In response to the Old Kent Road Area Action Plan consultation in spring 2021, XRS’s Lobbying Group submitted the following response to the council, highlighting our concerns with regards to the climate aspect of the AAP. We believe this re-development could present a really exciting opportunity for Southwark to step up as a pioneer of environmentally-friendly urban living, and encourage the council to involve residents and local groups in more meaningful consultation to collectively imagine what this could look like.

Do you agree that Old Kent Road Area Action Plan will address the climate emergency?

That this is even a question in the consultation for the 2020 version of the Old Kent Road Area Action Plan signifies the deep lack of understanding permeating through Southwark Council about what is needed to combat climate change, and particularly in planning decision-making and policy development.

It’s clear that this AAP was not designed to address the climate emergency, and any claim to do so is both greenwashing and deeply irresponsible given the gravity of the climate crisis.

The carbon off-set fund and the myth of net zero carbon

Firstly, there have been permissions for approximately 9,500 homes in planning applications approved in the Old Kent Road Area Action Plan area without reference to any adopted policy on reducing carbon emissions. 

In XR Southwark Lobbying Group, we do not believe the myth of net zero carbon. There are no transparent and accountable of carbon capture off-setting methods being used in Southwark. Proposed methods are also not referred to in policy AAP3: Climate Emergency and statements such as “We will: Achieve a net zero carbon Area Action Plan” have no evidence-based targets and no monitoring structure, so are rendered completely meaningless, especially in the face of the level of development, in the form of unaffordable high-rise developments which the OKR AAP is actually proposing.

The OKR AAP says “we are aiming to achieve net carbon zero by 2030” – but this distant net-zero date lulls people into a false sense of security when emissions aren’t being cut and there is no published pathway to net zero. Southwark Council still does not have a Climate Strategy in place two years after first declaring a climate emergency and, if one is ever adopted, it is unlikely to be binding on all council departments, particularly the planning department. 

Southwark Council’s planning committee has consistently approved planning applications which do not meet zero carbon targets and trigger large payments to the carbon offset fund, as Southwark Law Centre, XR Southwark’s Lobbying group and Fossil Free Southwark highlighted to the committee in a letter dated 7 September 2020 in respect of an application for Daisy Business Park SE15 1PD (enclosed). This application was approved with a £116,180 payment into the carbon off-set fund (on the pre New London Plan amendment figure of £60/tonne), although it is unclear if this payment, or any carbon offsetting payments dating from 2011’s Green Fund, have ever been properly measured, collected, and reinvested in green initiatives as intended. This is just one example of an application being approved which exceeds the current carbon reduction requirements on-site as set out in the Building Regulations Part L, yet was waived through by Southwark Council’s planning committee. This carbon off-setting – or actually “paying to pollute” – is expressly allowed by the OKR AAP with no reference to how emitting carbon above the regulations will be off-set. There is no way this option can address the climate emergency.


The OKR AAP should be maximising and encouraging the increase of walking, cycling and bus journeys wherever possible within the area.

We know that car journeys drastically need to be reduced in the area. Furthermore, the Bakerloo line has been shelved for the foreseeable future, and is unlikely to have the required committed funding within the projected timelines in the current plan period for both the New Southwark Plan and the OKR AAP. We know this given what the Secretary of State for Transport has said publicly about this project and also Crossrail 2, which is also uncertain in the foreseeable future. There is no chance the Bakerloo line will be delivered with two new stations by 2036, so this false commitment should be removed from the OKR AAP. Old Kent Road needs sustainable forms of transport now, and XR Lobbying Group believe that energy would be best spent by Southwark Council investing in cycling infrastructure, which will be increasingly desperately needed.

Also needed is a sustainable freight strategy which a) reduces driven freight deliveries and b) integrates the deliveries in and around the existing and new development into the local area. The term cargo bikes only appears in relation to sites in sub-area 5. As part of a sustainable freight strategy, they should be integral to the whole AAP and a key part of the traffic reduction strategy. The Old Kent Road offers huge opportunities for Southwark to create an outstanding sustainable freight district; with a couple of exceptions there is no description in the AAP of how this could be delivered. Needed is a whole corridor strategy that identifies the total number of movements that will be likely for the total new and existing residential and working population and the businesses in the AAP area, works out where freight hubs will need to be located and then works with developers and e-cargo bike/other sustainable freight operators to begin to deliver a strategy that minimises driven deliveries and maximises e-cargo bikes delivery.

In relation to the Movement strategy, many of the pedestrian improvements are back loaded with for example, “3.2km of traffic free routes by 2036”. As is the case with the Nine-Elms development, the fear is that all of the construction will have been delivered and the area will remain a very hostile one in which to walk and cycle in. The pedestrian and public realm improvements need to be far more front loaded with local people and visitors starting to see improvements early on rather than at the end of the regeneration. While there is talk of traffic free routes, those strategies could be relatively easily delivered early through the roll out of Low Traffic Neighbourhoods as at the very least are outlined in the TfL June 2020 Strategic Neighbourhood Analysis (content.tfl.gov.uk/lsp-app-six-b-strategic-neighbourhoods-analysis-v1.pdf). This sets out a perfectly workable set of potential LTNs for the OKR AAP area. These might have to be low-cost implementations to start with but these will have a tremendous benefit for local people and potential visitors to the area early in the redevelopment and start to set the scene for further pedestrianisation later on.

In reference to AAP 7, there is no clear strategy described to deliver the commitment that “Southwark aspires to maintaining 50% less driving than before lockdown” and how that relates to the OKR AAP. Policies need to be described that will suppress car usage. Improving public transport and improving walking and cycling infrastructure are good but will not alone deliver this level of change. Road pricing is essential to deliver a quantum reduction in vehicle usage. This should be coupled with an area-wide programme of LTNs and increased parking charges that are ideally emissions-based. The policies that Southwark can control should be delivered early (i.e. now) in order to assess their impact so that a review of performance and what other measures may be needed can occur before the target is found to be unattainable.

AAP 11: Parks and Healthy Streets — The Greener Belt. Transform Old Kent Road to become a Healthy Street by 2036, by prioritising pedestrians and cyclists, retaining existing and planting new trees, improving crossings and reducing noise pollution through using acoustic road surfaces.

This policy indicates a commitment which is again too slow and means that in spite of all the redevelopment, benefits to local people will not be linked clearly to the huge change in their area. If the BLE is unlikely to occur then there will be a real need for other approaches such as a rapid bus service/tram to be developed earlier in the regeneration. This offers huge opportunities to make early change to the character of the OKR. We need to see a description of a greater commitment to these changes from Transport for London who control this corridor as part of the TLRN and especially how they will deliver a corridor that has an effective 20mph speed limit with high levels of compliance.

The omission of carbon in demolition (embodied carbon) and construction

The OKR AAP completely ignores the fact that net-zero carbon emissions could not be achieved taking into account the huge carbon emissions expended in constructing developments such as those described in the OKR AAP and the planning applications which have already been approved. The list of highest carbon emission sources in Old Kent Road is misleading and unsupported by any up to date evidence. The role of embodied carbon in demolition and new build development in the construction stages has been wilfully excluded. There is no mention of sustainable construction methods or materials, and this is a huge omission given that the construction industry is responsible for approximately 40% of carbon emissions. XRS have repeatedly called for a cap on total permissible emissions during a building’s lifecycle (demolition, construction, and over 30 years of use) and linking this to social use (i.e. X tons of CO2 permissible per social housing unit created and a negative cap on emissions permissible in non-social housing or commercial building projects to ensure the building must create more renewable energy than it uses in order to go ahead).

There is a cursory reference to retrofitting which runs in complete contrast to the rest of the plan. It would be easier, more sustainable and achieve strong community support if the current buildings could be repurposed for the industrial uses they were built for, as industrial space is so desperately needed in the area. There could be sustainable development of affordable housing for Londoners to live in, rather than property speculators to build and sell off overseas.

In respect of District Heating Networks and the SEHCLP, connecting to low carbon heat networks is clearly an important step and will become more so as the technology is developed. Studies and improvement are still going on to improve efficiency and understand carbon outputs of the waste incineration energy production. All of this is welcome, but it is only one part of the picture in bringing down real carbon emissions in Southwark. However, district heating plans are overwhelmingly relied on as the main focus of the climate emergency policy AAP3. This is not enough to address the climate emergency.

The energy use in tall buildings and large developments – the operational phase

There are real concerns about the energy use in tall buildings as proposed for the Old Kent Road area action plan area. A research study by UCL energy institute found that residential buildings use more energy in operation, per square metre of floor area, the taller they are. Professor Steadman detailed: “We suspect that the reasons for our findings are connected with the physical and meteorological consequences of building higher. Air temperature decreases with height, and average wind speed increases. Taller buildings that stand up above their neighbours are more exposed to these strong winds, as well as to more hours of direct sun. Thus energy use for heating and cooling would both be increased. But these hypotheses have yet to be tested.”

A hypothesis which will also have to be tested is whether connection to District Heating Networks can mitigate this increased energy use to any meaningful level. Servicing of tall buildings contributes to carbon emissions, for example in the use of lifts to get to the higher floors.

Another part of the UCL study looked at the relationship of different forms of building to their densities, where density is measured by taking the total floor area and dividing by the site area. The work has shown that, in many circumstances, the densities achieved by tall towers can be achieved with lower-rise slab or courtyard buildings. It is not always necessary to build tall to achieve high densities and energy use could, in many cases, be greatly reduced by building in different forms on fewer storeys. This is also particularly the case where the housing in Southwark which is needed is overwhelmingly family housing for 3 – 4 bed households. These households do not opt to live in high rise developments where there is choice and it very often is not appropriate for their needs. We also have concerns about the lower levels of affordable housing being achieved by taller buildings, as was provided in a FOIA response to Southwark Law Centre dated 20 February 2019 (enclosed).

Cleaner, Greener, Safer

XR Southwark Lobbying group think that the scale and massing of the development proposed in the OKR AAP is incompatible with Cleaner, Greener, Safer policies outlined in AAP12. This policy is not sound as it has not been justified and it is not effective. We refer to our earlier submissions about concerns with tall buildings. We do not consider the policy AAP12 effective because it makes demands that cannot realistically be met but provides no detail as to how to go about contributing to net gains in biodiversity and/or enhancing important sites and populations of protected species.

Nowhere in this policy is the impact of this intensification of development on current biodiversity analysed and presented.


The large-scale demolition of industrial buildings and building of high rise unaffordable flats, especially without reference to any overarching Southwark Council policy to reduce carbon emissions across the borough such as a published Climate Strategy, will do nothing to address the climate emergency.

XR Southwark also has significant concerns about this consultation process, in which there have been virtually no consultation events in order to engage residents and the priod of consultation has mostly taken place in a strict third lockdown taking place during the COVID-19 pandemic. This consultation, certainly in respect of the climate emergency but also in respect of everything else of such importance to borough residents, businesses and community groups, should be bringing residents and groups together in order to create innovative solutions in planning the borough to address the crises we face, informed by expert evidence and detailed baseline data. This has absolutely not been the case in this consultation.

The words ‘carbon neutral area action plan’ are meaningless without laying out exactly how this will be achieved. As XR Southwark’s Lobbying group has repeatedly said, there is no reward for effort or slapping buzzwords on your plans; there are only catastrophic consequences if you fail. The world faces enormous climate and ecological risks, presenting existential risks to human communities and to other species. Time is running out to prevent catastrophe, which requires halting emissions to net-zero as soon as possible. The Old Kent Road redevelopment will be one of the most significant developments across London in the coming decade. This is an opportunity on a global scale for Southwark Council to step up and act as a pioneer of environmentally-friendly urban life using innovative solutions, similar to Paris’ commitments for the Champs-Élysées. 

We can do better than this AAP for the Old Kent Road.

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