New Local Plan Review: Issues and Options

Summary of Responses

Q.1.1

Overall Vision for the New Local Plan

The Planning Acts require each local planning authority to identify the strategic priorities for the development and use of land in its area. We intend to do this through the New Local Plan Review (NLPR), with an ambitious and succinct overall vision that reflects our ambitions and our priorities for future development.

This vision must be guided by and reflect the priorities identified in the Council Plan following extensive public engagement. We have reflected on these suggestions. In particular that we will need to:

  • narrow the inequality
  • put green issues and the environment at the heart of all new development
  • further enhance the Borough’s outstanding townscape

What do you think should be included in the New Local Plan’s vision?

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Q2.1

Section 2 of the Issues and Options paper sets out four key concepts that should underpin the NLPR and run as a common theme across what we are trying to achieve. These are:

  • An Inclusive Borough
  • Connected Borough
  • Green Borough
  • A Beautiful Borough

Please give us your views on the key concepts, should there be any others?

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Q3.1

SECTION 3: PLACES

The current Local Plan has identified eleven "Places" or areas which would benefit from local visions to help shape their nature in the future. The Issues and Options paper groups these Places into two broad categories:

  • Areas that can accommodate growth
  • Areas with a particular national or international reputation

The Places are set out in the maps and tables in Section 3 of the Issues and Options paper. These include a precis of the existing visions for these areas. The full visions can be viewed in the relevant place chapter within the current Local Plan.

Please let us know your views on these areas of change.

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Q3.2

Last time you told us that we had identified the correct Places. Do you still think this is the case?

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Q3.3

The Council will look again at the existing visions for these Places and consider whether they remain appropriate. Do you have any views on the shortened visions for the Places as drafted in the table above? Is there anything else we should include?

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Q5.1

SECTION 5: LOCATIONS FOR FUTURE DEVELOPMENT. ‘A CALL FOR SITES’

As a central and highly built-up area, with extraordinarily high land values, Kensington and Chelsea has very little space that is free for development. Most land that has not been built on is strongly protected for either its historic or landscape value. However, we would be interested to hear of any additional sites which may be suitable for new development and which may have the potential to contribute to the Borough’s future needs.

In the responses to the Borough Issues paper consultation, 13 sites were suggested as suitable for new development. The proposed sites have gone through the first stage of the sifting process to assess their suitability for being designated as new site allocations.

Are you aware of any sites that might be suitable for new development?

If so, please provide us with:

  • the site location
  • the potential type of development
  • the scale of development; and,
  • possible constraints on development such as historic buildings, parks and open space or protected uses such as offices, education and medical uses.

This question has been answered 39 times.

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Q5.2

How do you feel about the sites that were identified in the first round of call for sites? Do you find them suitable for development? Do you agree with their current categorisation?

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Q6.1

SECTION 6: BLUE-GREEN FUTURE

Issue 1: Climate change and building design

The Local Plan will be one of the key documents in achieving the Council’s target to be a carbon neutral borough by 2040. It can set out how we expect the energy efficiency of both new and existing buildings will be improved.

A series of options for policy approaches towards the reduction of toxic emissions are set out under Issue 1 of Section 6 of the Issues and Options paper.

Which of these options do you support? You can pick more than one.

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Q6.2

Do you have any other options to suggest?

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Q6.3

Issue 2: Air Quality

In this borough, we remain concerned about concentrations of nitrogen dioxide (NO2) and particulate matter (PM10 and PM2.5), and the whole borough has been declared an Air Quality Management Area (AQMA).

We must reduce emissions of nitrogen dioxide and particulate matter as well as addressing the negative effect of climate change in order to become more resilient. A series of options for how we can control air pollution through the New Local Plan are set out under Issue 2 of Section 6 of the Issues and Options paper.

Which of these options do you support? You can pick more than one.

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Q6.4

Do you have any other options to suggest?

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Q6.5

Issue 3: Noise and vibration

Pollution also comes in the form of noise and vibration which can seriously affect the amenity of residents and visitors both during the construction and operation of new development. The Council is committed to protect residents’ amenity and quality of life from development where noise and or vibration is generated.

A series of options for how we can control noise and vibration in the Borough are set out under Issue 3 of Section 6 of the Issues and Options paper.

Which of these options do you support? You can pick more than one.

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Q6.6

Do you have any other options to suggest?

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Q6.7

Issue 4: Flood risk

There is no doubt that increasing global temperatures will lead to more intense rainfall and severe weather. Therefore, we need to plan for more surface water (rain) and sewer water flooding, the main types of flooding that we expect across our borough.

A series of options for addressing flooding and flood risk in the Borough are set out under Issue 4 of Section 6 of the Issues and Options paper.

Which of these options do you support? You can pick more than one.

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Q6.8

Do you have any other options to suggest?

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Q6.9

Issue 5: Biodiversity

A new Environmental Bill is expected to become an Act of Parliament (law) later this year, which will introduce a requirement for all developments to provide a biodiversity net gain.

A set of options for policy approach to biodiversity in the Borough are set out under Issue 5 of Section 6 of the Issues and Options paper.

Which of these options do you support? You can pick more than one.

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Q6.10

Do you have any other options to suggest?

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Q6.11

Issue 6: Green Infrastructure

Green infrastructure can be found in cities in the form of parks of different sizes, front and rear gardens, grassed areas, street trees, allotments, hedges, green roofs and green walls.  It can have lots of benefits including reducing pollution, enhancing biodiversity, reducing the risk of flooding and as a space of children. The NLPR will build on the benefits of green infrastructure and ensure a holistic approach to increase not only the greening cover in the Borough but also its quality.

A set of options for policy approaches to green infrastructure in the Borough are set out under Issue 6 of Section 6 of the Issues and Options paper.

Which of these options do you support? You can pick more than one.

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Q6.12

Do you have any other options to suggest?

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Q6.13

Issue 7: Waste Management

People, businesses and new development generate waste. The Mayor of London wants as much waste as possible to be managed in London and encourages a move towards a circular economy to reduce the amount of waste that is produced. The current Local Plan approach to managing waste is to work closely with other London boroughs to ensure that there is enough capacity to manage this amount of waste, this approach will continue.

A set of options for policy approaches to waste management are set out under Issue 7 of Section 6 of the Issues and Options paper.

Which of these options do you support? You can pick more than one.

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Q6.14

Do you have any other options to suggest?

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Q7.1

SECTION 7: HOMES

Issue 1: Delivering the homes that we need

Every Council in the country needs to have a housing target and is required by the Government to deliver this. Our housing target is set through the London Plan 2021 and is 448 homes per annum.  We need to plan proactively, and make sure that each site maximises its potential if we are to deliver it.  However, it is also essential that we do not compromise on the quality of new developments.

A set of options for how we support the delivery of new housing in the Borough are set out under Issue 1 of Section 7 of the Issues and Options paper.

Which of these options do you support? You can pick more than one.

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Q7.2

Do you have any other options to suggest?

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Q7.3

Issue 2: Protecting existing homes

The loss of existing homes makes it more difficult for us to meet our housing target. One of the main ways we lose homes is when a number of smaller flats are amalgamated to create a single larger unit.

A series of options for how we can protect existing homes through the New Local Plan are set out under Issue 2 of Section 7 of the Issues and Options paper.

 

Which of these options do you support? You can pick more than one.

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Q7.4

Do you have any other options to suggest?

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Q7.5

Issue 3: RBKC Community Housing

The Council adopted a new planning document entitled RBKC Community Housing in June 2020. ‘Community Housing’ is the term we use to describe genuinely affordable housing in the Borough. Within this term we prefer three housing products that we consider to be genuinely affordable – social rent; London affordable rent and intermediate rents set at London Living Rents at the lowest ward level (currently Notting Dale).

Our current policy requires at least 35 per cent affordable housing on residential development that is 650 sq. m or more. However, national policy says we should be requiring this only where 10 homes are being created or there is a floorspace of 1,000 sq. m. In addition, the Government has introduced a new requirement that 25 per cent of the affordable housing provision should be First Homes (Planning Practice Guidance NPPG: First Homes).

A set of options for policy approaches to affordable housing are set out under Issue 3 of Section 7 of the Issues and Options paper.

 

Which of these options do you support? You can pick more than one.

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Q7.6

Do you have any other options to suggest?

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Q7.7

Issue 4: Housing for older people

Our existing Local Plan policy provides support for all types of older people’s housing. However, to be more effective the policy needs to be revised to be finer grained and reflect the future need for the various types of specialist older people’s housing in the Borough. This includes an understanding of the need that can be fulfilled by private provision and that which needs to be genuinely affordable.

A set of options for policy approaches to older people’s housing in the Borough are set out under Issue 4 of Section 7 of the Issues and Options paper.

Which of these options do you support? You can pick more than one.

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Q7.8

Do you have any other options to suggest?

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Q7.9

Issue 5: Other housing products

The Borough's residents may benefit from a range of different types of housing, including Build to Rent Homes, shared living, co-living or houses in multiple occupation.

A set of options for policy approaches to other housing products in the Borough through the New Local Plan are set out under Issue 5 of Section 7 of the Issues and Options paper.

Which of these options do you support? You can pick more than one.

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Q7.10

Do you have any other options to suggest?

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Q7.11

Issue 6: Estate renewal policy

The Council made a commitment to end estate regeneration on Council owned estates. There is no change to this commitment. However, the current Local Plan retains a policy on estate renewal from 2010, which helps guide developments on housing estates owned by registered providers. Certain elements of this policy should be updated to reflect the London Plan 2021. For example, we would like to make it clear that in such schemes we will be looking not just for the replacement of the existing homes but net additional community homes. A series of options for doing so are set out under Issue 6 of Section 7 of the Issues and Options paper.

Which of these options do you support? You can pick more than one.

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Q7.12

Do you have any other options to suggest?

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Q7.13

We consider that most parts of the retained policy CH5 are still fit for purpose, but it can be updated to be further strengthened as described above. We would be guided by the community on this. Please provide us with your views.

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Q8.1

SECTION 8: TOWN CENTRES

Issue 1: Covid-19 recovery and maintaining the vitality of our centres

Town Centre First

The NPPF and the London Plan require a “town centre first approach” and a “sequential test” for any new town centre use. This means that councils are expected to direct new shops and other commercial town centre uses to existing centres. These principles have served the Council well and we intend to take these principles forward into our new Local Plan. However, the NLPR is an opportunity to revisit some of the details around these tests, and to consider whether we need to change our current approach.

Options for policy approaches to town centres are set out in Issue 1 of Section 8 of the Issues and Options paper, under Town Centre First.

These options are not mutually exclusive. Do you support these options?

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8.2

Do you have any other options to suggest?

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Q8.3

Mix of Uses in our Centres

Recent changes to planning regulations means that planning permission is no longer required for one “commercial, business or service” use to change to another.  The NLPR must reflect these changes and can no longer have detailed frontage policies which set out the proportion of shops that we can expect in different parts of our town centres.

Options for policy approaches to deliver a mix of uses in our centres are set out in Issue 1 of Section 8 of the Issues and Options paper, under Mix of Uses in our Centres.

Which of these options do you support? You can pick more than one.

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Q8.4

Do you have any other options to suggest?

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Q8.5

Residential uses within our centres

A recent change to planning regulations means that a Council can only consider a narrow suite of issues when deciding whether most town centre uses can be used for housing.  We intend to make what is known as an “Article 4 direction” to ensure that planning permission will continue to be required. However, this is a long process, which cannot be confirmed until at least August 2022. 

Do you support us making an Article 4 direction to ensure that planning permission will continue to be required for changes of use of commercial, business and service uses to residential? If so, should the direction cover all of our town centres?

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Q8.6

Do you have any other options to suggest?

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Q8.7

Issue 2: The future nature of our town centres

An attractive town centre which provides a range of unit types will be best placed to make a strong and lasting recovery in the future. Options for policy approaches to guide the future of our town centres are set out under Issue 2 of Section 8 of the Issues and Options paper.

Do you support any of these suggested strategies for our town centres?

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Q8.8

Do you have any other options to suggest?

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Q8.9

A review of a local plan also offers an opportunity for us to review the boundaries of our town centres.

Are any areas or parades which should be added to, or removed from an existing centre? Please be specific and explain why.

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Q9.1

SECTION 9: BUSINESS AND CULTURE

Issue 1: The provision of offices The Council values offices as a use which can support the local and the wider economy. In a borough such as ours, where residential property values are generally significantly higher than any other, new offices rarely come forward unbidden. To meet our need for new office floorspace we try to stop the loss of any existing offices; and encourage the provision of new offices in appropriate locations. This approach has proved successful however, it is now timely to consider whether this approach is still appropriate. Options for policy approaches to office space in the Borough are set out under Issue 1 of Section 9 of the Issues and Options paper.

Q9.1: Which of these options do you support? You can pick more than one.

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Q9.2

Do you have any other options to suggest?

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Q9.3

Issue 2: Light industrial uses

The Council promotes the widest range of business uses to ensure that the Borough can benefit from the talents of all those who live here. To this end we have tried to support light industrial uses where we can, and to resist their loss to residential. However, this ambition must be seen in the context of planning regulations which have long allowed one business use to change to another without the need for planning permission.

Options for policy approaches to light industrial uses in the Borough are set out under Issue 2 of Section 9 of the Issues and Options paper.

Which of these options do you support? You can pick more than one.

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9.4

Do you have any other options to suggest?

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Q9.5

Issue 3: Affordable workspaces

A Council can require the provision of an affordable workspace when granting planning permission for a large new commercial development. However, it will have a "cost" on the development which may mean that other benefits cannot be provided.

Options for policy approaches to affordable workspaces are set out under Issue 3 of Section 9 of the Issues and Options paper.

Which of these options do you support? You can pick more than one.

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9.6

Do you have any other options to suggest?

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Q9.7

In pre-Covid times tourism was one of the borough’s key economic drivers. Whilst current uncertainty and restrictions means that it may not be until 2024 when we might expect to welcome visitor back in the numbers we have before, the good times will return.

Platforms such as Airbnb, TripAdvisor and HomeAway are relatively new and provide visitors with many more options in addition to the traditional hotels. The NLPR should provide a supportive environment balancing other issues they can create for residents in the quieter parts of the Borough.

Options for policy approaches to hotels and visitor accommodation are set out under Issue 4 of Section 9 of the Issues and Options paper.

Which of these options do you support? You can pick more than one.

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Q9.8

 Do you have any other options to suggest?

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Q10.1

SECTION 10: SOCIAL AND COMMUNITY USES

Issue 1: Types of social and community use

The current Local Plan identifies five broad categories of social and community use. These are:

  • medical or quasi-medical uses
  • education uses
  • sports facilities
  • uses supporting the emergency sectors
  • other ‘valued use’

Options for policy approaches to identifying and defining types of social and community uses in the New Local Plan are set out under Issue 1 of Section 10 of the Issues and Options paper.

Which of these options do you support? You can pick more than one.

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Q10.2

Do you have any other options to suggest?

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Q10.3

Issue 2: The protection of social and community uses

The starting point within the existing Local Plan is that existing social and community uses should be protected. The Government recently changed planning regulations, which mean that the Council is no longer able to protect all social and community uses. Any new policy must reflect the freedoms offered by the new regulations.

Options for policy approaches to the protection of social and community uses are set out under Issue 2 of Section 10 of the Issues and Options paper.

Which of these options do you support? You can pick more than one.

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Q10.4

Do you have any other options to suggest?

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Q10.5

Issue 3: The need for new social and community uses

The Council will carry out a review of the current and projected need for social and community uses to ensure that the right uses are provided in the right places. We are also preparing an updated Infrastructure Delivery Plan (IDP) which will set out the type of infrastructure required to support development in the Borough.

The proposed policy approach to support delivery of new social and community facilities in the Borough through development is set out under Issue 3 of Section 10 of the Issues and Options paper.

Do you support the option proposed?

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Q10.6

Do you have any other options to suggest?

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Q11.1

SECTION 11: TRANSPORT

Issue 1: Increasing active travel

Whilst the private car will always remain important, walking and cycling can improve health and are good for the environment.

The proposed policy approach to supporting and facilitating walking and cycling in the Borough through new development is set out under Issue 1 of Section 11 of the Issues and Option paper.

Do you support this option? You can pick more than one.

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Q11.2

Do you have any other options to suggest?

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Q11.3

Issue 2: Traffic congestion

The majority of the Borough’s streets were designed and laid out before the advent of the car. They are often dominated by traffic, despite borough residents having some of the lowest levels of car ownership in the country.

Options for policy approaches to controlling traffic congestion in the Borough through the New Local Plan are set out under Issue 2 of Section 10 of the Issues and Options paper.

Which of these options do you support? You can pick more than one.

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Q11.4

Do you have any other options to suggest?

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Q11.5

Poor air quality is increasingly one of our residents’ main transport-related concerns, and with justification. There are high levels of pollutants, nitrogen dioxide (NO2), particulates (PM10) and fine particulates (PM2.5) on the Borough’s arterial roads.

Electric vehicles are becoming more prevalent and new developments are required under the London Plan to provide on-site charging. Whilst a move to electric vehicles will greatly reduce tailpipe emissions, it will not solve the issue of fine particles generated by braking and tyre wear. Any reductions in pollution that serve to encourage more walking and cycling will be self-reinforcing. These could potentially be achieved by requiring the use of electric vehicles, where it would be reasonable to do so, or securing additional tree planting and green infrastructure.

Options for policy approaches to electric vehicles (EVs) and EV charging infrastructure are set out under Issue 3 of Section 11 of the Issues and Options paper.

Which of these options do you support? You can pick more than one.

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Q11.6

Do you have any other options to suggest?

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Q11.7

Issue 4: Improving access to public transport

Public transport accessibility is generally good in much of the Borough but there are areas in the north west, along parts of the western boundary, along the River Thames and in the south west that are less accessible, particularly in terms of accessibility to the Underground network. It is important that everyone can travel spontaneously and independently on public transport services.

Options for policy approaches to improving public transport accessibility in the Borough through the Local Plan are set out under Issue 4 of Section 11 of the Issues and Options paper.

Which of these options do you support? You can pick more than one.

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Q11.8

Do you have any other options to suggest?

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Q12.1

SECTION 12: STREETS, PARKS AND OUTDOOR SPACES

Issue 1: Parks and play space

In a built-up area like Kensington and Chelsea the provision of safe and stimulating play facilities are vital for children’s’ well-being and development.

The proposed policy approach to supporting provision of new parks and play spaces through the Local Plan is set out under Issue 1 of Section 12 of the Issues and Options paper.

Do you support this option? You can pick more than one.

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Q12.2

Do you have any other options to suggest?

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Q13.1

SECTION 13: CONSERVATION AND DESIGN

Issue 1: Building heights

The London Plan 2021 Policy D9: Tall Buildings requires that our NLPR should define what is considered a tall building for specific localities. Tall buildings should not be less than 6 storeys, or 18 metres measured from ground to the floor level of the uppermost storey. It also says that our NLPR should identify locations where tall buildings may be an appropriate form of development. It is therefore important that we start addressing this issue as part of this consultation.

A series of options for how we address tall buildings in the New Local Plan are set out under Issue 1 of Section 13 of the Issues and Options paper.

Which of these options do you support? You can pick more than one.

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Q13.2

Do you have any other options to suggest?

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Q13.3

Issue 2: Design quality, character and growth

Chapter 12 of the NPPF recognises that one of the fundamental requirements of the planning and development process is to deliver well designed, high quality buildings. It puts the onus on local authorities to proactively support high quality new development by working with local communities to identify the type, scale and character of new building that will acceptable across the Borough.

The Borough’s design policies put the preservation of its character at their heart. As part of producing the NLPR we have been undertaking a Character study. This will assist us to identify areas and opportunities for growth, as well as reinforce areas for protection.

Options for approaches to design policy are set out under Issue 2 of Section 13 of the Issues and Options paper.

Which of these options do you support? You can pick more than one.

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Q13.4

Do you have any other options to suggest?

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Q13.5

Issue 3: Fire Safety

Within the national framework, fire safety matters are front and centre of major planning applications. However, the majority of planning applications are either minor or ‘other’ applications, and as such fall outside of the scope of the London Plan Policy D12(B) or the Building Safety Regulator. While it is agreed that within the planning regime, major planning applications generally have a higher risk profile than other developments, there are other development types that also have a suitable risk profile that could warrant the requirement of a Planning Fire Safety Strategy to be submitted showing that the development meets the policy objectives of London Plan 2021 Policy D12(A).

Options for approaches to fire safety policy in the New Local Plan are set out under Issue 3 of Section 13 of the Issues and Options paper.

These options are not mutually exclusive. Do you support these options?

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Q13.6

Do you have any other options to suggest?

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Q13.7

We consider that most parts of the following existing policies are still fit for purpose, but some of them can be updated to be further strengthened as described above. We would be guided by the community on this. Please provide us with your views on this.

  • Policy CL5 Living Conditions
  • Policy CL6 Small-scale Alterations and Additions
  • Policy CL7 Basements
  • Policy CL8 Existing Buildings – Roof Alterations/Additional Storeys
  • Policy CL9 Existing Buildings – Extensions and Modifications
  • Policy CL10 Shopfronts
  • Policy CL11 Views

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Q14.1

SECTION 14: INTEGRATED IMPACT ASSESSMENT

We have produced an IIA Scoping Report published alongside this consultation. The IIA objectives have been considered around the three key elements of sustainability. These are set out in Section 14 of the Issues and Options paper.

Please have a look and give us your views.

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Q15.1

Do you have any other comments on any part of the Issues Paper?

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