Harrow & Wealdstone Area Action Plan Consultation
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Harrow and Wealdstone Area Action Plan Regulation 21(1)(c)(i-iv) Consultation Statement LDF Local Development Framework May 2012 1. Introduction 1.1 Consultation on the Harrow and Wealdstone Area Action Plan Issues and Options document took place between 13th May and 24th June 2011. Consultation on the Preferred Option document took place between 12th January and 23rd February 2012. Both rounds of consultation were undertaken in accordance with the Council’s Statement of Community Involvement and in line with regulations that were in place at the time (Regulation 25 of the Town and Country Planning Local Development Regulations 2004, as amended). These regulations required the Council to produce a statement (the 'Consultation Statement') setting out the consultation undertaken in the course of preparing the Area Action Plan, a summary of the main issues raised to consultation, and to detail how the Council’s took account of the comments received in preparing subsequent versions of the plan, including the latest version - the Pre-Submission version of the Area Action Plan. 1.2 Since consultation on the Preferred Option was undertaken in January 2012, new regulations have been published. The Town and Country Planning (Local Planning)(England) Regulations 2012 came into effect on 6th April 2012. While the numbering of the regulations has changed, the requirement upon the Council to produce a Consultation Statement has not changed. This Consultation Statement therefore fulfils the requirements under the new Regulation 22(1)(c)(i-iv) to produce a statement of the plan’s production (and represents the former Regulation (30)(1)(d) Consultation Statement). 2. Summary of consultation undertaken on the Area Action Plan Issues and Options consultation document 2.1 Upon commencement of the project to prepare an Area Action Plan (AAP) for the Harrow and Wealdstone Intensification Area, the Council established a cross-agency officer working group, comprising membership from the Council; the Greater London Authority; Transport for London; the Homes and Communities Agency; and representatives from the engagement forums (see below). The purpose of the working group was to provide specialist technical input into the preparation of the AAP. A Project Board was also established comprising director level representation from each of the authorities as well as the relevant Council Portfolio Holders. The purpose of the Board was to have oversight of the development of the AAP, including the monitoring of progress against deliverables, the adequate resourcing the project (both financial and staff time), and providing the political and agency sign-off required for key project milestones. 2.2 In addition to the Officer Working Group and Project Board, the Council also established a number of engagement forums as follows: The Landowners, Developers and Agents Forum – comprising membership of active local agents, key landowners within the Intensification Area, and developers with an interest in sites within the Intensification Area or active across the Borough; The Community Forum – comprising membership of local community groups, residents’ associations, and amenity societies; The Local Business Forum – comprising membership of local businesses, Harrow in Business, and the town centre managers for Harrow and Wealdstone town centres; The Youth Forum – comprising membership from the Harrow Youth Parliament as we as those actively involved in the Harrow MyCity2 project. 2.3 The engagement forums were set up to help champion and develop the AAP. Each was chaired by an independently appointed representative, who was then also appointed onto the Officer Working Group. The initial meetings of the engagement forum groups were held in September 2010 and were used to raise awareness of the purpose of preparing the AAP, its broad objectives, the statutory process required to prepare a Development Plan Document, and the requirements for plan making in terms of soundness and a robust evidence base. Subsequent forum meetings, held in October – November 2010, were used as a sounding board to confirm the key issues, challenges and opportunities facing the area currently and/or over the coming years, and to test alternative broad spatial development options for the area. 2.4 On 7th April 2011, Harrow’s Cabinet considered a report on the Harrow and Wealdstone Area Action Plan (see http://www.harrow.gov.uk/www2/documents/s74493/Harrow%20and%20Wealdstone%20AAP.pdf ). At that meeting Cabinet recommended the AAP be referred to Full Council for approval. 2.5 On 14th April 2011, Full Council endorsed the Area Action Plan Issues and Options document and resolved to publish the document for consultation for a period of six weeks. 2.6 In addition to the above Council sign-off, the Deputy Major for London also formally signed off on the AAP Issues & Options document for public consultation on behalf of the Greater London Authority. 2.7 In summary, the Issues and Options document put forward four broad alternative spatial development options for consideration by the community. The four broad options, including a brief commentary of their respective strengths and weaknesses, were: Option 1: One Centre – This option would see the three sub-areas (Harrow town centre, Wealdstone town centre and Station Road) being joined together by a shared intensification of activity, reducing any distinctions between the areas and, over time, see them developed as one large centre. This is a highly ambitious option that requires the maximization of the capacity of all strategic sites within the Intensification Area with development types (housing and employment) and densities being applied equally across the whole area. As a result, this option offers the highest overall outcomes in terms of levels of residential development and job outputs but this is likely to be at the cost of local context. This option may also not be compatible with existing levels of public transport accessibility and there is a risk that the market might not be able to absorb this level of development. Option 2: Harrow + – In this option, intensification and development would be focused on Harrow town centre. It would ensure the centre’s Metropolitan status was enhanced and retained, and would see significant public realm and infrastructure improvements delivered in the centre that would benefit the wider community. However, it would require most housing to be met in tall, flatted schemes, which presents risks in terms of market saturation as well as opposition from residents to see this form of development within the town centre. The option would only result in modest growth and benefits for Station Road and Wealdstone, and therefore does not optimize the regeneration opportunities that exist within these sub-areas. Option 3: Two Centres – This option would retain and reinforce the distinctiveness of Harrow town centre and Wealdstone, ensuring new development is sensitive to these areas. Growth would be focused within the two town centres, with flatted housing development in Harrow town centre (but at a much reduced scale than required under option 2) and the provision of family orientated housing in Wealdstone. The regeneration of Wealdstone will also benefit from housing and employment development of the Kodak site. Station Road does not play a significant role under this option, and therefore the opportunity to strengthen its role as a link between the two town centres and to regenerate Station Road will be missed. Option 4: High Roads and Centres – This option is similar to option 3, but with the additional benefit of realizing the development opportunities that exist along Station Road, which would facilitate much needed public realm improvements along this corridor. However, this option would require appropriate controls and more detailed guidance to be put in place to ensure the three sub-areas retained their distinctiveness, in terms of function and built form, and did not morph into one homogenous entity as proposed by Option 1. 2.8 To secure the widest possible understanding of the modelled outputs, housing densities were presented in the consultation document as five typologies and equated to forms of existing residential development in the Borough from lower density traditional family housing to higher density modern blocks of flats. Similarly, the employment outputs were expressed as numbers of jobs in office, industrial, retail & leisure and other sectors. To convey how the modelled outputs might vary between the three component parts of the Intensification Area, the distribution of housing and job types was disaggregated in relation to Harrow town centre, Wealdstone and Station Road, with a further modest allowance for additional & infill sites. 2.9 Formal notification of the AAP Issues and Options Publication (old Regulation 25) was given on 13th May 2011, and representations were invited for a six week period ending 24th June 2011. Representations were also invited on the Sustainability Appraisal during this period. 2.10 A formal notice setting out the proposals matters and representations procedure was placed in the ‘Harrow Observer’ newspaper on both the 12th and 19th of May 2011 (see Appendix A). In addition, on 12th May 2011 a total of 1,045 letters (see Appendix B) were sent by post or email to all contacts on the LDF database (see Appendix C), including all appropriate general consultation bodies. Enclosed with the letter was the Statement of the Representations Procedure (see Appendix D), a questionnaire (see Appendix E) and explanatory notes on how to use Council’s on-line consultation portal. Those emailed were also provided with the web link to the documents on the Council’s consultation portal and LDF web pages. All specific consultation bodies (see Appendix F) were sent a letter by post (see Appendix G) on 12th May 2011. Enclosed with the letter was a hard copy of the AAP Issues and Options document, the Statement of the Representations Procedure, the questionnaire and response form, as well as a CD containing the Sustainability Appraisal Report, the Equalities Impact Assessment, an electronic copy of the AAP Issues and Options document, and the Baseline Report.