planning+-+news+-+LDFcore7.09


 * Haringey’s Local Development Framework **
 * Core Strategy: Issues and Options **
 * - HFRA response **


 * __A. INTRODUCTION: PLANNING POLICIES AND SUSTAINABLE COMMUNITIES__**


 * i.** Everyone now recognises that we must have environmentally and socially sustainable communities throughout Haringey, and indeed London.

We are facing extreme pressures from private and corporate developers and town planners leading to a range of concerns & problems, and pressure on an already inadequate social infrastructure (schools, health facilities, parks, public transport, community centres and other facilities etc). Some policies supposedly meant to protect the interests of communities are being systematically flouted by developers, supported or ignored by Haringey Council.

Faced with constant pressures for inappropriate or damaging development, residents want to ensure that all residents and future generations will live in strong and sustainable communities.


 * ii.** Throughout Haringey there are an ever-growing number of residents’ objections, controversies and campaigns over proposed local developments. Residents groups and associations are forming more and more alliances to resist what’s wrong with major developments, eg Haringey Heartlands (Wood Green), Wards Corner (Seven Sisters), Tottenham Hale, Crouch End Open Spaces, and Lawrence Road (Central Tottenham) as well as smaller but equally important sites in our local neighbourhoods.

Hence we need to look at the reality of how current (eg HUDP) policies are actually working on the ground. Haringey Council may express valid concerns on various planning issues, but their Annual Monitoring Report 2005-6 (for example) stated that £3,900,805.05 was received by them from developers in S106 payments. This is a powerful incentive to a cash-strapped Council, however principled it may be, to favour development over the concerns and needs of local communities.


 * iii.** Residents’ concerns include the following problems:
 * loss of **heritage and conservation** features ***** unwanted **over-development**
 * **over-intense housing development** //- maximum densities were __tripled__ from 1998 2006//
 * vast majority of **housing development is unaffordable** to local people in need //in 2005/6 a scandalously low 11% of 624 homes completed in Haringey were social housing, despite housing problems being used as ‘justification’ for otherwise unacceptable policies//
 * poor quality of interior and exterior **housing design*** loss of valued **‘backlands’** sites***** loss of undesignated but important **open space*** failure to address open space **deficiencies*** lack of children’s **play facilities*** poor project **design*** loss of **community facilities** //eg. healthcare sites, local shops, meeting places & community pubs//***** loss of **publicly-owned land*** loss of **affordable offices and sites** for voluntary groups and small businesses
 * stress and competition over **availability of land** generally in the borough***** loss of **front gardens** //- concerns include the quality of street scene, pedestrian safety, flooding etc//*** environmentally unsustainable development** //- eg energy use, materials, design, car use etc//
 * increasing **pollution** //- visual, air and noise//***** illegal advertising **hoardings and billboards** ***** **street clutter*** **increasing traffic**, undermining the need for safer, greener, ‘living’ streets
 * **lack of resources** for maintenance and improvement of public facilities, buildings & services


 * iv.** It has been our experience that the Haringey UDP, despite many good sentiments, is not effective in protecting the interests of local communities. The reasons include:

- **The policies** themselves - **The interpretation of the policies** - **Failure to commit to, and enforce, key policies** **which are supposed to protect community interests** (eg social infrastructure, housing density limits, heritage, social housing targets etc) when contrasted with other policies (eg house-building and large scale development) - **Lack of enforcement of conditions and agreements** - **The lack of a level playing field** between local residents & well-resourced developers - **The reliance on S106 payments**, instead of __actual__ planning gains - **Objectors denied their right to appeal**, unlike developers - **The need to listen to, genuinely consult, and empower communities** instead of allowing increasing influence and power to developers and local authority planners. This includes the need to support the community and defend appeals effectively.


 * __B. SOME DETAILED COMMENTS__**

We set out below some responses to various paras, questions and sections in the draft Core Strategy Issues and Options document. We thank Avenue Gardens Residents Association, Hornsey Conservation Area Advisory Committee and Tottenham & Wood Green Friends of the Earth for their comments, which have helped us formulate some of our own responses.


 * __Section 4: Description of the borough__**


 * Paras 4.1 and 4.10** The official census figure for Haringey is well-known to be greatly underestimated by at least 5-10%. The Council has itself raised with the ONS queries as to the accuracy of this figure (most notably the letter from George Meehan to the ONS, dated 23 April 2003).This should be stated.


 * Para 4.4** It is not the case that Borough displays some areas of suburban characteristics, while the majority is urban. Precisely the opposite is the case. The Borough is majority suburban areas with some areas of urban higher density. This is made clear in the definitions provided by The London Plan in para 4.47 (page 177):

“4.47 Appropriate density ranges are related to location, setting in terms of existing building form and massing, and the index of public transport accessibility (PTAL). Site setting can be defined as: • //Central// very dense development, large building footprints and buildings of four to six storeys and above, such as larger town centres all over London and much of central London. • //Urban// dense development, with a mix of different uses and buildings of three to four storeys, such as town centres, along main arterial routes and substantial parts of inner London • //Suburban// lower density development, predominantly residential, of two to three storeys, as in some parts of inner London and much of outer London.”

It is absolutely clear and indisputable that by far the majority of the Borough best fits the ‘Suburban’ definition of The London Plan.


 * Para 4.10** Suggest an additional para: ‘**//Haringey has a mosaic of hundreds of community groups and networks of all kinds. This contributes to community spirit and cohesion, mutual aid, engagement, empowerment, representation, advocacy and the drive for improvements to services, facilities and the environment.’//**


 * Para 4.22** Add at end… **//‘and many Conservation Areas and listed buildings’.//**


 * __Section 5: Future challenges__**


 * Para 5.3** Add after ‘High Quality design’ … **//‘Strong communities’//**


 * Para 5.12** Noise and air pollution is a major concern. It is vital for the long term sustainable development of our communities and transport that it is recognised that cars, heavy goods vehicles, and buses must be managed appropriately in all residential areas.

· Cross borough maximum building heights at a human scale · Good practice guidelines and requirements for new development adjacent to existing development and adjacent to streetscape · A strategy to improve all public thoroughfares, treating them as ‘living streets’ · Support for the good use and maintenance of all green spaces including private gardens which contribute to the street scene · The reduction of urban clutter including removal of many traffic signs · The removal of all unnecessary advertising · The reconsideration of illuminated advertising · A strategy for enhancing all publicly owned buildings and land, for example schools, housing, police stations and so on.
 * Para 5.13** Some discussion is needed as to what High Quality Design actually is. HQD should be a concept related to the creation of pleasing, human space for people to enjoy in the carrying on of their ordinary lives, including an emphasis on the street scene. There is nothing in this document on HQD about which discussion can begin. To be included in this discussion:


 * Add new para after 5.13:**


 * //‘Strong communities’//**

Add a supporting para on the theme //‘People at the heart of change’// - [taken from the __Haringey Sustainable Community Strategy__ pp2-5]: **//‘ People will be at the heart of change. We will empower people, ensuring that young people and children are included, so they can participate in what is important to them. We want to see a dynamic and engaged voluntary and community sector to strengthen cohesion, inclusion and to help bring about improvements. Communities will see clear benefits from development and change, with people from all communities sharing and enjoying well managed, high quality, improved and accessible services and amenities, open spaces, schools and a plurality and diversity of first class leisure and cultural opportunities that everyone can share and use.’ //**


 * Para 5.14** Add: ‘regardless of their age, disability, gender, sexual orientation, race, **//class,// //economic status,//** culture or religion.’


 * __Section 8:__** __**Visual and spatial objectives**__


 * Para 8.5** Amend title to: ‘Managing development **//with people at the heart of change//**//.’//

Add extra bullet point: **//‘To support and strengthen the distinctive character and cohesiveness of local communities, and their accessibility to the local services and amenities that serve their diverse needs.’//**


 * Para 8.7** Add to 4th bullet point: ‘To meet the **//appropriate//** needs of different, **//sustainable//** sectors of the economy…’

Add to 5th bullet point: ‘To support the development of Haringey’s most successful **//and sustainable//** sectors.’


 * Para 8.8 Add to third bullet point… ‘**To improve the **//provision of and//** access to local services and facilities for all groups.’


 * Q1** They need amending as proposed.


 * Q2** Important objectives to include are:

· To provide more green public open spaces in order to meet the London Plan guidelines on distance to areas of green space

· To resist development pressure on the Borough’s green spaces

· To improve the quality of affordable housing provision, particularly family affordable housing, by ensuring that new developments are not too small, overcrowded or over dense.


 * __Section 9: Haringey’s places__**

Alexandra Palace is not mentioned in the UDP 2006 policies on Areas of Change and should not be listed in this Core Strategy under Areas of Change. The bullet should be struck out.
 * Para 9.3** The bullet in this Core Strategy calling for the ‘Transforming of Alexandra Palace into the leisure and entertainment centre for North London’ is not consistent with the UDP 2006, which provides the strongest safeguards in Policy OS4 to preserve and enhance the special architectural and historic interest and setting of the Palace and the historic form and layout of the park land. The UDP requires (para 9.13) that any future uses of Alexandra Palace and Park must fully respect the listing of the Palace and the MOL and Conservation Area status of the Palace and Park as well as the Park’s Historic Parks and Gardens status.


 * Q GEN 3** Need an additional objective for all three areas: **//‘Support and strengthen the distinctive character and cohesiveness of local communities, and their accessibility to the local services and amenities that serve their diverse needs.’//**


 * __Section 10: Issues and options__**


 * Para 10.3** Item 2 Amend to: ‘Managing development **//with people at the heart of change//**//.’//

Add extra bullet point ‘e’: **//‘Strengthening local communities in every area and the local services and facilities they need’//**

Item 4 Amend title to: ‘Creating a vibrant, prosperous **//and sustainable//** economy’.


 * __Section 11: Environmentally sustainable future__**


 * Q ENV 4** All areas and sectors of society must adopt whatever targets are scientifically recommended in order to be effective. Anything else is irresponsible.


 * __Q ENV 5 24__**

The policies opposing and mitigating climate change, and for achieving environmental sustainability must be backed up by effective encouragement and enforcement on all developments including current buildings (wherever possible) so they are not seen as just window dressing. This should include all residential, public, commercial and industrial sites. On these and other similar subjects we will be guided by the responses from Friends of the Earth and Sustainable Haringey.

However, we add the following comments:


 * - Generally** Regarding workplaces, there needs to be a clear strategy and effective policies for increasing sustainable and necessary local goods and services geared to the needs of local residents and people in London generally including the local production of food and a wide range of useful goods, renewable energy generation, ‘green’ enterprises of all kinds etc. This should include policies ensuring the transition of outmoded and unsustainable business units to useful, sustainable production. In this way we will also be supporting the development of relevant and sustainable skills.


 * - Q ENV 14** Yes, although all front gardens can be made of porous construction even when paved. This also applies to roads and pavements. Where front gardens form an integral element of the urban structure (e.g. in the extensive traditional terraced housing areas of the borough) front gardens should be protected against encroachment by motor vehicles regardless of whether the ground surface is permeable or not, in order to protect the historic and functional integrity of the urban structure, and the attractiveness of the street scene.


 * - Q ENV 18** We can reduce noise pollution by, for example: ensuring all homes have effective noise insulation; reducing and slowing traffic (ensuring all residential streets have a ‘default’ 20mph limit); replacing internal combustion engines with electric or hybrid ones; replacing road surfaces with acoustic surfaces especially on higher speed routes; preventing any growth in aviation and starting to reduce it; reducing reliance on conventional air conditioning.


 * - Para 11.32** Amend first bullet point to read: ‘improve road safety through 20mph zones and local safety schemes, **//eventually introducing a ‘default’ 20mph limit for all residential streets’//**


 * - Q ENV 21** It should be remembered that ‘transport interchanges’ are usually centres of community life (eg Seven Sisters, Wood Green, Turnpike Lane, Muswell Hill etc). Hence any development in such areas should improve the conviviality of the area and be consistent with the needs of the surrounding communities.


 * - Q ENV 22** Regarding ‘car-free’ housing developments, this should not be allowed to be an excuse for higher density over-development. It must be a condition that any area of the development that would have previously been ‘parking space’ be instead devoted to play space, green space and community facilities etc. The needs of disabled and specialist drivers (who need vehicles for work etc) need to be considered.


 * __Section 12: Managing development [Housing]__**

Although this section is entitled ‘Managing development and areas of change’ it is almost all about housing.

Regarding housing, the overall question might be summed up as:
 * Are current planning policies failing to produce the type of housing that’s most needed, and also exacerbating other long-term problems?**

We note some of the key housing issues quoted in the Council’s recent Scoping Report for a Housing Supplementary Planning Document. For example (with key phrases highlighted for effect):

· //‘The review highlighted that there is a need… for an improvement to housing services focusing on the __needs of all residents__, to maximise the amount of __affordable housing__ from all available sources and to __protect existing housing under the pressure of redevelopment’.__//

· N. London Housing Strategy Key Targets and indicators: //- ‘Increasing the supply of __permanent__ affordable housing’// //- ‘Meeting the needs of homeless households’// //- ‘Contributing to the __development of balanced and sustainable communities’__//

· Housing Strategy Statement 2003-8 Key Targets and indicators: //- ‘Regenerate our neighbourhoods, achieving __decent homes for all__ and __improve the environment’__// //- ‘The __high cost of market housing’__// is also noted as a //‘main issue’//

· 2007 Housing Needs Assessment //- ‘that the __costs to occupants of affordable housing meets the needs of residents__, in particular the households with support needs, older person households, key workers, BME households and over-crowded households’//

· Baseline data: //- ‘The requirement for affordable housing is __most acute for 3 or 4 bedroom properties’__// //- ‘The Housing Needs Study suggests that around __14.7% of the net affordable housing requirement comes from key worker households’.__// [HFRA Comment: presumably this is recognition that the vast majority of the affordable housing should be social housing for those on housing waiting lists]. //- ‘There has been an annual average of 257 new affordable housing completions between 2002-03 and 2004-05.’// //- ‘A key aim for housing accommodation is to provide __permanent affordable housing for those households in temporary housing’__.//

Some of the Questions in the LDF Core Strategy address important points (see our responses to them later), but many of the key issues are ignored or mis-framed.

__Housing: Additional Key Questions to be added to the Core Strategy__

Our question at the start of this section: **‘Are current planning policies failing to produce the type of housing that’s most needed, and also exacerbating other long-term problems?’** is broken down into a number of Qs below.

As we had stated in our [Feb 2008] response to the Scoping Report for a Housing Supplementary Planning Document, we feel that the key housing planning issues are not being addressed. We therefore propose the following issues and questions are added to the Core Strategy Housing Pages [Section 12]:


 * Additional Question 1.** **Over-high housing densities do they undermine the need to ensure sustainable communities?** The scale, character and density of housing development is probably the most radically new, untested, risky and controversial of all the HUDP planning policies and in urgent need of appraisal and amendment. The Inspector who’d conducted the 2005 Public Inquiry into the Haringey UDP policies expressed concern over the //‘extremely high’// housing densities proposed for the borough //‘which are not explained or justified in a satisfactory way’// despite being up to 1,100 habitable rooms per hectare, //‘at least 2 or 3 times the maximum density proposed in the former 1998 UDP…. The prospect of the serious problems of poorly designed and managed tower rise blocks being repeated is ominous.’//

Current social and environmental infrastructure is inadequate to deal with the needs of current population levels, let alone greater and denser population levels. And do we really want to see a return to the failed tower blocks and estates of the past?

[See Apx 1 to the HFRA Response to the Housing SPD Scoping Report for a detailed development of this point]


 * Additional Question 2.** **‘Affordable’ and social housing: why is development failing to reach even the very modest percentage targets from new housing completions?** Despite targets of 50% ‘affordable’ and 35% social housing of housing completions each year, the Council's own official figures for the latest three recorded years show that only 34%, 32% and 30% of homes built were ‘affordable’, and only 22%, 11% and 22.5% of homes built were social housing.

In any case, isn’t most so-called ‘affordable’ housing well out of the reach of the vast majority of those who need it? It is currently defined in the HUDP as housing //'affordable by households on incomes of less than £49,000 (as at Sept 2005).//' Shouldn’t it be redefined to ensure it is genuinely for those who need it most? Isn’t social housing the only genuinely affordable, permanent housing? The low percentages of social housing in new build mean that those in need are being excluded from the overwhelming majority of homes being built, when the homes should be being built for them. These issues, along with finding ways to prevent the controversial ‘buy-to-let’ domination of new ‘market’ housing, are in urgent need of appraisal and amendment.

[See Apx 2 to the HFRA Response to the Housing SPD Scoping Report for a detailed development of this point]


 * Additional Question 3.** **Are the current HUDP policies (especially re housing) capable of ensuring sustainable communities?** The Council’s own officially stated views to the Mayor of London are highly critical of the home-building targets and densities, and the lack of adequate social infrastructure for the current population, let alone the increased population predictions. The Council, for example in its formal response (19.10.2005) to the Mayor of London over his draft North London Sub-Regional Development Framework, stated:

//'The Council considers that the London Plan has prioritised housing provision without sufficient attention given to the need for necessary community, health and education infrastructure. For example, Haringey will experience particularly high growth in school numbers up to 2021, which will place considerable pressures on its existing schools. The Council is concerned that there may not be sufficient land to cater for a necessary increase in the number of health care services in the borough and such services will have to compete with other land uses, such as housing and employment uses.'//

[See Apx 3 to the HFRA Response to the Housing SPD Scoping Report for a detailed development of this point]


 * Additional Question 4.** **What can be done about over-development and failure to ensure adequate social and environmental infrastructure?** What can be concluded from the contrast between the drive for new residential building (even though the vast majority of it is of the wrong type) and the failure to adequately recognise let alone reduce open space deficiency? What does this say about LBH commitment to policies which protect community interests? Although we welcome the recent draft Open Spaces & Recreational Standards SPD as a step forward, we are concerned that some vital standards have been watered down. And there seems to be no planning standards or targets for all the other key community amenities each neighbourhood needs local meeting places, pubs, corner shops, playcentres and schools, health facilities, libraries etc. Indeed, many such facilities are under threat from current development or are under threat of being ‘centralised’ away from local communities.

[See Apx 4 to the HFRA Response to the Housing SPD Scoping Report for a detailed development of this point, and the Haringey Friends of Parks/HFRA Joint Response to the recent Open Space & Recreational Standards SPD consultation]


 * Additional Question 5.** **Do S106 agreements lead to actual planning gains, and if not what can be done about it?** In Haringey where there is stress and competition over land usage, community facilities and amenities of all kinds essential to sustainable communities are not only failing to be extended to address existing deficiencies, let alone the ever greater population pressures, but in fact they are under threat and being eroded on a daily basis in local neighbourhoods and town centres alike.

There is clearly an inherent flaw in the policies: ie that policies promoting highly intensive residential development in Haringey are at odds with policies promoting sustainable communities, and that no amount of S106 contributions can mitigate the real effects on the ground.

However, S106 policies could and should be strengthened and strongly enforced to ensure that developers are compelled to provide the maximum amount of open space, children’s play areas, community facilities and amenities etc.

[See Apx 5 to the HFRA Response to the Housing SPD Scoping Report for a detailed development of this point]


 * Additional Question 6.** **What can be done about the failure to ensure that a majority of new build housing consists of family-sized housing, especially family-sized genuinely affordable and social housing?** As the Housing SPD Scoping Report recognised at para 1.5.1. //‘The requirement for affordable housing is most acute for 3 or 4 bedroom properties’.// In Haringey: //'The recommended mix for affordable housing developments is: 26% 3-bed, and 32% 4-bed.'// Yet the 2006/7 UDP Annual Monitoring Report states: //'Of the total housing completions in 2006/7 94% were one and two bed units. Of the affordable housing completed in 2006-7 only 11% were 3 or 4 bedrooms.'//


 * Additional Question 7.** **How do we ensure that all new housing, including all ‘affordable’ and social housing, is designed to conform to accepted, good quality standards?** This relates to the interior and exterior of every home. It should apply to all aspects of the design (eg space, materials, energy usage and energy generation, greenery etc). It also includes every development’s impact on and contribution to the street scene (eg ensuring green, set-back, convivial, active frontages rather than buildings slap bang next to the highway).


 * Additional Question 8.** **How do we ensure that every residential development contributes effectively to improving public open spaces and recreational facilities of all kinds?** This issue has been debated during the recent consultation over the Open Spaces and Recreational Standards SPD. Please see the joint response from the Haringey Friends of Parks Forum / Haringey Federation of Residents Associations.


 * Additional Question 9.** **How can we ensure that, in a borough with serious land stress and competition, that all available land is earmarked for community needs rather than for what developers can grab in order to make the most profit out of?** What kind of policies do we need to put in place in order to ensure effective protection for existing amenity land (eg land currently used for health services, education, and community facilities and services of all kinds) from being whittled away and sold off for housing by cash-strapped bodies like the Council and Primary Care Trust?


 * Additional Question 10.** **What can be done to respond to ever-increasing house prices, rents and insecurity?**

__Housing: Responses to some of the Questions posed in the Core Strategy__


 * Q HSG 25** This is a confusing / misleading question. It does not deal with the type of ‘growth’, the scale of such ‘growth’ and whether such ‘growth’ is acceptable at __any__ location. It does not deal with any design or social infrastructural issues. All development should be appropriate to the area it takes place in and should enhance and fulfill the needs of local communities and Haringey residents generally.


 * Q HSG 26** This question is inadequate. A lot of people reading it will fail to realise (or be shocked if they do) that ‘backland sites or rear gardens’ could be designated as ‘brownfield’ sites. Any development should be on vacant, derelict or unwanted but already built-on sites - all green or open spaces should be preserved. Yes, new development should be restricted to brownfield sites, but some brownfield sites are also areas of high biodiversity, and within the open spaces strategy and through S106 contributions we should be seeking to bring them into public ownership for nature conservation and, if appropriate, public access.

In addition, backland sites and rear gardens should NOT be considered suitable for new housing unless the housing can be inserted in accordance with the recommendations of //Sustainable Residential Quality: new approaches to urban living,// DETR (2000) cited in your Appendix A. Under “Appropriate plot depth and configuration” (para 6.3.9, P43), Sustainable Residential Quality explains that: //"A fundamental requirement for successful backland development is for the backland plot to be of sufficient depth to accommodate new housing in a way which provides a quality residential environment for the new and existing residents. Our design exercises suggest that the minimum plot depth for backland development is 80 metres between the facing rear elevations of: existing properties. This is sufficient to accommodate a new residential street with houses or flats on each side and provide both the new and existing properties with a rear garden of 10 metres."//

New housing should not be considered on “vacant or derelict” sites deliberately made vacant or derelict by owners in pursuit of a change of use where the existing (or former) use remains economically, socially or environmentally viable.


 * Q HSG 27** This is a confusing / misleading question. See HFRA comments about density and related considerations above (eg in the HFRA Additional Qs 1,3,4 and 7). The problem is too high densities and over-development.


 * Q HSG 28** There should be no tower blocks or tall buildings, especially any residential ones, at any locations.


 * Q HSG 29** Agree with effective policies resisting too high a proportion of conversions into flats and HMOs.


 * Q HSG 30** Agree that strong policies are needed to ensure all empty homes are brought back into use for those who need them. We should use all means available to bring empty homes into use, including Empty Dwelling Management Orders, Compulsory Purchase, and grants.

b. Sometimes - eg should pool contributions from developers in order to acquire land for new open space in areas of open space deficiency. But not if this lets developers off the hook in providing __actual__ planning gains within and by their development.
 * Q HSG 31** a. No. The social and amenity infrastructure should be in place before the housing is agreed. Also, S106 often fails in practice to ensure the additional planning gains needed, rather than just being absorbed into LBH services general running costs - see HFRA Additonal Q5 above.


 * Q HSG 32** Yes


 * Q HSG 33** a. Yes. Mixed use may be encouraged where it can contribute to social, economic or environmental sustainability and is not detrimental to residential amenity. b. Yes, depending on suitability.


 * Q HSG 34** Yes.


 * Q HSG 35** a. No. b. No.


 * Q HSG 36** Yes.


 * Q HSG 37** b. No.


 * Q HSG 38** a. See our response HFRA Additional Q2. Social housing is the only housing which is genuinely and securely ‘affordable’. b. Social housing is a minority of housing in the borough. There is a desperate need for more of it in all areas. No housing development should be allowed to avoid this fact.


 * Q HSG 39** Yes


 * Q HSG 40** a. Most housing developments (wherever practicable) should ensure they are designed to be suitable for family housing. Developments which are unsuitable for families (like tower blocks) should generally not be allowed. After all, ‘single people’ or couples can be part of or become families. Obviously there are exceptions (like sheltered accommodation for the elderly).


 * Q HSG 41** No comment


 * Q HSG 42** a. Yes b. Yes


 * __Section 13: Creating a safer, attractive and valued urban environment__**


 * Q QUAL 43** a. Yes b. No. A design cannot be considered acceptable simply because it is considered that it “does not harm the appearance of an area.” Good design must effectively address a number of functional, social, spatial and environmental criteria besides “appearance”.


 * Q QUAL 44** a. No comment. b. Yes. Good design should be sought everywhere. Good design should not be considered as an add-on, option or trade-off. The borough should not be segregated into areas where good design is required and other areas in which good design is not required.


 * Q QUAL 45** a. Yes b. Generally no.


 * Q QUAL 46** The local distinctiveness of all areas of the borough should be protected. Where the “local distinctiveness of certain parts of the borough” lying outside conservation areas is of positive value to the people and communities of the borough this should be protected by using planning briefs, guidelines and development control to protect the positive aspects of that “distinctiveness”. Clutter, unnecessary signs, pavement advertisements, hoardings should be removed.


 * Q QUAL 47** Yes

• expansion and enhancement of the pedestrian realm and further constraints on the volume and speed of motor vehicle traffic not providing public transport • more and better planting, and improved maintenance • avoiding unnecessary clutter of street furniture, signage, lighting, etc • a 20-mph speed limit throughout all residential areas of the borough which would allow dispensing with much signage and some of the calming measures • where vehicle and pedestrian paths cross (e.g., corners) make “raised” crossings to give continuity to pedestrians rather than to vehicles • further restrictions on commercial billboards and signage, and ensure effective enforcement action • further restrict the amount, size and duration of “for sale” signs as an excuse to illegally advertise estate agency businesses, and ensure effective enforcement action is taken
 * Q QUAL 48** Works to “improve the visual attractiveness and use of public spaces” include:


 * Q QUAL 49** The Streetscape Manual should become a recognised planning document. All developments must actively contribute to enhancing the street scene, with set back, green, attractive and active areas (including benches and playable spaces etc) adjacent to any public space/street/route. Local residents and residents associations must be fully involved with the development of strategies to improve their neighbourhoods and public spaces.


 * Q QUAL 50** All green open spaces (including those with restricted access like allotments, school playing fields and nature reserves) should be fully protected, and more should be created to address the levels of deficiency (as defined in the London Plan).


 * Q QUAL 51** a. This question is wrongly cast as an ‘either-or’. The Council, in consultation with local groups and residents, should identify potential sites for new open space, and then seek through planning contributions to purchase it and/or re-landscape and manage it for biodiversity, allotments and/or amenity purposes. The Council should also improve quality and access of existing open spaces. b. All open spaces must be brought up to Green Flag standards.


 * Q QUAL 52** a. Yes b. eg New developments should be expected to have green space, green or brown roofs for wildlife, and could also have bat and bird nesting sites such as swift bricks, green walls etc.


 * __Section 14: Creating a vibrant, prosperous local economy__**

Note: Amend title to: __Creating a vibrant, propsperous **AND SUSTAINABLE** local economy__


 * Q ECON 53** Yes


 * Q ECON 54** Yes


 * Q ECON 55** No comment


 * Q ECON 56** No comment


 * Q ECON 57** No comment


 * Q ECON 58** No comment


 * Q ECON 59** All Haringey’s town centres are part of their surrounding communities. Those communities must be respected.


 * Q ECON** **60** This question is unclear. What does ‘focus for development’ mean? What kind of ‘development’? Over-development of any kind is inappropriate. Any inappropriate development is unacceptable.


 * Q ECON** **61** Independent and small businesses need protection from corporate chains.


 * Q ECON** **62** Some efforts are needed to restrain the growth in the number of take-away outlets for reasons of litter and rubbish generation, noise, odours… and to ensure the managers of night-time premises are sensitive to the needs of local communities (regarding any noise and anti-social behaviour from customers).

All pubs and cafes etc should, as a condition of their license, allow their toilets to be publicly accessible during opening hours.


 * Q ECON** **63** Independent and small businesses need protection from corporate chains. Smaller, local shopping centres (and corner shops) need protection as vital parts of neighbourhoods if we are to protect and develop sustainable communities.


 * Q ECON** **64** Local shopping streets, parades and corner shops should be protected as they usually are the centres of local communities. They are more sustainable, reducing transport generation.


 * Q ECON** **65** Yes.


 * __Section 15: Improving health and community well-being__**


 * Q CWL** **66** Generally, yes.


 * Q CWL** **67** Generally, yes although not at the expense of other issues (eg greenery, playspace etc) or to justify private gated communities.

A very bad example was recently set by the Planning Committee refusing to insist on a condition sought by residents and LBH Recreation Services for windows to be set in a proposed sheer blank wall (at the side of homes) overlooking an entrance into a park. Such simple safety measures must become standard.


 * Q CWL** **68** Not sure what ‘measures’ this refers to. All public areas should be accessible, attractive and well-designed, including taking on board safety issues (but not at the expense of other issues).


 * Q CWL** **69** a. Seem OK. b. All are important.


 * Q CWL** **70** No comment


 * Re: Para 15.11** This para makes some comments that the //‘structure of healthcare and provision is changing from hospital-based to community-based healthcare.’// Such changes, many of which are meant to be being ‘consulted’ over, are highly controversial and believed to be a cover for health cuts and privatisation. Many of the proposals are strongly opposed throughout the UK. In fact, as the document recognises (in Paras 15.13 and 15.18) a key element of the proposed ‘changes’ is a move __away__ from ‘//community-based healthcare’// by neighbourhood-based GP surgeries into more distant and centralised ‘Super Health Centres’. This is a highly worrying proposal which runs counter to the policies and practices supporting sustainable communities, and should be strongly opposed by the Council and everyone who wants to see sustainable communities.

The Council in its formal response (19.10.2005) to the Mayor of London over his draft North London Sub-Regional Development Framework, stated:

//'The Council considers that the London Plan has prioritised housing provision without sufficient attention given to the need for necessary community, health and education infrastructure. For example, Haringey will experience particularly high growth in school numbers up to 2021, which will place considerable pressures on its existing schools. The Council is concerned that there may not be sufficient land to cater for a necessary increase in the number of health care services in the borough and such services will have to compete with other land uses, such as housing and employment uses.'//

To ensure that such community needs (and the general urgent need for improved social infrastructure) are catered for there should be a moratorium on any selling of publicly-owned land. There should also be no redesignation of land currently reserved for community uses into any designation for commercial or residential uses.


 * Q CWL** **71** Every part of the borough needs the improvements identified in para 15.8.


 * Q CWL** **72** a. Seem OK. b. No comment


 * Q CWL** **73** No comment


 * Q CWL** **74** a. Yes b. No comment


 * Re: Para 15.29.** Agree strongly with the UDP policy that //‘The loss of a community facility is only permitted where it is replaced or the use is no longer required and there is no demand for another community use at that location.’//


 * Re: Para 15.30** If the above policy (in Para 15.29) is applied, and there really is no possibility of any community facility (including open space etc) being needed at the location, then the community should be engaged to help decide the best possible alternative use for such a location.


 * Q CWL** **75** There are very many community facilities and amenities urgently needed throughout the borough including health and education facilities, green open spaces, urban open spaces, play areas, allotments, nature reserves, leisure amenities, pubs, community centres and meeting places, corner shops and local parades, affordable premises for all local voluntary and community organisations….


 * Q CWL** **76** Each of the above facilities and amenities should be provided in every neighbourhood where there is a lack.


 * Q CWL** **77** Developments should contribute to all key community services (including open spaces).


 * Q CWL** **78** eg The Core Strategy takes no account of the facilities and services provided by the wide range of voluntary and community organisations, the vital ‘third sector’. Their needs should be assessed and effectively incorporated into planning policies and the Core Strategy.

Light pollution needs to be addressed.

Recognition of the importance of (and need to protect) individual trees and tree masses, whether or not subject to Tree Preservation Orders, is missing and should be included.

//Ends//