Agenda item

City Plan 2040

Report of the Planning & Development Director.


The Sub Committee considered a report of the Planning and Development Director setting out the potential ways that the City Plan’s policies around health, inclusion and wellbeing could be amended based on current evidence, best practice and the responses to the consultation on the draft City Plan 2036. The report also provided an update on the engagement plan and overall work programme for the City Plan.


Officers introduced the area of the report focusing on the health, inclusion and wellbeing policies within the City Plan. They explained that it was essential to ensure that the Plan was as inclusive as possible with a view to putting independence, access, dignity, comfort, safety and enjoyment at the heart of the document. They went on to set out the background of these policies, their current status and expectations for their development in the future. It was also recognised that there were other policies which dealt with these matters concerning things such as the development of tall buildings, public realm and the Thames Policy Area which also dealt with the need for publicly accessible and inclusive spaces.


Officers highlighted that the report also featured an Integrated Impact Assessment (IIA). They clarified that there was a statutory duty to prepare a sustainability appraisal setting out the economic, social and environmental implications of the Plan but that the draft Plan went beyond this and pulled all of this together alongside an equalities impact assessment and a health impact assessment. This had been undertaken in house but was then audited by an experienced external consultant. The Sub Committee were informed that the IIA had not identified any real problems with the way in which the Plan addressed matters of health, inclusion and wellbeing. welcomed the focus on health, inclusion and wellbeing policies. It was highlighted that this was an iterative process with each stage of the plan subject to an IIA intended to flag up any issues and that, at the end of the process, there should not be an IIA that flagged any problems with any part of the Plan.


Officers went on to highlight that the report also flagged some of the broad comments received in response to the consultation on the Plan. Members were informed that there was very strong support overall for the way that health, wellbeing and social inclusion was addressed within the Plan. It was noted that there were some detailed comments around the need for health facilities as well as around daylight/sunlight, air quality and around sports and leisure provision. The Development Industry had also been broadly supportive of the Plan although did feel that there should be more flexibility such that Health Impact Assessments were not necessarily applied to all developments, only larger ones. Having taken all of these comments on board, the report flagged where Officers felt that some further changes could now be made to the Plan to make it more inclusive and better address health and wellbeing. It was recognised that there had long been a focus on physical accessibility but that this now needed to be much wider and to incorporate other forms of accessibility for those with sensory or non-physical disabilities.


The Plan included proposals to make buildings healthier and to create healthier working environments. In addition to this, it was recognised that there were more children coming into the City and that it therefore needed to be more child friendly and welcoming to families. Light pollution and noise pollution were also addressed and the question of whether a specific policy was also needed on sport and recreation provision was tackled. Consideration was also given as to whether developers should also be required to look at equalities impact assessments and produce these as part of a planning application.


Finally, the Plan sought to address safety and security in the City (particularly for women and girls) and considered whether there ought to be a policy on community safety and for this to also be included within assessments going forward. Officers concluded by underlining that they were looking for a steer from Members today as to whether these were the kinds of areas that they would be content to see worked up into detailed draft policies or whether there were any views as to additional areas of focus.


In response to a query from a Member, the Sub Committee was informed that there has been significant research into the impact that building design can have on the experience of neurodiverse users within buildings and in terms of public realm. Members were informed that developers would be expected to consider utilising inclusive lighting and access features and to consider obtaining expert advice in relation to how aspects of their building design may impact on people with neurodiverse conditions. It was suggested that supplementary guidance on this topic could be drafted to set out these requirements in more detail with the Plan acting as an overarching hook for this. Members were also informed that the Greater London Authority (GLA) was considering reviewing its own accessibility guidance and that the City Corporation would need to liaise with them to ensure a consistent/pan-London approach.


In response to a query from a Member regarding the development of a community safety and security policy that referenced the safety of women and girls in the City specifically, it was explained that there is a need for the City Corporation and developers to engage with this group to ensure that their experiences inform the design of the urban realm going forward. The Sub Committee discussed the importance of being cognisant of the equality issues experienced by different groups with protected characteristics as part of the public sector equality duty and how these issues overlap and intersect – something which Officers suggested could be handled through the IIA process.


A Member pointed out that there is more recent guidance from Public Health England in terms of better health outcomes than that referred to within the report, which was dated as 2017. The Member that the NHS and Public Heath England encouraged the public to spend at least 40 minutes per week with an elevated heart rate/undertaking anaerobic exercise and that this responsibility should be put on to individual boroughs. Furthermore, the Member informed the Sub Committee that he had received recurrent feedback from female residents and workers stating that they often found gyms within the City intimidating, particularly those within the workplace. They had indicated that they would therefore welcome outdoor spaces/gym equipment to exercise with friends. The Planning and Development Director informed the Sub Committee that these matters would also be taken on board.


In response to a query from a Members as to the pressures faced by GP surgeries in the City and neighbouring boroughs, the Sub Committee was informed that Officers had met with NHS North-East London in relation to the pressures the City of London’s general practitioner (GP) services may face as a result of more new office space being approved, given the entitlement for employees to register with a GP in close proximity to their place of employment. The meeting involved discussions on population growth, housing development and the future need for GP provision. It was highlighted that, at present there was just one GP surgery within the City which largely catered for people on the western side of the City. Members were informed that currently NHS North-East London were of the view that there is no significant increased demand for GP provision within the City. However, they had now committed to approaching the relevant surgeries directly in order to try and better understand any emerging patterns and any future action that might need to be considered as a result of these. Officers had also taken the opportunity to flag with them the increasing number of students coming into the City as well as workers. However, it was noted that students are more likely to be registered with a GP near their university than their halls of residence. They had also been asked to consider the introduction of a minor injuries clinic in the City and continued to be in active discussion with NHS England on all of these matters, with quarterly meetings in the diary. Finally, it was highlighted that, if there was sufficient demand, the provision of a facility for a GP or dentist could be required through the planning system. However, the planning system could not be used to provide a GP and it was recognised that there was currently a national shortage of these.



A Member made the general point that health, inclusion and wellbeing transcended across many areas of the Corporation’s work and encouraged Officers to always keep this much bigger picture in mind in terms of a vision for what the Square Mile should look like. She noted that some additional points to consider further in relation to health, inclusion and wellbeing included the City’s offering for teenagers and older school aged children, waste management/cleaning and greening policies, making the City safer for women and girls specifically, including the need for better lighting or CCTV in certain areas/small alleyways, the 15-minute City, restricting take away facilities within close proximity to schools for example and the development of a River Strategy. Members agreed that there were limited play spaces for children within the City. Officers responded to state that they were using ‘child friendly’ as a catch all term nut that, in reality, this would be much wider and include school aged children and teenagers too. They added that they fully intended for this to be an integrated plan as opposed to a series of disjointed policies considered in isolation. With regard to the 15-minute City, Officers commented that this did not sit neatly with the makeup of the City, although they were happy to see how the principles sitting behind this might be further drawn out within the Plan. It was highlighted that there would be a separate policy on the Riverside as a key area of change. Members were informed that the issue of hot food takeaways was looked at in quite a bit of detail when drafting the Plan. It was recognised that the Mayor of London had a policy to restrict these within 400-500 meters of a school which potentially covered large parts of the City in terms of the location of COLPAI and Aldgate School. That being said, there also had to be adequate provisions for City workers and visitors. Officers also cautioned that certain establishments were not considered to be hot food takeaway premises but rather restaurants, albeit with large takeaway elements. Members were informed that consideration had also been given to the introduction of allotments/community gardens in the City.


A Member commented that identifying space for children to play and partake in sport in the City was important. In response to a query from the Member, the Sub Committee was informed that the City Corporation’s Sports Strategy would be available in draft form in January 2023. It was anticipated that leisure facilities would be covered in this strategy. The Member stressed that it would be important for this and the Plan to be interlinked. Officers reported that Hackney had developed an SPD on child friendly cities and that this was considered to be fairly exemplary. It was therefore possible that the City may look to develop something similar and to fold this into the Plan to underpin the high level policy approaches for children and young people.


With regard to IIA’s, the Member welcomed these but reiterated previous concerns that she had voiced as to the robustness of the makeup of the current City of London Access Group and whether they were the correct group to be consulting on these issues. The Member went on to flag the importance of access to affordable healthy food for all but commented that there were currently no budget supermarkets within the City. She queried the view that open space provision on rooftop terraces was as valuable as ground floor space, highlighting that not everyone would necessarily know to approach/enter a building and access this. Finally, the Member echoed the importance of safety and security measures for women and girls in particular given that 97% of women aged between 18-24 had reported that they had experienced sexual harassment and 80% of women of all ages had experienced this in public places. The Member highlighted that Wandsworth had a strategy on this out for consultation at present and suggested that Officers also look to consult this.


Officers recognised that there was more to be done in terms of ensuring that all who were able to access roof terrace spaces were feeling more informed about them and more welcome/able to do so. It was suggested that this may form the basis of a Planning Advice Note in order to make these places truly inclusive. It was also highlighted that this was not intended to be a replacement for ground floor public realm as this was always the first priority. However, it was also recognised that, within the City Cluster there just was not great capacity for this, with many spaces at ground floor level being particularly overshadowed and windy. A Member suggested that it would be useful to have some data in terms of numbers accessing these publicly available roof terrace spaces in due course.


The Sub Committee agreed that public toilets should preferably be accessible 24 hours a day to avoid issues concerning antisocial behaviour and cleansing and that this ought to be made clear to developers and secured through the planning process. A Member noted there was a lack of awareness of the Community Toilet Scheme, in which pubs and restaurants in the City allowed public access to their facilities. Another Member was of the view that the Community Toilet Scheme was not helpful for Destination City purposes as most City businesses were closed during the evenings and on the weekends. She added that this was an issue that needed to be addressed in the planning of new developments.


A Member discussed suicide prevention and stated that she felt that it should be more visible within the Plan. Officers highlighted that there was now a Planning Advice Note on suicide prevention in tall buildings and that developers were required to consider the impact of their buildings and how they could mitigate the risk of suicide as well as to demonstrate how they had done so but it was recognised that there was still work to be done here in terms of all buildings as well as along the River.


Members discussed the process and timeline for the production of the Plan. Officers reiterated that this was an iterative process and that a final draft of the City Plan alongside various policies worked up in detail and would be brought to this Sub-Committee in February 2023, to the grand Committee in March 2023, on to Policy and Resources and the Court of Common Council and then out to formal, regulation 19 consultation in June 2023. This would highlight any changes made as a result of previous discussions with Members. Some Members expressed concern at this approach and stated that they would prefer the opportunity to scrutinise this in more manageable chunks which had been the approach adopted previously.


A Member highlighted that this Sub-Committee had previously underlined the need for meaningful public consultation/engagement on the Plan and stated that she had anticipated a list of potential consultees as well as a timetable for public consultation being brought to this meeting for approval.


Officers reported that they had worked to develop an engagement strategy for the City Plan setting out the stakeholders that Officers intended to engage with over the course of the next year as various policy approaches were reviewed. Members were informed that a Statement of Community Involvement and Developer Engagement Guidance would also be brought to the Planning and Transportation Committee for consideration in October. It was also highlighted that other parts of the organisation were progressing various other pieces of work such as the Climate Action Strategy and that it was therefore important for any engagement strategy to also set out these various projects clearly in the context of the City Plan.


Officers reported that a series of meetings and updates had been put out to various stakeholders on a monthly basis and that the first stage of this would be a meeting with stakeholders next month to update them on the City Plan and provide them with an opportunity to ask questions and highlight how they might want to be involved in its production. In future months, further discussions on some of the key issues raised during the previous consultation and the opportunity to explore the policy approaches in response to those would take place. As the formal consultation stage approached, updates would then be provided on how to respond to this and things such as a Frequently Asked Questions document about the Plan and its development would be provided alongside a quarterly newsletter updating this and other policy documents. Members were informed that Officers were also in the process of procuring an online engagement platform which would significantly improve online presence. Finally, it was reported that, internally, Officers would work on their consultation database and seek to develop a comms strategy for press and social media.


Officers went on to highlight that a stakeholder mapping exercise was currently underway in order to provide a clearer picture as to who the City were/should be engaging with and how best to engage them including those groups that the organisation had traditionally struggled to communicate effectively with. It was reported that Officers were considering procuring consultancy support on developer engagement work which it was felt might be beneficial for the programming of and facilitating various events.


Members were informed that Officers did not intend to make major adjustments to policies within the City Plan, but that they may redraft the Plan to remove repetition and make it more concise and thereby accessible as a final document.


A Member was concerned that the details of the engagement plan would be submitted to the October Planning and Transportation Committee meeting without this Sub Committee having had the opportunity to scrutinise it. The Member stated that it was important that Members were provided with an explanation of the development of the policies within the plan.


A Member commented that the Plan should be sound and coherent at Regulation 19/Inspection stage and therefore underlined the importance of meaningful engagement having taken place way in advance of this.


Several Members supported scheduling additional meetings of this Sub Committee to scrutinise the draft plan in early 2023 if necessary.


A Member requested an explanation as to why the Sub Committee had not been provided with a list of stakeholders consulted so far and a plan for meaningful engagement, as was requested and discussed at great length at the previous meeting. The Member stated that it was important to obtain the public’s views on priorities within the City Plan, particularly where certain objectives/policy areas may conflict with one other and spoke in favour of something more akin to co-production.


In response to Members’ concerns about stakeholder engagement, the Sub Committee was informed that Officers recognised the importance of broad and meaningful consultation and underlined that this was very much their intention. Officers apologised for not having provided the documents requested at the previous meeting and informed the Sub Committee that the information about stakeholders consulted so far and intended future stakeholders could be provided in advance of the next meeting.


A Member pointed out that the engagement section of the report stated that engagement would be taking place from September to January, which in her view would leave insufficient time for meaningful engagement to take place in view of the Christmas and New Year period.


A Member requested clarity regarding whether engagement work would be divided by topic and how the prioritisation of policies and policy conflict would be managed for the next Sub Committee meeting. Members were informed that it was important that direct conflicts and any overlap between different policies were explained to stakeholders and that this would be made clear during the consultation process.


RESOLVED – That Officers continue to progress work on the City Plan based on Members’ views on the proposed policy direction in relation to health, inclusion and wellbeing, and the approach to engagement.

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