Comments from The Pinner Association on the Draft New London Plan.

February 2018.

These comments refer to the Design, Housing, Heritage and Green Space, and Transport policies proposed in the Draft New London Plan (DNLP) which will most affect the amenity of current and future residents of outer London boroughs.

Background to The Pinner Association’s comments below:

Pinner is in the London Borough of Harrow and constitutes a “village” centre dating back to medieval times, together with mostly 20th century “Metroland” development and more lately an increasing number of flats developments in and near the “town centre” (designated as a “District Centre” in the DNLP). With the loss of employment opportunities within Harrow borough, the majority of Pinner residents now work in central London, commuting via the Metropolitan Line. It is an area with well regarded schools (both state and private) which has attracted many families to move to the area. In the main planning applications are to extend houses, but more recently applications to demolish existing detached houses and rebuild a larger dwelling are being submitted. Many new one bedroomed flats have been, or are being built, or converted from office buildings under Permitted Development, in those areas with good access to public transport. Harrow Council has just granted itself planning consent to build twenty 3 and 4 bedroomed houses for rent (or sale?) on a council owned car park in Pinner, with only 10% “affordable housing”. The number of new housing units created over the past five years is already well over that proposed in the current Harrow Local Plan Core Strategy to the year 2026, and very little of this is “affordable housing”. However, insufficient, if any, concomitant improvements in local infrastructure have been supplied and many Pinner residents complain of the difficulty in accessing GP and other health services and school places.

General Comments on Draft New London Plan:

Objection: We have grave doubts about the practical implementation of any New London Plan as Harrow Council, and we suspect many other local authorities, do not now have sufficient numbers of well trained and knowledgeable officers to write all the modifications to Local Plan documents that will be required. A 20% increase in planning fees will not cover the resources required for this complex and detailed task, even if all the increase in fees were to be assigned to cover this additional work. The current parlous state of local authority budgets mean that it is possible that some of the increased planning fees money will be allocated to other uses, as this additional money is not to be ringfenced for Local Plan purposes.

Objection: We question why an arbitrary 800 metre from a town centre boundary or Tube or railway station radius has been chosen in the DNLP as the area within which to “optimise the delivery of housing delivery” in addition to using the well tried and tested PTAL categories (PTAL’s 3 – 6) which take account of the actual walking or cycling routes available to access transport hubs.

Objection: The absence of a table of recommended housing densities in the DNLP is regrettable as this would be of great use to local residents in establishing whether a proposed new development would be in keeping with the surrounding area and whether an undue strain may be placed upon the local infrastructure.

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Comments on specific policies in Chapters 2,3,4,5 7,8, and 9:

Policy SD9 Town centres: Support: Local partnerships and [C] (1) – “Article 4 directions to remove permitted development rights implementation for office, light industrial and retail to residential in order to sustain town centre vitality and viability and to maintain flexibility for more comprehensive approaches to town centre housing and mixed‐use intensification.” Policy D1 London’s form and Support: characteristics [B] ‐ “Development design should: 1) respond to local context by delivering buildings and spaces that are positioned and of a scale, appearance and shape that responds successfully to the identity and character of the locality, including to existing and emerging street hierarchy, building types, forms and proportions.” Policy D9 Basement Support – and should be extended to outer London boroughs. development We are finding that even in the “leafy suburbs” planning applications to demolish existing houses and rebuild with “large scale” basements are being submitted. In an area infamous for “shrinkable London clay” subsoil this is a cause of great concern for surrounding property owners. Policy H1 Increasing housing Strong Objection: supply Table 4.1 appears to take no credence of the very large number of new “homes” – mostly one bedroomed flats – which have already been, or are being, constructed in up to 19 storey towers or converted from office blocks in Harrow town centre and the surrounding town and district centres. The local transport, health, education and opportunity for employment infrastructure has not been increased to keep pace with this rapid development. Policy H2 Small sites Strong Objection: A “presumption in favour of small housing developments” would completely change the character of the suburban areas of the outer London boroughs. In particular, infill developments on garden land would seriously adversely affect the amenity of surrounding residents, as would increasing the height of existing residential buildings. Table 4.2 ‐ In Harrow borough a target of nearly 965 per annum for ten years for new “homes” to be built on “small sites” would completely change the character of many areas in which families have chosen to live and put an increased strain on the already insufficient local infrastructure. “4.2.9 Loss of existing biodiversity or green space, as a result of small housing developments, should be mitigated through measures such as the installation of green roofs, the provision of landscaping that facilitates sustainable urban drainage, or off‐site provision such as new street trees in order to achieve the principle of no net loss of overall green cover.” – The loss of garden land, an acknowledged extremely important resource for biodiversity in Greater London, would not be “mitigated” by green roofs and street trees – these items should be in

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addition to green space and not a replacement for that amenity. Fig 4.3 ‐ An arbitrary 800 metre from a town centre boundary or Tube or railway station radius as the area within which to “optimise the delivery of housing delivery” in addition to using the well tried and tested PTAL categories (PTAL’s 3 – 6), which take account of the actual walking or cycling routes available to access transport hubs, is arbitrary and there is no justification as to why this particular distance has been specified. Policy H5 Delivering Is the “target” of 50% “affordable housing” achievable in practice? In affordable housing our experience, even with the current more modest affordable housing requirements, developers provide viability assessments that conclude that a site cannot be developed with any affordable housing. Policy H12 Housing size mix Objection: 4.12.3 – “Family units have historically been considered to be those consisting of three or more bedrooms. However, as many families do live in two bedroom units this should be taken into account” – classifying two bedroomed units as “family accommodation” will lead to cramped living conditions for many people, however convenient it may be for the GLA and LA’s to use when monitoring whether they have met the required targets. Policy S2 Health and social Support – if this compels some joined up thinking in the planning of the care facilities increased health and social care infrastructure which will be required should the proposed additional housing be built. Policy S6 Public toilets Support. Policy E9 Retail, markets and Support [B] (5) – “provide a policy framework to enhance local and hot food takeaways neighbourhood shopping facilities and prevent the loss of retail and related facilities that provide essential convenience and specialist shopping” – the vitality and viability of primary shopping areas in town and district centres is of increasing concern. Policy HC1 Heritage Support [C] – “Development proposals affecting heritage assets, and conservation and growth their settings, should conserve their significance, by being sympathetic to the assets’ significance and appreciation within their surroundings. The cumulative impacts of incremental change from development on heritage assets and their settings, should also be actively managed. Development proposals should seek to avoid harm and identify enhancement opportunities by integrating heritage considerations early on in the design process.” – except that “enhancing” heritage assets can cause harm and decrease the heritage significance of the site. Policy HC7 Protecting public Support as being important to protect the character and vitality and houses viability of town and district centres. Policy G2 London’s Green Belt Support – but concerns re [A] (2) as to what may be regarded as “appropriate multifunctional uses". Policy G3 Metropolitan Open Support Land Policy G4 Local green and Support open space Policy G7 Trees and Support – but how does this fit with the presumption for development woodlands on small sites such as infill development on garden land? Page 3 of 4

Policy SI9 Safeguarded waste Support – and boroughs should be required to co‐operate so that the sites most easily accessed, with the shortest journey, waste site may be used by residents of other boroughs rather than being required to drive a distance across a large outer London borough to access “their” waste site.

Comments on Chapter 10 – Transport: 1. Agree with concept of healthy street although pollution is less of a problem in leafy suburbs 2. Agree with aim of increasing walking, cycling and use of public transport. However, this is hard to achieve in outer London where distances are greater and public transport less well provided. It is totally unrealistic to expect the targets of reducing car use will be met in outer London. 3. In the light of 2, provision must be made for reducing congestion at key junctions. This reduces pollution from stationary or slow moving vehicles and reduces journey time especially for buses 4. Agree with more street trees. It’s what makes the suburbs attractive and is good for the environment 5. Agree with Vison Zero for Road Safety. Sufficient resources must be available, eg traffic police for monitoring and road safety engineers and trainers 6. Accessibility at stations must be improved. Harrow on the Hill scheme must be completed. 7. All Harrow’s bus stops are already disabled compliant. This must be monitored for new stops or in case of any changes 8. More frequent trains to Watford are required. Completion of Metropolitan line extension (not mentioned in Transport section and funding now withdrawn by Mayor of London) and at least 4 trains per hour on Overground 9. Aim for night service on Metropolitan line and Piccadilly line to Ruislip 10. Agree with transport assessments for new developments 11. Objection: Cycling targets totally unrealistic. Danger of wasted space for unused cycle storage 12. Objection: Car parking must be minimum not maximum standards. It is unrealistic to assume that restricting parking will restrict car use. Inadequate provision just leads to parking on the roads, which is dangerous, reduces access e.g. for emergency and refuse vehicles and is unsightly. On‐ street parking restrictions should be removed where they are unnecessary and it is safe or expedient to do so 13. Agree flexibility in parking standards is necessary subject to above 14. Objection: Motorcycling has minimal impact on car use and car parking spaces should not be sacrificed to allow for them 15. Objection: Car clubs are not practical in low density suburbs 16. Agree adequate freight access should be provided for retail developments

The Pinner Association. Registered Charity 262349. www.pinnerassociation.co.uk February 2018.

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