(DRAFT) SUBMISSION FROM THE OUR TOTTENHAM PLANNING WORKING GROUP 14th April 2014
INTRODUCTION
Tottenham is a great place with a rich social and architectural history, made up of vibrant, diverse and talented communities. We want to ensure this continues. The Our Tottenhamnetwork brings together 40 key local community groups, projects and campaigns standing up for the interests of people in Tottenham, especially around planning and regeneration issues (http://ourtottenham.org.uk/?page_id=31). We work together to fight for our neighbourhoods, our community facilities and the needs of our communities throughout Tottenham. This response, formulated by the Our Tottenham Planning Policy Working Group, is based on the principles embedded in the Community Charter for Tottenham agreed by the Our Tottenham network on 6 April 2013 (available here: http://ourtottenham.wordpress.com/community-charter/). This was followed up by a Community Planning for Tottenham conference in February 2014. We attach as background our recent response to Haringey Council’s consultation on Area Action Plans for Tottenham.
Most local residents and businesses are happy and proud to live, work and invite their friends to Tottenham. It is already ‘a place for diverse communities that people are proud to belong to’, to use the headline of the Sustainable Community Strategy 2007-2016 approved by the Council. Consequently, the aim enshrined in the approach to planning in Tottenham – by the London Plan, the Upper Lee Valley Opportunity Area Planning Framework and the Area Action Plans for Tottenham that Haringey Council has recently consulted on – of attracting new investments, new residents, new businesses and new development to Tottenham should not be done at the expense of the existing community, i.e. by displacing local residents and local businesses; and it should actually improve the lives of existing residents (by creating jobs which locals can access and developments which generate true and significant benefits or facilities accessible to the community). Regeneration should not lead to gentrification in which local residents are forced or priced out of the area, and should not be done at the expense of the people of Tottenham. We do not want a form of regeneration which will over-develop Tottenham, which will push up house prices and private rents, reduce the amount of council housing in the area, force out small shops and businesses, encourage the exploitation of low-paid workers, and drive out large numbers of the poor and members of ethnic minorities to make way for a new higher-income population.
OVERALL COMMENTS ON THE FALP
The Our Tottenham Planning Working Group considers thatthe alterations introduced to the London Plan (FALP) would compound and intensify existing problems with the approach to planning and development in Tottenham. We refer to the detailed submission from Just Space which questions the rationale and soundness of the alterations in being based in revised population forecasts for London.
We consider that the FALP could have damaging effects without doing much to solve the desperate housing affordability problem of London. Decent and affordable housing for all is one of the core areas of action within the Our Tottenham Community Charter, agreed by affiliated groups at a conference in April 2013. The proposed alterations to housing policies in Chapter 3 of the Plan – including increasing housing targets without any guarantee as to the proportion which will be in any sense ‘affordable’; increasing the flexibility regarding density which is likely to push up land and housing prices; and removing any prioritisation of meeting London’s urgent housing needs – risk fuelling the house-price and rental boom without solving the central housing problems.
As Tottenham lies within the Upper Lee Valley Opportunity Area (ULVOA), like other Opportunity and Intensification Areas, it also stands to experience the effect of the alterations more strongly than other areas. We have had no involvement in the development of the ULVOA Planning Framework. The FALP for the ULVOA in Annex 1 note that this was produced ‘by the GLA working with TfL and the London Boroughs of Enfield, Haringey, Waltham Forest and Hackney’. There is no statement of community involvement, and there has to our knowledge been no opportunity for public debate and involvement in the production of the ULVOA. The Just Space submission highlights this as a much broader problem in the preparation of OAPF’s, and support their suggestion for much stronger community involvement and social impact assessment to be introduced.
We are concerned to see in Annex 1 of the FALP a very large increase proposed for the new homes target for the ULVOA from 9,000 to 20,1000 homes, with no detail provided to assure us that any significant number of the new homes proposed for the Upper Lee Valley Opportunity Area will be affordable in any sense, and no assurances that existing affordable (especially council and social) housing will not be lost through the development process. This is of current concern in many planned developments in Tottenham, for instance 297 council homes are at risk of demolition as a result of a ‘Spurs-led regeneration’ of the area (see Annex B). The alterations are therefore very counterproductive and do not at all address the concerns of the Our Tottenham network regarding decent and affordable housing for all, namely to ensure that new developments provide the secure, affordable housing that people need, and that ‘gentrification’ doesn’t force thousands of local residents out of our borough (Haringey).
We are also believe that the increasing emphasis on housing delivery (e.g. at para 2.60 – 2.62) over jobs in Opportunity Areas and Intensification Areas will ramp up further the destruction of existing, viable and productive businesses operating in Tottenham, damaging the local economy and community. We wish to draw attention to the way in which existing businesses lying within the development areas in North Tottenham have been ignored and dismissed by local plans and development proposals, and fully support the work of the Tottenham Business Group to try to redress this (see Annex C). We note that options which could have prevented the displacement of existing businesses were presented by the developer Arup, but rejected by Haringey Council (see Annex D). We also fully support the work of Wards Corner Community Coalition to develop a community plan which sets out how Wards Corner could become a genuine destination and attraction for the people of Tottenham and London as a whole. Wards Corner is a vibrant and ethnically diverse local economy that attracts local residents and people from all over London. Yet the planning system has thus far not recognised the value of these activities. We therefore urge the Mayor to take leadership to ensure existing businesses are not displaced but instead have an affordable and sustainable future in any new developments on London’s high streets and town centres and to ensure that bottom-up community and business led proposals and initiatives are supported.
MAIN RECOMMENDATIONS
In light of the analysis presented above, we recommend that:
– The FALP are withdrawn, and a full, open, transparent and participatory review of the London Plan and its evidence base is undertaken, with renewed commitments to involve local residents, businesses and community centres and to take seriously the proposals about planning and development developed by bottom-up initiatives across London such as Our Tottenham (see our response to Haringey Council’s recent consultation on Area Action Plans and Site Allocations DPD for Tottenham, sent in alongside this submission).
– The GLA’s planning approach to Tottenham and the Upper Lee Valley Opportunity Area more generally are fully revised and reviewed in line with the proposals developed by the Our Tottenham network. Support and resources should be given from the GLA and Haringey Council to support communities in developing community plans for Tottenham.