Thamesbank
New member
Thamesbank\'s submission to the LP alterations (sorry, long)
THAMESBANK'S CONCERNS ABOUT THE RIVER THAMES IN THE LONDON PLAN
THIS IS IMPORTANT - PLEASE FORWARD AS APPROPRIATE
WE WILL SEND OUT OUR FINAL SUBMISSIONS NEXT WEEK - PM me if you have a comment for inclusion.
We welcome any comments we can pass on to the lawyers by first thing Monday next week.
Attached and partial, with the draft key 'areas of Thamesbank's concerns' noted below.
Since the conference with the lawyers, Thamesbank has noticed that Chapter 5 - the Subregional Frameworks have changed boundaries and areas, and has been re written. This has not been made clear, but most importantly it is noticeable that it appears (please correct us if we are wrong) the River Thames has literally been left off these important maps policies and texts of these broken up sections across London.
CAZ - the Central Activities Zone map pA83, new pol p31 2Aiii and new pol 5G.1p345 fails to mention that there is a River running through the middle, and fails to superimpose the Thames Policy Area -Map LPpA33, or any related
space, river transport, World Heritage Site (2) and 6 of top 20 tourist attractions are on the riverside in this central London area.
The CAZ "Environment" is 'iconic' but without mentioning the unifying, uniqueness and heritage of the River Thames or that it is London's finest environmental and dynamic asset.
Pol2Aiii commits the Mayor ... to prepare a strategic framework for the zone.
Thamesbank welcomes this as having the potential to focus and identify the environmental 'icon' AS the River Thames and its relationship to the " World Heritage Sites(Westminster and the Tower of London)(which are identified in Pol 4B13 and related Policies as needing 'management plans that should
...protect their historic significance and safeguard...enhance their settings' ie the River Thames) and the 6 top tourist attractions. By maximising the environment and social potential of the River Thames, the CAZ strategy could balance the economic and built environment and bring
added value to the economics of this area in Central London and would have a great environmental influence in the other Sub Regions along the River to the other World Heritage sites, such as Greenwich, the Royal Botanic Gardens and the related reach and much needed protection for the famous Oxford & Cambridge Boat Race reaches course leading towards Hampton Court Palace.
This much needed World-Class protection for the River Thames would be exemplary - sustaining the River Thames right down into the Estuary and river side lands.
Also the Thames Policy Area has not been superimposed onto the other maps relating to the functions of the River especially the river side land and also the important river tributaries in the OPEN SPACE and the BIODIVERSITY maps
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"3.3 As a general approach, Thamesbank believes that the whole of the LP is in issue, not just the textual changes proposed by the Further Alterations.
4 Areas of Concern for Thamesbank
4.1 The main issues of concern for Thamesbank are:
(i) A lack of recognition of the value of the Thames and its environment as a single living entity;
(ii) A lack of recognition of the Thames and river land as part of the realm of open space and a key element of London's natural environment which should be given special status and protection;
(iii) The incremental loss of unique river land (ie the foreshore and land immediately adjacent to it) for non-river related purposes, and the need to afford river land special status (eg through a designation of 'blue belt' or 'blue field');
(iv) The lack of a holistic approach to the river and the absence of overall responsibility, coordination or management of the river environment;
(v) The lack of genuine stakeholder engagement and involvement in environmental decision-making for the river.
5 Issues in London Plan
5.1 The Mayor's overall vision for London is to become an exemplary sustainable world city (page vii-xv). Following this, the Mayor has produced a set of 6 objectives to guide the policies of the LP. Objective 6 is: to make London a more attractive, well-designed and green city, and includes a policy direction to enhance the use and environment of the Thames and the Blue Ribbon Network (page xxv). The reference to the Thames and the Blue Ribbon Network in the Objectives was a major success of Thamesbank's
involvement in the original consultation and EiP of the draft LP in 2003.
5.2 The main purpose for the review of the LP is to include policies on climate change. The key policies addressing adaptation to climate change (Chapter 4A, pages 208-216) are highly relevant for Thamesbank, dealing with flooding and sewage issues.
5.3 The Blue Ribbon Network (BRN) refers to London's network of rivers, canals and waterways and has a specific set of policies relevant to it at Chapter 4C (page 263-287). The policy for Sustainable Growth Priorities for the Blue Ribbon Network (Policy 4C.12, page 270) remains unchanged. This policy was a major issue of debate for Thamesbank at the previous EiP. This is the most relevant part of the LP for the purposes of Thamesbank.
5.4 Appendix 1 contains important tables of relevance: Table 3D.1 London's public open spaces hierarchy (page A68) and Table 3D.2 Draft Targets for Restoration and Re-creation of Priority Habitats (page A69).
5.5 London Plan Performance Indicators are contained in Table 6B.1 (pages A87 - A89) and are set against each of the Objectives and linked to specific policy. Targets numbers 14 (passenger and freight transport) (page A88) and 24 (functional flood plain) (page A89) are the most relevant.
6 Detailed Issues in Further Alterations
6.1 There is a concern that the definition of the BRN is too limited. The definition is provided at paragraph 4.77 (page 265). It does not include any river land. Thamesbank therefore wishes to challenge this definition and widen it so that BRN policies have a wider scope.
6.2 The term natural environment is rarely used. Thamesbank is concerned that there is no sufficient and clear distinction in the LP between natural and built environment and no clarity of how these relate to the Thames. Thamesbank believes natural environment should be defined and should expressly incorporate the River and river land.
6.3 The term natural environment has been used in the following policies:
(i) The Sustainable Design and Construction Policy, see Policy 4A.2i Chapter 4A (Climate Change and London's Metabolism) (page 199), fourth bullet point on page 200. This policy is relevant to the concerns over climate change.
(ii) The Design Principles for a Compact City, see Policy 4B.1 Chapter 4B (Designs on London) (page 240), ninth bullet point on page 241.
6.4 The Blue Ribbon Network Principles (BRN Principles) are a series of five principles based upon the five river functions contained in RPG3b/9b. The LP stated that planning decisions should be based on the Blue Ribbon Network Principles (Policy 4C.1 and paragraph below, page 266). This requirement is being deleted, as is the background reference in paragraph 4.76 (page 265).
6.5 An example of this may be identified in the deletion of the Royal Docks Policy (Policy 4C.33, page 285), including the reference to taking a precautionary approach. The reference to BRN Principles in paragraph 4.140 (page 285) is deleted and replaced with the Mayor's policy. Thamesbank is
concerned to ensure the inclusion of the principles of the five river functions from RPG3b/9b and the maintenance of a clear and transparent set of principles for the river as a basis for decision-making.
6.6 Thamesbank is concerned over the lack of priority given to the river in the open space hierarchy contained in Table 3D.1, page A68. Linear open spaces include open spaces and towpaths alongside the Thames, canals and other waterways, but are placed last.
6.7 The new policy relating to flood risk management (Policy 4A.5v and Policy 4A.5vi, page 209) is not adequately implemented in performance indicators and targets:
(i) The London Plan Performance Indicators (Table 6B.1, page A87) provide for a sustainable approach to flood management (target 24, page A89), as being 'no net loss of functional flood plain within referable applications'. This seems to be a reduction of the target from the published version.
(ii) The draft targets for Restoration and Re-creation of Priority Habitats (Table 3D.2, page A69) list the Tidal Thames and Rivers and Streams. The targets are considered minimal.
THAMESBANK'S CONCERNS ABOUT THE RIVER THAMES IN THE LONDON PLAN
THIS IS IMPORTANT - PLEASE FORWARD AS APPROPRIATE
WE WILL SEND OUT OUR FINAL SUBMISSIONS NEXT WEEK - PM me if you have a comment for inclusion.
We welcome any comments we can pass on to the lawyers by first thing Monday next week.
Attached and partial, with the draft key 'areas of Thamesbank's concerns' noted below.
Since the conference with the lawyers, Thamesbank has noticed that Chapter 5 - the Subregional Frameworks have changed boundaries and areas, and has been re written. This has not been made clear, but most importantly it is noticeable that it appears (please correct us if we are wrong) the River Thames has literally been left off these important maps policies and texts of these broken up sections across London.
CAZ - the Central Activities Zone map pA83, new pol p31 2Aiii and new pol 5G.1p345 fails to mention that there is a River running through the middle, and fails to superimpose the Thames Policy Area -Map LPpA33, or any related
space, river transport, World Heritage Site (2) and 6 of top 20 tourist attractions are on the riverside in this central London area.
The CAZ "Environment" is 'iconic' but without mentioning the unifying, uniqueness and heritage of the River Thames or that it is London's finest environmental and dynamic asset.
Pol2Aiii commits the Mayor ... to prepare a strategic framework for the zone.
Thamesbank welcomes this as having the potential to focus and identify the environmental 'icon' AS the River Thames and its relationship to the " World Heritage Sites(Westminster and the Tower of London)(which are identified in Pol 4B13 and related Policies as needing 'management plans that should
...protect their historic significance and safeguard...enhance their settings' ie the River Thames) and the 6 top tourist attractions. By maximising the environment and social potential of the River Thames, the CAZ strategy could balance the economic and built environment and bring
added value to the economics of this area in Central London and would have a great environmental influence in the other Sub Regions along the River to the other World Heritage sites, such as Greenwich, the Royal Botanic Gardens and the related reach and much needed protection for the famous Oxford & Cambridge Boat Race reaches course leading towards Hampton Court Palace.
This much needed World-Class protection for the River Thames would be exemplary - sustaining the River Thames right down into the Estuary and river side lands.
Also the Thames Policy Area has not been superimposed onto the other maps relating to the functions of the River especially the river side land and also the important river tributaries in the OPEN SPACE and the BIODIVERSITY maps
----------------------------------------------------------------------------
----------------------------------------------------
"3.3 As a general approach, Thamesbank believes that the whole of the LP is in issue, not just the textual changes proposed by the Further Alterations.
4 Areas of Concern for Thamesbank
4.1 The main issues of concern for Thamesbank are:
(i) A lack of recognition of the value of the Thames and its environment as a single living entity;
(ii) A lack of recognition of the Thames and river land as part of the realm of open space and a key element of London's natural environment which should be given special status and protection;
(iii) The incremental loss of unique river land (ie the foreshore and land immediately adjacent to it) for non-river related purposes, and the need to afford river land special status (eg through a designation of 'blue belt' or 'blue field');
(iv) The lack of a holistic approach to the river and the absence of overall responsibility, coordination or management of the river environment;
(v) The lack of genuine stakeholder engagement and involvement in environmental decision-making for the river.
5 Issues in London Plan
5.1 The Mayor's overall vision for London is to become an exemplary sustainable world city (page vii-xv). Following this, the Mayor has produced a set of 6 objectives to guide the policies of the LP. Objective 6 is: to make London a more attractive, well-designed and green city, and includes a policy direction to enhance the use and environment of the Thames and the Blue Ribbon Network (page xxv). The reference to the Thames and the Blue Ribbon Network in the Objectives was a major success of Thamesbank's
involvement in the original consultation and EiP of the draft LP in 2003.
5.2 The main purpose for the review of the LP is to include policies on climate change. The key policies addressing adaptation to climate change (Chapter 4A, pages 208-216) are highly relevant for Thamesbank, dealing with flooding and sewage issues.
5.3 The Blue Ribbon Network (BRN) refers to London's network of rivers, canals and waterways and has a specific set of policies relevant to it at Chapter 4C (page 263-287). The policy for Sustainable Growth Priorities for the Blue Ribbon Network (Policy 4C.12, page 270) remains unchanged. This policy was a major issue of debate for Thamesbank at the previous EiP. This is the most relevant part of the LP for the purposes of Thamesbank.
5.4 Appendix 1 contains important tables of relevance: Table 3D.1 London's public open spaces hierarchy (page A68) and Table 3D.2 Draft Targets for Restoration and Re-creation of Priority Habitats (page A69).
5.5 London Plan Performance Indicators are contained in Table 6B.1 (pages A87 - A89) and are set against each of the Objectives and linked to specific policy. Targets numbers 14 (passenger and freight transport) (page A88) and 24 (functional flood plain) (page A89) are the most relevant.
6 Detailed Issues in Further Alterations
6.1 There is a concern that the definition of the BRN is too limited. The definition is provided at paragraph 4.77 (page 265). It does not include any river land. Thamesbank therefore wishes to challenge this definition and widen it so that BRN policies have a wider scope.
6.2 The term natural environment is rarely used. Thamesbank is concerned that there is no sufficient and clear distinction in the LP between natural and built environment and no clarity of how these relate to the Thames. Thamesbank believes natural environment should be defined and should expressly incorporate the River and river land.
6.3 The term natural environment has been used in the following policies:
(i) The Sustainable Design and Construction Policy, see Policy 4A.2i Chapter 4A (Climate Change and London's Metabolism) (page 199), fourth bullet point on page 200. This policy is relevant to the concerns over climate change.
(ii) The Design Principles for a Compact City, see Policy 4B.1 Chapter 4B (Designs on London) (page 240), ninth bullet point on page 241.
6.4 The Blue Ribbon Network Principles (BRN Principles) are a series of five principles based upon the five river functions contained in RPG3b/9b. The LP stated that planning decisions should be based on the Blue Ribbon Network Principles (Policy 4C.1 and paragraph below, page 266). This requirement is being deleted, as is the background reference in paragraph 4.76 (page 265).
6.5 An example of this may be identified in the deletion of the Royal Docks Policy (Policy 4C.33, page 285), including the reference to taking a precautionary approach. The reference to BRN Principles in paragraph 4.140 (page 285) is deleted and replaced with the Mayor's policy. Thamesbank is
concerned to ensure the inclusion of the principles of the five river functions from RPG3b/9b and the maintenance of a clear and transparent set of principles for the river as a basis for decision-making.
6.6 Thamesbank is concerned over the lack of priority given to the river in the open space hierarchy contained in Table 3D.1, page A68. Linear open spaces include open spaces and towpaths alongside the Thames, canals and other waterways, but are placed last.
6.7 The new policy relating to flood risk management (Policy 4A.5v and Policy 4A.5vi, page 209) is not adequately implemented in performance indicators and targets:
(i) The London Plan Performance Indicators (Table 6B.1, page A87) provide for a sustainable approach to flood management (target 24, page A89), as being 'no net loss of functional flood plain within referable applications'. This seems to be a reduction of the target from the published version.
(ii) The draft targets for Restoration and Re-creation of Priority Habitats (Table 3D.2, page A69) list the Tidal Thames and Rivers and Streams. The targets are considered minimal.