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Agenda Item 11
Agenda item:
[No.]
CABINET 26 January 2010
Report Title. LB Haringey comments on the draft replacement London Plan (LP), the draft London
Economic Development (EDS) Strategy and the draft Mayor’s Transport Strategy(MTS)
Report of Niall Bolger
Signed :
Contact Officers : Marc Dorfman ext 5538/ Sule Nisancioglu ext 5562 /Ambrose Quashie ext
6914 (Planning and Regeneration); Joan Hancox (/Sustainable Transport) ext 1777
Wards(s) affected: All
Report for: Key
1.
Purpose of the report (That is, the decision required)
1.1
The Mayor published three major draft policy documents for consultation in October and is
seeking views from the Boroughs, public agencies and all stakeholders. These are
• Draft replacement London Plan (LP)
• Draft Economic Development Strategy (EDS)
• Mayor’s Draft Transport Strategy (MTS)
1.2
Following the publication of these strategies, the London Development Agency’s (LDA)
draft Investment Strategy was published in December. This sets out the broad investment
priorities for 2010-2013 with the intention of supporting the delivery of outcomes identified
in the replacement London Plan, draft MTS and draft EDS.
1.3
This report sets out the Council’s response to all draft strategies. The response to the
LDA’s Investment Strategy is incorporated into the responses to the draft replacement
London Plan, draft MTS and draft EDS.
1.4 The proposed Borough’s key comments are set out in the main body of the report at Section
7. In Appendices 1-4, summaries of the 3 Plans/Strategies are set out along with both
proposed general and key comments.
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2.
Introduction by Cabinet Member (if necessary)
2.1
The London Plan is the Spatial Strategy to guide growth and development in the region.
The current plan was adopted in 2008. There are now a new set of draft proposals for a
replacement plan to provide a strategic framework for the development of London
between2011-2031. The proposed new Plan will need to be respected by the developing
Haringey Local Development Framework (2011-26) and will have more strength than the
current London Plan in terms of local planning decisions.
2.2
The Mayor also published two other draft strategies for consultation; the economic
development strategy and the transport strategy, both of which aim to support the new
vision and objectives set out in the draft replacement London Plan.
2.3
Whilst the Council supports the Mayor’s attempt to update and integrate these three
strategies, there are a number of areas where the Council has considerable concerns.
These are discussed in the report.
3.
State link(s) with Council Plan Priorities and actions and /or other Strategies:
3.1
The London Plan forms part of Haringey’s statutory development plan. The Haringey’s
Local Development Framework will need to reflect regional policies which have
implications for a number of policy areas including housing provision, use of industrial
land, quality of built environment, and safer communities, vitality of town centres, transport
policies and economic regeneration.
4.
Recommendations
4.1
It is recommended that Members endorses the proposed comments in Section 7 of this
report and in Appendices 1-3, and that these are submitted to the Mayor of London as The
Council’s formal comments on the draft replacement London Plan, Economic
Development Strategy and the Mayor’s Transport Strategy.
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5.
Reason for recommendation(s)
5.1.
The London Plan is the overall strategic plan for London setting out an integrated
economic, environmental, transport and social framework to guide the growth and
development in London between 2011-2031. The local planning decisions and the future
preparation of the spatial planning policy documents by the Council will have to comply
with the London Plan when it is adopted. EDS and MTS have implications for future
growth and investment in Haringey. It is therefore important for the Council to consider
and comment on these three documents. Summaries of draft strategies and the
Council’s key comments are listed below in Section 7. In Appendices 1-3, summaries of
the 3 Plans/Strategies are set out along with both proposed general and key comments.
6.
Other options considered
6.1.
The draft London Plan is produced as part of statutory process. The report sets out the
Council’s support, objections and comments on the draft replacement London Plan
proposals. There are no alternative options considered.
7.
Summary
Background
7.1
The Mayor published three major draft policy documents for consultation in October:
• Draft replacement London Plan (LP)
• Draft Economic Development Strategy (EDS)
• Mayor’s Draft Transport Strategy (MTS)
7.2
Below is a summary of these there draft documents. The proposed Borough’s key
comments are also set out in this section. In Appendices 1-4, summaries of the 3
Plans/Strategies are set out along with both proposed general and key comments.
7.3
Draft Replacement London Plan : The key challenges set out in the draft London are as
follows:
• A growing population, (9m by 2031), mainly forming smaller households
• An ever diverse population
• Continued economic growth but open to the global market and dependent on skill
upgrades and business innovation
• Persistent poverty and disadvantage
• Critical need to address climate change both in terms of mitigation and adaptation
• Careful and efficient management and use of resources available to London – since
there will be less over the first half of the plan period
• Strong neighbourhood and citizen desire for improved quality of life and safety
• Perceived tension between the demands of growth and the conditions for a good
quality of life, and a concern about the loss of things that have made living in London
and its neighbourhoods a distinctive experience.
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7.4
LP predicts that London is expected to grow by 14% with 600,000 additional households,
750,000 new jobs and 3 million additional journeys per day by 2031. The aim of the draft
Plan is to ensure that growth contributes positively to the quality of life in London and
takes place within current boundaries without encroaching on the Green Belt or open
spaces, or having adverse impact on the natural environment and natural resources. The
growth is expected to lead to demand for 40,000 more hotel rooms, 1.3 – 2.2 m2 of
comparison goods floorspace, 2.25 m2 of office space in central London alone and 33,000
more homes per annum across London. Securing the Legacy of 2021 is the highest
regeneration priority for the London Plan period.
7.5
The draft Economic Development Strategy (EDS), entitled ‘Rising to the Challenge’,
follows on from the EDS proposals published in May 2009 (which the Council responded
to), and seeks to position London as the premier global city, but with the highest standards
of quality of life. The strategy has five key aspirational objectives that focus on:-
• cementing London’s competitiveness as a leading centre for international business,
• managing climate change in the transition to a low carbon economy,
• ensuring that all Londoner’s have the skills now and in the future to take advantage
of new employment and enterprise opportunities,
• business development, and
• area regeneration.
7.6
Draft London Transport Strategy: The Mayor’s Transport Strategy (MTS) predicts that
by 2031, there will be additional 3 million journeys per day. A key challenge for the MTS is
to accommodate this additional demand for travel as well as address overcrowding on
public transport and traffic congestion. The draft MTS contains six key goals:
• support economic development and population growth
• enhance the quality of life for Londoners
• improve the safety and security of all Londoners
• improve transport opportunities for all Londoners
• reduce transport’s contribution to climate change and improve its resilience
• support delivery of the London 2012 Olympic and Paralympic Games and its legacy
7.7
General Comments
London Plan does not properly address the “urban challenge” that the City is facing |
7.7.1 Overall, Mayor’s three draft strategies do not set out a strong, clear and deliverable vision
for London. It is not clear what the key “urban challenge” is for London over the next 20
years.
Tackling poverty, deprived areas and climate change should be the challenge and
priority:
7.7.2 LBH sees tackling ongoing deprivation and poverty and climate change as key challenges
for London for this plan period. LP and associated strategies do not put enough priority on
dealing with poverty and disadvantage.
7.7.3 We propose as the key challenge” dealing with persistent poverty and deprived areas to
ensure equality of opportunity and growth at a time of serious concern about climate
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change and economic instability - and the limits of growth. There is a need for London to
have a diverse economy so it can future-proof its community and its role in the UK
economy…”
Growth Areas should be prioritised – Upper Lee Valley is critical
7.7.4 The Mayor supports all growth corridors with no specific prioritisation on tackling key areas
of deprivation and opportunity for growth and investment. Upper Lee Valley (ULV) corridor
is listed one of 30 New Strategic Outer London Development centres with a specific focus
on industry. It is an area identified for growth and change. However, the investment into
the already affluent growth areas is identified but no firm priority is given to the Upper Lee
corridor.
There should be stronger focus on economic development in Outer London
7.7.5 The employment has grown fastest in inner and central parts of London with comparatively
lower levels of employment growth in outer London. This new Plan is seen as an
opportunity to address the employment generation in Outer London. However, the key
focus for growth in all three strategies is still the Inner London and Central zone. None of
the strategies offer specific policies or actions to deal with disadvantage and economic
stability in Outer London.
London should invest in modern manufacturing and green industries
7.7.6 Despite policies on new and emerging economic sectors, it is clear from the LP and EDS
that the overwhelming focus is on central London and the financial and business services
sectors to secure London’s economic future. While this was to be expected an
opportunity has been missed in the draft strategy to set out in more detail how Outer
London can make more of a contribution to economic growth in the capital.
London Plan does not clearly enough argue the case for growth or show how a growing
population and sufficient homes can be accommodated in terms of community
infrastructure
7.7.7 The London plan supported by its key delivery strategies does not show strategically how
population and household growth will be supported in particular with adequate transport,
health and educational facilities – and the protection and growth of well located public
open space. This strategic framework needs to be in place to give residents businesses
and investors confidence that London will grow – but grow with quality services and
environment.
7.8 Key Comments on the New draft Replacement London Plan (LP)
7.8.1 The LP does not set out clear vision on how the proposed growth in London integrates
with transport and other infrastructure in a way that demonstrates a comprehensive future
spatial approach for the capital. The draft Plan is especially weak on delivery,
infrastructure requirements and implementation.
Growth Areas should be prioritised
7.8.2 The LP includes two growth areas of national importance – Thames Gateway and
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London-Stansted-Cambridge-Peterborough Corridor, of which Haringey is a part – as well
as those of importance to the wider south east region – London-Luton-Bedford,
Wandsworth-Croydon-Crawley (‘Wandle Valley’), and the Thames Valley/‘Western
Wedge’.
7.8.3 There is no prioritisation for investment between these growth areas. LBH suggests that
there should a prioritisation of opportunity areas and areas of intensification based on the
criteria of need. The Upper Lee Valley Corridor should be given a priority for investment.
More practical focus on Outer London
7.8.4 The focus on Outer London and its role in economic development is welcome. However,
the key focus for growth in all three strategies is still the inner London and central zone.
There is no prioritisation of town centres in Haringey and no strong orbital transport
proposals which is one of the key issues Outer London faces.
Opportunity Areas should also be the focus of improved services and local job creation
7.8.5 Policies for Opportunity Areas are very much focussed on “development and transport“.
There is not sufficient focus on access to services and jobs. More focus on outcomes for
people would increase access to jobs for people in Haringey and promote less reliance on
in-commuting. This in turn would release capacity for spend for more orbital transport
links.
Upper Lee Valley (ULV) should be priority amongst Growth Areas
7.8.6 The Upper Lee Valley corridor (ULV) is listed as having a focus as an industrial area but
there is no recognition that ULV could be a “green district”. We welcome commitment to
support new and emerging growth sectors and the emphasis given to the green sector
both in LP and the EDS. It is discouraging however to note that ULV, Marsh Lane and
Central Leeside area are not recognised for support for a “green industry district “.
7.8.7 LBH suggest that London Plan should have a strong description about content and spatial
vision for ULV Opportunity Area in the same way as there is for Central Activity Zone
(CAZ). This lack of emphasis on ULV indicates how centrist the draft LP still is.
ULV Opportunity Area should be extended to include the Tottenham Corridor
7.8.8 The Opportunity Area boundary in ULV should be widened west and move to at least the
rail line that runs from Liver pool street to Enfield Town. This will allow the Tottenham
Corridor to feature strongly in the Opportunity Area Planning Framework and properly
compete for growth funds for the delivery of homes and public realm improvements at the
heart of a persistently deprived community. It will also prove to be cost effective in terms of
external funding than supporting the creation of new residential communities in the middle
of the ULV strategic industrial and employment zone.
Definition of Areas of Intensification
7.8.9 We ask the Mayor to review its definition of “Areas of Intensification” to incorporate areas
where investment is needed for the regeneration of an area based on intensification in
cultural, leisure, heritage and entertainment activities. For instance, we propose Haringey
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Heartlands to be extended to include the whole Wood Green town centre and also include
areas such as the Alexandra Palace respecting its legal, public open space and cultural
purpose.
More emphasis on green industry development
7.8.10 LP and EDS shy away from setting out a strong and diverse economy for the capital
whose economic strength is equivalent to an average European country. There must be a
strong support for green industry as well a general innovation, and industrial land must be
kept for “elbow room” to allow new industry to locate on low value land in a high value city.
More emphasis on the protection of Strategic Industrial Land
7.8.11 This should be supported by increased emphasis on Strategic Industrial Land designation
which includes most of Upper Lee Valley with two industrial areas in Haringey (Tottenham
Hale area and the north east Tottenham. Loss of industrial land must slow significantly.
Cultural Areas declared for Haringey
7.8.12 There should be support for visitor economy in Haringey, and the north of the Borough
should be declared a “cultural area” (Tottenham Hotspurs and Green, Haringey Heartland
cultural quarter, Green Lanes and Alexandra Palace).
Concern about Affordable Housing Delivery
7.8.13 The removal of the 50% affordable housing target could be problematic for areas such as
Haringey with already high levels of social and intermediate housing as pressure could be
exerted to achieve higher housing targets to balance out lower targets in other parts of
London. The Mayor needs to set out how, by removing this target, he will ensure an
adequate spread of affordable housing across London; this will be crucial in helping to
reduce the social polarity that is highlighted in the London Plan. Consideration should be
given to including a strategic percentage figure in the London Plan.
Concern about Housing Supply
7.8.14 The draft Plan sets new housing targets for Haringey as 820 units per year between
2011-2021. This is based on a London-wide study of Strategic Housing Land Availability
Assessment Study. We understand that Haringey figures include sites already identified in
the UDP.
7.8.15 However, we are concerned that the draft London Plan does not provide sufficient
information on how this growth will be supported by necessary social, physical and green
infrastructure, and Council would like more clarity and discussion with the GLA on this
particular issue.
Concern about Traveller Policy
7.8.16 We note that Haringey is required to provide 25 additional pitches for Gypsies and
Travellers. We query the methodology for these figures. It is not clear why Haringey is
allocated more additional pitches than some of our neighbouring boroughs. A clarification
is needed for figures quoted in the draft Plan and we look forward to a more equal
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distribution of sites across the subregion.
Minimising carbon dioxide emissions
7.8.17 The justification text for the Renewal Energy Policy refers to the presumption that all major
development proposals will seek to reduce CO2 emission by at least 20 percent through
the use of onsite renewable energy generation wherever feasible. We feel that the text is
more appropriate for the policy rather than the justification text.
7.8.18 We support in principle that where, exceptionally, carbon reductions cannot be met on site
any shortfall may be provided off-site or through in lieu cash payments, and the principle
that funds can be pooled to meet carbon reduction emissions where on-site reduction
cannot be fully met through borough-based carbon saving projects.
Concern about Community Infrastructure provision for Growth
7.8.19 LP lacks enough evidence to show how community infrastructure will support the predicted
growth. This assessment appears to be largely left to the boroughs. Whilst Haringey
supports Mayor’s new emphasis on “strong neighbourhoods”, failure to show how growth
can be accommodated in terms of infrastructure is very disappointing.
Concern about transport over crowding and congestion
7.8.20 LP and Transport strategy does not address infrastructure implications of the population
and household growth. The draft Plan should set out how specific measures will be
promoted and delivered to support this growth and also support policies on road
congestion and climate change. This is especially important in the light of information set
out in the Mayor’s draft Transport strategy for overcrowding in tube and rail connections.
Lack of orbital transport in Haringey
7.8.21 It should be recognised there are very few strong orbital transport projects in any of three
strategies, and the rail improvements will do more for commuters than Haringey residents
and businesses.
Concern about split of responsibility between local and strategic action
7.8.22 Lack of a clearer framework for the capital’s future direction and development, coupled
with a significantly high number of “loose” policy issues left to boroughs to determine at
local level will have implications for increased workload for local councils during the next
review of Core Strategies. On the other hand, in a number of cases the Planning
Decisions section contains material that is of an inappropriate level of detail for a strategic
plan (e.g. policies 5.9 Overheating and Cooling, 7.6 Architecture).
7.9
Key Comments on the draft Economic Development Strategy (EDS)
Proposed London economy is too narrowly focused
7.9.1 The key focus of the EDS appears to be a London as a world city whose economic
success is mainly based on finance, business opportunity and hospitality.
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Need for focus on “good business” as an aim – not just any business
7.9.2 EDS focuses too much on developing a good climate for business development and not
enough on developing “good businesses” and businesses with good business skills. Good
business is about firms which are more socially and environmentally aware.
EDS should focus more on deprived communities and neighbourhoods
7.9.3 EDS has the same flaw as the new draft LP and MTS. It has too many priorities. The
document should be more focussed on improving economic development ability of
deprived communities and neighbourhoods. The role of the London Development Agency
(LDA) should not be reduced to just an enterprise agency. There are others such as the
London First to play that role. The LDA should also focus on need and creating
opportunities for a more to meet that need.
7.10
Key Comments on the Mayor’s draft Transport Strategy (MTS)
LP and MTS should be more “polycentric” – still too focused on cental London and
support for commuting
7.10.1 MTS shows that congestion will be the same or worse by the end of the strategy
period/LP period. This is not a sustainable outcome. The strategy does not set out
sufficient measures to reduce commuting
7.10.2 All three strategies are based on prediction that most of employment growth will be in
Inner London, Central Activity Zone and along Cross-Rail route. This is an area which
is already supported for growth and amelioration of disadvantage. This pattern of
growth will reinforce the existing radial travel patterns and transport links, which are
already overcrowded. The reinforcement of existing radial travel patterns will not
reduce the need to travel or lead to shorter journeys being made and it will make it
even more difficult in the future to change the dominance of radial patterns.
7.10.3 A polycentric approach to growth around London metropolitan town centres and
interchanges with investment in orbital routes should be considered as this can
promote less local travel by car.
Critical Haringey strategic transport projects must be delivered
7.10.4 Haringey Council welcomes the publication of the MTS at the same time as the draft
London Plan and EDS to allow a comprehensive view of emerging policies and the
work on integrating planning and transport policy. The MTS provides details of possible
public transport expansion such as 4 tracking of West Anglia lines. However, this is
not committed.
7.10.5 The investment in the Gyratory is committed and this project must be delivered. We
emphasise the importance of works at Tottenham Gyratory to facilitate regeneration
and sustainable growth in this part of London.
7.10.6 We welcome the opportunity to work with TfL on progressing some of the
infrastructure proposals such as a review of the Hackney-Chelsea Line.
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More support for transport interchanges
7.10.7 The need for investment applies to the improvement in interchanges and stations.
Seven Sisters/South Tottenham, Finsbury Park and Tottenham Hale are identified as
priority strategic interchanges although Wood Green as a key bus/tube interchange is
not identified as such.
More support for travel demand management and changing travel behaviour
7.10.8 There should be more demand management. Otherwise congestion will not be
addressed and carbon emissions will continue to grow. There is a need for more
specific measures identified for more restrictions on destination car parking; more
congestion charge pilots; restricting single occupancy trips; promotion of cycling,
walking, school and work place travel plans. Smoothing traffic flow is supported but
only if number of car trips is reduced.
7.10.9 More support is needed for transport behavioural change in outer London.
7.10.10 Measures for improving and managing congestion for North Circular should be
smoothing traffic flow and improvement measures should not lead to road capacity
being increased. Priority for public transport improvements must support internal
London movement and not commuting.
8.
Chief Financial Officer Comments
8.1
There are no direct financial implications for the Council and the cost of preparing this
response has been contained within existing budgets. However, the draft plan and the
strategies mentioned above have implications for the infrastructure investment in the
subregion and in Haringey. These issues are highlighted in relevant policy sections in the
Haringey’s draft response and as these strategies evolve into more specific proposals and
projects that require decisions on funding, reports will be presented to the relevant
Committee as necessary.
9.
Head of Legal Services Comments
9.1.
The London Plan is 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.
9.2.
The draft plan sets out a vision, policies and explanatory supporting material (reasoned
justification) to guide the growth and development in London between 2011-2031. The
local planning decisions and the future preparation of the spatial planning policy
documents by the Council will have to comply with the London Plan when it is adopted.
10.
Head of Procurement Comments – [Required for Procurement Committee]
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11.
Equalities &Community Cohesion Comments
11.1 The London Plan is the responsibility of the Mayor of London. Equalities and diversity is
one the key themes in the draft replacement London Plan. However one of the key
concerns of Haringey is that there is not enough priority given to deliver people focussed
outcomes. Including tackling deprivation.
12.
Consultation
12.1
The draft London Plan policies require a corporate response, and council services were
invited to make an input to the Haringey’s response to the draft London Plan. The
following services have provided an input into the development of Haringey’s (draft)
response to the Replacement London Plan: Economic Regeneration, Leisure, Transport
Policy (comments on Mayor’s transport strategy). Draft Transport strategy was reported
to CAB, and the EDS was reported to CEMB. LDF Members Advisory Group were
consulted on the implications of the three draft strategies. This report incorporates and
integrates comments received so far on these three strategies.
12.2
Consultation on Mayor’s strategies ends on 12th January 2010. An interim response to the
Mayor of London was submitted by 12th January 2010. Due to the Cabinet cycle, the GLA
has agreed to accept Haringey’s formal comments at the end of January after the Cabinet
decision by 26th January.
13.
Service Financial Comments
13.1
There are no direct financial implications for the Council. However, the draft plan and the
strategies mentioned above have implications for the infrastructure investment in the
subregion and in Haringey. These issues are highlighted in relevant policy sections in the
Haringey’s draft response.
14.
Use of appendices /Tables and photographs
Appendix 1- Key Diagram - Draft Replacement London Plan
Appendix 2- Comments on the Draft Replacement London Plan (LP)
Appendix 3- Comments on the Draft Economic Development Strategy (EDS)
Appendix 4- Comments on the Draft Mayor’s Transport Strategy (MTS)
1.
Local Government (Access to Information) Act 1985
15.1 The following documents were used in the preparation of this report:
•
Draft New London Plan (2009)
•
Draft Economic Development Strategy (2009)
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•
Draft Mayor’s Transport strategy (2009)
•
LDA Investment Plan (2009)
•
Adopted London Plan (2008)
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APPENDIX 1- Key Diagram (draft London Plan October 2009)
Figure 1: Key Diagram – draft
Replacement London Plan)
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APPENDIX 2 – COMMENTS ON THE DRAFT REPLACEMENT LONDON PLAN
(October 2009)
1
Context and Strategy
1.1 The general approach of the draft replacement London Plan is supported: to ensure that
growth contributes positively to the quality of life in London and takes place within current
boundaries without encroaching on the Green Belt or open spaces, or having adverse
impact on the natural environment and natural resources.
1.2 However, we do not consider that the draft Plan sets out a clear vision and strategy for
the future of London. It is especially weak on delivery, infrastructure requirements and
implementation. We propose as the key challenge for the Plan as follows¨
” Dealing with persistent poverty and deprived areas to ensure equality of opportunity
and growth at a time of serious concern about climate change and economic instability -
and the limits of growth. There is a need for London to have a diverse economy so it
can future-proof its community and its role in the UK economy.”
2
London’s Place
2.1 Policy 2.3 Growth Areas: The Mayor supports all growth corridors with no specific
prioritisation on tackling key areas of deprivation and opportunity for growth and
investment. Upper Lee Valley (ULV) corridor is listed one of 30 New Strategic Outer
London Development centres with a specific focus on industry. It is an area identified for
growth and change. However, the investment into the already affluent growth areas is
identified but no firm priority is given to the Upper Lee corridor.
2.2 The Upper Lee Valley corridor (ULV) is listed as having a focus as an industrial area but
there is no recognition that ULV could be a “green district”. We welcome commitment to
support new and emerging growth sectors and the emphasis given to the green sector
both in LP and the EDS. It is discouraging however to note that ULV, Marsh Lane and
Central Leeside area are not recognised for support for a “green industry district “.
2.3 LBH suggest that London Plan should have a strong description about content and spatial
vision for ULV Opportunity Area in the same way as there is for Central Activity Zone
(CAZ). This lack of emphasis on ULV indicates how centrist the draft LP still is.
2.4 Policy 2.5 Sub-regions: New boundaries for the sub-regions are set for monitoring
purposes and they are flexible to respond joint working arrangements for specific issues.
This is welcome. It is important to emphasise that sub-regional working takes place in a
flexible way to ensure that sub-regions and boundaries are most suited to a specific
issue, and that existing cross-borough arrangements are not jeopardised.
2.5 Policy 2.6 Outer London Vision: The emphasis on Outer London is welcome. However,
it is clear from the draft Plan that the overwhelming focus is on inner London and Central
Activity Zone and already affluent growth areas. This is an opportunity missed in setting
out in detail how Outer London can make more of a contribution to economic growth in
the capital and how opportunities identified by the Outer London Commission can be
realised.
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2.6 Policy 2.7 Outer London Economy: Recognition of need for job creation based on its
diversity and strengths focus on town centres and quality of life, transport links between
town centres and orbital routes is welcome. The draft Plan is seen as an opportunity to
address the employment and job issues in Outer London. However, the key focus for
growth in all three strategies is still the inner London and central zone. None of the
strategies offer specific policies or actions to deal with disadvantage and economic
stability in Outer London.
2.7 Policy 2.8 Outer London Transport: It should be recognised there are very few strong
orbital transport projects in any of three strategies, and the rail improvements will do more
for commuters than Haringey residents and businesses
2.8 Policy 2.13 Opportunity Areas and Intensification Areas: We welcomed the continued
designations for the Upper Lee Valley including Tottenham Hale as one of the opportunity
areas and Haringey Heartlands as an Area of Intensification. They are among 43 such
areas identified across London. We suggest that that there should a prioritisation for
investment in opportunity areas and areas of intensification based on the criteria of need.
The Upper Lee Valley Corridor should be given a priority for investment. The investment
into the already affluent growth areas is identified but no firm priority is given to the Upper
Lee corridor. One example we would like to highlight is the transport infrastructure, for
instance the extension of Victoria line to Northumberland Park and beyond to Enfield.
2.9 OAPF for Upper Lee Valley area: ULV Opportunity Area should be widened west and
move to at least the rail line that runs from Liverpool street to Enfield – this will allow the
Tottenham Corridor to feature strongly in the Opportunity Area Framework (OAPF) and
properly compete for growth funds for the delivery of homes and public realm
improvements at the heart of a persistently deprived community. It will also prove to be
cost effective in terms of external funding than supporting the creation of new residential
communities in the middle of the ULV employment zone
2.10 Definition of Areas of Intensification (page 254) and Policy 2.13 : We ask the Mayor
to review its definition of “Areas of Intensification” to incorporate areas where investment
is needed for the regeneration of an area based on intensification in cultural, leisure,
heritage and entertainment activities. For instance, we propose Haringey Heartlands to
be extended to include the whole Wood Green town centre and also include areas such
as the Alexandra Palace respecting its legal, public open space and cultural purpose.
2.11 Policy 2.15 Town centres: Emphasis on town centres as key drivers for development
capacity and as focus for attractive business and public realm is welcome. However,
there is no prioritisation of town centres in Haringey and no strong orbital transport
proposals which is one of the key issues Outer London faces.
2.12 Policy 2.16- Strategic Outer London Development Centres- Upper Lee Valley (ULV) is
one of 30 centres New Strategic Outer London Development centres with a specific focus
on industry. Haringey welcomes this. However we would like more explicit emphasise in
the Plan for the ULV especially for green industries and low carbon technologies.
2.13 Policy 2.17 Strategic Industrial Land: Haringey welcomes the strengthened Strategic
Industrial Land Policy. It is noted that the SIL designations do not include Haringey
Heartlands- It covers Tottenham Hale and North East Tottenham. Proposal for a more
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flexible approach to car parking for office development in outer London is supported as
the current standards are unrealistic.
3
London’s People
3.1 Policy 3.3- Increasing Housing Supply and Table 3.1: The draft Plan sets new housing
targets for Haringey as 820 units per year between 2011-2021. This is based on a
London-wide study of Strategic Housing Land Availability Assessment Study developed
with input from all London boroughs. The Haringey figures include sites already identified
in the current UDP. However, we are concerned that the draft London Plan does not
provide sufficient information on how this growth will be supported by necessary social,
physical and green infrastructure, and Council would like more clarity and discussion with
the GLA on this particular issue.
3.2 Policy 3.5 Quality and Design of housing development and table 3.3: The minimum
space standards set out in Mayor’s draft Housing Design guide are included in the Plan
and new housing is to meet space standards. Haringey is supportive of the proposed
standards and welcomes its application to all tenures including private sector housing.
3.3 Policy 3.9 – Gypsy and Travellers sites- We note the pitches required for the Gypsies
and Travellers. Haringey is required to provide 25 additional pitches. We query the
methodology for these figures. It is not clear why Haringey is allocated more additional
pitches than neighbouring boroughs such as Enfield. A clarification may be needed for
figures quoted in the draft Plan and we look forward to a more equal distribution of sites
across the sub-region.
3.4 Policy 3.12 Affordable Housing- Boroughs can decide to set their affordable housing
targets in absolute or percentage terms. Haringey’s current policy is to continue to seek
50% affordable housing across the borough which is based on Housing Needs study
2007. However, the removal of the 50% housing target could be problematic for areas
such as Haringey with already high levels of social and intermediate housing as pressure
could be exerted to achieve higher housing targets to balance out lower targets in other
parts of London. We question how, by removing this target, the Mayor will ensure an
adequate spread of affordable housing across London; this will be crucial in helping to
reduce the social polarity that is highlighted in the London Plan. Consideration should be
given to including a strategic percentage figure in the London Plan. Consideration should
also be given to the likely adverse impact of removing a percentage target figure for
London on land prices. Targets can provide clarity to developers and landowners on likely
affordable housing contributions, and reduce the likelihood of competitive bidding for
scarce sites.
4
London’s Economy
4.1 Policy 4.1 Developing London’s Economy: Employment has grown fastest in inner
and central parts of London with comparatively lower levels of employment growth in
outer London. This Plan is seen as an opportunity to address the employment and job
issues in Outer London. However, it is clear from the Plan and the draft Economic
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Development Strategy (EDS) that the overwhelming focus is still on central London and
the financial and business services sectors to secure London’s economic future. While
this was to be expected an opportunity has been missed in the draft strategy to set out in
more detail how Outer London can make more of a contribution to economic growth in the
capital. For example, the EDS strategy highlights sectors such as health and social work,
which have significant representation in Outer London. However, continuing with the
example of health and social work, no link is made to the emerging personalisation
agenda and how the growth of social enterprises can be supported through this.
4.2 Also there are also other sectors to consider - a good starting point in the identification
process would be the new national Skills Strategy, which highlights the following sectors:
life sciences; digital media and technology; advanced manufacturing, engineering and
construction; and low carbon technology. It is particularly important to consider a more
diverse range of growth sectors to mitigate against a scenario of lower than expected
population and employment growth.
4.3 Policy 4.4 - Managing industrial land and premises: Haringey welcome the rigorous
approach promoted by the draft Plan on ensuring there is sufficient stock of land and
premises to meet the future needs of different types of industrial and related uses. It is
noted that the SIL designations for Haringey Heartlands is removed although local
designations still apply. SIL designations cover Upper Lee Valley inc Tottenham Hale
and North East Tottenham in Haringey as having a focus as an industrial area but no
details as to what this means
4.4 Policy 4.5 and Policy 4.6 –Visitors economy and Arts, Cultural and Entertainment: We
welcome the emphasise on Outer London for new arts, cultural and visitors attraction.
There should be support for visitor economy in Haringey and the north of the Borough
could be declared a strategic cultural area (Tottenham Hotspurs / Haringey Heartland
cultural quarter and Alexandra Palace and Park).
4.5 Policy 4.10 Emerging New sectors: We welcome commitment to support new and
emerging growth sectors and the emphasis given to green sector. However, it is
discouraging that the ULV, Marsh Lane and Central Leeside area are not recognised for
support for a “green industry district “.
5. London’s response to Climate Change
5.1 The removal of the current strategic target for new developments is a concern. The
justification text refers to the presumption that all major development proposals will seek to
reduce CO2 emission by at least 20 percent through the use of onsite renewable energy
generation wherever feasible. We feel that the text is more appropriate for the policy
rather than the justification text.
5.2 We support in principle that where, exceptionally, carbon reductions cannot be met on site
any shortfall may be provided off-site or through in lieu cash payments, and the principle
that funds can be pooled to meet carbon reduction emissions where on-site reduction
cannot be fully met through borough-based carbon saving projects.
6
Transport
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6.1 While we welcome the general approach to this section for promoting sustainable modes
of transport, the draft London Plan does not go much further than the general statements
in national planning policy guidance. It is important to state where the priorities are for
promoting sustainable travel, with private car given the least priority.
6.2 Table 6.3 – Indicative List of Transport Schemes- We note the list of transport
schemes, which will help to support predicted growth across London and the support
given to the Gyratory project. However, there has not been any attempt to link these
projects to the wider growth approach of the draft Plan. Transport is a key infrastructure
to support predicted growth. The draft Plan should set out how specific measures will be
promoted and delivered to support this growth and also support policies on road
congestion and climate change. This is especially important in the light of information set
out in the Mayor’s draft Transport strategy for overcrowding in tube and rail connections.
6.3 Policy 6.4 – Enhancing Transport Connectivity: The policy on transport connectivity is
supported. However, the importance of improvements to orbital routes should be
included especially for outer London boroughs. Outer London town centres and greatly
improved urban environment within town centres are key priorities. Wood Green is one of
12 identified town centres in London and MTS diagrammatically shows proposed
enhancements from north, south and the west to Wood Green. However, MTS envisages
enhancements to be better information and marketing for bus and rail links, improved
walking and cycle routes to/from town centres and maximising benefits of existing rail
services rather than any specific proposals for improving orbital routes.
7
London’s Living Places and Spaces
7.1 Whilst Haringey supports Mayor’s new emphasis on “strong neighbourhoods”, failure to
show how growth can be accommodated in terms of infrastructure, provision of open
space and quality public realm is very disappointing.
8
Implementation
8.1 It is crucial for the regional plan to demonstrate how the proposed policies will be
implementation and delivered (PPS 11 requirement). The Plan should have demonstrated
how the Mayor will be using the resources at his disposal and thorough his agencies and
others such as Homes and Communities Agency to support the delivery of Plan’s policies.
8.2 The draft Plan supported by its key delivery strategies does not show strategically how
population and household growth will be supported in particular with adequate transport,
health and educational facilities – and the protection and growth of well located public
open space. This strategic framework needs to be in place to give residents businesses
and investors confidence that London will grow – but grow with quality services and
environments.
8.3 The Plan lacks enough evidence to show how community infrastructure will support the
predicted growth. This assessment appears to be largely left to the boroughs.
8.4 We note the list of transport schemes, which will help to support predicted growth across
London and the support given to the Gyratory project. However, there has not been any
attempt to link these projects to the wider growth approach of the draft Plan. Transport is
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a key infrastructure to support predicted growth. The draft Plan should set out how
specific measures will be promoted and delivered to support this growth and also support
policies on road congestion and climate change. This is especially important in the light of
information set out in the Mayor’s draft Transport strategy for overcrowding in tube and rail
connections.
APPENDIX 3 - COMMENTS ON THE DRAFT ECONOMIC DEVELOPMENT STRATEGY
(EDS) October 2009
General points
1. Overall, the EDS alongside the revised London Plan and draft Transport Strategy does not
set out a strong, clear and deliverable vision for London. It is not clear what the key “urban
challenge” is for London over the next 20 years.
2. We see tackling ongoing deprivation and poverty and climate change as key challenges for
London for this plan period. The EDS and associated strategies do not put enough priority
on dealing with poverty and disadvantage. In our view the EDS has the same flaw as the
new draft LP and MTS: it has too many priorities. The document should be more focussed
on improving economic development ability of deprived communities and neighbourhoods.
3. We propose as the key challenge:”dealing with persistent poverty and deprived areas to
ensure equality of opportunity and growth at a time of serious concern about climate
change, economic instability and the limits of growth. There is a need for London to have a
diverse economy so it can future-proof its community and its role in the UK economy…”
4. While the draft EDS is a strategic document that provides more aspirational policy
objectives (relative to the London Plan and Transport Strategy) the implementation plan
that will accompany the final version of the EDS and Investment Strategy need to have
more detailed actions around delivering these objectives.
5. We have concerns that the links between the three draft strategies (London Plan, Transport
Strategy and EDS) do not set out clearly how proposed growth in London will be integrated
in a way that that demonstrates a comprehensive future spatial, transport and social
approach for the capital.
6. The proposals in the draft EDS are underpinned by the belief that London’s economy will
remain resilient to the effects of the recession and there will be robust growth in population
and employment up to 2031. However, there is no analysis of what the implications will be
if population and employment growth is not as robust as expected. This presents a major
gap in the draft EDS that we feel will need to be addressed in the final version.
7. It is clear from the draft EDS that the overwhelming focus is on central London and the
financial and business services sectors to secure London’s economic future. While this
was to be expected an opportunity has been missed in the draft EDS and Investment
Strategy to set out in more detail how outer London can make more of a contribution to
economic growth in the capital, an ambition that is articulated in the draft EDS. It will also
be particularly important to consider a more diverse range of growth sectors to mitigate
against a scenario of lower than expected population and employment growth.
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Objective 1: To promote London as a city that excels as a world capital of business
8. This objective seeks to sustain London’s leading place in the global economy by better co-
ordinating its marketing and promotion and exercising its global strengths to the full.
Key implications
9. The major risk is that work to sustain London global competitiveness will not focus on the
whole of London and just the central area of the capital.
Key comments
10. While we welcome the commitment to improve economic performance in outer London
more details are needed on how the Mayor will help to deliver this.
Objective 2: to ensure that London has the most competitive business environment in
the world
11. This objective seeks to strengthen London’s economic productivity and competitiveness,
through fostering innovation, supporting business, removing barriers to effective business,
and by addressing weaknesses which inhibit investment. A core aim will be to improve the
quality of life in London.
Key implications
12. Investment for supporting SMEs needs to focus on access to finance and in the provision of
high quality and affordable business incubation and move-on space. This investment
needs to be distributed across Outer London to even out provision and make business
support ‘local to the businesses that need it’
Key comments
13. The draft EDS focuses too much on developing a good climate for business development
and not enough on developing good businesses that have good business skills.
Objective 3: to drive London’s transition to a low carbon economy and to maximise the
economic opportunities this will create.
14. This objective supports efforts to make the transition to a low carbon economy and in so
doing adapt to, and mitigate the effects of climate change, essential if London is to remain
competitive on the global stage and continue to be a place where people wish to live, work
and invest. It also aims to ensure London is well placed to exploit the economic
opportunities represented by the transition to a low carbon economy.
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Key implications
15. The significant focus on a low carbon economy is to be welcomed and presents
opportunities for the borough. Indeed, the Council has been proactive in this area
illustrated by the successful application for the borough to be one of up to 10 low carbon
zones in London.
Key comments
16. Additional investment will be needed to achieve this aspiration - especially for retrofitting
existing properties and decentralised energy networks. This also needs to be linked to
supporting employment and training opportunities to disadvantaged Londoners.
Objective 4: to give all Londoners the opportunity to take part in London’s economic
success, access sustainable employment and progress in their careers.
17. This objective supports efforts to address weaknesses in educational attainment, low skills
and poor access to and retention of work, seeking to improve opportunities particularly for
those most in poverty and in need, and to provide the quality of workforce essential for
London’s globally competitive economy.
Key implications
18. The Mayor commissions employment and skills interventions, through the LDA (including
the North London Pledge, which Haringey Council manages), and the proposals to have a
“single outcome focused regional commissioner, accountable to the London Skills and
Employment Board” (LSEB) need to be more detailed and considered carefully.
Key comments
19. The lack of engagement from the LSEB with Haringey Council and our programmes, such
as the Haringey Guarantee, is a cause of concern.
20. The proposal to have a “single outcome focussed regional commissioner accountable to
the LSEB” is potentially significant, and as such needs to be more detailed. If this proposal
is taken forward Haringey Council would expect to be a key consultee in its development.
Objective 5: to maximise the benefits to London from investment to support growth and
regeneration, and from the 2012 Olympic and Paralympic Games and its legacy.
21. This objective seeks to promote, manage and steer investment in order to assist all sectors
of the economy, from the most productive global businesses to the corner shop, in the ways
that are most cost-effective and to places that most need it, including outer London.
Key implications
22. While the Mayor’s aspirations here are to be supported more details are needed in areas
such as: linking the development of Opportunity Areas to tackling deprivation; the benefits
from the 2012 Olympics legacy; and the Mayor’s support for town centre development.
Key comments
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23. As above but also the EDS and LDA’s Investment Strategy need to tie into the outcomes of
the London Plan – seeking and matching the right investors to the right projects. Borough
councils, including Haringey, already work through their Economic Development Functions
with developers to realise the potential of good schemes and also to deliver wider economic
benefits of those schemes.
APPENDIX 4 – DRAFT MAYOR’S TRANSPORT STRATEGY (MTS) (October 2009)
1. The Mayor’s Transport Strategy (MTS) relates to the period up to 2031. The draft MTS
contains six key goals:
• support economic development and population growth
• enhance the quality of life for Londoners
• improve the safety and security of all Londoners
• improve transport opportunities for all Londoners
• reduce transport’s contribution to climate change and improve its resilience
• support delivery of the London 2012 Olympic and Paralympic Games and its legacy
2. By 2031 there will be additional 3 million journeys per day. A key challenge for the MTS
is to accommodate this additional demand for travel as well as address overcrowding on
public transport and traffic congestion. The mode share for cycling is predicted to
increase from 2% to 5% from 2006 to 2031. Increases in walking and public transport
share are also predicted with a 6% fall in private vehicle use.
3. Committed investment in public transport [Crossrail, tube capacity expansion,
Thameslink and suburban rail capacity] will increase capacity in the morning peak by
30% from 2006 to 2031. However, even with this investment some areas will continue
to be crowded from population and housing growth.
4. The draft strategy includes a target to reduce CO2 emissions by 60% from 1990 by
2025. MTS holds out the prospect of more stringent measures [road pricing and low
carbon vehicle incentivisation within the context of growth in employment and
population until 2031. Other issues covered are the difficulties of orbital travel,
integrating land use and transport planning and dealing with predicted increases in
traffic congestion.
Key Comments
1. Haringey Council welcomes the broad perspective of the MTS, in that it covers many
topics which are sometimes neglected from transport documents. It particularly
welcomes the coverage on accessibility, safety, the importance of the public realm and
support to the role of outer London. We also welcome the publication of the MTS at the
same time as the London Plan and EDS to allow a comprehensive view of emerging
policies and the work on integrating planning and transport policy.
2. The Council welcomes the proposals for infrastructure investment and the efforts that
have been made to identify what infrastructure investment is necessary to address the
predicted increase in the demand for travel. We note the list of transport schemes which
will help to support predicted growth across London.
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3. Of particular note for Haringey is the continuing importance of works at Tottenham
Gyratory to facilitate regeneration and sustainable growth in this part of London. Also
we welcome the opportunity to work with TfL on progressing some of the infrastructure
proposals such as a review of the Hackney-Chelsea Line.
4. However, Mayor’ all three draft strategies are based on prediction that most of
employment growth will be in Inner London, Central Activity Zone and along Cross-Rail
route. This is an area which is already supported for growth and amelioration of
disadvantage. We are concerned that this will reinforce the existing radial travel patterns
and transport links, which are already overcrowded. In addition, this pattern of growth
does not seem to reduce the need to travel which should be the underlying principle of
the transport strategy.
5. The MTS analysis of demand and investment shows that even with all the proposed
infrastructure investment there will still be overcrowding on the road and public transport
network, despite there being some medium term improvements. This would seem to
indicate that the level and/or the distribution of growth cannot be achieved in a
sustainable way. We are aware of the work that has been done in looking at alternative
growth distributions and the transport investment needs for these different patterns.
However, Haringey’s view would be that more and different scenarios need to be tested,
with less concentration of growth in inner and central London. The reinforcement of
existing radial travel patterns will not reduce the need to travel or lead to shorter
journeys being made and it will make it even more difficult in the future to change the
dominance of radial patterns.
6. Our other concern with the planned pattern of growth is that this could lead to more
journeys over 5km, particularly car journeys. Haringey already experiences severe
traffic and environmental problems due to a number of strategic radial routes through
the borough and a relatively high percentage of through journeys. The borough can
seek to work on changing travel behaviour for shorter journeys, but needs a London-
wide approach to tackle these medium and longer journeys. We are not convinced
that the existing proposed measures and policies in the draft MTS will help tackle
increases in medium and long car journeys and thus the proposed measures and
policies on traffic restraint need to be strengthened. The proposed improvements in
quality of life, through enhanced environments, improved air quality and reduced noise,
as well as reductions in carbon emissions, is unlikely to be achieved in those areas
where through traffic increases. A polycentric approach to growth around London
metropolitan town centres and interchanges with investment in orbital routes should be
considered as this can promote less local travel by car.
7. Transport is a key infrastructure to support predicted growth. The MTS should set out
how specific measures will be promoted and delivered to support this growth and also
support policies on road congestion and climate change. This is especially important in
the light of information set out in the draft strategy for overcrowding in tube and rail
connections.
8. We welcome the identification of Wood Green as one of 12 identified town centres in
London and this accords with the borough’s own plans for regeneration and growth in
Haringey. It is a key bus/tube interchange and should also be identified as a priority
strategic interchange and would also assist promotion of orbital movements. Seven
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Sisters/South Tottenham, Finsbury Park and Tottenham Hale are identified as priority
strategic interchanges.
9. MTS forecast growth means that unspecified parts of the overground network which
includes Barking – Gospel Oak line could justify longer trains. However, no funding
commitment for this with an implication that trains will be overcrowded.
10. We are not convinced that the eradication of road humps will provide a significant
reduction in noise and do not support replacing them with other speed reduction
alternatives.
11. We welcome the continued support on setting an ambitious target to reduce CO2 by
60% by 2025. We have also set an ambitious target for carbon reduction and
appreciate what a challenge it will be to meet this.
12. More support is needed for transport behavioural change in outer London. Measures for
improving and managing congestion for North Circular should be smoothing traffic flow
and improvement measures should not lead to road capacity being increased. Priority
for public transport improvements must support internal London movement and not
commuting.
13. We particularly support the following policies: Support for enhancements to rail and
coach services and the strategic road network in London (Policy1), support for
connectivity and capacity on radial transport corridors into metropolitan town centres
[e.g. Wood Green] (Policy 6), support for improved orbital connectivity in outer London,
particularly between adjacent metropolitan town centres where shown to be value for
money (Policy 7) support transport improvements within metropolitan town centres for
people and freight that help improve connectivity and provide enhanced travel facilities
for pedestrians and cyclists (Policy 8), support for development control processes to
seek i) all high trip generating developments are located in areas of high public
transport accessibility; ii) design and layout of development sites maximise access on
foot, cycle and public transport; iii) maximise the opportunities for sustainable freight
distribution; iv) planning contributions are sought for transport improvements, support
for bringing transport assets to a good state of repair and maintain them in that
condition (Policy10), support for reducing the need to travel, appropriate parking
standards, smarter travel initiatives (Policy11), support for promotion of healthy travel
options such as walking and cycling (Policy17), support for improvements to road
safety, accessibility improvements such as streets, bus stops, enhancements to
accessibility to jobs in deprived areas (policy 19,21,22).
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