the WCOA developments will incorporate the latest design for low carbon construction and energy efficient operation.

D: White City East Paragraph 8.6 pg 59: The penultimate point mentions local facilities as shopping, leisure, recreation, schools and health. No mention is made of youth facilities. These are very important if anti-social behaviour is to be reduced.

E: Add "youth facilities" as an example of Local Facilities.

D: White City Opportunity Area Para 8.8ff pg 60: There are proposals for "substantial employment" and that "a high proportion of jobs should be taken by local people." No information is given on what proportion of jobs go to local people in large developments now. Thus, it is not possible to determine what "a high proportion" actually is. Creating an additional 10,000 jobs may give very little benefit to local residents while bringing many problems (congestion) to the area. It may therefore be far more beneficial not to encourage creative and other industries which will employ non-residents in favour of smaller businesses that will employ a higher proportion of residents. With good transport links out of the borough, it is more important to provide skills and training so residents can qualify for jobs anywhere in London rather than bring more jobs to the borough for which they cannot hope to obtain.

E: Provide a data on the percentage of residents obtaining jobs in large developments for creative and other industries versus small businesses that cater to local needs. Then base job creation initiatives on the data.

D: Transport Para 8.13 pg 61: Other than the West London Line, all references are made to projects that help east-west travel, benefit cars or benefit people travelling through the borough. No mention is made of schemes that will improve north-south travel or reduce car travel within the borough.

E: Include references to improving the transport infrastructure so that roads are designed to provide more space for bus routes, cycle lanes and pedestrians.

D: Delivery Para 8.16 pg 61: The claim is made that 4000-5000 new homes and 10,000 additional jobs can be created in the WCOA. However, the document does not state if this balance provides the greatest benefit to residents or how this balance fits in with the other goals outlined in the document. Also, what measures will be implemented to ensure the new homes do not go to people taking the new jobs that are being created? Given the emphasis on creating home ownership, it may very well be that fewer jobs and more homes would provide far more benefit to residents. As stated before, with the good transport links to other areas of London, jobs in the borough are less important than training and skills and an affordable place to live.

E: Provide supporting evidence that the balance between jobs and homes do meet the needs of residents or reconsider the balance.

D: White City East Para 8.19 pg 62: We support the Preferred Option described but would like "community facilities" strengthened. Youth facilities should be a large part of any development in the area. They can play an important role in preventing social exclusion and anti-social behaviour.

E: Add "youth facilities" to the list of supporting uses in a development of White City East.

D: Section 8 Preferred Option - Old Oak Common and Hythe Area pg 98: Promoting a Crossrail Station and hub for a national high speed rail link to Heathrow does not seem in keeping with the current or proposed industrial uses for the area. If the Crossrail Station and high speed hub were to be constructed, they would attract a very different type of development to the area. There would be conflicts with the differing needs of these developments. The area would also be quickly subjected to over-development and a loss of the valuable industrial premises that other parts of the document are trying to encourage.

E: Far more information must be provided on the affects of a Crossrail Station and a hub for a national high speed rail link to Heathrow would have on the area before the scheme is actively promoted.

D: What makes a decent Neighbourhood Paragraph 9.3 pg 103: Again, "What makes a decent Neighbourhood" makes no mention of sustainability issues. A decent neighbourhood should also be one that does not waste resources or encourage unsustainable living.

E: Change the fifth point to: Well designed buildings that incorporate the latest principles of sustainability, encourage active streets and respect their surroundings.

D: Policies for housing development Paragraph 9.3 pg 104 Preferred Option point D pg 103: No mention of sustainability issues.

E: Include a statement that the carbon footprint of the dwellings should be reduced through energy saving design, construction and operation.

D: Supporting communities facilities and services Paragraph 9.26 pg 111: Preferred Option lists many examples and goals for community faculties and services. No reference is made to youth facilities. They are implied but should be made explicit given their role in preventing anti-social behaviour and reducing social exclusion.

E: Explicitly refer to youth facilities as a community facility and service that meet the needs of young people to have something constructive to do with their time.

D: Schools and other educational training facilities Paragraph 9.31 pg 112: We support the Council's aim to improve education and training so young people can take advantage of local jobs. But this should be extended to jobs in the London area. Given the good transport links to other parts of London, young people should be encouraged to aspire to careers not available in the borough and companies not located here. Also, the sentence as written does not make sense. The last clause ("will result in improvements and changes to the borough's schools.") needs to be altered.

E: Change the sentence so that the Council's aim is improved education "… so that young people will be better able to take advantage of jobs locally and across London. This will require improvements and changes to the borough's school buildings and facilities."

D: Paragraph 9.50 Preferred Option - Built Environment pg 119: Support the points made in this discussion but would like it strengthen regarding minimising the opportunities for crime. Good design contributes to preventing crime. But providing alternatives to crime and anti-social behaviour also contribute to reducing crime being committed.

E: Change the fifth point to: "be designed to enhance community safety, minimise the opportunities for crime and provide facilities which meet the needs of young people."

D: Paragraph 9.57 Preferred Option Reduce Carbon Emissions and Resource Use pg 121: Support the points raised in this section. We believe that consider needs to be made to encourage developers to exceed BREEAM and the Code for Sustainable Homes. This could be done by allowing higher density development or reducing Section 106 commitments for developments that exceed the standards and use innovative technology to reduce carbon emissions or resource use.

E: Include a statement and policies which encourages developers to exceed BREEAM and the Code for Sustainable Homes through the planning process.

D: Preferred Option - Transport pg 126: Point Four implies improvements will be made to roads so that cars can use them more easily thereby reducing congestion. Point Five implies walking and cycling are leisure activities and not means to reduce congestion. No mention is made of improving roads for buses or introducing new bus routes. In fact, much of the Commentary deals with High Speed Rail for which the Council has little real influence over.

E: Include an explicit statement to increase bus routes, to improve existing bus routes, to provide more road space for cyclists and to provide pedestrian areas.

D: Transport Paragraph 9.75 pg 126: According to the first sentence, a key issue for the transport strategy is to reduce "the adverse impact of road traffic and traffic congestion." No mention is made anywhere in the Commentary about efforts to actually reduce road traffic or traffic congestion. To reduce the borough's contribution to carbon emissions, car use must be reduced. Given the layout of the borough, improving north-south travel and public transport means improving bus routes and encouraging cycling. This can only be done by reducing cars on the roads; not by reducing the impact of cars.

E: Change the first sentence so that a key issue is to reduce the number of cars on the borough's roads so that taking buses and cycling become more an appealing options to car use.

D: Transport Infrastructure paragraphs 10.19 to 10.22 pg 131: No data is provided for the sources of traffic in the borough. Different solutions need to be considered if most traffic is east-west commuters traversing the borough rather than if most traffic is residents struggling along the few north-south routes. In addition, no mention is made of bus lanes, cycle lanes or pedestrian areas. These also form part of our Transport Infrastructure and should be considered in the document.

E: Provide an analysis of the source of traffic in the borough to inform solutions to transport problems faced by residents. Second, include bus lanes, cycle lanes and pedestrian areas as part of the Transport Infrastructure and provide a strategy accordingly.