Our response to the OPDC Local Plan 19.2 consultation

Between 14 June and 30 July, OPDC consulted on a revised version of its Draft Local Plan.

It is unusual for a Local Plan to need to be consulted on for a third time.  The range and number of changes that OPDC had to make to its 2017 ‘Regulation 19’ version were such that a further round of public consultation was required.

Our previous posts on the Draft Local Plan and on ‘how the key players responded’ explain the outcome of the 2017 round of consultation.  OPDC planners have had to make substantial revisions to their proposals. The most significant of these is that Local Plan policies for ‘Old Oak South’ are not expected to take effect within the 2018-38 ‘plan period’.

This area, north of Wormwood Scrubs, is to be the location for the HS2/Queen Elizabeth Line rail interchange, due for completion in 2026.  The original OPDC 2015 ‘vision’ saw this ‘place’ as the commercial heart of a new part of London.   But the constraints of existing rail infrastructure, including newly built depots, means that development is no longer seen as viable for a further 20 years.

The Old Oak Neighbourhood Forum has long argued the case for use of the neighbourhood planning framework as a vehicle for creating planning policies and site allocations that can be adjusted to changed circumstances.  The infrastructure costs of regeneration at Old Oak are such that funding through planning obligation receipts (CIL and S106) will never be sufficient to resource all OPDC ambitions.  Major uncertainties remain as to how regeneration and new transport infrastructure can be financed.

We believe that planning for the area should be more evolutionary and incremental, and will need more frequent review and updating than for most Local Plans.  OPDC did not share our view that designation of a 280 hectare Old Oak neighbourhood area could have achieved a more responsive planning process.

We think that Old Oak needs some realistic ‘meanwhile’ policies and site allocations, and a  strong element of co-design with the existing local communities in the area.   Brexit, a faltering London housing market, and the potential competing construction demands of Heathrow expansion, are all good reasons for avoiding an over-prescriptive and ultra high density Local Plan for Old Oak.  Yet the 19.2 OPDC Local Plan heads relentlessly in this direction.

A copy of the Forum’s consultation response to the OPDC 19.2 Draft Local Plan can be downloaded here OONF response to Regulation 19.2 OPDC Local Plan.   OPDC intend to submit their finalised Plan to the Secretary of State in autumn 2018, with the Examination in Public held during the winter of 2018.  Adoption of the Plan is scheduled for early 2019.