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Planning

Pre-hearing meeting agenda

Agenda for the Core Strategy pre-hearing meeting on 26th May is now available (copied from the original letter from Southwark Council):

1.Introductions


2.Briefing Note from the Inspector:

  • Inspector and Programme Officer
  • Purpose of the Pre-Hearing Meeting
  • Purpose and Scope of the Examination
  • Hearings Procedure and Examination Programme
  • Representations and the submission of further information
  • Core Documents
  • Site visits


3.Procedural Questions for the Council:

  • Has the Core Strategy (CS) been prepared in accordance with the statutory procedures under section 20(5)(a) of the 2004 Act and the associated regulations, including in respect of publication and availability of documents, advertisements and notification?
  • Has the CS been prepared in accordance with the Council’s Local Development Scheme (LDS)?
  • Has the CS been prepared in accordance with the Council’s Statement of Community Involvement (SCI) and met the minimum requirements of the relevant regulations in terms of consultation and publicity?
  • Has the CS been subject to sustainability appraisal with a final report of the findings?
  • Is the CS in general conformity with the Regional Spatial Strategy and has this has been confirmed by the Regional Planning Body?
  • Has the CS been screened for likely significant effects on any European Wildlife (Natura 2000) sites within and near the plan area and has an appropriate assessment been carried out?
  • Does the CS contain a list of superseded saved policies
  • Has the CS taken account of the Council’s other plans, including the adopted Local Plan and the Sustainable Communities Strategy?
  • Has the CS taken account of the plans of adjoining local authorities and the Mayor of London?
  • What is the programme for the preparation of other DPDs?
  • Is the Council aware of any fundamental procedural shortcomings?

4.Questions


5.Any other business

Pre-hearing meeting announced

Details for the Pre-hearing meeting have now been confirmed and are as follows (copied from the original letter from Southwark Council Examination in Public (Eip) team):

A Pre-Hearing meeting (PHM) will be held on Wednesday 26th May 2010, to discuss the management of the Examination. The meeting will take place in the Southwark Town Hall, Peckham Road, SE5 8UB, starting at 10am.  The meeting, which may be complete by 13.00 or earlier, will not debate or consider the merits of any of the representations which have been made.  It is essentially a procedural meeting to enable those who may subsequently appear, to understand how the hearings part of the examination will proceed and to prepare for it.

Please note that those representors supporting the Core Strategy cannot speak at an Examination unless invited to do so by the Inspector.

Further information upon the process of Examination can be obtained from The Planning Inspectorate website . If you would like to read more information on the Council’s Core Strategy please visit the Southwark Council website.

The Secretary of State has appointed Andrew Seaman BA (Hons) MA, MRTPI of the Planning Inspectorate to conduct the Examination.

If you have submitted a representation to the Core Strategy and would like to attend the pre-hearing meeting, please let Leonna Staple, the Programme Officer, know either by This email address is being protected from spambots. You need JavaScript enabled to view it. or by telephone on 0207 525 4954 before 19th May 2010.

You can download the revised guidance here.
       

Core Strategy: What Next?

The 5th March deadline is fortunately behind us, but the work on the Core Strategy does not stop there. The Council is meant to collate all of the comments and representations, then submit the document to the Secretary of State by 26th March. An inspector will be allocated and, some 3-6 weeks after the submission, he/she will set dates for both the pre-hearing (usually some 8 weeks after the submission) and the hearing.

Detailed description of the procedure can be downloaded from here.

Core Strategy Representation 23: Camberwell, Communities, Transport

The SE5 Forum is a grassroots, non-political, umbrella organisation that exists to work for the improvement of Camberwell to benefit all members of our diverse community.

Camberwell within the LB Southwark’s Core Strategy

There are a number of positive elements within the proposed core strategy which we support and applaud:

There are plans for an Area Action Plan (AAP) set out in the Local Development Scheme to be developed in partnership with LB Lambeth. This partnership working approach is to be applauded as it has been advocated by the SE5 Forum as a way of progressing the future of Camberwell strategically. This partnership is essential at the outset of any process.

Camberwell is maintained as a district centre and is seen as strategically important in the Retail background paper – January 2009. Whilst we recognize that Camberwell is not a metropolitan centre it does serve its local community, and as such should be seen as a key strategic location. The tendency is to focus resources and funding on larger centres at the long term cost to the smaller centres, and this top down trend should not be allowed to perpetuate. The importance of thriving local centres which act as a feeder to larger centres, focusing local spending power into the community is a key element of regeneration. The perceived or real difficulties of cross border working should also not be permitted to act as a brake to progress in this case, but should be used as a driver to effect change.

There is mention of an Enterprise Strategy being written to ‘get more businesses in the borough’. A proactive approach led by the local authority around current business retention and support is an essential element of this, as well as a strategy to attract more businesses into the borough’s town centre. However it is essential that this strategy be founded in fact and not fiction, and is not based on simplistic town centre health checks which are often superficial in nature, and which do not incorporate the complexities of an area which local businesses and people are privy to. We would advocate that this strategy be developed in partnership with local business communities, with focus groups for each locality to add a breadth to the consultation process often missed in a strategic context.

Support within the core strategy for the long-term extension of the Bakerloo Line and/or proposed new station on the Thameslink line at Camberwell, as well as increased cycling accessibility through Camberwell, are to be commended.

The negative elements within the strategy as we see it are:

The Core Strategy recognises that Camberwell has strengths, including its vibrancy, shopping centre, and artistic influences. However, in referencing its "successful" and "attractive" retail offer, the Core Strategy does not pay sufficient attention to its threats, for example variable/deteriorating public realm, lack of sensitivity towards the conservation area, insufficient town centre management, high level of road casualties, and the need for investment in Camberwell Green. Such factors may undermine Core's aspiration for a "diversity of shops, services and facilities within successful town centres", and as such the descriptions of Camberwell could not be said to be based on a wholly sound evidence base.

The economic development of Camberwell centre has not been well thought through or structured to date, and whilst the Core Strategy acknowledges Camberwell, the strategy does not propose any immediate solutions. The Core Strategy refers readers to the Local Development Scheme for details of the timetable for producing Area Action Plans. Given the challenges facing the area, it is disappointing to see that consultation on the Camberwell plan will not commence until April 2012, and that the plan will not be adopted until 2015. Whilst this timetable may well have now been agreed in the Local Development Scheme, it does not provide an effective basis for tackling Camberwell's immediate challenges, and for pursuing complementary and joined-up regeneration strategies in tandem with nearby Peckham. We would recommend that the Core Strategy takes steps to bring this process forward, or else notes the need for interventions in the interim to support the regeneration of Camberwell. We would advocate that the SE5 Forum be aided to develop the Area Action Plan for the area in partnership with the community and the local authority to be completed within the next two years in order to expedite the situation and halt any decline of the retail centre.

There is some confusion and a lack of consistency in the document regarding whether Camberwell is, or is not, an identified 'action area' for regeneration. Whilst Camberwell is referred to as an "action area" on pages 32 and 36 and in section 5, it is merely referred to as "Camberwell" on page 52. Possibly as a consequence, section 6 does not include any implementation plan for Camberwell, to deliver the vision for this action area (despite including implementation plans to deliver the visions for the action areas of Aylesbury, Canada Water and Peckham and Nunhead). These inconsistencies and omissions would not appear to provide an effective basis on which to support the necessary regeneration of Camberwell in the immediate future.

Camberwell is seen as subsidiary to Elephant and Castle Surrey Quays (Canada Water) as it is only ‘medium priority and regeneration’ as opposed to the high priority of the former two areas. Whilst we recognize that not everywhere can or, indeed, should be the highest priority we see the challenges faced by Camberwell every day, and would also urge that its profile within the Core Strategy documentation be raised to ‘high and regeneration’ in order to ensure it is a priority for Lambeth and Southwark collectively.

The Enterprise Strategy has no deadline for development, which does not support effective resident engagement in this proposal.  We would hope that a timescale could be developed and included as part of the Strategy.

More generally we have other comments as follows:


Pages 90-93 set out the strategy for jobs and business. This recognises the importance of supporting creative, cultural and tourism facilities and encouraging new facilities in "strategic cultural areas" (i.e. Bankside and London Bridge). However it would also support effective policy making if other areas within the borough were recognised for their important contribution towards nurturing and sustaining the creative industries, including in particular in Camberwell.

Linked to this, we feel the Core Strategy should provide a greater focus on what is distinctive and what represents opportunity within the hinterland of the Borough, and how areas such as Camberwell are going to be enhanced in the future.

We believe it would be a positive inclusion on page 73, to note that Southwark Council will take steps to ensure that local residents are fully aware of the health, education and community benefits derived from section 106 agreements.

We would ask that Camberwell be seen as a priority due to the enthusiasm and commitment of local residents who have demonstrated their commitment to their community through a long history of involvement and action. We are proven deliverers, and aspire to this for the long term.

SE5 Forum for Camberwell also supports and endorses the comments submitted by Southwark Living Streets.


Strategic Policy 4:  Places to Learn and Enjoy
There are concerns that the Council's Asset Management Strategy is very limited in scope, only covering 73 properties across the borough and looking to reduce this number, when surely the opposite should happen.  The infrastructure for community groups and active residents in the borough is extremely poor and there is a clear need for support centres for community groups spread across the borough which would provide information, advice, support and other resources.

Town Centre Manager and Camberwell Business

There is a desperate need for better town management and parking as well as support for small entrepreneurs who are trying to build shops in the area.

There is no centralised planning policy in regard to street management, transport and parking.  The piecemeal approach to development in Camberwell is reflected in the increasingly shabby and shambolic look of the town centre.

This is an area where independent start-up businesses (an important route out of poverty) are almost doomed to failure or merely make ends meet.

Our existing bars, cafe, restaurants, shops and businesses would also like to see a better management plan to enable them make long term investment plans  (and create more employment) at the moment they can’t do this.

The plan mirrors this attention to the small business owner so perhaps more funding and support could come into Camberwell for this reason (96% of businesses in Southwark are micro or small businesses employing less than 50 people.)

Transport
Much has been said in the plan regarding the limited transit connections and a desire to improve this.  One way would be to sign and improve the cycling and pedestrian connections within Camberwell and to other areas of the Borough.  With a significant number of residents choosing to make their trips on bike, it seems that the CORE strategy would have a more definitive reference to both a larger plan and improvements.

(reproduced courtesy of SE5 Forum)

Core Strategy Representation 22: SP4 Places to learn and enjoy part 2

The text confirms the experience of the community sector that the Council is unaware of many of the needs of the community sector, especially that part of it resident-led,  which are very different from those of the voluntary sector.  There is no evidence of research that has been conducted to identify these different needs and so the policy is deficient. Some indications:

The Council's Asset Management Strategy is very limited in scope, only covering 73 properties across the borough and looking to reduce this number. The opposite should be the case as the infrastructure for community groups and active residents in the borough is extremely poor and there is a clear need for support centres for community groups spread across the borough which would provide information, advice, support and other resources.

Because of the very large unmet demand for premises from across the voluntary sector and community sector, there should be a proactive policy from the Council to identify empty buildings and encourage them to be made available for short, medium and long term lets whether private or publicly owned.

Whilst the Government's Quirk Review encouraged community ownership of assets, through asset transfers from Local Authority to community ownership, there is no evidence of this happening on the ground in Southwark.

The experience over the last few years, of the way the Council is managing the disposals of its own property, is that their process has a severe disrupting effect on community and resident-led projects. The Core strategy needs to demonstrate how there will be integrated working on these matters within the Council especially between community policies and the Housing and Property Departments at strategic, policy and practical levels.

Southwark has a poor infrastructure for community groups and active residents and the Core Strategy reinforces this problem. There need to be support places for community groups spread across the borough where active residents and informal community groups can go for information/ advice/ support and other resources.

The policy should at least

  • identify, with the agreement of community sector representatives, what the needs are and indicate these in the text.
  • list what it considers to be community facilities (as required by London Plan Policy 3A.18 and 3.100) and include in this list community groups' need for meeting space
  • include a policy mechanism to unlock the use of empty buildings in the borough

 

(reproduced courtesy of Eileen Conn)

Core Strategy Representation 21: Transport, Communities and Consultation

Sustainable Transport

Sustainable transport is mentioned in the Core Strategy, at a variety of places the policy is to limit the number of car parking spaces in new developments to lessen car usage, there is no policy for reducing car usage in existing areas. Minimising car parking for new developments does not mean minimising car usage, it is only going to encourage more pavement parking, more parking on corners and illegal parking in general. With the proposed new developments within the Core Strategy, at best, only 5% are to be affected by the car parking policy. “Safeguarding land for planned public transport improvements and where the need arises in the future” (page 58: How we will do this, 3rd bullet point). The bullet point has no meaning as the need arising is arbitrary. “Safeguarding” is a malleable concept, safeguarding from whom? Safeguarding against what? Will open space be eligible for safeguarding for the needs of public transport?

An item that needs to addressed is cars passing through the Borough, these bring no income to the area yet the council tax payers have to maintain roads, pay for power for lighting and traffic lights and suffer from the pollution. The technology and road width exist to implement a through traffic toll system. It is probable that central government and TfL approval is needed but that does not stop such a scheme being policy. This policy would need to be Borough-wide to keep side streets being used to evade the toll charge, this would also allow for cutting out the many “rat runs” in narrow side streets. Having a policy in place to work towards these objectives makes a move towards a more sustainable transport system.
The “priority for walking and cycling”, which is in several sections, is meaningless. There is no guide as to what form of transport walking and cycling will have priority over. Taken with “maximising the use of public transport”, cycling and walking will be given lower priority.

Noticeably absent is how provision for pedestrians and cyclists is to be met – will pavements have minimum widths for different zones? Far too many pavements are too narrow for present pedestrian use now, if this issue is not addressed it can only worsen with the increase in population density intended. What will be the minimum safety standards applied to the walking and cycling areas? Safety includes separation of sustainable transport from cars, etc., the priority at junctions (at present there is roughly eight seconds for pedestrians to cross any junction using traffic lights). What facilities are to provided to promote cycling? Cycling parking facilities do not meet the needs of the Borough now and they are often sited where they are not of use or in dark areas.

There is no policy on how public transport, walking and cycling will be merged or even if they are to be. Disabled access to rail variants of public transport are not available at some locations. What is mentioned of rail, tram and underground transport is mere wishes, there is no policy on what Southwark wants or expects from providers of these forms of transport. The present situation is that the South London Line services to Southwark are to be reduced. The Core Strategy should be more along the lines:

  • We will work with the train providers to maintain at least a regular service as is provided at present and we will strenuously work towards re-opening the stations in Camberwell and Walworth.
  • We will liaise with the train providers to find suitable sites for new stations to serve housing estates, business areas and leisure facilities in order to make transport as sustainable as possible.

Both trains and buses need the issue of transporting prams, wheelchairs and cycles addressing if an increase in public transport is to be used more. Having one space for one pram or wheelchair is not acceptable as it leaves people waiting for the next bus for a space. There is no reason why the policy can not include working towards the carrying of cycle trailers and tricycles, both of which will make both forms of transport more accessible to many and ergo better used.

There is no other strategic policy for how car usage is to be lowered. This policy needs to be on a Borough-wide basis and to be specific as to what measures are to be considered. If Sustainable Transport is not to be considered at the Borough level the present situation, which is not geared towards sustainable transport, will continue. The council is claiming that these issues will be addressed on an area by area basis leaving cycle tracks starting and finishing without connecting to another route, pedestrians to cross major roads and road junctions – which often leads to going further afield to shop and use a car in the process.

Page 68: “Small retail facilities ...”
The small retail facilities encourage the need to travel yet the Core Strategy is to promote the use of town, district and local centres which promote travel. Centres need to be less compact and more spread such as Lordship Lane; Walworth Road could become a similar shopping area but car parking and shop density make the Elephant & Castle more attractive to traditional shopping methods.

I submit that the Sustainable Transport Policy as is in the Core Strategy is not a policy at all but a “green wash”, there will be no reduction in fossil fuelled transport and public transport usage will decrease due to there being less train stations and services. Many of the policies contradict each other to the point where they are unsound and implementation will not be ineffective but impossible.


Page 70: “We will do this by”
The council claims to consult the community as required by SCI. The community continually claims not to have been consulted, this alone shows the unsoundness of the councils consultation system. SCI suggests that consultations are to be held over several days at different times, the council has had one day consultations for the Core Strategy. The only community panel which appears to exist is for the SCA (Sustainable Communities Act) and this is made up of 50% councillors. There has not been time within the final consultation period for the Core Strategy to find out how many pre-planning applications have been held, if any.


Communities
Add a definition of community facilities to bring it to the standard of education. There are non-specific mentions of what constitutes community facilities. More specific council documents suggests that Tenant and Resident Association halls use be extend by mixed use for the whole community, agreement for the use of the halls can be easily made then there is the problem that the halls are not fit for purpose – urinals in accessible to the disabled, lack of security, limited electrical supply, etc.

Having community facilities defined will remove the need for churches to be included in community groups. Church(es) is  discriminatory when used on its own as churches are used by some of the orthodox christian groups, other religious groups use chapels, synagogues, mosques, ashrams, temples and a whole range of other structures specific to them.

Community in itself needs to defined, is it a group with a common interest/goal or a group specific to a locality or both or something entirely different.

Having community facilities and community defined will remove the need for community groups being defined as it will be a logical extension, without definition of the terms no targets for the Core Strategies for community can be set nor can what the council are willing to facilitate be known. At present this area of the Core Strategy iss ineffective to the point of being a non-policy.


Community consultation
The lack of effectiveness of Southwark's consultations is shown in that the wider community probably still does not know of the Core Strategy or how to make representation. The timetable for the final consultation of the Core Strategy displays the unsoundness of the implementation of the consultation process – November's council meeting had the public consultation period to begin in November (the publication date of the Core Strategy document is November on the cover). This date was changed to February and the closing date is in a continual state of flux. Community involvement in the Core Strategy is made even harder by the fact it is not listed on the council's web site under the letter “c” of the glossary.

This is the council's public consultation on solely the Core Strategy, it is typical of the unsoundness of any consultation has made for community involvement. For community facilities the council's facilitation of community involvement is worse and possibly does not meet the guidelines. It must be noted that the council is making the decision as to the soundness of consultation, what the community has to say is ignored.

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