All planning authorities in England are required to prepare and publish a Local Plan. This sets out the policies against which planning applications for proposed new developments are assessed and decided.
The OPDC started drafting its Local Plan in 2015. In early 2016 a first Draft Plan (‘Regulation 18 version’) was published and consulted on. We submitted a detailed set of comments which can be seen at this link response-to-opdc-draft-local-plan-final
A second ‘Regulation 19’ version of the Local Plan was published in June 2017. Public consultation on this new version ran until September 11th 2017.
A copy of the Old Oak Interim Forum’s response to this first Regulation 19 version of the Local Plan at this link OONF response to OPDC FINAL
Normally this would have been the final round of public consultation prior to an Examination in Public of the Draft Local Plan, carried out by a planning inspector. In this instance, the nature and extent of responses into the 2017 version was such that substantial changes needed to be made. This work was carried out by OPDC planners in late 2017 and the first half of 2018. A ‘Second Regulation 19’ Draft Local Plan was published by OPDC on June 12th, and a third 6 week consultation runs until July 30th.
Key Diagram from Regulation 19.2 OPDC Draft Local Plan
Our response to the first Regulation 19 version of the Local Plan repeated our previous views on the Regulation 18 version. We questioned the highly ambitious target of delivering 24,000 new homes at Old Oak. In our view this number of new homes is not realistic for successful and sustainable development, once site availability and other constraints are looked at in any detail.
In our comments on the 2017 Draft Local plan, we made the following points:
- this housing target leads to density levels in excess of the current London Plan Density Matrix. Even for an Opportunity Area with ‘intensification’ allowed the end result would be an urban environment a long way from the ‘vision’ of world class regeneration promoted by the Development Corporation.
- the 2017 Draft Plan excluded a map showing density ranges, which had appeared in the Regulation 18 version and which gave the public some idea of what to expect in different parts of the OPDC area
- the 2017 version also gave no clear information on expected building heights. It was less transparent and honest on this issue than was the previous version.
- this version included a set of site allocations, identifying a precise targets for the number of housing units on each site. Despite our request that information be provided to the public expected site densities and resultant building heights, the document did not include this information.
- the policies for the 12 ‘Places’ in the Plan were at a level of detail inappropriate for a Local Plan, revised only every 5 years or so. These policies were defined in the document as ‘strategic’ (and hence requiring ‘general conformity’ in any neighbourhood plan) whereas they did not meet nationally set criteria for ‘what makes a policy strategic’.
- policies protecting every inch of Strategic Industrial Land (SIL) at Park Royal are an outmoded approach for the period 2018-2030. The area of ‘Old Park Royal’ should be allowed to become a mixed use area, with residential as well as employment use provide that no employment floorspace is lost.
- future residents at Old Oak will want to live as close to their workplace as possible. For many their workplace may well be their home as working patterns change. In an area with poor transport links and huge challenges on ‘connectivity’ it makes diminishing sense to zone different parts of the OPDC area as ‘industrial’ and ‘residential’.
The new 2018 version of the OPDC Draft Local Plan can be found at this link to the OPDC consultation webpage. There is a ‘tracked changes’ version of the document, which allows the reader to see what edits have been made to the 2017 version. There is also a summary of these changes.
A separate page on the OPDC website takes you to a list of the 63 Supporting Studies and 15 further background documents that make up the full consultation exercise. These include a Tall Buildings Study, a Development Capacity Study, a Bus Strategy update, and a set of ‘Development Framework Principles’ for Victoria Road and for Old Oak North and Scrubs Lane.
From an initial read, these latest changes to the Drant Plan do little to reduce our concerns. In some cases, the new Draft Plan and the Supporting Studies reinforce our view that future plans for Old Oak need a radical rethink. Much of the proposed development around the new rail interchange is rephased until beyond the plan period of 2018-38, calling into question the whole ‘vision’ of a new Old Oak set out by Boris Johnson as Mayor in 2013.
There is much uncertainty as to whether the two proposed Overground stations (now ‘potential’ stations) at Old Oak Common Lane at at Hythe Road will ever be built, as no funding for these has been secured and TfL have major budget problems. Reliance on an improved bus network, on our already congested north-south routes, seems optimistic as a solution for a development of 24,000 ‘car-free’ new homes.
The revised Draft Plan acknowledges that Old Oak will be developed at an average density of 450 housing units/hectare (i.e. an average already well above above the maximum guideline of 405 units in the current London Plan Density Matrix. No map of density ranges is provided. No figures for anticipated densities are provided in the schedule of 35 specific site allocations in the document, even though these would be straightforward to calculate.
At the ‘Regulation 19’ stage of Local Plan preparation, comments and responses need to be confined to pointing out where proposed policies fail to meet a set of legal tests, as set out below. Generalised comments or objections will have little impact. The Forum will be doing its best to assemble a response which will meet these requirements.
|Positively Prepared:||The Local Plan should be prepared based on a strategy
which seeks to meet objectively assessed development
and infrastructure requirements, including unmet
requirements from neighbouring authorities where
it is reasonable to do so and consistent with
achieving sustainable development.
|Justified:||The plan should be the most appropriate strategy,
when considered against the reasonable
alternatives, based on proportionate evidence.
|Effective:||The plan should be deliverable over its period
based on effective joint working on
cross-boundary strategic priorities.
|Consistent with National Policy:||The plan should enable the delivery of sustainable
development in accordance with the policies in
the National Planning Policy Framework and the supporting National Planning Practice Guidance.
Our further (third) response is being drafted and will focus on the changes made to the 2017 Draft Local Plan. As before, we will be asking that Plan is written in language that the public can understand, and is honest and open on issues that local people worry most about (including building heights, traffic, availability and phasing of schools and health facilities).
We will also be asking that the Forum be given the opportunity to give oral evidence before a Planning Inspector at the Examination Public, likely to take place in late 2018 or early 2019.