NORTH LONDON STRATEGIC ALLIANCE RESPONSE TO NORTH ...

NORTH LONDON STRATEGIC ALLIANCERESPONSE TO NORTH LONDON DRAFT SUB-REGIONALDEVELOPMENT FRAMEWORKIntroductionThis response concentrates on matters considered to be of sub-regional importance. Itconcentrates on the economy and employment, town centres, housing, transport andmatters arising for the forthcoming London Plan review. It should be seen ascomplementing the more locally or functionally specific responses from the four NorthLondon Boroughs and other stakeholders.The NLSA has been glad to participate in the process of preparing the SRDF and haswelcomed the willingness of the Mayor’s representatives to discuss matters, even ifsome remain unresolved. The process has enabled us jointly to achieve a clearerunderstanding of many of the key issues facing the sub-region and promote a coherentsub-regional approach to development and regeneration across North London.The NLSA has worked closely with the GLA, before and after the publication of the draftSRDF. The joint GLA / NLSA conference on 16th September was valuable in giving awide range of stakeholders a better grasp of matters, with over 100 registereddelegates. The report from this event has been circulated and has informed thisresponse.The SRDF will we hope provide a useful tool to inform and guide the LDF process.However there are gaps in the SRDF approach, specifically around social issues andtransport, and we would be happy to discuss this issues further.Key Issues• The scale of population growth (15%), is much greater than the projected growthin employment (4%). We have deep concerns about what this will mean for socialexclusion, sustainable development and quality of life.• While there is major growth envisaged there is little indication of how thesupporting social infrastructure will be planned and provided. The final SRDFmust give more detail on how this.• The NLSA will be working closely with TfL on the emerging Sub-regional NetworkPlans. However we are still concerned about the low levels of transportinvestment planned for North London. The NLSA may make a furthersubmission to the SRDF or to the London Plan review process as appropriatefollowing the publication of the Network Plans.October 2005

Part One: Identity and overall direction for the sub-regionThe NLSA welcomes the ‘positioning’ of North London set out in part one. In manyways, promoting a sense of North London’s strategic location has been one of the keyoutcomes of the development of the SRDF.Diagrams 1 and 2 and accompanying text refer to North London’s strategic hub orgateway position between the Government’s Thames Gateway and London-Stansted-Cambridge Growth Areas, the M1/A1 corridor linking it to the Milton Keynes/SouthMidlands Growth area, and the UK’s key economic driver of central London. NLSA iskeen to ensure that the sub-region obtains most benefit from this, in terms of “theimprovements in accessibility, quality of life and economic performance that such aposition could offer” (draft SRDF paragraph 16), given that it is an integral part of theLondon economy.However, we are much concerned that the locational advantages brought out in PartOne are not clearly carried through in developing and realising North London’s potentialfor sustainable growth, regeneration and economic development in Part Two of theSRDF. The SRDF currently sets out a vision for North London as a strategic growtharea and promotes the idea of strategic development. However it then includes a seriesof projections which imply the region will develop as a residential dormitory, with astrategic function of supplying workers to other sub regions.NLSA supports the strategic direction for North London referred to in the Core Actionsat the end of Part One, and wishes the final version to:• Indicating how this direction is to be taken forward in Part Two in a clear andconsistent manner. This will summarise how the sub-region will gain access tothe opportunities offered by growth surrounding it.• Set out measures for improving co-ordination of cross-boundary issues,particularly regarding the London-Stansted-Cambridge Growth Area including theairport; Stratford, the Lower Lee valley and adjacent areas of Thames Gateway(bearing in mind the 2012 Olympics opportunity). The NLSA would be happy todiscuss with the GLA and others how we would aid in the formation andresourcing of such cross-boundary structures.AirportsIt is worth noting that both Stansted and Luton are currently consulting on masterplansthat would increase their capacity. This will have implications for the spatial corridors ofCricklewood-Luton-Milton Keynes and Upper Lee-Stansted-Cambridge.2

Part Two:Economy and EmploymentNLSA regards the most important issue arising from Part Two to be the worseningimbalance it revealed between an expanding population and resident workforce on onehand, and very low projections of employment growth (which as Table 2.1 showscondition land requirements for job-creating development) on the other. In 2001, NorthLondon contained 14% of London’s population and 8% of its jobs. The London Planenvisages that 2001-2016 the sub-region will see 13% of London’s housing growth(45,000 of 345,000), but only 4% of employment growth (26,000 of 636,000).The Employment section of Part Two relies upon projections of job growth to 2016 thatare based on historic trends. The SRDF also states that these trends will occur “if theforces underlying historic trends are not addressed”. NLSA considers that they indicatea minimal-growth employment future that does not reflect:• the ‘strategic hub’ position indicated in Part One,• North London’s own economic strengths arising from the structure and size of itseconomy and its internal drivers of change• A policy commitment to sustainable development and the accompanyinginterventions from bodies such as the LDA and Government Office throughERDF.There is we believe considerable potential for growth, which can be realised through atailored package of interventions reflecting the themes of the Mayor’s EconomicDevelopment Strategy 2005 (including infrastructure and access, site renewal,investment in workforce, business development and marketing), which will be amplifiedin the forthcoming North London Sub-Regional Implementation Plan (SREDIP).Of particular significance in this regard are the London Plan’s Opportunity Areas andkey town centres:-• The Upper Lee Valley, offering considerable opportunities for renewal asLondon’s main industrial corridor (comprising a wide mix of business activities),including the Central Leeside, Blackhorse Lane and Innova development areas,• Tottenham Hale, developing as a key transport hub with links toStratford/Thames Gateway, with ‘urban business park’ potential together withhigher density housing and mixed uses,• Cricklewood-Brent Cross, London’s second largest development, after Stratfordcity, evolving an integrated town centre of metropolitan status, related tosubstantial office development and housing growth, with improved accessibility,and taking advantage of its location at the southern end of the ‘M1/A1 corridor’,• The metropolitan centre of Wood Green together with the Haringey HeartlandsArea for Intensification, with potential and capacity for growth in retail and mixeduse,cultural and creative industries,3

• North London’s major centres and certain well-located district centres, whichoffer mixed-use intensification potential,• The Upper Lee valley is particularly well-placed to benefit from the legacy of the2012 Olympics.There are solid policy objectives for supporting employment growth within London’souter boroughs, for example reducing the need to travel, by placing employment closerto residential areas. We would welcome a fuller discussion with the GLA family, andGLA Economics specifically, around their reliance on passive historic trends to baseinvestment and policy decisions.Employment LandWe welcome the openness to hold a discussion around planning for employment landset out in actions 1G (page 24). The NLSA believes the GLA Economics projectionshould not be taken to imply that North London can release 100ha. of industrial land.The GLA trends should be used to indicate issues to be addressed in regenerating andexpanding the sub-regional economy to counter an increasing jobs deficit. We realisethat changing employment land to new uses such as housing will be a feature in NorthLondon, but the NLSA does not accept the 100ha. ‘benchmark’ is justified by the localemployment and opportunity situation. It should be replaced by a more ‘monitor andmanage’ approach, relating existing and future demand to supply in localcircumstances, and leading to actions agreed through the North London SREDIP, e.g.to reconfigure specified areas and secure mixed-use redevelopment where justified andappropriate. The emerging joint LDA/NLSA Employment Land Study should form thebase assessment for this when finalised.We welcome the designation of Strategic Employment Locations, however thedesignations in Annex 2 may have to be revisited following the completion of the jointLDA /GLA study.Three further points:-• The Upper Lee Valley should be recognised as of strategic importance toLondon. Brimsdown is the city’s second largest industrial estate after ParkRoyal. It is an important regional cluster, providing services to it adjacent growthareas. The Upper Lee Valley could have a role as a Strategic Logistics Park(paragraph 98), but it would also require measures to enhance accessibility tothe M25,• The GLA’s proposed London Plan Waste Alteration indicates that a significantamount of ‘surplus’ industrial land in North London will be needed for wastemanagement and recycling activities. We would welcome interventions toencourage the development of “21 st Century” responses to waste management,for example transferring Dutch and Germany approaches and technology,4

• Regarding the importance of logistics/distribution activities in North London,future growth should be considered in a cross-boundary way with adjoiningHertfordshire and Essex authorities, related to the M25 and the demands ofgrowth and construction in the Lower Lee Valley.ActionsNLSA accepts and is taking forward many of the Actions 1B (page 17), including thereference to SMEs, as they are positive measures not based on the pessimistic attitudederived from the GLA Economics projection. The final action point however appears toimply that sustainable communities are created by the release of land for housing.NLSA’s fear is that we do not retain sufficient employment in the sub-region to create asustainable community.NLSA wishes to see changes to the Actions 1G (pages 24-25) as follows:-• The strategic monitoring benchmark for the sub-region will be replaced throughthe outcome of the LDA/NLSA supply and demand assessment and reflect a‘monitor and manage’ approach, for application in LDFs in light of the nationalrequirement to justify the release of industrial land,• The fourth action should refer at the end (regarding SLPs) to cross-boundarycollaboration,• Mention of the North London SREDIP needs to be made in this section.Town CentresAs regards retail development NLSA notes that the sub-region should plan for 104,000to 160,000sq.m. of extra comparison goods floorspace on top of the 55,000sq,m.committed at Brent Cross, and between 7,000 and 34,000sq,m. of convenience space.NLSA regards exploration of capacity within centres to accommodate growth; checkingand co-ordinating the pipeline; and assessing future provision for conveniencefloorspace (including the proportion of comparison goods space now in largersuperstores) (paragraph 59) as a matter largely for Boroughs, whose response shouldbe taken fully into account. The NLSA would be happy to discuss supporting a coordinatedapproach for retail provision across the sub-region.We support the long term objective of making north London’s out of centre retail parksevolve into more sustainable forms of land use. This will require closer workingbetween the boroughs and the GLA family to develop shared strategies.As regards Action 1C, second bullet, the final SRDF should indicate how the Mayor willundertake this co-ordination and involve sub-regional partners and cross boundaryissues, for example the impact of Stratford. It is also worth noting that LB Haringey hasjust embarked on a major masterplanning process for Wood Green. The viability of this5

project will rely on close working with the GLA.Section 2A deals with the Town Centre Network. NLSA accepts paragraph 107,indicating that the basis for the distribution of retail floorspace should be that eachcentre plays to its (functional) strengths, taking account of (existing and potential),accessibility, and performing the widest possible diversity of activities. This statement iswelcome, as while the scope for retail development is important, other town centrefunctions warrant full prominence. Town centres, as cultural and social hubs need tobe considered, reinforcing social cohesion.Allied to housing intensification at centres supporting further development of services,the employment outcome of this diverse growth of activities will be substantial and likelyto modify the GLA Economics projections substantially.The NLSA recognises there will be a need for sub-regional working to plan for the futureof the sub-region's town centres. The NLSA is at the start of the process of developinga North London Town Centre Group. This will bring together the boroughs to discussissues of shared interest. It would also be a strong forum for the GLA to work with onspecific issues such as developing a sub-regional approach to office development. TheNLSA suggests that the Group’s outcomes forms an input to the London Plan review asregards the North London dimension of delivering on present Policy 2A.5.Regarding the evolution of the town centre network, at the strategic sub-regional scale,and in addition to Brent Cross, two major locations are of particular significance:• Wood Green as the metropolitan centre, where, in conjunction with HaringeyHeartlands, considerable capacity exists for a diversity of development, asdemonstrated by the LDA/GOL Town Centre Enhancement (TEN) Study• Walthamstow which should receive regeneration priority to develop its retailfunctions alongside growth in leisure, cultural/creative and niche business servicesectors, responding to the challenge of Stratford.These centres, together with Enfield Town, occupy key locations within the London-Stansted-Cambridge Growth Area.Haringey’s retail capacity study undertaken as part of its UDP process in 2003 forecastsgreater demand than that contained within the SRDF, and the current Wood Greenmaster planning processes looks to consolidate this centre’s role. In addition Leyton'sstatus as a District Centre needs to be considered.Regarding office (business services) growth, NLSA sees particular scope, as part ofmixed-use developments, at Wood Green and also at Enfield Town and TottenhamHale. Such growth would be oriented to sub-regional and local scale services and tostimulate SME office businesses, particularly in the Lee Valley area. This could also beencouraged at a smaller scale as part of residential intensification schemes at key6

district centres, e.g. Edmonton and North Finchley. The Cricklewood-Brent CrossOpportunity Area remains the location for major office growth over the long term; thefinal SRDF should reflect the latest scale of development intentions there in Section 2Cand Annex 2, as indicated by Barnet Council.NLSA wishes Actions 2A to be modified accordingly for the final SRDF. We would beglad to be involved in redrafting the fifth bullet point, and in clarifying the sixth ahead ofthe London Plan Review. In this respect reference should be made to realising theintention in London Plan policy 2A.5 to produce an integrated policy for town centres.NLSA also proposes an additional bullet point for the final SRDF, referring to theoutcome of the LDA/GOL Town Centre Enhancement Study, due to be published soon.NLSA, with LDA and GOL are currently developing a programme of dissemination.HousingNorth London’s Borough Councils will make the main responses on the Housing contentof the SRDF. NLSA adds or underscores the following points from its sub-regionalperspective.A central concern which the SRDF does not consider, but with the increasing influenceof the Mayor in housing issues should be referred to, is the focus of investment bybodies such as the Housing Corporation on the ability to deliver new housing, ratherthan the housing needs in a specific location. Coupled to this are the currently weakstructures for tenants to be allocated housing in locations outside the subregion/London. While we have nationally designated housing growth areas there is littleor no mechanism to give, for example, tenants in Haringey the opportunity to influenceor access housing allocations in locations such as Milton Keynes. Initial work by theNorth London Housing Group indicates an active resistance by non-London GrowthAreas to consider London’s population growth. While it is potentially cheaper todevelop housing in these non-London locations it will do little to relieve the seriousproblems of overcrowding and homelessness in North London. As a specific action wewould like the GLA, with the ODPM, to show leadership on ensuring a more joined upapproach between the Housing Growth Areas.The proposed actions in 1A (page 15), addresses issues of producing “balanced”communities. We welcome this approach and recognise that North London boroughsare already progressing these objectives. On a note of caution it must be recognisedthat some of North London’s problems arise from an oversupply of poor quality privaterented accommodation. Therefore producing private housing, in a strong buy to letmarket, may produce unforeseen problems.References to housing are split between Section 1A, paragraphs 104-105 at the start ofSection 2, and Section 5 regarding density and housing mix. The SRDF’s intentionswould come across more clearly if co-ordinated in one section.7

Paragraph 40 (page 14) notes that the outcome of the Housing Capacity Study will bereflected in the final SRDF. The proposed London Plan Housing Alterations whichderive from the Study envisage an increase in annual provision of new housing from thepresent 2,980 p.a. to 3,720 p.a. from 2007. NLSA notes that this increase isconcentrated in Barnet, where an annual rate of 1,965, over 50% of the North Londontotal, is proposed. In referring to this, the final SRDF should refer to the sustainabilityimplications of such an increase in this part of the sub-region, bearing in mind that thiswill be a matter for the statutory alterations process.This leads to a further point about housing growth generally: its scale needs to bephased in accordance with ability to provide the requisite social infrastructure capacity,in terms of health facilities, increased school and further education provision, publicamenities etc., if the substantial growth envisaged is to lead, as intended, to moresustainable communities. This is referred to in Section 1E (page 22), but the Actionsthere are for Boroughs to advance. The final SRDF should add a further bullet pointhere to specify the role of the Mayor and the GLA group in providing its strategicauthority to deliver on this critical concern.Paragraph 42 indicates that further opportunities for intensification should beconsidered. No specific action follows, other than a general exhortation at town centres.It is assumed that any further areas of strategic significance will be for identificationthrough the London Plan Review process. The final SRDF should however add areference here to the outcome of the Town Centre Enhancement Study, whichexamined potential at a selection of centres from an urban design perspective.We support the point in paragraph 41 that more work has to be undertaken to build ashared vision for action. The role of elected representatives should not be forgotten inthis context.The two issues of density, referred to in paragraph 105 and Action 2.1 (third bullet) isdealt with again in Section 5A. This needs relating to what is said in Section 5C onhousing mix. NLSA makes three points:-• The stated need for a much higher proportion of family dwellings is welcome, buthas implications for density policy that the final SRDF should clarify.• The location of higher density housing and intensification needs to be closelyrelated to the public transport and interchange situations as they evolve, if suchdevelopment is to be sustainable. The final SRDF should emphasise this.• We welcome the acknowledgement that achieving high densities will require asensitive approach and higher standards of design (paragraph 191). It isdisappointing therefore that Action 5A only appears to focus on “driving up”density, rather than acknowledging in certain locations lower density may be amore appropriate response. As indicated the provision of high quality familyhousing may require lower densities.8

As regards Suburbs (Section 2C, particularly Action 2C second bullet point), in view ofthe extent and character of North London’s suburban areas, the disposition of housinggrowth should respect the importance of protecting and enhancing suburban quality oflife. This is important in order to retain people in the higher-order occupational andfamily groups, which are showing an increasing propensity to move out of London.Actions 2C should make this clear by adding to the second bullet point “consistent withthe need to safeguard and enhance quality of life”. Public sector investment in thesuburbs is still required to make sure that their facilities (libraries, leisure centres,schools) are maintained.In response to action 5B (page 46), causes of the under provision of larger units withinthe sub-region include the GLA’s own policies to increase density and the way that theHousing Corporation allocates funding on a narrow cost per unit formula. We wouldlook to the Regional Housing Board to undertake a full review of this issue and itsimpact on sustainable communities.TransportNorth London is suffering from particularly low levels of committed transport investment.In a situation where TfL is unwilling to refer to projects not yet committed, prospects forimproving North London’s relative locational competitiveness and investment prospectsappear dim. There is no identification in the draft SRDF of the key needs to increasepublic transport capacity in order that growth can become sustainable and for potentialsat town centres and opportunity areas to be realised.As matters stand, the only major enhancement in prospect is completion of the surfacerail Thameslink 2000 project by 2012, which will increase capacity to central London.Otherwise, North London will rely on incremental improvements to tube capacity andbus services. Apart from the now delayed improvement to the North Circular Road,there is no mention of the key need to improve orbital transport, which is particularlyimportant to increase access to employment locations. The final SRDF and thesubsequent London Plan Review provides the GLA with the opportunity to champion theinvestment required in North London.The west boundary of the sub-region will see significant growth, with Brent Cross –Cricklewood alone predicted to have up to 10,000 new homes. This will produce moreinward commuting with significant implications for pinch points such as Camden.Thameslink 2000 will we hope play a significant role in supporting the growth corridor tothe west of the sub-region.However it should be recognised that many of the transport investments set out in theNorth London SRDF will do little to improve the sub region’s needs, e.g. CTRL andCrossrail.9

The sub-region, via the NLSA and its subcommittee the North London Transport Forumhas developed a good understanding of its transport needs. North London has twocritical central transport problems which we would like to see reflected in the SRDFwhether or not funding has been agreed to address them;• Poor orbital routes, with inadequate public transport, east to west• Inadequate rail links, north to south, along the Upper Lee Valley, with poorlyconnected stations and weak connections to Stratford.North Circular and Orbital public transportNorth London lies between 3 growth areas and is projected to experience significantinternal population growth. Congestion on the A406 will be an ever-increasing problemunless significant resources are invested. The North Circular is a vital artery for NorthLondon linking its network of town centres and areas of opportunity and growth, such asBrent Cross / Cricklewood and the Upper Lee Valley. The limited improvementsreferred to in paragraph 146 have been delayed. They will also have little impact onthe increasing demands further west as up to 10,000 homes are built in Brent Cross /Cricklewood. There is no simple answer to North London’s orbital transport challenges,but we hope that discussions around the Network Plans can bring forward sometangible projects.West Anglia RouteThe West Anglia line lies along the Upper Lee Valley and provides a key route betweenStansted and the City. In addition it will play an increasingly important role insupporting the London – Cambridge – Stansted Growth Corridor. The Government hasasked BAA to bring forward proposals for a second runway at Stansted Airport,increasing passenger throughput from 18m.ppa (2003) to up to 80m.ppa. In additionthe draft East of England Plan envisages 40,000 new jobs and 63,250 new dwellingswithin the Corridor. Strengthening links to the employment opportunities of east Londonwill also become increasingly important as major developments such as Stratford Citycome on stream around 2009-2010.However the line is currently only twin track – one line north, one line south. Pressurefor more fast passenger trains along the route will have a significant impact on theservices to smaller stations that lie along the Upper Lea Valley, reducing the frequencyof their service and threatening to further isolate already deprived communities. It is alsoessential that any upgrade is in parallel with improved bus interchange with thesesmaller stations.The importance of securing the West Anglia Route Modernisation Enhancements beforeOlympics 2012 should be referred to in the SRDF. Specifically commitment is neededfor additional capacity on the Lee Valley Line, including the Stratford – Tottenham Halelink and other improvements to enhance access to the Olympic Zone from Stansted10

Airport, the Lea Valley Line, Walthamstow and Chingford. This investment will ensurethat the Upper Lee Valley can play a strong role in supporting and benefiting from thegrowth areas to the north and south.Relatively small investments, such as the reinstatement of services along the Hall FarmCurve and reopening of Lea Bridge station, plus an increase in services along theTottenham Hale to Stratford line could make a significant impact the regeneration of theUpper Lee Valley, its capacity to accommodate housing growth and the provision oftransport services to the Olympic zone.There is an over-riding priority to sustain, improve and invest in the public transport inthe Upper Lee Valley, to facilitate the regeneration and growth prescribed in the LondonPlan.The SRDF makes passing reference to these key issues for North London but sets outno firm actions for taking it forward. We would like the SRDF to include three tangibleactions:• Champion improved orbital routes and West Anglia Route ModernisationEnhancements, including enhanced links to the east, as strategic policyobjectives• GLA and TfL with NLSA will set up a joint working group to develop tangible,sustainable and deliverable improvements to orbital transport. This will include asuite of options for various modes of transport.• GLA, TfL, LDA and NLSA, with the relevant rail authorities, BAA and the East ofEngland Assembly will set up a joint working group to develop and agreeproposals for the long term future of the West Anglia Rail Route and itsinvestment requirements.The intention to link growth and development to the transport capacity situation iswelcome: paragraph 130 (page 32) refers to development being ‘carefully phased tointegrate’ with good or improving transport accessibility, and paragraph 152 states thatthe form, scale and phasing of development will be integrated with the capacity of andaccessibility provided by the public transport system at the different locations. Action 2.1(page 27) indicates that such phasing plans will be prepared in conjunction with subregionalpartners, for inclusion in the final SRDF. Will this now occur, or will it be amatter for the London Plan Review?To advance this, Action 2E.4 (page 38) states that TfL will produce, in consultation, anIntegrated Sub-Regional Network Plan which reflects development planning issues andwill feed into the London Plan Review. TfL has issued a note on this, which indicatesthat the plan will have three parts: identifying travel demands; clarifying needs forcapacity and accessibility improvements to accommodate growth; recommending11

solutions and scheme prioritisation ‘and influence’. TfL intend a consensus on the mainissues and priorities at sub-regional level during this autumn, leading to identification ofsolutions by the turn of the year. Currently (early November) preparation is proceedingwith the first (data, modelling) stage. The NLSA will be working closely with TfL on thedevelopment of the final network plan and already had initial meetings.NLSA welcomes the SRDF’s and Network Plan’s intentions, but the situation lacksclarity, in the following respects:-• The extent to which the Integrated Network Plan process will specify the requisitetransport projects and how they will be incorporated into realistic, fundabletimescales.• Whether the reference to ‘influence’ refers to securing achievement of futurefunding to realise these projects.• What measures will be put in place to link the pace of development (particularlyhousing) to the capacity increases arising from these projects.• The extent to which the sub-regional plan will look across boundaries toneighbouring growth areas, particularly to Stansted and Stratford. As regardsCricklewood-Brent Cross consideration needs to made of its potential impact oncentral London’s transport capacity.• The extent to which the outcome will be available for the final SRDF in the winter,as distinct from it being an input into the London Plan Review.With reference to Action 2E.4, clearly the overall relationship between transport capacityand the scale/pace of development will be a key Review issue in this and other subregions.This should be made clear in the SRDF.NLSA welcomes the references to managing demand for car travel (paragraphs 153-154) and looks forward to the development of road network corridor plans (paragraph147) to manage the efficient operation of the road network. This is crucial to contain theworsening congestion that would otherwise occur from growth.Finally it is worth reflecting on the need for greater co-ordination between sub regionson their long-term ambitions. For example the Central London Partnership is currentlyproposing that the central London tram runs as far as Finsbury Park. There may be acase for extending the route to Wood Green (as occurred with past tram routes). TheNLSA will make contact with its partners to discuss such projects.Culture, LeisureWe welcome the section on culture and leisure, as we recognise that North London’stown centres are currently underprovided for in this respect. In addition we recognisethe potential of creative industries as economic drivers and will be working with the 4Greens Group, LDA and others to promote creative clusters in the sub-region.12

North London has an extremely low proportion of hotel bed numbers compared with therest of London. The forthcoming Olympics, the increase in the amount of budget airtravel and North London’s proximity to central London all suggest that there should be astrong market-led imperative to increase the hotel capacity, primarily in the budget hotelrange. Hotel development at Walthamstow Town Centre, and potentially Leyton orLeytonstone in relation to the Olympics needs, for example, to be considered.The role of North Finchley as a cultural and leisure centre needs to be reflected.Social InfrastructureThe SRDF places great emphasis on the need for integrated planning for developmentand supporting infrastructure - healthcare, education and community facilities. There isa lack of information for predicting need in a range of social infrastructure. We aredeeply concerned that in the drive to produce more homes there may not remainsufficient land to cater for the necessary increase in health, education and othercommunity facilities.The SRDF states that “the anticipated increase in demand for health care will largely beabsorbed by existing services” (paragraph 65). We do not accept that a predicted 15%increase in population will have such a modest impact. In addition considering thespecific issues north London has (such as pockets of deprivation, high levels ofpopulation transience and diversity), providing adequate social infrastructure will becritical for sustainable communities. The Mayor has indicated that addressing healthinequalities and creating sustainable, healthy, communities is a key objective, however,the SRDF gives little indication what role it plays in this.The NHS will be making their own submission to the SRDF. We would however raise aspecific point they raise about funding. The NHS funding regime is complex, but isessentially linked to population size, weighted for age, deprivation, ethnicity and othersimilar factors. The funding each NHS Primary Care Trust receives for its localpopulation will increase over time if the population increases; however, there is asignificant time lag of years between population increase and an increase in capitationfunding. This means that, for example, if a number of small housing developments areagreed in a borough over a number of years (as is predicted across the sub-region),there is no direct link to the additional need for health services and health facilities. TheSRDF does not recognise this issue, particularly the effect of relatively small, cumulativegrowth in population, where section 106 agreements may be modest.Specific mention should be made about ensuring appropriate mechanisms are in placeto ensure the local NHS can meet the increased need, particularly for primary andcommunity care services.The same issues face education, where population and skills projections have not beenfully discussed with LEA, FE and HE providers.13

The GLA must use its influence to ensure that central Government and its agencies areplaced to respond to London’s growth agenda.Skills developmentNorth London has 14% of London’s population but only 8% London’s jobs – and the gapis set to widen as population is projected to grow 3 times faster than its economy.However there is significant sub-regional variation, with Barnet showing strong growthand Waltham Forest projected to lose jobs. Sustainable development requires localjobs as well as access to employment elsewhere.The majority of the population is highly skilled but there are significant concentrations ofworklessness, particularly in the Upper Lee Valley and eastern Haringey and, to alesser extent, the Edgware corridor. Currently the sub-region has nearly 75,000 nonemployedpeople who want to work an average of 11% of the working age population.We can benefit from growth provided the right support is offered to ensure our residentshave the skills, aspirations and hope to succeed in the London labour market.NLSA includes the following comment from the North London Learning & Skills Councilon paragraphs 74-75 under Social infrastructure (Section 1E).The SRDF quite rightly identifies ‘skills development’ as a key issue. Skills levels inNorth London are somewhat polarised, almost a third of the population has achievedlevel 4 or above while over a quarter of the population have no or very low level skills.This illustrates the need to focus on basic skills that open up the employment market tothis group of the population. This is borne out by the higher than averageunemployment rate. However, this must be tempered with the findings of employers inthe sub-region who do not report a high level of vacancies and few ‘skills relatedvacancies’. The implication is that wider circumstances around transport, sectoraldecline, economic development and infrastructure lie at the heart of the unemploymentin the sub-region.Participation rates in further education are high, currently around 82%, which issignificantly above both the London and national participation rates. This would suggestthat improving participation rates would be best served by looking at alternativepathways rather than expanding the existing offering. A far more pressing issue is theimprovement of the current FE accommodation rather than new provision.Paragraph 78 is factually inaccurate. It should be deleted and replaced with:-78 A new 16-19 school is being established in east Haringey. It will be the sixth formfor four schools and is being jointly funded by the LSC and Local Authoritythrough ‘Building Schools for the Future’. The school will open in September2007.The final SRDF should make a clear link between the need to target skills developmenttowards sectors of employment growth and where employment opportunities are14

located.Design and the public realmA key issue for North London is the quality of its public realm, specifically in its towncentres and by rail, tube and bus stations. A key action would be for the sub-region,working in partnership with TfL, to develop a programme of investment to enhance theenvironment around these transport interchanges. Such enhancements could be acatalyst for private sector investment and the development and intensificationhighlighted in the SRDF.North London, like other London sub-regions, is developing an urban design networkand series of Cabinet level design champions. The SRDF should recognise this and setout how GLA family design champions will work with borough level champions at a subregionallevel. If supported this could be a powerful way of driving up standards.Green spaceParagraph 179 highlights that although the sub region has within it the Lee ValleyRegional Park, many of those living in the sub region fall within the indicative deficiencyarea mainly concentrated along the Upper Lee Valley. Enhancing the links betweenthose living along the Upper Lee Valley and the regional park should be seen as astrategic priority.Opportunity AreasWe believe that the boundaries of the Opportunity Areas should include an area ofinfluence, addressing the deprived neighbourhoods that lie beyond the coreemployment areas. Development Frameworks will provide the detail, which may alsoinvolve changes to boundaries over a period of implementation.North London may be able to provide further Opportunity Area and Areas forIntensification, given the two spatial corridors leading to Luton and Stansted airport andthe outcome of the Town centre Enhancement (TEN) Study.Upper Lee ValleyThe NLSA welcomes the GLA’s intention to produce a framework covering the whole ofthe Opportunity Area and we have held an initial meeting with the GLA to discuss thiswork. We believe that it is important that we take this work forward in partnership. TheNLSA is tasked with and funded by the LDA to develop an Upper Lee Valley WorkingGroup, to ensure closer working between the three boroughs and other relevantagencies. We see the production of the development framework as a significantagenda item for the working group. We hope that this group can play a significant rolein helping to deliver the framework and ensuring that it has ownership within theboroughs and its principles are reflected in their LDF’s and other actions.15

Closer workingA key element for the SRDF process is to develop a shared vision between the Mayor,sub-regional partnerships, Boroughs and others partners, to present to Government thecase for transport and social infrastructure investment. The SRDF, specifically sectionone, has been partially successful in achieving this. As North London represents amajor area of growth and change for London we believe that senior representation isrequired to ensure that we can develop a stronger compact with which to lobbyGovernment for the resources to deliver our joint objectives.Action PointsThe draft SRDF contains too many actions. At the same time it is hard to draw out fromthem tangible outputs from these actions. Many of them reiterate London Plan policiesthat the boroughs when drawing up their LDFs must conform generally with andtherefore do not need restating. Clearly other actions are only for the consultationprocess and will be lost. It would be better to focus on the overall purpose of the SRDF.We would welcome a rigorous re-examination of the actions so that only those dealingwith clear strategic matters and / or those of sub-regional significance are retained.There needs to be ownership and a clear lead for these actions. The NLSA would behappy to discuss our role in the delivery of the final actions.MonitoringThought needs to be given to how the actions and the outcomes of the SRDF will bemonitored and how this relates to the forthcoming London Plan Review process.Unless there is a commitment to undertake some form of monitoring the actions mayremain as mere aspirations. Sub-regional performance measurements, sources ofinformation and indicators need to be clarified if the activity is to be meaningful.However consideration needs to be given to producing yet more demands on alreadystretched borough planning departments.The only reference to monitoring is in the last bullet point of the Core Actions in PartOne; it is not covered in the Part Two Actions. In the current situation, the final SRDFshould clarify how definition of sub-regional monitoring indicators should proceed. Anydiscussion on this point should be in tandem with the other London sub-regions whohave made similar points.Matters for the Review of the London PlanIt has become clear in preparing this response that the most critical issues we raisecannot be resolved through the SRDF, given its non-statutory, non-policy-makingnature. They will need to be carried forward to next year’s London Plan Review, notingthat it will have an extended horizon beyond 2016, to 2025.Key among these issues are:-16

• The worsening employment/workforce balance in North London (and much ofouter London generally), requiring much stronger measures to realise localpotentials and provide links, including adequate public transport, to jobs outsidethis area.• The outcome of the East of England Plan Examination-in-Public as regardsdevelopment and transport relationships across the regional boundary, includingthe London-Stansted-Cambridge Growth Area and the Stansted Airport situation,and the position of Cricklewood-Brent Cross in the M1/A1 corridor to Luton andbeyond.• Integrated policy for town centres to realise their potentials (includingemployment and role in promoting sustainable development), as envisaged inpresent London Plan policy 2A.5.• A close relationship between public transport and highway capacities, and thescale and locations of future housing (noting the increasing targets) andemployment growth (cf. comments above on the proposed integrated transportnetwork plan).• Ditto between growth and provision of health, education and other socialinfrastructure, together with their employment/labour market implications.In other respects NLSA accepts that the matters referred to in Annex 5 should beconsidered in the Review.Finalisation of the SRDFThe NLSA requests that the open way in which the Mayor has prepared the draft SRDFwill continue in producing the final version. We are keen that collaboration shouldcontinue in taking account of the responses made, and are particularly willing to discusstextual changes which would address the concerns we have raised in this sub-regionalresponse. This could include reducing the number of Actions, notably those addressedto Boroughs, and focusing on those, which are of sub-regional importance.17