housing+-+planning+policies

Haringey Federation of Residents Associations //7th February 2008// __Includes Appendices:__
 * HFRA RESPONSE TO SUSTAINABILITY APPRAISAL SCOPING REPORT FOR THE LBH HOUSING SUPPLEMENTARY PLANNING DOCUMENT **
 * - including 12 proposed additional Key Issues and Opportunities **

Apx 1. High housing densities – do they undermine the need to ensure sustainable communities? Apx 2. Haringey’s very low affordable and social housing as a % of new housing completions Apx 3. Are the current HUDP policies (especially re housing) capable of ensuring sustainable communities? Apx 4. Overdevelopment and failure to ensure adequate social and environmental infrastructure Apx 5. Do S106 agreements lead to actual planning gains? 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. Hence we need to look at the reality of how 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.
 * __ A. Introduction – planning policies and sustainable communities __**
 * A.1. ** It is impossible to separate housing and housing development from the need for sustainable communities. Everyone now recognises that we must have environmentally and socially sustainable communities throughout Haringey, and indeed London.
 * A.2. ** 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.
 * A.3. ** Residents’ concerns include the following problems:

* poor quality of interior and exterior **housing design** * loss of valued **‘backlands’** sites * loss of undesignated but important **open space** * ** increasing **pollution **//- visual, air and noise//** A.4. ** 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 - ** 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 ** __ B. Regarding the scoping report for appraising a new Housing SPD __ B. 1. ** It appears to us that the Scoping Report neglects to deal with a wide range of very important housing-linked concerns. Please see the 12 Proposals in section C.2. below. ** B.2. ** We note some of the key issues identified in the Report. For example (with key phrases highlighted for effect): Para 1.4. //‘The review highlighted that there is a need… for an improvement to housing services focusing on the __needs of all residents__, to maximize the amount of __affordable housing__ from all available sources and to __protect existing housing under the pressure of redevelopment’.__// Table 2-1-1. 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’ // ** B.3. ** We note some of the key baseline data. Para 1.5.1. // ‘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’__. // ** B.4. ** Para 1.5.2 then identifies the //‘Key Sustainability Issues and Opportunities’//, but only outlines 3 such issues: - which wards have //‘the largest shortfall of affordable accommodation’// - // ‘more affordable homes need to be built to high design standards’ // - // ‘there needs to be strong planning and design with regards to density, dwelling mix, appropriate space provision and in particular energy efficient concerns’ // ** __ C. HFRA objections and proposals __ C.1. ** The above 3 issues seem wholly inadequate as a summary of the Key Issues to identify, investigate and appraise. It is not clear how the list of ‘Sub-Objectives’ in table 2-1-2 will be applied to all housing-related development. In any case, there are additional Key Issues which are equally as important as the three identified in 1.5.2, and so need to be added. Many of them mirror the key concerns raised by residents as set out in sections A3 and A4 above: ** C.2. ** We propose the following are added as Key Issues & Opportunities: ** Proposal 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. 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 for a detailed development of this point] ** Proposal 2. ‘Affordable’ and social housing: the failure to reach even the very modest % 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 for a detailed development of these points] ** Proposal 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. [See Apx 3 for a detailed development of this point] ** Proposal 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 and GLA commitment to policies which protect community interests? [See Apx 4 for a detailed development of this point] ** Proposal 5. Do S106 agreements lead to actual planning gains? **In Haringey where there is stress and competition over land usage, community facilities and amenities of all kinds essential to sustainable communities (eg open spaces, childrens’ play areas, health, education, sports, leisure and meeting places, local shopping parades etc) 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. [See Apx 5 for a detailed development of this point] ** Proposal 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 Scoping Report recognises 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.'// ** Proposal 7. How do we halt the spread of Houses In Multiple Occupation? ** Homes are being divided into ever smaller units, causing not only loss of much-needed family accommodation but also unacceptable over-crowding. ** Proposal 8. 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). ** Proposal 9. How do we ensure that every residential development contributes effectively to improving public open spaces and recreational facilities of all kinds? ** This issue is largely being debated in current 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. ** Proposal 10. 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? ** Proposal 11. What can be done to respond to ever-increasing house prices, rents and insecurity? And could there be more effective action to prevent homes being left empty for unnecessarily long periods? Proposal 12. Bearing in mind the need for urgent and drastic cuts in carbon emissions to avoid dangerous climate change, what comprehensive policies and practices need to be imposed on all housing development eg regarding energy, materials, design, space, greenery and green space, recycling etc? ** Despite the pro-environmental sentiments in the HUDP only 4 Haringey development applications in 2005-6 had travel plans (3 of them schools), only I application had an energy statement, and there were only 3 applications for renewable energy sources. These shocking figures apply to all development, not just housing development – but they indicate that all new LDF policies and SPDs need to be very carefully appraised and strengthened regarding environmental sustainability if they are to be taken seriously on such matters.
 * loss of **heritage and conservation** features
 * unwanted **over-development**loss of valued **‘backlands’** sites
 * * ** **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//
 * 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
 * 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// **
 * ** stress and competition over **availability of land** generally in the borough
 * **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**
 * - ** 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

Submitted by Dave Morris - HFRA Secretary ** __ Appendix 1 __

High housing densities – do they undermine the need to ensure sustainable communities?

a. In 2005 Haringey Council provided the Haringey UDP Inquiry Inspector a table of comparisons of housing densities in neighbouring boroughs:
 * 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 need of amendment. In response we make the following additional comments (in no particular order):

Islington (2002): range 200hrh-350hrh, max 450hrh. Barnet (as of 2005): range 148-235hrh, new development to be >250hrh Waltham Forest (as of 2005): 200-250hrh, but in 3 key locations 200-450hrh. Camden (2000): 99-247hrh, with a max 617hrh in Central Area. Although no current ranges included in revised UDP (as of 2005). Note: Camden includes Central London locations. Enfield (1999): 150-240hrh.

Haringey’s adopted UDP (1998) had a density range of 175-250hrh, up to a max of 350 in specified areas - generally in line with the other boroughs’ current densities. But the Council's draft UDP, since September 2003 had been calling for maximum housing densities to be __doubled__ from the existing 1998 UDP, up to a max of 700 hrh (which was itself controversial and opposed by many community groups eager to protect the character and sustainability of local neighbourhoods).

Under enormous last minute pressure from the GLA (who had refused to certificate the HUDP unless max densities were increased even further), by-passing the entire 2 year public consultation process, and ignoring the view of the HUDP Inquiry Inspector (Report Comment No. 4.156) that //'The prospect of the serious problems of poorly designed and managed tower rise blocks being repeated is ominous',// the Council reluctantly in July 2006 __trebled__ the maximum to 1100.

This whole process was highly controversial throughout the borough and was perceived as contempt for the wishes of local communities and the undermining of the democratic process. It brought the GLA and the London Plan into disrepute. The HFRA therefore call for a return to the sensible and sustainable housing densities which have operated successfully for decades in most London boroughs. b. There is enormous pressure on Councils to accept high density development throughout the borough due to the S106 agreements, which are then portrayed as 'planning gain' but in reality mainly go into shoring up basic services. But, however much money is given to Councils as 'compensation' for development, its of no use in mitigating the pressure on the social infrastructure if there is no land available and no means of actually expanding the facilities and amenities in local neighbourhoods to __actually__ compensate. Hence this undermines other LP policies about protecting and expanding community facilities, open spaces, protecting the character of areas, and ensuring sustainable communities.

c. Many of the schemes in a borough with land competition involve __actual__ loss of facilities (informal green spaces, workshops and garages, local community pubs, community amenities, healthcare and other public sites).

d. Its not just that higher densities mean that its only housing for single people... it also means that even 2 and 3 bed places are being crammed into ever smaller footprints. And single people form couples and have kids etc. So all the people in such higher density housing will suffer.... __and__ there will be a greater strain on the ever-decreasing social and community amenity infrastructure leading to unsustainable communities.

e. Post-war high density housing in the past, especially tower blocks, caused lots of problems and in many cases tower blocks had to be torn down. Its only 'saving grace' was that society recognised that it was an effort to solve the problem of housing homeless people from waiting lists - ie almost all of it was public housing. This ‘justification’ and mitigation for otherwise unacceptable high density can not be applied to current development. It was further justified by creating a great deal of open space around the high density housing - again this mitigating feature is almost always absent from current development.

f. In a borough with limited land availability land is needed now to expand those amenities which are recognised to have deficiencies in the light of current population densities (open space, play areas, allotments, community facilities, health and education sites etc). Yet the constant drive for over-development means that such land is being stolen for intensive housing, which then creates even greater demand for action to address even greater deficiencies, yet with no means to address this.

g. Only 11% of the 624 homes completed in Haringey 2005-6 were social housing (Haringey UDP Annual Monitoring Report). Claims that housing policies are there to build 'homes for the homeless' are untrue, but are used to justify highly unpopular and controversial housing schemes.

h. Continually building higher densities around London - especially if they are not exclusively for social housing waiting lists (ie local people in compelling need) - will only serve to attract more people from all over the UK to come and live in London. We may get the discredited 'motorway' effect where, as everyone knows, more and bigger roads don't reduce traffic or congestion but only generate ever-increasing demand. ** __ Appendix 2 __ // January 2008 // ** Haringey’s very low affordable and social housing as a % of new housing completions - Statistics regarding targets for new housing: specifically the exceptionally low percentage of social housing completions in Haringey in the years 2004-6 - The London Plan’s annual target for affordable housing as a % of newly completed homes is 50%. - The London Plan’s annual target for social housing as a % of newly completed homes is 35%.

Haringey adopts these targets, which indeed may be thought to be very low percentages, considering the numbers of people on waiting lists and in temporary accommodation (over 10,000 households). Further, in Haringey (similar to other boroughs) 'affordable' is defined as //'affordable by households on incomes of less than £49,000 (as at Sept 2005).'// From this point it’s not hard to conclude that social housing is the only genuinely 'affordable' housing, ie affordable to the households in most need.

Much residential development throughout Haringey (and throughout London) is highly unpopular and controversial because land is limited, and the amount of social infrastructure we all need is inadequate (health and education services, open space and play areas, community centres etc). Worse, much of this infrastructure – vital for ensuring sustainable communities - is gradually being sold off for even greater numbers of homes, often in highly dense and poor quality developments.

We are told that this has to be done in order to ‘solve the housing problem’. But does it? What kind of housing is actually being built?**

__In 2004__ **According to the Council's own official figures, extracted from the 2004/5 Unitary Development Plan Annual Monitoring Review Report p12 (para 4.12), only 22% of completions were social housing.

//'In 2004, 285 affordable housing units were completed in the borough* which represents 34% of all housing completions. Of these affordable housing completions, 65%//** //were social rented units and 35% were shared ownership / intermediate units.'//


 * ie 34% affordable out of a total of 834 dwellings (p2, 2nd bullet pt) - this is well below the 50% target
 * ie 22% social housing (185 dwellings) out of a total of 834 - this is well below the 35% target


 * __In 2005__** According to the Council's own official figures, only 11% of completions were social housing.

Their UDP AMR reports that: //'In 2005/6 624 dwellings were completed in the borough...'// of which //'201 affordable housing units were completed, which represents 32%* of all housing completions. Of these completions, 36% **were social rented units and 64% were intermediate units.'**//


 * **ie 32% affordable homes is scandalously below 50% target**
 * **ie 36% out of the 201 affordable completions, means a total of only 72 homes or 11% of completions being social rented homes - this is scandalously below the 35% target**

__In 2006__ **According to the Council's own official figures, '//There were 1067 net additional dwellings in 2006/7'//. Of these //'312 affordable housing units were completed'// - ie only 30% of the net additional dwellings. It then goes on to add that //'of these completions, 75% were social rented units'// - ie only 22.5% of completions were social housing.

A further major concern to anyone is that, in Haringey //'The recommended mix for affordable housing developments is: 26% 3-bed, and 32% 4-bed.'// Yet the 2006/7 UDP AMR 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.'//**

__Some Conclusions__ **The Council's own official figures for the latest three recorded years show that only 22%, 11% and 22.5% of homes built in Haringey were available to those in real need. They are being excluded from the overwhelming majority of homes being built, when the homes should be being built for them. Compiled by Dave Morris, Secretary of the Haringey Federation of Residents Associations for the LBH Overview & Scrutiny Cttee //- January 2008// ** =Appendix 3 = Are the current HUDP policies (especially re housing) capable of ensuring sustainable communities? - including the Council’s official stated views to the Mayor of London 1 It is essential that all specific policies contribute to creating and maintaining sustainable local communities throughout Haringey.

2 In a densely-populated borough with competing priorities for the use of existing land, and a recognized scarcity of any further available land to use, it is clearly essential to challenge and amend detailed policies which promote over-development or inappropriate development, and which fail to protect and extend open spaces and other community facilities. Such policies are not socially or environmentally sustainable.

3 This has been officially recognised by 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 – a highly significant planning document affecting the borough.

//' ... the Council .......is concerned that the document lacks visible plans and proposals for essential infrastructure, such as transport, which is necessary to enable London to operate as a world class city. '//

//'It is considered that the document has missed the opportunity to promote greater sustainability by not addressing wider sustainable communities issues, such as homes for life, transport, social care services, access to community facilities for older people and equalities, including age discrimination. These are key quality of life issues for people living in London.'//

//'The Council is concerned that the phrase ‘intensification should be sought across the sub-region’ (paragraph 105) does not address the character of areas. .... Some areas of Haringey are// //suburban in character with relatively lower densities and it should be recognised that these areas provide a role in providing family sized housing. It would be helpful if the SRDF provided some analysis of future housing density in North London and provided maps of public transport accessibility and urban character.'//

//'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.'//

//'The Council disputes the assertion in the draft SRDF that the anticipated increase in demand for health care will largely be absorbed by existing services (paragraph 65). Where is the evidence to support this claim? Also, the conclusion that primary care provision is inadequate to meet future demands contradicts this claim. It would be helpful if the SRDF identified the relationship between the development of Opportunity Areas or Areas for Intensification and other areas of significant housing growth and the location of planned or improved primary care facilities and location of school development.'//

//'The Council considers that significant additional public transport infrastructure and services are required to support housing growth and regeneration initiatives and to improve access to jobs for Haringey’s residents. Although it is recognised in paragraph 121 that stronger orbital public transport capacity is required to serve key development areas, town centres and residential areas, there is an absence of schemes in the draft SRDF to improve orbital movement or to improve key transport interchanges.'//

4 These comments re-emphasise the Council's comments made as part of the formal consultation over the original London Plan itself:

The LBH Executive Committee meeting on 17th September 2002 accepted the proposed response to the London Plan drafted by the LBH Director of Environmental Services. The Report to the Executive which was adopted stated [Para 3.7 of the Report to the Executive] that //‘…it may be considered that it// [the Draft London Plan] //involves an unrealistic expansion in housing, in advance of providing for the other essential needs of the existing as well as the future population of the borough.’//

The Report also noted: [Para 6.28] that: //‘the approach….. would impact upon Haringey residents’ quality of life’ …. ‘and fails to provide a sustainable solution to housing demand in London’. ‘The proposed housing target… would require more schools to be built, class sizes increased, pressure on community facilities and supporting services’ … ‘lack of land and funding for supporting services eg. schools’…. ‘lack of engagement with local communities on bringing forward such a controversial proposal for high density housing development in advance of transport infrastructure.’//

These points above summarised the Council’s formal response to the London Plan.

5** The only possible conclusion that can be drawn from the above-quoted Reports by the Council is that substantial increases in house-building sites and densities throughout the borough are unsustainable. **Firstly because it is recognised that the current social infrastructure and facilities for the __existing__ population need to be improved first (schools, health, open space, community centres, public transport, road safety etc). Secondly that any increase in the population must be accompanied by an equivalent increase in the full range of social facilities that residents are entitled to. As well as the need for greater education, healthcare and transport services, there is for example a huge and recognised shortfall in the amount of and accessibility to open space, of allotment provision and of children’s play spaces and equipment. **

Appendix 4
Overdevelopment and failure to ensure adequate social and environmental infrastructure - A look at two key related policies – housing densities and open space deficiencies A. Is the tripling of housing densities in Haringey (as criticised by the Haringey UDP Inquiry Inspector) sustainable?


 * 1 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.’// High housing densities mean town cramming, poor quality homes for those who end up living in them, and pressure on already-inadequate public facilities (health care, education, open space etc).

2 Haringey’s previously adopted UDP (1998) had a density range of 175-250hrh, up to a max of 350hrh in specified areas - generally in line with other similar boroughs’ densities then and until recently.

3 We therefore propose that 350hrh should be the maximum density allowed.**

B. Why has the GLA failed to ensure Haringey adopts the London Plan standards on open space deficiencies? 4.3 A closely-related issue is the need for the protection and expansion of adequate open green space throughout the borough. The HUDP Inspector made a special note in his Report [para 8.275]: //‘The genuine and forceful complaints about the way open space assessments and policies have been prepared for this HUDP suggests that this issue could have been handled more carefully by the Council. This implies that when Haringey’s open space policies and standards are reviewed there should be much closer consultation with local organisations such as the HFRA.’//

4.4 He criticised the Council for failing to establish any //‘local open space standards’//, and for failing to explain why they had defined ‘open space deficiency’ as an area lacking in ANY public open space (as small as 0.25ha) rather than an area lacking a recognized local park (at least 2ha). [Note that a hectare is an area of 100 metres x 100 metres.] This fails to conform to the London Plan requirement (and GLA Guidelines to Councils on preparing for UDPs and Open Space Strategies) that any area which is more than 400m from a Local Park (>2ha) shall be deemed to be deficient in open space.

4.5 An adequate definition of deficiency is crucial to ensure the effective protection and expansion of much needed green space.

4.6 The __Haringey Open Space Strategy__ was completed in 2005, and adopted by the LBH Executive on 1.11.05. Its Action Plan, Objective 1.2 is: //‘To adopt the GLA Guidelines for provision of the different types of open space as the standard to which Haringey will work towards. Timescale: Immediate’.//

4.7 What are these //‘GLA Guidelines’//? The __London Plan__, p146, para 3.251, specifies that Table 3D.1 - London’s Public Open Space Hierarchy //‘provides a benchmark for the provision of public open space across London’// and //‘highlights areas where there is a shortfall… More detailed guidance on how to assess local needs is included in the Guide to Preparing Open Space Strategies, published by the GLA.’// Table 3D.1 identifies a standard of every home being no more than 400 metres from a local park and open space of more than 2ha in size.

4.8 __The Mayor’s Best Practice Guidance - Guide to Preparing Open Space Strategies__ (para 2.33 and Table 3) recommends that: //‘The starting point in defining the pedestrian catchments of local parks [HFRA/HFoPF note: defined as >2ha] is the 400 metre fixed radius catchment identified by the hierarchy. This should also be done for District size parks using the 1.2km radius.//** //This will provide the basis for identifying which parts of the borough are not adequately served in terms of access to public open space. **[our emphasis]… The areas of deficiency highlighted by this approach should be viewed as indicative only and should be used as a guide to broadly identify those areas of the borough which are deficient in public open space.’**//


 * 4.9 The Guidance does not suggest that access to smaller open spaces compensates for the deficiency in access to Local Parks - although it is obviously helpful if such smaller spaces can be mapped. There’s obviously a fundamental difference between an area with no open space, and an area of open space deficiency.

4.10 Access to ‘any open space’ as tiny as 0.25ha in size is however the basis of the Atkins Map 8.1 of deficiency (adopted in the HUDP). It is thus in contradiction to the London Plan and inappropriate for the purposes of identifying the areas of deficiency referred to in para 8.49a.

4.11 We can only conclude that there seem to be double standards when promoting and enforcing housing density policies and practices, but failing to promote and enforce social infrastructure policies and practices in London boroughs.**

**Appendix 5**
Do S106 agreements lead to actual planning gains? DOCUMENT PRODUCED BY THE HFRA FOR LONDON PLAN FURTHER ALTERATIONS EXAMINATION-IN-PUBLIC HEARING, 28.6.07


 * i. Supplementary Question from the Panel, Matter 5.1/1 Bullet Pt 3 asks the hearing to comment on the following HFRA view: whether S106, and by implication other planning conditions imposed in mitigation of high-density development in town centres and elsewhere, are failing to be translated into __actua__l planning gains for the communities affected. The Panel ask if this is an inherent flaw or a matter for individual boroughs.

ii. It is the HFRA case that this is an inherent flaw, and has commented on this in its Response (Dec 2006). The relevant section (Section 4) of the HFRA Response is enclosed below as an example of this problem.**

iii. **In particular, the Response explains that a key indicator of the effectiveness of ‘planning gain’ mitigation is whether there is any real commitment by the Mayor and the GLA to policies promoting sustainable communities e.g the London Plan policies which are supposed to address open space deficiency throughout London (London Plan Table 3D.1).

iv. The relevant section of the important GLA document __The Mayor’s Best Practice Guidance - Guide to Preparing Open Space Strategies [March 2004]__ was effectively ignored by both the LA and the GLA during the Haringey UDP Public Inquiry in 2005, despite every effort of the HFRA to formally raise the issue. A belated recognition of the correctness of our approach was eventually received from John O'Neil, Senior Planner, Greater London Authority in 2006 (see Appendix 2 – the correspondence).

v. In fact, __The Mayor’s Best Practice Guidance - Guide to Preparing Open Space Strategies [March 2004]__, a key planning document referred to in the London Plan (at LP para 3.251), seems to have not been included in the EiP Core Documents Library. We hope this is not an indication of how seriously its Guidance is taken.

vi. In areas of London (such as Haringey) where there is stress and competition over land usage, we have contended in our Responses and Written Statements that community facilities and amenities of all kinds essential to sustainable communities (eg open spaces, childrens’ play areas, health, education, sports, leisure and meeting places, local shopping parades etc) 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.

vii. This all begs the question whether this is really just an enforcement issue, or whether the reality is that there is an inherent flaw in the policies: ie that London Plan policies promoting highly intensive residential development throughout town centres and elsewhere around London are at odds with policies promoting sustainable communities, and that no amount of S106 contributions can mitigate the real effects on the ground.

viii. If that is true, as we and the London Tenants Federation contend, based both on sound reasoning and bitter experience, then planning policies must be re-examined.