Below is the text of the Forest Hill Society submission regarding the Proposed Crofton Park and Honor Oak Neighbourhood Plan Area. Further details of the proposed forum and boundaries can be viewed on Lewisham council website.
The Forest Hill Society is
the local amenity society for the SE23 postcode area which is run by the community
for the community and has over 400 members. It works to make the whole of
Forest Hill 'an even better place to live' in a range of ways, including
through involvement in the planning system, transport issues, environmental
improvements, community events and working with a range of other groups and
organisations. The SE23 postcode area includes the neighbourhood of Honor
Oak Park and we have many members that live in this part of the area.
Over the past 3 years the
Forest Hill Society have been involved in various workshops, discussions and
ideas around neighbourhood planning in SE23 and nearby, including meeting with
the Council. Our current approach is to work positively on ideas for improving
key parts of the area that need it most and to see whether a neighbourhood plan
is the effective way of achieving change on a case-by-case basis. The
Forest Hill Society is positive about the potential of neighbourhood planning
and would like to support and work with any group or community within or around
SE23 looking to improve their area.
In relation to the current
applications for the Neighbourhood Plan boundary and Neighbourhood Forum we
have a number of concerns and we to object to both applications as they stand
at the moment.
NEIGHBOURHOOD PLAN BOUNDARY
APPLICATION
We are concerned that the
boundary does not represent a neighbourhood as it actually functions and
excludes many residents who rely on and use key parts of the planned
area. As the proposed area is currently set out, and taken together with
the proposed constitution which states that the neighbourhood plan is for the
benefit of the inhabitants of the area, this would mean that many people who
associate with either Crofton Park or more particularly Honor Oak Park but who
do not live in Crofton Park Ward would be excluded both from membership of the
forum and more importantly from voting in a future referendum.
"Membership of the Forum is open to those
who live or work in Crofton Park Ward and to the area's elected
representatives."
In this case the proposed
NP boundary reflects the Ward Boundary for Crofton Park Ward. There is no
reason for the Neighbourhood Plan to be this boundary as within Metropolitan
areas there are no set rules for how a NP boundary should be set. We can
see that boundaries need to be somewhere but in order to be effective, both in
their preparation and their ratification these should reflect functional
neighbourhoods or communities.
Our particular concern in
this case is that the NP boundary does not reflect the neighbourhood or
community of Honor Oak Park as it only includes land to the east of the railway
line and not the other half of this community to the west. This is a
problem because one of the key areas that could really benefit from the
potential opportunities that neighbourhood planning could secure is Honor Oak
Park and the important local shopping centre that is located along this
road. As it stands the boundary would mean that the many residents of
Honor Oak that do not live within Crofton Park ward would not be able to
influence, contribute to or vote on key changes that might be proposed through
the neighbourhood plan for this area.
A key open space (Honor Oak
recreation ground) that is used principally by residents of Honor Oak Park is
also excluded from the NP boundary. Other parts of Honor Oak Park e.g.
One Tree Hill, are also closely associated with this area but we can see that
they also have a wider significance.
There is also a concern
that the southern part of the proposed Neighbourhood plan boundary may be
functionally part of Forest Hill rather than Honor Oak Park.
At a recent Crofton Park
Ward Assembly meeting we understand that residents who did not live within the
ward (but who live very close to the boundary) were not allowed to be part of the
discussion about the proposed Neighbourhood plan even though they had come
along specifically to find out more about it. It would therefore
seem that the NP boundary being following Ward boundaries might actually create
more problems than it solves and end up marginalizing residents who would be
impacted on by the plan but who don't live within the identified area.
It is interesting to
contrast this approach to the NP boundary and forum application with that for
Grove Park which is also on your website and which does appear to have covered
these issues in some detail.
We would suggest that as an
authority it may also be worth Lewisham considering separating the approval of
an NP boundary with that of the neighbourhood forum. This is the approach
being taken in at least one other London Borough (Westminster) and it allows
the boundary application and debate to focus on whether it covers a functional
neighbourhood, before the application is considered about whether the proposed
forum membership and constitution is inclusive and appropriate in those
specific circumstances and for the approved boundary.
As part of our
consideration of the NP proposals for Honor Oak Park and Crofton Park we have
spoken with a number of FHS members and residents who live within the proposed
NP area and nearby. It appears to us that this concern about the boundary
is one shared by quite a number of local people.
NEIGHBOURHOOD FORUM
APPLICATION
We are concerned about the
wording of the proposed constitution in that it only includes those that live
and work in the area and does not take account of the fact that the NP boundary
does not reflect a functional neighbourhood and that it is in a complex urban
area of overlapping places and functions. The Grove Park application does
at least appear to have considered these issues.
It is not clear how the NP
Forum intend to include, work with and take into consideration the views and
contributions of people living nearby the NP area and who will rely on, use and
feel part of key centres within the NP area on a day to day basis (principally
Honor Oak Park local centre). To some extent this will always be an issue
in high density urban areas but is a particular problem in this case because
the NP area does not accurately reflect one or more functional neighbourhoods.
We are aware that there is
a duty to consult with neighbouring groups and statutory consultees as part of
the regulation 14 consultation set out in the Neighbourhood planning
regulations. However, this stage of consultation is too late for any meaningful
opportunity for neighbours to influence the vision and objectives of the plan
as it is only undertaken once a plan is written and ready to be consulted
on. It is also unlikely that neighbouring residents would be consulted at
this stage as the focus is really on neigbouring authorities and
organisations.
In parished areas outside
of major cities it may well be appropriate to focus the neighbourhood forum on
only those who live or work in the Parish as there is more likely to be lower
density, rural or peripheral areas around key areas of focus, such as towns or
villages or local centres. However, in urban areas such as this, with a
number of overlapping communities it is important to both consider and reflect
how people relate to and use an area, as well as take account of this 'overlap'
and propose how to address it in the constitution of the neighbourhood forum.
Unfortunately we understand
that whilst the draft constitution says lots of positive things about working
with local groups and being inclusive we have concerns that this may not
reflect the intention of the some of those in the group when it comes to
including groups who operate partially within and also outside of Crofton Park
Ward (such as the Forest Hill Society). We are concerned that any
neighbourhood forum needs to be inclusive of individuals and groups who are
wholly within the neighbourhood area and also those who operate partially
within it too, such as the Forest Hill Society, or who live nearby.
We would ideally like some
assurances, if this application is approved, that the Forest Hill Society, as a
key civic group and local stakeholder with members in a large part of the
proposed NP area would be able to contribute to the plan and to work
collaboratively with the forum. We think that best way to achieve this is
if the Forest Hill Society and other groups are listed in the proposed
constitution of the Forum as one of a number of groups that will be consulted
with and engaged with as the plan develops, and ideally be involved in Forum
meetings. We would be happy to look to identify Forest Hill Society
representatives who are also residents within or nearby to the Neighbourhood
Plan area.
We would welcome the
opportunity to engage with this forum and have previously made some attempts to
do so. We very much want to work with any Neighbourhood Forum in the
development of a Neighbourhood Plan that serves local people and seeks to
improve an area. We believe the spirit of Neighbourhood planning should
be about inclusion, collaboration, and a best practice approach to working
community issues. We do not believe it should be about the idea of perceived
'exclusive' control of an area by one group.
We hope that the concerns
we have about the current proposals are clear to you in this letter. We would
be very happy to discuss these with you further if this would be helpful.
