Draft London Plan EiP: Heritage and culture are now dusted

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Draft London Plan EiP: Heritage and culture are now dusted

Draft London Plan EiP: Heritage and culture are now dusted

Dr. Malcolm Hockaday 11 Mar 2019
Lichfields is currently monitoring the draft London Plan Examination in Public (EiP), which is scheduled to last until May 2019, and will report on relevant updates as part of a blog series. The fourth blog of the series focuses on the hearing sessions for draft policies HC1-HC7 on Heritage and Culture, which took place on 8 March 2019.
 
The possible sources of land supply are becoming increasingly restricted and controls over development are becoming stronger as the London Plan Examination in Public (EiP) rolls on, all done in the positive spirit of preserving the best of London.  Planning has always exposed the dilemmas facing society.
With the EiP Panel member Roisin Barrett doing her best to open up queries about the validity, effectiveness and the implications of seven proposed policies, the various participants and the Mayor’s team mostly agreed that each of those was indeed effective and important.
On the capital’s heritage generally and with recognition that this is an essential component of Good Growth, all of the participants agreed with the GLA’s proposals and sought stronger controls and additions to policy.  Notable was the criticism that the policy is ‘only about architecture and archaeology’ and that there is a need to add environmental heritage – more categories of parks and gardens, ancient woodlands, inclusion of waterways with canals and rivers all being described as part of London’s archaeology – and to support wider cultural heritage through conserving the diverse lifestyles of Londoners.
Nicky Gavron for the London Assembly Planning Committee rightly explained that such heritage is good for Londoners and also good more widely through its USP of environmental quality for its tourist visitors, bringing added economic value and added cultural value to the city – enjoyed by the world.  With the GLA Act 1999 not including a heritage role for the GLA, she sought encouragement for the Mayor to produce also a Heritage SPG through its planning powers.
Interest groups pressed for inclusion of Conservation Area Management Plans and the intended National Park City designation to be recognised as planning tools.  And for the stronger approach of ‘preserve and enhance’ rather than conserve.
There was general agreement that draft Policy HC1 on heritage should start with a new paragraph which sets out the overall reasoning for the policy, stressing the need for a comprehensive and much wider interpretation of heritage – both built and otherwise.
The GLA team responded by indicating that it would add references to the importance of community involvement and the economic and cultural role of heritage.  Thankfully, all agreed that the wording of the tests of harm and balancing are well-expressed in the NPPF and that it did not need further referencing in the final Plan.
Extra controls over London’s four World Heritage Sites (draft Policy HC2) were encouraged by all present, particularly following the UNESCO criticisms and the trial review studies of the Westminster WHS.  The GLA noted that buffer areas can be defined for close-up appraisals but that settings are much wider and their assessments should be built into the Plan and SPG.  And that cumulative effects of multiple proposals should form an additional assessment.
The Westminster trial assessment had highlighted the need for 3D visual modelling to be established, now built into the evidence base for the Lambeth Local Plan Review and to be incorporated in the Westminster evidence base.
Another tick for increased controls.
The importance of managing and protecting London’s Strategic Views and locally-defined views through the long-winded draft Policies HC3 and HC4 was also generally supported.  The GLA said that it is seeking to update the London View Management Framework SPG (LVMF SPG) to have better information for each view, define new or better viewpoints, strengthen guidance on river views and to sort out in the Policy a better expression of concern for background views (following from the case of the Stratford block seen behind St Paul’s in the view from Richmond Park). 
There was little or no questioning of the current basis for assessment, including whether telescopic views have any real relevance where things are not visible to the naked eye – arguably not ‘the viewer’s ability’ as required by policy.  There could be a continuing need for night-time assessment in key locations.
With the criticism expressed that the LVMF approach ‘is still a Zone 1 Policy’, there was also a general consensus that local views – to be adopted through local plan reviews – should be given equal weight, even if they restrict delivery in Opportunity Areas.  And that new policies should include seeking the rectification of past mistakes rather than their acceptance.
A big criticism was of the outdated technology expressed in the LVMF SPG and the need for better 3D modelling (apparently to be progressively delivered for free by the GLA).  However, the GLA said there would continue to be a role for parallel methodologies for the foreseeable future.
So the morning session concluded with important existing and new protections and controls to be built into the system.
The afternoon addressed London’s cultural activities and identities, noting in particular the effects of gentrification on settled and ethnic communities and the parallel economic pressures on small and creative businesses.
Discussion on draft Policy HC5 supported the blanket protection to be offered to all cultural venues, facilities and activities across London, with only a written justification support for replacement where necessary for other similar purposes.  There was regular cross-reference to this also being part of the cultural heritage to be protected by heritage policy HC1.
The need for retention and creation of spaces for creative industries was naturally encouraged, but together with the need to ensure that they do not detract from the neighbourhoods they sit in.
Interestingly, the London Assembly Planning Committee pressed for the preparation of a Cultural Action Plan for all larger mixed use developments and for schemes of over 100 residential units, with audits of all existing businesses and jobs – matters now already being picked up by the Mayor in his decision-making.
The night-time economy is to be supported (and controlled) by a new draft Policy HC6, encouraging locations in the CAZ, town centres and other locations around transport nodes.
The difficulty will be the need for balancing of the pressures from operators and users with those from the adjoining residential areas – sounds familiar?  This is all apparently to be managed by ‘the involvement of local communities’.
Lastly – the populist government and Campaign for Real Ale approach to protection for all remaining pubs in London is to be enshrined in draft Policy HC7, with little or no voices of opposition raised at the Panel session.  The Inspector had no questions for the GLA.  The GLA merely repeated that the required 2-year marketing period is necessary to avoid pubs being run down and avoided the question of how this could slow down delivery of Good Growth policies associated with new homes and jobs.
So, the day was full of well-supported and important protections for heritage, World Heritage Sites, views, cultural heritage, the night-time economy and pubs.  There remains every prospect that these will be carried through to the final adopted version of the London Plan.
But the day also naturally ignored the pressing issues from earlier in the EiP about the necessary delivery of sufficient homes for Londoners and the right spaces for their jobs when set against similar protections against the loss of industrial land, green belt and MOL, parks and gardens - and even back gardens – all tightening the screw on much-needed development options.
There is no clear answer to this overriding dilemma and sets up an unenviable task for the Panel to write up.