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RIBA London Submission, March 2003
Introduction
RIBA London is the Royal Institute of British Architects’s region covering the capital and represents over 1,200 registered architectural practices, 7000 architects and 2500 students. RIBA London provides services to members in the areas of education and practice, as well as public and promotional services.
In June 2001, RIBA London published ‘Design for a Greater London’ containing proposals for London’s public realm. This was followed by the publication of ‘Delivering the Vision’ RIBA London’s response to the draft London Plan in September 2002. Both documents are available from the web site www.designforlondon.com.
RIBA London supports the draft London Plan general policies for development and growth led by principles of sustainability and high quality design. The following submission highlights areas of the policies that support these aims and any reservations concerning the detail of the policies.
"London must become a more integrated, compact and sustainable city"
Delivering the vision RIBA London, Sept 2002
Issue 6.1
Does the draft Plan provide an acceptable approach to meeting London’s development needs in relation to site selection and proposals guiding the density of commercial development?
1. The RIBA is committed to the principle of sustainable development and to following strategic objectives including:
- Optimising the development of brownfield sites and the enhancement of urban densities
- Encouraging development that is easily accessible to public transport
RIBA London is encouraged by the support of the draft London Plan for these objectives.
2. RIBA London in particular endorses the Mayor’s vision (dLP Item 23, page 6) "to develop London as an exemplary sustainable world city".
"World class, sustainable design is central to the successful future of London and must remain at the heart of the London Plan" Delivering the vision RIBA London, Sept 2002
3. Policy 2A.5 on sequential development is therefore supported but needs to be made clearer and more robust. RIBA London has endorsed the principle of ‘Brownfields first’ and has further suggested a Greenfield development tax.
4. A clearer exposition of the phrase in policy 2A.5 "well-served by public transport" needs to be made. It can be argued that almost all of the London area falls into the category of being ‘well-served by public transport’ as there is or there could easily be a bus route in the near vicinity of almost all possible sites. This should not be enough in itself to prioritise site development. Public transport accessibility should be defined by maximum anticipated travel times to major interchanges or town centres or by similar objective criteria.
"intensive development should be concentrated in locations with high levels of accessibility and capacity" Delivering the vision RIBA London, Sept 2002
5. Similarly other infrastructure issues should be taken into account including access to and capacity of shopping, leisure, health and education etc. facilities. The rationale behind the sequential approach is one of creating sustainable communities. Site selection needs to consider all relevant matters of sustainable development including the densities that are going to be achieved.
6. While a principle generally in favour of development is supported, Policy 2A.5 should also make reference to those areas, including the Green Belt and Metropolitan Open Land where development will not be accepted or permitted.
7. Policy 2A.6 (Sustainability criteria) is similarly and strongly supported (with modifications as suggested below) and indeed deals with issues raised in item 5 above. RIBA London believes that the criteria listed in this policy should come before those listed in policy 2A.5 and that this policy should be the key policy that determines site selection. In particular the impact of flooding and the deleterious effects of mitigating measures must be taken into account.
8. In addition the Environment Agency’s proposal that a form of Sustainable Threshold Analysis should be applied to site appraisal and selection is supported.
9. The first bullet point in Policy 2A.6 could be usefully amended to include those previously developed sites that are not currently realising their potential and read – ‘optimising the use of previously developed land with available capacity and vacant or under-used buildings’.
10. The principle of a sequential approach outlined in Policy 3D.2 is also supported but the lack of any references to public transport accessibility is questioned. Policies 2A.5 and 3D.2, as well as 3D.4, 3D.5, 3D.6 & 3D.7 should be consistent with one another.
11. On the second issue raised in question 6.1 of commercial density policies 4B.1 and 4B.3 are fully supported. However within the text the use of crude plot ratios is not welcomed. The measurements of plot ratios are contentious and they have been discredited in their past life as maximum (rather than minimum) development controls. A better and more adaptive method of defining required densities should be provided.
12. In general guidance should allow for uneven local, but high overall densities across an area in particular allowing rewards for the provision of open space within developments. Flexibility of approach may be required to facilitate this.
Issue 6.2
Is the draft Plan’s approach to mixed-use development appropriate?
1. RIBA London believes that ‘New development should promote balanced neighbourhoods with mixed uses and tenures’.
2. The principle of mixed-used development runs through the draft London Plan and this is fully supported by RIBA London which regards mixed-use as essential in the creation of sustainable communities. They make it possible to live and work, to enjoy life and contribute to that of the community without undue travelling and dislocation. The arguments for mixed-use developments are well made in Clause 4B.7 of the draft Plan, which also highlights the associated needs for intensive, high-density development and for accessible open space.
3. Mixed-use developments also pose challenges as to how different uses can successfully co-habit in an area without causing nuisance or problems of security and becoming the social and environmental failures of tomorrow. For this reason a high quality of planning, design and maintenance regimes is necessary in the creation of mixed-use developments and neighbourhoods. RIBA London has called for detailed analysis and guidance to be produced to identity best practice in high density, mixed use, sustainable design.
4. The large number of references to mixed-use in the draft London Plan has, perhaps inevitably, led to a degree of inconsistency between the application of the term. The principle of mixed-use should be derived from the need to create sustainable development that provides most services locally and ideally within walking distance. This in turn leads to increased liveability and continuous use of an area through the day or week, resulting in greater vitality and security. In places within the Plan this principle appears to have become confused with the need to provide more residential units, omitting the need to also ensure other amenities and services whether open space, schools, health centres or retail and leisure facilities are available.
5. Similarly the policies in the draft plan intended to generate the large amount of housing required have diluted the need for full mixed-use in the case of housing provision. Policy 3A.5 encourages large residential developments but only with provision for ‘suitable non-residential uses in appropriate locations’. The wording of this policy undermines the principle of mixed-used sustainable developments and it should be re-written to ensure that such developments are fully master planned to achieve the mixed-use, sustainable outcomes outlined elsewhere (for example Policy 2A.6) in the draft Plan.
6. RIBA London recognises that the mix of uses in a local area is of greater importance than having a mix of uses in individual buildings, although in certain dense central areas (Soho, The City, Clerkenwell etc.) this is an essential part of their character. The Plan should show flexibility in encouraging individual, smaller buildings that will provide single uses beneficial to an area and complementing the other uses available or anticipated in that area.
7. There is a also need to increase the mix of uses in existing areas of London, particularly those which currently have a single use (residential, offices, commercial, light industrial etc.) Small scale infill developments and conversions of existing buildings for other uses should be actively encouraged and supported by the planning system and borough UDPs. London’s planning system should be a force for greater richness and vitality within the city and be used to breakdown many of the mono-use zoning restrictions that currently exist.
8. RIBA London vigorously supports the principles of mixed-use development and believes that the draft Plan’s approach is similarly appropriate. Modifications within the Plan are required to ensure that a consistent approach runs through the whole document and that the identified need for additional housing does not take precedence over the need for the maintenance and creation of high quality and sustainable neighbourhoods and environments containing full ranges of uses.