London Borough of Islington Matter 2 – Area Spatial Strategies General Matters 2.1 Is the overall strategy set out by the area spatial strategies justified? 2.1.1 Yes. The approach to the area spatial strategies is also explained and assessed in the Integrated Impact Assessment chapter 4 (pages 91-99) (document reference PD4). As the IIA explains, the spatial strategies are based on key areas where the level of change expected over the plan period requires specific spatial policies for managing growth. The principle of growth and development is already established in the spatial areas through the adopted Core Strategy. The Core Strategy featured seven key area policies including Bunhill and Clerkenwell, the borough’s four town centres and two other key areas of change around key transport hubs and regeneration areas. These key areas have been carried forward into the Draft Local Plan. 2.1.2 An explanation of the approach to the area spatial strategies is provided in Topic Paper – Vision, Objectives, Policy PLAN 1 and Spatial Strategies (document reference SD20). As set out in the Topic Paper, the issues that existed when the spatial areas were derived continue to exist, with the spatial strategy reflecting the areas where growth and development needs have been and continue to be focused and recognising constraints for growth elsewhere. 2.1.3 A further explanation of the approach to the Area Spatial Strategies is set out in LBI03 (LB Islington response to the Inspectors letter INS04). The spatial strategy areas already accommodate established functions and land uses and these areas have the greatest capacity to accommodate future growth, with around 80% of the growth identified from allocated sites taking place in spatial strategy areas. Targeting growth towards the spatial strategy areas therefore responds to the identified need for land supply and opportunity from changing needs for different uses with spatial policies there to help guide the competing pressures for land use as well as to ensure that growth and change is accommodated sustainably. 2.1.4 Within the context of the above there are not considered to be any reasonable alternatives to the overall strategy set out by the area spatial strategies. 2.2 To be positively prepared, should each area spatial strategy set out indicative delivery figures in terms of residential and employment uses? 2.2.1 The indicative delivery figures for each spatial area are set out in the Site Allocations document at Table 1.2 and the Bunhill and Clerkenwell Area Action Plan at Table 4.2. These tables provide a clear illustration of the growth assumption associated with sites and read alongside the spatial strategies help the plan to be positively prepared in setting out how each area can contribute towards objectively assessed needs. 1 London Borough of Islington Matter 2 – Area Spatial Strategies 2.3 Are all of the area spatial strategy diagrams suitably legible? 2.3.1 It is acknowledged that in some instances some of the text can be difficult to read in the Regulation 19 Strategic and Development Management Policies. This is due to the way the software compressed the document when it was published which has effected the resolution of some of the images. A high resolution version of the document was produced for printing purposes and can be uploaded alongside or in replacement of the document that is currently online to assist with legibility. 2.4 Does the Plan adequately address the issue of neighbourhood planning? 2.4.1 Yes. Islington has no 'made' neighbourhood plans at present. However, the Plan acknowledges 'made' neighbourhood plans are part of the Development Plan paragraph 1.6 of the Strategic and Development Management Policies document. Each DPD also sets out how the AMR will also provide information on neighbourhood planning1. Paragraph 5.4 of the Strategic and Development Management Policies document highlights the role that neighbourhood plans can play in the designation of local green spaces. Through providing clarity about which policies are considered to be strategic, the Plan provides a clear framework for neighbourhood forum to use in the production of future neighbourhood plans. Strategic and Development Management Policies DPD Policy SP2 – King’s Cross and Pentonville Road 2.5 To be positively prepared and justified, should the approach to residential use in the area spatial strategy be set out? 2.5.1 The approach to residential uses on specific sites is set out in relevant site allocations, while other policies in the plan provide a framework for the approach to residential use in different circumstances. A large part of the spatial policy area to the north and east is made up of established residential uses. As recognised in paragraph 2.10 high-density, office retail and housing development has taken place on both sides of the Camden/Islington boundary. Aside from the established residential areas and specific site allocations where residential is recognised a key land-use challenge is how competing land uses can be balanced, particularly given King’s Cross development as a key commercial designation, with high profile tenants in the area creating a ‘halo’ effect. In this context a key role of SP2 in being positively prepared is to reflect the opportunity for the King’s Cross area to help meet Islington’s significant projected jobs growth over the plan period through protecting and intensifying business uses. The spatial policy reflects this in identifying existing employment locations (the King’s Cross Priority Employment Location is one of the largest in the borough) and also opportunities for further commercial-led development. Within this 1 Paragraph 10.7 of Development Management Policies, paragraph 5.8 of Bunhill and Clerkenwell Area Action Plan and paragraph 10.8 of Site Allocations. 2 London Borough of Islington Matter 2 – Area Spatial Strategies context part of the spatial area is within the CAZ. It is proposed to add some additional commentary on residential use in the supporting text. Proposed modification Amend text as follows: 2.13 The remainder of the Spatial Strategy area – outside of the PELs – may also be appropriate for the development of business floorspace as the ‘halo effect’ from the King’s Cross central development continues. North of the canal it is recognised that there is a predominantly residential character where the development of business uses will be considered in line with relevant policies including B2 and H2. …… Add new paragraph: 2.24 Housing development will come forward on sites allocated for housing. It is recognised that smaller windfall housing development, including through the utilisation of permitted development rights, will also come forward in the area over the plan period. 2.6 If residential use is considered to be unacceptable in the area spatial strategy area, does this comply with the NPPF and the London Plan? 2.6.1 Residential use is not considered to be unacceptable. The approach to residential use in the area outside the CAZ and PEL is picked up through other policies in the plan and Site Allocations. Assumptions for residential growth through site allocations are set out in the Site Allocations document (PD2) and topic paper (SD23). Other policies in the plan also provide the framework for competing land-uses to be prioritised and the circumstances in which residential use will be considered. The approach complies with the NPPF and London Plan. 2.7 For the Policy to be effective should the boundary of the knowledge quarter be defined? 2.7.1 The Knowledge Quarter (KQ) is defined as a partnership of 89 academic, cultural, research, scientific and media organisations located in a one-mile radius around King’s Cross, Euston Road and Bloomsbury2. It is a phenomenon that has emerged in recent years in Camden where world class institutions started to cluster in the area surrounding King’s Cross/St Pancras and Euston Stations. However because it is still emerging in Islington there is no defined boundary at this stage. The development of the KQ in the borough will be kept under review and it may be formally defined in a future review of the plan. Part B of spatial policy SP2 seeks the maximisation of business floorspace in this area to support the expansion of the KQ in Islington. 2 https://www.knowledgequarter.london/wp-content/uploads/2017/12/Knowledge-Quarter_Connection-and-Trusts.pdf (pages 02/03) 3 London Borough of Islington Matter 2 – Area Spatial Strategies 2.8 Is the approach of Policy SP2 to residential moorings justified? 2.8.1 Yes, the approach to residential moorings set out in Policy SP2 is justified as it balances the competing interests in use and enjoyment of the canal waterspace and corridor, including the use for boaters and navigation, as an open space, and a green space and biodiversity habitat. The Council supports development of new residential moorings where appropriate, including where they do not impact on leisure provision, and where there is no detrimental impact on the canal with regard to character, nature conservation, and air quality. Refer to question 3.57 for information on how the identified needs of boat dwellers will be met by the Local Plan. 2.9 Is the Central Activity Zone (CAZ) boundary in this area spatial strategy justified? 2.9.1 As part of the recommendations to review employment designations in the ELS (2016), the study considered that the council might review the CAZ boundary, in light of the pressures from the City economy3. This is also acknowledged by in Islington Local Plan: Scope of the Review report (PD11)4. This recommendation was considered general (not specific to this area spatial strategy). There is no evidence to support a change to the CAZ boundary at this time, particularly given the emerging nature of the KQ around King’s Cross and impacts of the wider King’s Cross Central scheme which is not yet complete.