Notes on the London Plan

Notes on the London Plan

Prepared by Penny Noy, Jan 2010

We have a copy of the plan, which is also available online (here), and I have been studying it with reference to the food and growing aspects. However, though the my notes are mostly food and growing related, I have referenced other aspects as well, if they seemed significant.

Below you will find comments on specific policies or paragraphs, and a list of related documents at the bottom. These other documents are very useful, especially for relevant statistics.

Sect 0.2 ‘The London Plan is intended to be the overall strategic plan for London, setting out an integrated economic, environmental, transport and social framework for the development of London over the next 20-25 years.

Sect 0.4 ‘The Mayor has to have regard … to: … climate change and the consequences of climate change … achieving sustainable development in the United Kingdom … promoting use of Thames for freight transportation … reducing health inequality and promoting Londoner’s health’

Sect 0.10 ‘(The Mayor) has also published ‘Leading to a Greener London’, and environment programme for the capital.’ **

Sect 0.11 Refers to ‘Sustainability Appraisal and Habitats Regulations Assessments’

Sect 0.14 The Sustainability Appraisal is included in the Integrated Impact Assessment **

Sect 0.25 ‘public involvement … reflects the principles in the Aarhus Convention on access to information, public participation and access to justice in environmental matters which has been ratified by the UK Government.

Policy 2.18 ‘Green Infrastructure: the network of open and natural spaces’

Strategic A: ‘The Mayor will work … to secure benefits including … local food production, mitigating and adapting to climate change …’

Planning decisions: E ‘Development proposals should … develop the innovative use of street trees.’

Sect 2.80 ‘Green infrastructure performs many of the following functions: … as a place for local food production, in line with the Mayor’s ‘Capital Growth’ strategy … as an outdoor classroom’

Policy 5.10 ‘Urban Greening’ Strategic B The mayor seeks to increase the amount of surface area greened in the Central Activities Zone by at least five per cent by 2030, and a further five per cent by 2050’. * Could submit these areas should be greater. Also conflicts with the KPI of reduction of gardens per year allowed.

Policy 5.11 ‘Green roofs and development site environs’ Planning decisions A ‘Major development proposals should be designed to include roof, wall and site planting, especially green roofs and walls where feasible, to deliver … adaptation to climate change (ie aiding cooling) … mitigation of climate change (ie aiding energy efficiency) … growing food.

Policy 5.13 ‘Sustainable drainage’ Planning decisions A ‘Development should utilize sustainable urban drainage systems … in line with the following drainage hierarchy: 1 store rainwater for later use’ … 7 discharge rainwater to the combined sewer.’

Policy 5.16 ‘Waste self-sufficiency’ Strategic A ‘The Mayor will work … to a) manage as much of London’s waste within London as practicable … c) work towards zero waste to landfill by 2031.’ – more detail on how this is to be achieved.

P136 Developments for manufacturing from recycled waste.

P144 cycle parking and promoting walking by improved urban realm

P153 Increase of cycling to at least 5% of modal share

P155 walking – ‘significant increase’

P156 Improving local services to reduce the need for travel

P166 matrix of cycling and walking schemes

P173 ‘Blue Ribbon Network’ map – rivers and canals.

P173 ‘London’s public spaces … easy to understand and maintain … incorporate the highest quality landscaping, planting, furniture and surfaces’ * could submit that this leaves out importance for the future for resilience – add something along permaculture lines.

P174 ‘green the urban realm’ ‘making the most of existing vegetation. Mayor’s aim for 2 million trees to be planted in London * Make these productive.

Policy 7.4 Architecture * could add about green roofs here, though there is a separate entry for that.

P185 Green belt strategy – Metropolitan Open Land defined.

P187 Public open space hierarchy.

P188 Woodland – * no mention of the use of the woodland, just about increasing it. Sometimes there is no conflict between use of the trees and maintaining biodiversity – again permaculture, or something about maintaining habitats. Ok, but this is a section about biodiversity.

P191 Trees and woodland – the Mayor will produce ‘supplementary guidance’ * is this adequate?

P192 ‘Wherever possible the planting of additional trees should be included in new developments’ * should be stronger, and something about the type and purpose of the trees.

7.53 There are 7 million trees in London (a quarter in woodland). The mayor wants to see an increase in tree cover with an additional 2 million trees by 2025, plus 10,000 street trees. * Should say how many per year, and about type of trees. ‘Right place, right tree’ is how the type of tree is decided. See ref 33 ‘London Tree and Woodland Framework’ GLA, 2005 **

Policy 7.22 ‘Land for Food’ looks good, but doesn’t have targets. Apart from Capital Growth having 2,012 new food growing spaces by 2012. Useful points about benefits. ***To do: copy section. Reference to the Mayor’s ‘Food Strategy’. Ref 34 ‘The Mayor’s Food Strategy’ LDA, 2006 **

P195 national planning policy – use water based transport. Increasing use of Blue Ribbon Network for freight – safeguarding of wharves.

P198 Some original rivers are now part of the sewage network. Key Performance Indicators section

P206 Key Performance Indicators ‘ No more than 120 residential units to be developed on garden land / year’ * This should be reduced or go the other way.

P207 45% of waste recycled / composted by 2015 0% to landfill by 2031 Zero carbon in residential developments by 2016

Indicative Actions section

P209 Forestry Commision – Produce guidance on Borough Tree Strategies. Nothing in ‘indicative actions’ for the implementation plan on food growing. Not sure about locally sourced/ UK food. * Add something about food growing

General talk of ‘intensification’ of many areas. * Wrong language to be talking about intensification, though there is a commitment to increase the number of houses.

General submission notes

The London Plan in relation to trees appears to be motivated primarily by the need for climate change mitigation and adaptation, and to make the environment more attractive (‘greening the urban realm’) to encourage walking, health in general. It also notes that the urban green spaces are and educational environment. Food growing is regarded as useful for enjoyment, wider access to good food, and food security. However, trees are not seen as a productive resource. I would like to write a submission that qualifies the undertaking to plant 2 million extra trees and 10,000 street trees to plan that a proportion of these should be productive – either fruit or nut trees, or other productive trees – suitable for coppicing for fuel or wood production, to produce fibres etc. – there also needs to be an investigation into the possibilities for this, unless this has already been done.

Add text ‘making such trees productive wherever possible, for example for fruit, nuts or fuel through coppicing and in general extending the concept of green spaces to include this kind of productivity – not just associated with formal food growing spaces such as allotments, community orchards and gardens.

There is a wider discussion needed of the need to increase food resilience dramatically, and to discuss the whole input-output of the ‘greening’ that is much discussed (although the wastes from green areas would probably be composted – it is more about the overall purpose to be productive)

*Possible submission

** Related documents, see below


Healthy and Sustainable Food in London: The Mayor’s Food Strategy, May 2006, GLA The London Food Strategy focuses on five themes; health, environment, economy, social/cultural and security. These themes capture the breadth of issues affecting food and affected by food, and incorporate the Mayor’s cross-cutting themes of health, equality and sustainability. Corresponding to these five themes, the London Food Strategy has five broad objectives. They are:

  1. to improve Londoners’ health and reduce health inequalities via the food they eat
  2. to reduce the negative environmental impacts of London’s food system
  3. to support a vibrant food economy
  4. to celebrate and promote London’s food culture
  5. to develop London’s food security.

Connecting Londoners with Trees and Woodlands: A Tree and Woodland Framework for London, March 2005, GLA Objective D4 Support the use of local tree and woodland products as part of sustainable management of the resource Products from woodlands are numerous, and include timber for construction, wood for the craft industry, fencing and furniture, grazing, wood and charcoal for fuel, and foods such as fungi and berries. But very few of the woodlands in London are now managed on a commercial basis. Energy production offers one of the most significant areas of potential. The London Bioenergy Report28 found that arboricultural operations carried out in London by contractors working for local authorities generate much material suitable for processing into a biomass fuel per year. If used to generate heat, this could result in a significant reduction in London’s net CO2 emissions.

Leading to a Greener London, July 2009, GLA P19 Studies show that increasing tree cover by 10 per cent can reduce the surface temperature of a city by between three and four degrees centigrade21. We aim to increase tree cover across London from 20 per cent today to 25 per cent by 2025 – around two million additional trees – with a further five per cent increase by 2050. We will investigate the right places to plant trees to deliver the greatest benefits, complementing our existing work that has determined the right species of tree22 to suit local circumstances in the face of a changing climate.

Right Trees Campaign ‘We need to ensure that the trees we are planting now in London and other urban areas will thrive in the face of a changing climate and also help us cope with the predicted warmer temperatures and changes in weather patterns we will experience for the rest of the century.’ Primarily looking at climate change – not food security. Also referenced in the London Tree and Woodland Framework as a report to be completed by the Forestry Commision.

From the Just Space draft response

Policy 7.22 Land for food growing draft of Just Space response to Draft Replacement London Plan 6 January 2009 30 This policy is far too short given the importance of the London Food Strategy. For example, there could be better integration with street markets and with ecological diversity. The Mayor should require boroughs to increase the number of allotment sites, and to earmark other land for food production e.g. by encouraging use of derelict land for allotments. There should be encouragement for the concept of edible estates and to ensure permaculture design principles are given priority in the planning of residential development and open space management. Without the London Plan making this a strategic priority, Boroughs are in a weak position if they introduce policies to require developers to provide space for local food production. Mayoral initiatives and funding to increase the capacity of allotments should be spelt out in the London Plan (see also local food growing and distribution within Policy 2.18).

Areas considered for submission:

  1. Community growing, food hubs and mapping for promoting local and national food resilience – should be more. Hard to do
  2. Use of trees – something explicit about this, though it may be in the other document: a) In the context of general woodland, b)In the context of planting trees in streets and open areas
  3. Outputs (compost, fruit, wood etc) and inputs of land and more general concept of productivity as in permaculture
  4. Forestry commission is main body for advice on trees – is this ok?

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