Draft London Plan: Battersea Society Response
1. This response relates to specific issues in the draft plan which are of direct relevance to development in Battersea. The Battersea Society as a member of the London Forum supports its separate detailed submission; and we do not reiterate their concerns below. However, we wish to draw attention to the following failings in the draft which are specific to Battersea and should be addressed.
2.MBUL1 Spatial Strategy : We question the unexplained omission of Clapham Junction from the list of Brownfield First Opportunity Areas (BFOAs), which could have major implications for the regeneration of the Winstanley Estate and the provision of net additional homes to meet Wandsworth’s housing target. We note, however, that Figure 2.2 for the Indicative 20 Year key diagram includes Clapham Junction among sixteen Future Candidates as Broad Locations for Growth (BLGs). A failing of the draft is absence of the basis of how these candidates have been selected, or how their candidate status might progress.
3. MBUL2 Optimising Use of land and site capacity. We regret that in a policy designed to optimise land use, there are no strong measures to promote land assembly, outside Opportunity Areas (covered in Policy PV1). There are examples in Battersea of allocated sites where development has been stalled for decades by the complexities associated with multiple landowners. Problems with land assembly have also led to tall buildings being developed on small sections of larger sites, rather than the mid-rise buildings that would have been appropriate across the whole site. Land assembly is often the problem that militates against the mid-rise developments the Draft Plan wishes to promote, and we propose that it should be addressed in the Plan.
4. MBUL3 Tall buildings and protection of the Thames Policy Area: We have some reservations about the designation of 17 locations where ‘metropolitan’ tall buildings of 100 metres or more ‘may be appropriate’, including Vauxhall and Nine Elms. It is unclear whether the locations have been assessed at borough level. There is also a tension between terminology such as ‘may be appropriate’ and a requirement on boroughs to incorporate the locations – albeit with precise boundaries as defined by them – in their Local Plans. At the most basic level, the policy lacks any explanation as to the benefits the clusters are intended to bring either to the locality or to London as a whole.
5. A major concern in Battersea is the protection of its heritage Thames frontage which has proved to be a magnet for developers of tall buildings over the past two decades and continues to be attractive to developers of new and replacement tall development. The draft fails in having no measures to ensure that the Thames Policy Area as a whole is protected from inappropriate developments of tall buildings. We propose that MBUL3 Development Management Policy A4 should be amended to cover buildings over 20 metres near the Thames, with A4 vi strengthened to refer to the Thames Policy Area: “proposals for buildings over 20 metres high near the River Thames, and particularly within the Thames Policy Area, should be accepted only in the most exceptional circumstances, and only if they protect and enhance the open quality of the river and the riverside public realm”.
6. MBUL5 Sustainable transport to enable London’s growth: the Battersea Society has consistently pressed for more realistic assessment of public transport capacity in relation to journeys likely to be generated by significant new development. This has been a major issue between Wandsworth Bridge, south to Clapham Junction and east to Vauxhall. Overcrowding at Wandsworth Town and Clapham Junction rail stations raises safety issues; buses are heavily used and traffic congestion, especially during the construction of cycle lanes and the closure of Albert Bridge, has increased uncertainty about the travel times. The NLE from the Power Station, while welcomed, has largely only mitigated pressures in the Nine Elms/Vauxhall area and will itself become increasingly congested as the Power Station site is developed. Current policy fails because it lacks reference to the need to consider the transport load implications not merely of the proposed development but also the cumulative impact of already approved development on the transport system.
7. It is also regrettable that Annex D Transport Interventions has no reference to improvements to Clapham Junction given the safety problems arising partly from the high number of inter platform changes and the work that has been in hand for a number of years looking to measures to address this. This is another instance of the weak consideration of the role of the Junction on this part of Battersea.
8. HN1 Housing Target: We consider the housing target (2343 per annum) for Wandsworth to be unrealistic. This clearly has a knock-on effect on housing delivery within Nine Elms and the rest of Battersea. While there is still some capacity to complete the target within the Nine Elms Opportunity Area together with other major schemes in the pipeline, notably the Winstanley redevelopment, the implied proposed delivery target remains unrealistic given market conditions and the lack of further potential sites to redevelop. We consider Wandsworth should be asked to review and provide a realistic figure for delivery over the next 10 years and not be penalised for not meeting the target set in the draft Plan.
9. HN3 Affordable housing: Given the history of recent housing delivery in Battersea and the objective of building a longer-term sustainable community with housing suited to retaining families in the area, the plan should provide greater flexibility for local variation of affordable thresholds . Battersea retains areas of extensive deprivation generating high level of demand for affordable housing for which the thresholds suggested are too rigid to meet needs locally. We concur with the arguments in the London Forum submission. In Battersea, as in other inner areas, it is crucial that the targets for affordable, and especially for low-cost rent, housing should be significantly increased.
10. HN5 Managing Specialist Accommodation: While we support the provision of Purpose Built Student Accommodation (PBSA) and welcome Clause A.2 on the need to identify areas of concentration the targets are based on unclear assumptions and methodologies, and do not take any account of what has been built already. The target for Wandsworth, which has seen a notable growth of PBSA, particularly in Battersea, is unacceptably high. We propose that the policy be strengthened to make it clear that further expansion of existing concentrations should wherever possible be avoided.
11 HN7 Housing Mix: The Battersea Society has consistently argued over the years both at EIPs and in relation to specific developments that the mix of dwelling size has inadequately reflected the local need for larger units. While we strongly support Clause A of this policy, we cannot agree with Clause B. Use of the Strategic Housing Market Assessment (SHMA) in this way fails to acknowledge that seeking to meet its assessment of current needs is likely simply to reinforce the negative impacts of an oversupply of small housing units: low fertility, family flight from London, and unbalanced, unstable communities. These damaging effects are particularly evident in Battersea. The impact on schools is now well-known, with declining rolls in inner London primary schools (though this will soon be felt in secondary schools too). But no effective measures are being taken to address the problem, which is not even mentioned in the Draft Plan.
12.In addition, the SHMA assumes that existing family-sized stock currently occupied by under-occupying older owners will become available to families. But there is no policy to establish a mechanism by which that happens or to address the lack of incentives for older people to downsize. The "under-occupied" 3+ bedroom homes are not, in practice, part of the family-home supply unless something incentivises older owners to downsize.
13. The plan therefore should provide greater flexibility to reflect local needs in relation to dwelling size. While we strongly support Clause A of this policy, we cannot agree with Clause B. We propose that Clause B be amended to state that “Any Local Plan policy on housing size mix for market homes should be based on a Local Housing Need Assessment”
14. GL2 Supply of Industrial Land: in Battersea there is a strong demand for industrial sites, with high rates of occupancy in both Strategic Industrial Locations (SILs) and Locally Significant Industrial Sites (LSISs). These areas offer a range of local employment and provision of essential inner-city services. In addition, there is an inconsistency between this policy and Policy PV5, which requires the release of industrial land for housing. As indicated in relation to local housing targets there is no such industrial land available locally in Battersea, and there is no indication in the Draft Plan as to how this tension is to be resolved. The development management policy (Clause F and para 4.19) to restrict non-industrial development in SILs and LSISs needs adjusting as it is inappropriate as a blanket policy unrelated to local demand for, and existing pressures on, industrial land.
15. PV3 Town Centres and High Streets: We welcome the new designation of Clapham Junction as a Metropolitan Town Centre, and the evidence for that as presented in the review of town centre classifications. We would have expected it also to be classified as at least metropolitan in terms of future network classification and even possibly International given rail links to Gatwick. Battersea Power Station now has a significant retail offer and spend per visit yet does not appear in any of the high street /town centre classifications which seems odd. We consider this underplays the growing role of the Power Station as another form of ‘high street’ and its impact on the local economy, transport demand etc. References to the development should be enhanced and strengthened.
16. PV6 Metropolitan Open Land (MOL). Battersea has significant areas of MOL including Battersea Park and parts of Clapham Common and Wandsworth Common. We therefore welcome the strengthening of Policy G3 in the current London Plan, and the new definition that requires any newly designated MOL to remain permanently open. We strongly support the policy that MOL is not to be treated as Green Belt, and that Policy PV7 does not apply to it. This should be made clearer in the policy itself.
17. PV8 Strategic and Local Views: While 13 of the current 27 Designated Strategic Views are River Prospects, it is notable that important views in west London do not feature in the list of designated strategic views. None of the views across and along the Thames west of Lambeth Bridge feature in the list, even though some - such as those in Chelsea and Battersea from both sides of the river - are iconic. We will respond to the new draft London View Management Framework and suggest some additions to cover omission relating to Battersea.