The public consultation on the the OPDC Post Submission Modified Draft Local Plan (PSMDLP) ended on July 5th 2021. Our Forum submitted a response in two parts. OONF and StQW reps on PSMDLP Part 1 June 6th 2021 raised a series of legal and other questions for the Inspector on the scale and extent of the ‘modifications’ proposed by the OPDC.
The second part PSMDLP Part 2 FINAL covered detailed comments and queries on individual modifications.
We have since asked OPDC to publish all responses in the ‘Examination Library’ (available from its own website). OPDC officers say that they are collating and reviewing all representations made, and will prepare responses to these, before forwarding the full set to Planning Inspector Paul Clark. It seems that only then will this material become public.
We argue that there a live planning issues in the OPDC area (particularly in North Acton and Scrubs Lane) on which the public have a right to know what is being said about the draft Local Plan – by developers, businesses, community groups and individual residents. Hence the need for us to understand this up to date context.
The Examination of the Draft Plan has been onging since September 2018. This is far longer than usual. OPDC and LB Ealing have not stopped deciding individual applications, and there are more in the pipeline.
We have been able to obtain copies of some of the representations submitted to OPDC by the Borough Councils affected:
Hammersmith & Fulham’s response
The comments from Hammersmith & Fulham Council OPDC MM LBHF RESPONSE.docx say as follows:
These (previous) representations also raised issue with the deliverability of the Plan through the proposed phasing of infrastructure and the inability to generate sufficient funds from CIL/S106 contributions. The deletion of the strategically important allocation of Old Oak North, and OPDC’s consequential attempt at a much-revised spatial strategy in response, have unfortunately not overcome these objections, rather they have only sought to make them more obvious and their unacceptability more apparent.
Further, new issues of concern have arisen that necessitate new objections from LBHF. These are primarily associated with ensuring the Plan is capable of delivering a coherent new neighbourhood for Old Oak North and Scrubs Lane that successfully integrates and respects the surrounding context, achieves a high quality sense of ‘place’ for new and existing residents and businesses, and circumvents predicted issues that are likely to arise.
This is hardly a ringing endorsement of the 20 months that OPDC spent in preparing its modified Local Plan. We agree with Hammersmith & Fulham Council that OPDC’s latest attempts to portray Scrubs Lane as a ‘place in it own right‘ which is ‘well-connected‘ within the local area are very unconvincing.
Kensington and Chelsea’s reponse
The submission from RB Kensington & Chelsea RBKC response to OPDC modifications is less critical. This is partly because this council is dealing with major development proposals for the Kensal Canalside area, to the east of Scrubs Lane.
RBKC is one of a number of councils subject to the the MHCLG ’tilted balance’. This ’tilt’ towards the ambitions of developers applies to those planning authorities which have failed over several year to meet their housing targets, as set in the London Plan.
Hence the RBKC planners are having to consider housing densities and building heights at Kensal Canalside which are well above those that this Council would have accepted in the past. Hitherto, RBKC have been a council which has resolutely refused to take part in London’s second phase of tall buildings (the first having been in the 1950s/1960s).
A change of approach to Kensal Canalside means that there will be planning battles in North Kensington similar to those experienced to date on applications consented by OPDC and LB Ealing at North Acton.
Ealing Council’s reponse
Our earlier post http://oldoakneighbourhoodforum.org/?p=623 speculated on how Ealing Council would respond to OPDC’s proposed modificataions. Disappointingly this submission OPDC LP 2021 – LBE response final focuses mainly ‘strategic issues of industrial land supply‘ and whether OPDC are doing enough to achieve a ‘plan-led’ approach to waste disposal sites.
There is little or nothing in the Ealing reponse that reflects the very public commitments of Ealing’s Leader Cllr Peter Mason on a rethink of the Council’s approach to tall buildings and to respond to widespread resident opposition to past decisions of Ealing’s Planning Committee. This may be a result of Ealing’s response to OPDC having been prepared without much input from the Leader and his new Cabinet colleagues.
We have also seen representations made by the Friends of Wormwood Scrubs and by the Hammersmith Society. Both of these raise majot concerns about the direction of travel pursued by OPDC.
Copies of any further responses to the OPDC consultation would be welcome, as we would like to build a fuller picture now rather than to have to wait on what could become a lengthy exercise in collation and review by OPDC officers. We will continue to press for early publication of all representations made, in the original form as submitted.
There is no definite timtable for when OPDC will complete its collation of all responses, and send these to the Planning Inspector. This might be by late August 2021. The next stage of the ‘examination’ is then entirely in the hands of the Planning Inspector.
OPDC continue to assume that they will have an adopted Local Plan in place by the end of the year. We continue to believe that the odds on this outcome being achieved are not great.