Protect Our Pubs FAQ's
The Greenwich Local Plan is on its very last stage of consultation, that means we can only respond about whether the plan is ‘sound’ or not in a legal sense. White Swan Music and Arts does not judge that the draft plan meets the criteria of sound in that it isn't:
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positively prepared to meet development and infrastructure needs
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justified by proportionate and robust evidence
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effective and deliverable over the plan period
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consistent with national policy
These FAQs detail where we consider the draft plan is unsound, where the council should improve and recommendations of further actions.
1
What does planning positively mean?
Greenwich Local Plan will shape planning policies for the next 10 - 15 years. The last local plan was adopted on the 30th July 2014 and since then Greenwich has seen a net loss of 17.5% of its pubs https://data.london.gov.uk/dataset/london-pubs-audit-2yp45
Behind that figure is an underlying trend that Greenwich pubs are decreasing on the whole, with small local community pubs being lost, closed and redeveloped. Hiding this loss of community pubs is the new larger commercially owned chain pubs being created in and around new developments.
Strategically the local plan recognises the unique contribution local pubs make to our communities, in practice the plan only creates the actual planning conditions for commercial redevelopment.
This response asks the council to positively plan for the retention of existing pubs in our existing communities (local areas and neighbourhoods).
2
What is the Financial Viability Test and who pays for it?
If the owner of a pub wants to turn a pub into something else as part of the planning application they (the owner) have to submit a Financial Viability Test (FVT), which they pay for as part of their planning proposal. The owners pay for their FVT, and Greenwich has the additional option of independently reviewing the owners FVT which again the owners pay for.
Under the current local plan proposals Greenwich already includes having due regard for CAMRA's viability test model:
“Applicants should also carry out an assessment of the needs of the local community or community facilities to show that the pub is no longer needed and that alternative provision is available. We will also have regard to the Campaign for Real Ale (CAMRA) public house viability test. “
White Swan Music and Arts submission asks Greenwich to go further and ensure any pub FVT includes a Community Ownership Economic Assessment in line with the proven economic model for public house actual proven viability as evidenced by the Plunkett Society. https://plunkett.co.uk/wp-content/uploads/Better-Business-Report-2025.pdf
A Community Ownership Financial Viability Test isn’t new, in fact, the last Government gave away £135 million using one as part of their Community Owner Fund.
3
What is an Ancillary Use?
There is no one definition of ancillary and it is generally interpreted to mean a secondary use to the primary use.
The Draft Local Plan recognises pubs as “Social and community infrastructure plays a fundamental role in supporting health, wellbeing, social inclusion and the everyday functioning of communities. They are a vital resource to support successful places and resilient community”. The plan is clearly stating that pubs are not to be treated solely as wet-business (i.e. beer) led financial commercial businesses’ and that therefore the primary use of a pub is its entirety, the spaces that make up building a community.
The Plan then goes on to not offer protection to the parts of a pub that deliver social and community infrastructure.
We are asking the Local Plan to be drafted to avoid confusion and misinterpretation of primary use and ancillary use and to instruct planners to treat a pub as a whole entity, which is the sum of all its parts. In the White Swan case that’s the building, the entire property internally and externally and any easements.
Thus providing protection from incremental changes with successive applications on one building that makes up a ‘pub to residential’ pathway.
4
What is a Supplementary Planning Document (SPD) or extra guidance?
Sometimes you can't fit everything you need to say in a tiny 566 planning document. When you need to double click on a planning point the council will produce an SPD. Other local authorities have worked with communities to provide detailed guidance on community spaces like pubs.
Here are a few examples old and new:
5
What's organised crime got to do with planning?
The Local Plan is a vital bridge between strategic vision and delivery. At a strategic level we ask Greenwich to be robust in reporting and preventing fraud or crime. Once Greenwich takes the strategic decision in the Local Plan to be proactive and take a zero tolerance approach to crime, conflicts of interest and fraud it should thoroughly review its policies and procedures including Money Laundering policy with a named Planning and Enforcement lead and proactive scrutiny of previous and current planning cases. Further guidance on Standards in Public Life can be found here:
Further examples of a Money Laundering Policy here:
https://democracy.towerhamlets.gov.uk/mgConvert2PDF.aspx?ID=226622