Dear Mayor of London,

 

I welcome the new London Plan emphasis on Good Growth; of a healthy, inclusive city and its determination to limit unsustainable modes of transport.  I support

GG3 1.3.4 The Healthy Streets Approach outlined in this plan. This puts improving health and reducing health inequalities at the heart of planning London’s public space. It will tackle London’s inactivity crisis, improve air quality and reduce the other health impacts of living in a car-dominated city by planning street networks that work well for people on foot and on bikes, and providing public transport networks that are attractive alternatives to car use. It will also ensure that streets become more social spaces.

 GG5 I support the aim of maximising London’s existing and future public transport; its walking and cycling network, as well as its network of town centres, to support agglomeration and economic activity.

 GG2 I welcome the policy of encouraging densification around major transport interchange points.
 

Where I feel the draft London Plan is not robust or ambitious in its objectives:

Road Pricing

T2 Road pricing: existing schemes reviewed – 2018-2020
 This must be more specific. Road pricing must include Taxis, PHVs and remove exemptions, all motor vehicles cause congestion. The hours of the Congestion Charge need to be extended to 24/7. And the price needs to be raised.
Road pricing: next generation charging (subject to further assessment) – 2022-2041
This need to be prioritised and ASAP.  The time frame is not ambitious enough.

 Parking

The car parking standards for outer London (policies T6.1, T6.2 and T6.3) seem unnecessarily generous and difficult to reconcile with the welcome objective of increasing to 80% the proportion of journeys to be made by sustainable modes of transport. We already have 6.8 million parking spaces taking up more than 78.5 km sq. We cannot afford to allocate any more precious floor space or land to this economically illiterate use of prime space. Carfree development must cover the whole of Greater London not just CAZ.
I support Policy T6.1  F. The provision of car parking should not be a reason for reducing the level of affordable housing in a proposed development. [But the definition of affordable housing must be clear. This is a loophole and needs to be more robust. Social housing must be clearly defined and not open to loopholes.]
Policy T6.1 makes the crucial point that car parking diminishes the ability to make full economic and socially inclusive use of prime space. Residential car lots and spaces make individual units less and less affordable for tenants. They also result in fewer units as a whole, meaning the supply of housing across the city is reduced. That too hikes up rents over time, as Boroughs run out of sites to develop
Table-10-3 in the draft London Plan sets out maximum parking provision for residential units, based on PTAL. Whilst I support CAZ being car-free, parts of inner London and Outer London PTAL have maximum car parking of between 0.25-1.5 per unit. If the Mayor achieves the increase from 29,000 homes a year to 66,000 per year, we can anticipate a significant rise in the number of car parking spaces in London.
This runs totally counter to the Mayors ambition to reduce car dependency. And how much potential housing and office floor space will be lost to more car storage? We must have NO more car parking in London. We need clear reductions in parking and car infrastructure to facilitate maximum usage of prime land for housing.
Conversely, the minimum cycle parking standards (Policy T5 and Table 10.2) are insufficient to drive “the ambitious aim to reduce Londoners’ dependency on cars”. Additionally we must supply  60,000 ambient cycle parking in the London Plan. This will facilitate a wide range of cycling trips.
Cycling CTAL replacing PTAL would increase access to public transport through cycling infrastructure. This is laid out on Page 40, 41, 42 of The Strategic Cycling Analysis Such an approach would unlock carfree development throughout Greater London. CTAL cycling infrastructure must compliment PTAL to open up areas throughout Greater London to car-free development.

 Cycling infrastructure

Section 106 and Community Infrastructure Levy must contribute funding to appropriate CTAL cycling infrastructure.
Licensing of pedicabs and emerging cycling taxi apps must be included as vital sustainable transport for ‘Good Growth’ Dedicated pedicab ranks at major interchanges must be provided in the London Plan.
I support all proposed walking and cycling bridges Rotherhithe, Nine Elms to Pimlico and would like these to be prioritised.
I do not support Silvertown Tunnel. We must not build new roads which induce more motor traffic use.
 The London Plan must include dedicated play streets across London.

Aviation

 I welcome the Mayor’s stance on Heathrow (policy T8D).  But am opposed to any expansion of airport capacity in the south-east including City Airport and Gatwick and believe that all journeys over land should be made by rail rather than air.

Housing

I believe using open green space for housing is unnecessary and counter to the ‘Good growth’ aim. Gardens are vital for biodiversity, Healthy soils store carbon and mitigate flash flooding. I support densification of the Outer boroughs but within their current footprint. We must not lose small green spaces and back gardens when car parking has such a high footprint.(6.8 million car parking spaces in London taking up a minimum of 78.5 km sq).
Under occupation of dwellings shows where densification is possible. Car Parks and car infrastructure like garages must be the first to be developed for housing.

Water and light

Water consumption must be addressed with more robust policies in the London Plan. Londoners are using 170 litres per day when the UK average is 140 litres. Cape Town is now down to 50 litres per person per day and still running dry. London is one of the 11 cities most likely to run out of drinking water
Access to sunlight must be embedded in the London Plan. Food growing which needs sun must be available to all Londoners. The sun is also vital for vitamin D and mental and physical wellbeing.
Solar must be integral to all new development.

Food

POLICY 4.8.e I support the range of London’s markets, including street, farmers’ and, where relevant, strategic markets, complementing other measures to improve their management, enhance their offer and contribute to the vitality of town centres. This must be broadened to develop the relationship between Londoners and the local food growers outside London. Helping with picking and building cultural exchanges.This is important for food security, health and well being.

Automation and tech

 Automation is a high energy user. The rush to automation cannot reduce our energy consumption sufficiently to meet the climate targets set by the Paris agreement.We must prioritise low energy, carbon efficient strategy.

The London plan must be worded in such a way that ‘takeover from the inside’ by tech corporations is not possible. WAZE is owned by google. Transport for London and the London Assembly must be wary of ‘free’ services.

Algorithmic transparency must be embedded in the London plan so that citizens can democratically scrutinise decision making. A bill was recently passed in New York so that the city’s ‘automated decision systems’ are fairer and more open to scrutiny. The bill would require the city to make public the computer instructions that are used, invisibly, in all kinds of government decision-making.
I would would also like all Section 106 to be held separately and independently. The London Ramblers have noticed that Section 106 are going missing and public access originally granted can be denied without documented evidence. This is effectively ‘land grab’.