All planning authorities in England are required to prepare and publish a Local Plan. This sets out the policies against which proposed new developments and any planning applications will be 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 last year a detailed set of comments which can be accessed 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. Local residents associations and community groups have been given an extra week to respond, because of the difficulties of organising meetings in August.
A copy of the Interim Forum’s response to this Regulation 19 version of the Local Plan at this link OONF response to OPDC FINAL
This is the final round of consultation prior to an Examination in Public carried out by a planning inspector (expected to happen in early 2018).
Key Diagram from Regulation 19 OPDC Draft Local Plan
Our response to this Regulation 19 version of the Local Plan repeats our previous views on the Regulation 18 version. We have a fundamental problem with the Plan in terms of its highly ambitious target of delivering 24,000 new homes at Old Oak. In our view this number of new homes is not realistic, once available sites and other constraints are looked at in any detail.
- this housing target leads to density levels way above the maximum envisaged in the London Plan. Even for an Opportunity Area with ‘intensification’ the end result would be an urban environment a long way from the ‘vision’ of world class regeneration promoted by the Development Corporation.
- this target may anyway be changed in the next London Plan if projections of an increasing London population fall back as a result of Brexit.
- this latest version of the Plan gives no clear information on expected building heights. It is less transparent and honest on this issues than was the previous version.
- the policies for the 12 ‘Places’ in the Plan are at a level of detail inappropriate for a Local Plan, revised only every 5 years or so. These policies should be in Area Action Plans or neighbourhood plans, which are more responsive to changing circumstances.
- policies protecting every inch of Strategic Industrial Land (SIL) at Park Royal are an outmoded approach for the period 2018-20130. 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 patters change. In an area with poor transport links and huge challenges on ‘connectivity’ it makes diminishing sense to zone different areas as ‘industrial’ and ‘residential’.
The new version of the OPDC Draft Local Plan includes a set of site allocations, identifying a precise targets for the number of housing units on each site. Despite our requests that information be provided on sizes of sites, expected densities, and a resultant range of building heights the document does not include this information.
At this final stage of Local Plan preparation, comments and responses need to be confined to pointing up where policies are not ‘sound’. Our consultation response identifies where we think policies are unsound or not justified, and our reasoning. Responses from other local organisations and groups make similar arguments. We have asked in our response for the opportunity to make oral representations at the Examination in Public.