Consultation Statement NPPF Revision to Westminster’S Core Strategy

Consultation Draft

Consultation Statement NPPF Revision to Westminster’s Core Strategy

Local Development Framework July 2012 Consultation Statement: NPPF Revision

1.0 Introduction

1.1 This Consultation Statement has been prepared to meet the requirements of Regulation 22 of the Town and Country Planning (Local Development) (England) Regulations 2012 (“The Regulations”), and forms part of the proposed submission documents for the purposes of Regulation 19 of The Regulations. It will be updated once the Regulation 19 consultation has taken place to form a final Consultation Statement.

1.2 The Statement details the consultation undertaken by Westminster City Council (‘the council’) during the Regulation 18 consultation on the revisions to the Core Strategy arising from the publication of the National Planning Policy Framework, referred to as the “NPPF Revision”.

1.3 It details who was consulted at Regulation 18 stage, for how long, and how they were invited to make representations. A summary of the main issues raised by the responses is provided, and details as to how these representations have been taken into account in the Consultation Draft NPPF Revision subject to the Regulation 19 consultation.

1.4 Consultation was carried out in compliance with the council’s Statement of Community Involvement (SCI, adopted January 2007), thus meeting Section 19 of the Planning and Compulsory Purchase Act 2004 (as amended).

1.5 All contacts on the council’s LDF database were consulted, together with all statutory consultees in Regulation 4 of The Regulations, all ward councillors, and all neighbouring boroughs. The council’s LDF database was created in April 2007 and was initially populated with contact information from the Unitary Development Plan (UDP) database. Since the creation of the database, consultee contact information has been updated on a continual basis, with contacts being added, removed or amended on request. The database currently has 2,254 consultees.

2.0 Formal Notification under Regulation 18 of The Regulations

2.1 Formal notification of the NPPF Revisions was carried out between 1st May 2012 to 15th June 2012, for a period of just over six weeks. Notification was made by email to the vast majority of the 2,254 consultees (see Appendix 4), with a small number of letters sent to those who were not able to be contacted by email. Statutory consultees and local/regional authorities contacted were: 1. The Environment Agency 2. English Heritage 3. Natural England 4. Homes and Communities Agency 5. Westminster PCT 6. NHS 7. The Highways Agency 8. Office of Rail Regulation

9. Civil Aviation Authority 10. Transport for London 11. Greater London Authority and Mayor of London 12. London Borough of Camden 13. London Borough of Southwark 14. London Borough of Lambeth 15. City of London 16. London Borough of Wandsworth 17. London Borough of Brent 18. Royal Borough of Kensington & Chelsea

2.2 A copy of the consultation letter is attached as Appendix 1. Consultees were advised that the City Council was intending to make two revisions to the Core Strategy: the NPPF Revision and the CMP Revision. Consultees were advised that notice was being made in accordance with Regulation 18, that once both revisions had been made this would replace the Unitary Development Plan, and that although the revisions were notified together, they would be progressed separately. Consultees were invited to let the council know what they would like to see in these two revisions, and asked what they thought the revisions should contain. They were also advised of the consultation timescale, provided with a telephone contact for further information, and relevant weblinks for further information.

2.3 The City Council’s website also advertised this stage of consultation on pages relating to the Core Strategy, City Management Plan and National Planning Policy Framework (attached as Appendix 2). This also included a link to the consultation letter.

2.4 Seventeen responses were received (attached as Appendix 5), with 11 of those responses having relevance for the NPPF Revision (with the others relating to the CMP Revision). The following is a summary of the main issues raised and details how the council took the main issues into account:

1. Take account of the London Plan 2011 (Mayor of London). 2. Strategies to support the London Plan and the Mayor’s Transport Strategy including safeguarding land for transport where necessary (Transport for London). 3. Climate change particularly flood risk (Environment Agency). 4. Thames Tunnel (Thames Water). 5. Need high quality infrastructure e.g. high speed broadband (St James’s Conservation Trust). 6. Over-sized housing that only meets investment needs rather than housing people (Knightsbridge Association). 7. Knightsbridge Barracks site (Knightsbridge Association). 8. Commercialisation of the Royal Parks (Knightsbridge Association). 9. Take account of different character of areas e.g. Covent Garden (Covent Garden Community Association). 10. Conserve heritage assets as appropriate to significance (Covent Garden Community Association). 11. Deliver homes and affordable housing (Covent Garden Community Association). 12. Positive support for sustainable economic growth (Barclays Bank, WPA).

13. Give more clarity and emphasis to all three aspects of sustainability as referred to in the NPPF (Verina Glaessner –individual). 14. Identify office development, where affordable housing must be provided alongside commercial development (Archdeacon of Charing Cross). 15. Locally people identify additional housing sites in return for some of the gains as permitted by the Localism Act 2011(Archdeacon of Charing Cross). 16. Change Policy CS15 so specialist housing is ‘prioritised’ rather than ‘allowed’ where need is identified (Archdeacon of Charing Cross). 17. Change Policy CS16 to state that the council and its partners will act to ensure the current unacceptable shortfall in affordable housing is urgently addressed and bring housing into use (Archdeacon of Charing Cross). 18. Places of worship also provide social and community services (Archdeacon of Charing Cross). 19. Reference to establishing the infrastructure requirements as part of infrastructure planning should be linked to CIL (Archdeacon of Charing Cross).

2.5 Revisions to the Core Strategy have been included to address most of the 19 key issues raised by consultees that relate to the NPPF Revision and these are referenced on the Schedule of Changes appended to the revision document. However, the following issues are considered to be already adequately covered by the adopted document or alternative mechanisms, and in some cases additional detailed policies being developed through the City Management policies will address these matters:

6. Over-sized housing that only meets investment needs rather than housing people (Knightsbridge Association). This is addressed by the requirement to optimise housing delivery in Policy CS14. Further detailed policies will also address (refer draft policies CMP 4.1 and CMP 4.4 which will be developed further).

8. Commercialisation of the Royal Parks (Knightsbridge Association). This is addressed by the Royal Parks Policy CS11. Further detailed policies will control events and noise in the Royal Parks (refer draft policies CMP 3.18 and CMP 6.4).

9. Take account of different character of areas e.g. Covent Garden (Covent Garden Community Association). Some changes have been made in relation to references to Covent Garden. However, at a broader level, the Core Strategy provides policies for all of the areas identified across Westminster, taking account of their different characteristics, needs and future.

11. Deliver homes and affordable housing (Covent Garden Community Association). Addressed through Policies CS 16 to CS16 and in the emerging City Management detailed housing policies.

14. Identify office development, where affordable housing must be provided alongside commercial development (Archdeacon of Charing Cross). This is already provided for in Policies CS1requiring housing from commercial development in the Central Activities Zone, where most commercial development is and CS16 which requires affordable housing as a proportion of housing above certain thresholds.

15. Locally people identify additional housing sites in return for some of the gains as permitted by the Localism Act 2011(Archdeacon of Charing Cross). The mechanisms for this do not lie with the Core Strategy although amendments have been made to refer to changes including neighbourhood planning.

16. Change Policy CS15 so specialist housing is ‘prioritised’ rather than ‘allowed’ where need is identified (Archdeacon of Charing Cross). The City Council would not necessarily prioritise specialist housing above, say affordable housing, even where there is an identified need. This wording is also about ensuring there is a need for the accommodation, and it is not used as a means to avoid other planning obligations such as affordable housing.

17. Change Policy CS16 to state that the council and its partners will act to ensure the current unacceptable shortfall in affordable housing is urgently addressed and bring housing into use (Archdeacon of Charing Cross). This is already considered to be adequately covered by the housing policies CS14 - CS16, taking into account competing land pressures, site constraints, viability etc as set out in the Spatial Strategy in Part II and Policy CS32 which deals with the level at which planning obligations and CIL are sought.

18. Places of worship also provide social and community services (Archdeacon of Charing Cross). This is covered by the reference to the third sector, of which churches are a part.

19. Reference to establishing the infrastructure requirements as part of infrastructure planning should be linked to CIL (Archdeacon of Charing Cross). This is about establishing the needs, which will not always be provided by CIL e.g. provision of on-site social/ community floorspace secured through S106.

List of Appendices

1. Copy of Regulation 18 letter. 2. Copy of webpages where Regulation 18 consultation invited. 3. List of specific consultation bodies. 4. List of consultees from database for Regulation 18 consultation (general consultation bodies and residents and other persons carrying on business in Westminster). 5. Regulation 18 responses.

Appendix 1: Regulation 18 letter

From: Councillor Robert Davis DL

Deputy Leader of Westminster City Council and Cabinet Member for the Built Environment

Westminster City Hall, Victoria Street, London SW1E 6QP 020 7641 8574

Please reply to: Lisa O’Donnell LDF telephone: 020 7641 2503 LDF email: [email protected]

Date: 1st May 2012

Dear Sir/Madam

Revisions to Westminster’s Core Strategy

Westminster City Council adopted its Core Strategy in January 2011. We are writing to advise you that the City Council is going to make revisions to the Core Strategy for the following:

1. NPPF Revision: To take account of the National Planning Policy Framework, published by the government on the 27th March 2012.

2. CMP Revision: To create a comprehensive policy framework by inserting the policies (and any necessary supporting text) from the City Management Plan into the Core Strategy.

This notice is being made in accordance with Regulation 18 of the Town and Country Planning (Local Planning)(England) Regulations 2012.

Once these two revisions have been made, the new document will be the Local Plan for Westminster and will replace all current policies in the Unitary Development Plan. Although we are notifying these revisions together, they will be progressed separately to ensure there are no unnecessary delays.

We are inviting you to let us know what you would like to see in these two revisions. What do you think these revisions should contain?

If you have any comments on the revisions to the Core Strategy please send them to us in writing by the end of the day on Friday 15th June 2012.

CMP revision

This revision is a continuation of the work already carried out to develop the City Management Plan, including the following consultations stages:

Notification of intent to prepare DPD [Regulation 25]: October - November 2008 On-going consultation including identification of policy options: June 2009 to end 2010 including: Workshops: Consultation on Policy Options: January to March 2011 Informal consultation on Consultation Draft: November 2011 to March 2012.

All responses to these consultation stages will still apply to the CMP Revision as though they had been made to the revision itself. Therefore, it is not necessary to repeat any comments made at an earlier stage, or to advise that you want them taken into account when preparing the CMP revision.

For more information, please call (020) 7641 2503. You can also find further information on the City Council’s website using the following links:

Core Strategy: www.westminster.gov.uk/corestrategy City Management Plan: www.westminster.gov.uk/ldf/cityplan NPPF: www.communities.gov.uk/publications/planningandbuilding/nppf (please note this page is not managed by Westminster City Council and no responsibility is taken for its content)

Yours faithfully

Councillor Robert Davis DL Deputy Leader of Westminster City Council Cabinet Member for the Built Environment

Appendix 2: Webpages for Regulation 18

Westminster City Council - Core Strategy

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Council Services > Environment > Planning > Local Development Framework (LDF) > Core Strategy Council Services Core Strategy Environment The Core Strategy Development Plan Document (DPD) Planning Westminster City Council adopted its Core Strategy on the 26 January 2011. The adopted Core Strategy and accompanying Proposals Map is available to download below: Local Development Core Strategy Framework Proposals Map (LDF) For information about the weight attributed to policies, please click here. Annual Monitoring Report (AMR) Revisions to the Core Strategy City Management Plan The Council will be undertaking two revisions to the Core Strategy and create a single Local Plan for Westminster: Contact Us

Core Strategy The NPPF Revision - to ensure the Core Strategy is in general conformity with the National Evidence Base Planning Policy Framework and update it since adoption (for example, the publication of a new London Plan) LDF Documents The CMP Revision - to insert the City Management Plan policies and any necessary supporting Local Development text into the Core Strategy. Scheme (LDS) The Council notified its intention to revise the Core Strategy on 1st May 2012. This first stage is a Metropolitan Views statutory requirement and provides an opportunity for you to tell us what you think the revisions Open Space should include. Consultation ends on Friday 15th June 2012. For further information about the Strategy revisions, please click on the links above. Planning Briefs Public Realm Interim Note on Affordable Housing Policy Credits SPD Interim Note on Affordable Housing April 2011 Rolling Land Supply for Housing (PPS3) This note sets out how the Council will apply affordable housing policy in the period between adoption of the City of Westminster Core Strategy (26 January 2011) and the adoption of the City SFRA Management Plan. It replaces the earlier version published during the Core Strategy EiP. Shopping Centre Health Check Further background papers can be viewed below: Reports Statement of Cabinet Member Report Community Decision Involvement (SCI) Appendix 1 Supplementary Planning Documents (SPDs) Sustainability Affordable Rent Appraisal (SA) and Appropriate The City of Westminster Affordable Rent Statement agreed by the Cabinet Member for Housing and Assessment (AA) Property in September 2011 sets out the City Council's position on the new affordable rent tenure.

http://www.westminster.gov.uk/services/environment/planning/ldf/corestrategy/[18/06/2012 09:42:50] Westminster City Council - National Planning Policy Framework

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Council Services > Environment > Planning > National Planning Policy Framework Council Services National Planning Policy Framework Environment The National Planning Policy Framework (NPPF) was published on the 27 March 2012. This replaces most existing national planning policy previously contained in PPSs and PPGs. Planning

Apply for Planning Core Strategy Revision Permission Basement The City Council will be revising the Core Strategy to take account of the NPPF and other changes Extensions that have happened since the adoption of the Core Strategy such as publication of a new London Building Control Plan. Comment on a Planning Application Implementing the NPPF Transitional Arrangements

Committee The NPPF includes transitional arrangements for the new system. This page sets out how they Contact Us apply in Westminster. Enforcement Heritage Assets Planning applications in Westminster must be determined in accordance with the Core Strategy, Unitary Development Plan (saved policies not replaced by the Core Strategy) and the London Plan, Local Development Framework (LDF) unless material considerations indicate otherwise. Local Land Charges and For the purposes of decision-taking, the policies in the Core Strategy, Unitary Development Plan Searches (UDP) and London Plan should not be considered out-of-date simply because they were adopted Major projects before the publication of the NPPF. However, policies in the NPPF are material considerations Maps which the City Council should take into account. National Planning Policy Framework The NPPF must also be taken into account in the preparation of plans. Plans will need to be revised Neighbourhood to take into account the policies in the NPPF. This will be progressed as quickly as possible, through Planning two partial reviews of the Core Strategy. One will make amendments required to take account of the Planning NPPF. The second will insert the City management Plan policies into the Core Strategy, to replace Newsletter those policies currently in the UDP. Planning Permission Until 27 March 2013, the City Council (and any other decision-takers such as the Planning Planning Policy Inspectorate) may continue to give full weight to relevant policies in the Core Strategy and London Publications Plan even if there is a limited degree of conflict with this framework. Search planning applications For the UDP, due weight should be given to relevant policies according to their degree of Unitary Development Plan consistency with the NPPF (the closer the policies in the plan to the policies in the NPPF, the (UDP) greater the weight that may be given). Urban Design and Public Realm Decision-takers may also give weight (unless material considerations indicate otherwise) to relevant

http://www.westminster.gov.uk/services/environment/planning/national-planning-policy-framework/[18/06/2012 09:43:55] Westminster City Council - City Management Plan

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Council Services > Environment > Planning > Local Development Framework (LDF) > City Management Plan Council Services City Management Plan Environment Draft City Management Plan Public Consultation

Planning Westminster City Council has previously consulted on the development of a second development plan document, the City Management Plan (CMP). Local Development We will not be taking the CMP forward as a separate document but instead will be inserting the Framework policies and any necessary supporting text into our Core Strategy, which was adopted in January (LDF) 2011. These changes to the Core Strategy will be called the "CMP Revision".

Annual Monitoring All of the consultation that has been carried out to date will inform the CMP Revision. Therefore, if Report (AMR) you have already submitted a consultation response you do not need to resend it for the revision. City Management Plan However, the revision will include some changes from the recent Consultation Draft (published November 2011). We will be carrying out a targeted consultation on those changes, notifying only Contact Us those who responded to the Consultation Draft stage for a period of six weeks. If you did not submit Core Strategy at this stage but still want to take part in this informal consultation, please contact us immediately and we will also consult you. Evidence Base Click here to see the formal notice of consultation. LDF Documents Local Development Contact Details Scheme (LDS) Tel: 0207 641 2503 Metropolitan Views Open Space E-mail: [email protected] Strategy Address: City Planning Delivery Unit, Westminster City Council, 11th Floor East, Planning Briefs Westminster City Hall, 64 Victoria Street, London SW1E 6QP Public Realm Credits SPD For more information about the weight attributed to policies, please click here. Rolling Land Supply for Housing (PPS3) SFRA Previous CMP Consultation Stages Shopping Centre CMP Policy Draft Consultation Health Check Reports The City Council consulted on a consultation draft city management plan between November 2011 and March 2012. Statement of Community Involvement (SCI) City Management Plan Consultation Draft, November 2011 Supplementary Consultation Draft Responses A-N Planning Consultation Draft Responses O-Z Documents (SPDs) Consultation Draft Responses Westminster Property Association Sustainability CMP Policy Options Consultation Appraisal (SA) and Appropriate The City Council undertook an informal public consultation on the range of approaches for the CMP Assessment (AA) at the beginning of 2011, ending in March. The policy options document is available below.

http://www.westminster.gov.uk/services/environment/planning/ldf/cityplan/[18/06/2012 09:42:19] Appendix 3: Specific consultation bodies

1. The Environment Agency 2. English Heritage 3. Natural England 4. Greater London Authority and Mayor of London 5. Homes and Communities Agency 6. Westminster PCT 7. NHS 8. The Highways Agency 9. Office of Rail Regulation 10. Civil Aviation Authority 11. Transport for London 12. London Borough of Camden 13. London Borough of Southwark 14. London Borough of Lambeth 15. City of London 16. London Borough of Wandsworth 17. London Borough of Brent 18. Royal Borough of Kensington & Chelsea

Appendix 4: General consultation bodies

1236 51 Degrees Services Ltd 1625 A Liammari 31 Alsop Verrill 2058 A2 Dominion Housing 1552 Alzheimer's Society 7 Abbey Arts 32 Amberley Club 8 Abbey Community Centre 33 Amberley Residents' Association 10 Abbots Manor Community Childcare Centre 34 Amberley Road Centre 11 Abbots Manor Tenants' Association 35 Ambika House Limited 12 Abercorn School Nursery 36 American School in London 2236 Aberdeen Asset Management 2231 Amwaj Property Ltd 13 Abou Zaki Holding Company 37 Anchor Trust - Norton House 1238 Abovenet 38 Ancient Monuments Society 1732 Acacia Environment 1919 Andrew Cotton 14 Academy Crèche 1147 Andrew Havery 1349 Accord Energy Limited 1678 Andrew Smith 16 Acorn Nursery 1773 Andy Ltd 17 Acorns Parent & Toddler Group 1182 Angela Harvey 1565 Action for the Blind 1141 Angela Hooper 1566 Action Trust for the Blind 2153 Ann Scheu 18 Acton Housing Association 1157 Antony Devenish 2152 AD Development 1430 AOL UK Ltd 2144 Adam Hug 1774 AON Ltd 1632 Adams Hendry 1775 Apollo Theatre 1768 Adams Kara Taylor 1776 Apple 1769 Adelphi Theatre 1777 Aquascutum 1350 AEP Energy Services Ltd 45 Aquila Street Residents' Association 1351 AES Barry Limited 41 Arab Welfare Advisory Centre 20 African Joy 1348 Arcadia Petroleum Limited 21 African Refugee Project 42 Archdeacon of Charing Cross 22 Afro-Carribean Mental Health Association 1274 Area One Steering Group Covent Garden 1613 Age Concern/Westminster Senior Citizen's Forum 1778 Areen Design Services Ltd 1014 Age Uk Westminster 44 Arlington Care Association 2218 Ahmad Al Hussenni 1562 Arthritis Care 2139 Ahmed Abdel-Hamid 1331 ARUP 24 Air Transport Users Council 46 Ascot & Windsor Residents' Association 25 Al Madina Nursery School 47 Ash Design Consultant Ltd 992 Alan Baxter & Associates 1603 Ashley Gardens Residents Association 1265 Alan Bradley 1604 Ashley Gardens Residents Association 2173 Alan Wipperman and Co 48 Ashmore Pre-School Group 1165 Alastair Moss 1779 Asprey 26 Albanian School Kosovo 49 Asset Consultants Ltd 1770 Aldwych Theatre 1561 Association for Spina Bifida and Hydrocephalus 1179 Alexander Nicoll 50 Association of Blind Asians 27 Alexander Reece Thompson 1671 Association of British Insurers 28 All Stars Youth Club 1475 Association of Electricity Producers 1771 Allford Hall Monaghan Morris 2103 Association of Local Government Ecologists 1313 Alliance Planning 1525 Association of Noise Consultants 1772 Allsop & Co 1269 Atisreal UK 1423 Alpha International Overseas Telecommunications 1223 Atkins Global

2172 Audley Property Management Company Limited 1695 Bevan Watt-Lattanzio 1143 Audrey Lewis 1352 BG Gas Services Limited 1780 Aukett Fitzroy Robinson 1926 Bianca UK 1781 Austin Reed 1712 Bill Hodgson 1476 Automobile Association 88 Biomedic Foundation 55 Avenue Gardens Residents' Association 2051 Black Architecture Limited 1099 Avenues Over 50s Focus Group 89 Blandford Estate Residents' Association 2113 Aviva Investors Global Services Ltd 1927 BLD International Fashion Agency Ltd 56 A-Z Restaurants 1789 Bloomsbury Association 1146 Aziz Toki 90 Blue Cross Animals' Hospital 1443 B Sky B Holdings Limited 91 BME Westminster 1195 Babygrow 2042 BNP Paribas Real Estate 60 Baker & McKenzie 2043 BNP Paribas Real Estate 1782 Bally UK Sales Ltd 94 Body Shop International Plc 1050 Ballymore Properties Ltd 1114 Boodle Hatfield 1751 Baqus Boxall Sayer 96 Boots the Chemist 1144 Barbara Grahame 98 Bosnia & Herzegovanian Organisation 1574 Barclays Bank Plc 1355 BP Exploration Operating Company Limited 1783 Barcode REMOVED FROM MAILING LIST 2232 Braeburn Estates Limited Partnership 1173 Barrie Taylor 2135 BRE Global Limited 62 Barrow Hill Pre-School 1790 Brecher Abram 1608 Barton Willmore 1110 Brent Planning Service 1649 Bayswater Area Forum 2233 Brewery Logistics Group 2199 Bayswater BID 1139 Brian Connell 66 Bayswater Families Centre 101 Bridge House Housing Association 1501 Bayswater Neighbourhood Watch 104 Brindley Community Association 2059 Bayswater Neighbourhood Watch 105 British Arab Resource Centre 67 Bayswater Residents Association 106 British Beer and Pub Association 1784 BBC 2184 British Beer and Pub Association 1785 BDO Stoy Hayward LLP 107 British Buddhist Association 74 Beauchamp Lodge Settlement 108 British Casino Association 75 Beethoven Centre 1544 British Deaf Association 76 Beginnings 1356 British Energy Generation Limited 993 Belgravia Police Station 1357 British Gas Trading Limited/Accord Energy Limited 77 Belgravia Residents Association 110 British Geological Society 1687 Belgravia Residents Association 1743 British Hedgehog Preservation Society 2120 Belgravia Society 1547 British Institute of Learning Difficulties 2195 Bell Cornwell 1488 British Lung Foundation 1786 Benetton (UK) Ltd 1489 British Medical Association 79 Bengali Cultural Association 111 British Motorcycle Federation 81 Bengali Institute 2167 British Sign and Graphics Association 82 Bengali Women's Group 1433 British Telecommunications Plc 1636 Bennett Urban Planning 112 British Transport Police 2056 Bennetts Associates 1738 British Trust for Conservation Volunteers 83 Bereavement Support Group 1075 British Waterways London 2057 Berkeley Homes 114 Broadway Malyan 84 Berkeley Street Club 1264 Broadwick (Stirling Court) Management Co Ltd 63 Berkely Group Holdings Plc 115 Bronwen Court Residents' Association 1787 Berners-Allsopp Estate Management Co Ltd 116 Brook in Euston 86 Berwin Leighton 1792 Brooks Brothers

117 Brownie Guide Unit 6th East Paddington 150 Central London Law Centre 119 Brunel Estate Residents' Association 151 Central London Partnership 120 Brunel Family Centre 1741 Central Royal Parks Wildlife Group 121 Brunswick & Dalkeith Residents' Association 152 Centre for Ecology & Hydrology 1217 BT Open Reach 153 Centre for Health and Healing 1728 Buckingham Palace 154 Centrepoint - Central Office 2052 Building Design Partnership 155 Centrepoint - Drury Lane Project 123 BRE Energy Conservation Support Unit 1362 Centrica Storage Limited 1314 Building Schools for the Future 158 Charing Cross Community Childcare Centre 125 BUJ Architects LLP 1451 Charing Cross Library 1793 Burberry 159 Charing Cross Police Station 1794 Burges Salmon LLP 1800 Charles Russell LLP 1941 Buro Happold 1258 Charlotte Street Association 127 Business Link for London 160 Charter Hospitals 2080 Business, Environment and Forests 1469 Chartered Institute of Environmental Health 2022 Butler Kelly Ltd 161 Chelsea Bus-Stop Counselling Service for Young People 1742 Butterfly Conservation 2234 Chelsfield Partners 1720 Buying Solutions 162 Cherubs Parent & Toddler Group 1795 Cambridge Theatre 1354 Chevron North Sea Limited 130 Camden and Westminster Refugee Training 163 Chic Bingo Club Partnership 164 CHICL Communities and Homes in Central London 1796 Cameron Mackintosh Ltd 165 CHICL Communities and Homes in Central London 131 Cameron McKenna 2090 Children & Families Commissioning 2146 Cameron Thompson 2082 Children and Families Commissioning 1256 Campaign for Clean Air (in London) 2162 Children's Centre Outreach Team 140 Campaign to Protect Rural England 642 Childrens Centres 2176 Canary Wharf PLC 1295 Children's Strategy Planning and Performance 1797 Candy & Candy 1477 Chiltern Railways 1798 Capita Symonds 1764 Chinatown Arts Space 138 Cardinal Hume Centre 168 Chinatown Unit 2083 Care and Health Commissioning 1040 Chinese Community Associaton 1253 Carers Network Westminster 1039 Chinese Community Centre 1359 Cargill PLC 167 Chinese Community Office 139 Caribbean Hindu Society 1801 Chinese Information and Advice Centre 141 Carlton Hill 169 Chippenham Housing Co-operative Limited 5 Carlton Hill Residents' Association 2225 Chippenham Mews Association 1702 Carol Cooper 1364 Chive Fuels Limited 1142 Carolyn Keen 999 Chris Thomas Ltd 1607 Carolyn Rayment 1188 Christabel Flight 1353 Carron Energy Limited 170 Christian Union Almshouses 1799 Cartier 1322 Christopher Hill Planning 1334 Cathedral Area Residents Group (CARG) 1503 Church St LARP 1944 Cavendish Communications 171 Church Street Children's Centre 144 Caxton Youth Trust 172 Church Street Drop-In Centre 1328 CB Richard Ellis 1452 Church Street Library 1568 CBRE 1086 Church Street Neighbourhood Management WCC 146 Central and Cecil Housing Trust 173 Churches Conservation Trust 148 Central and Cecil Housing Trust - Edna House 1036 Churches Together in Westminster 147 Central and Cecil Housing Trust- Dora House 1692 Churches Together in Westminster 149 Central London Dysphasic Group 175 Churchill Gardens Elderly Handicapped Club 1500 Central London Forward 15

1056 Churchill Gardens Estate 2170 Consolidated Developments Ltd 176 Churchill Gardens Lessees Association 213 Consolidated Real Estate Mgmt Services Ltd 177 Churchill Gardens Residents' Association 200 Consortium of Bengali Associations 178 Churchill Gardens Youth Club 1510 COPD Service 179 Cinema Exhibitors Association 1358 Corona Energy Retail Limited 180 Circle 33 Housing Association 1064 Corporate Property Division 1802 Cities of London and Westminster 1001 Corporation of London 181 City & West End Development Ltd 1808 Cosgrave Developments 2081 City Management 202 Cosmic - Children of St. Mary's Intensive Care 2085 City Management Commissioning 203 Cotes House Tenants & Residents Association 2086 WCC City Management 204 Council for British Archaeology 1491 City of London 2193 Counter Terrorism Security New Scotland Yard 2149 City of London 1276 Covent Garden Area Trust 1296 City Of London (Planning & Transport Dept) 205 Covent Garden Area Youth Club 1309 City of Westminster College 206 Covent Garden Community Association 2221 City Of Westminster College 1278 Covent Garden London Limited 1089 City Planning Built Environment WCC 1809 Covent Garden Restaurants 1111 City Planning Test 1810 Coverdale Davis 1465 City Property Association 207 Coyne & Co 1057 City West Homes 211 Crawford Buildings Residents' Association 2201 City West Homes 212 Crawford Mansions T & R' Assoc 2200 CityWest Homes 23 Crime & Disorder Reduction 1478 Civil Aviation Authority 1812 Criterion Theatre 2215 Civil Aviation Authority 1303 Cross River Partnership (Lambeth Office) 2169 Clear Channel 1267 CrossRail 1473 Clear Zones (Borough of Camden) 214 Crown Castle 184 Cliff Walsingham & Co. 1643 Crown Plaza London St James (Taj Hotel Group) 1191 Cllr Ian Wilder REMOVED FROM MAILING LIST 217 Croxley Project 1805 CLS Holdings Plc 218 Crypt Youth Club 185 Club Xpress After School Club 270 Crystal Palace National Sports Centre 187 Clubs and Vice Unit Metropolitan Police Service 2048 Culture Quarter London 1020 Cluttons LLP 1601 Cunnane Town Planning 1691 Cluttons LLP 1813 Cushman & Wakefield Healey & Baker 1196 Clyder Enterprises Limited 2084 Customer Commissioning 1153 Colin Barrow 1136 Cyril Nemeth 1647 Colliers CRE 1816 D E & J Levy 1073 Collingwood Environmental Planning 219 Daisies Day Nursery and School 1221 Colt 1818 DAKS 1518 Combined Heat and Power Association 2133 Dalton Warner Davis LLP 1807 Comedy Theatre (Ambassador Theatre Group) 1174 Daniel Astaire 1015 CABE Design Council 1183 Danny Chalkley 1016 Commission for Racial Equality 1725 Dave Dawson 2088 Commissioning Events, Filming & Contingencies 1819 Davenport Lyons 192 Communal Welfare Centre for Refugees 1192 David Boothroyd 2095 Communications and Strategy 2143 David Harvey 196 Voluntary Action Westminster 222 David Hicken Associates 1940 Condici Limited 224 Davis Coffer Lyons 1479 Confederation of Passenger Transport 1820 Davis Langdon LLP 198 Confide 1543 Deafblind UK 199 Connaught House School 1821 Debenhams Retail Plc

225 Defence Estates 1220 Easynet 1823 Delfont Mackintosh Theatres 251 Eaton House School 1439 Demon 2110 Eaton House Tenants Association (EHTA) 227 Densham House Residents' Association 252 Eaton Square Private (and Nursery) Schools Ltd 230 Department for Business, Innovation and Skills 258 Ebury Bridge Residents Association 232 Department for Children, Schools and Families 1688 Ebury Bridge Residents Association 1498 DEFRA 1745 Eccleston Square Private Garden 1572 DEFRA 1424 Eclipse Internet Home (KCOM Group Plc) 247 Department for Transport 1425 Eclipse Internet Home (KCOM Group Plc) 1704 DCLG 1730 Ecology Consultancy Ltd 228 Department of Culture, Media & Sport 1736 Ecology Consultanty Ltd 229 DEFRA 259 Eden House Residents' Association 1106 Department of Health 1224 EDF Energy 1119 Department of Media, Culture and Sport 1361 EDF Energy Plc 994 Department of Transport 260 Edgware Road Association 1553 Depression Alliance 1187 Edward Argar 1637 Derek Horne & Associates 2147 Edward Baxter 231 Derwent London 2055 Eight Associates 2039 Development Securities Plc 1363 ELF Exploration UK Plc 1744 Dez McKenzie 262 Elgin Pre-School 233 DGAA - Homelife 265 Emmanuel Pre-School Group 234 Dibdin Pre-School 1564 Employers Forum on Disability 2114 Dickon Robinson 266 Empty Homes Agency 237 Diocesan Board of Finance 267 English Churches Housing - King George's Hostel 1426 Direct Save Telecom (DST) 268 English Churches Housing - Queen Mary Hostel 238 Disability Network 1006 English Heritage 1633 DLA Piper 1492 English Heritage 2148 Dolphin Square Foundation 191 English Partnerships 1824 Donmar Warehouse 1470 Environmental Data Services (ENDS) 240 Dorothy Gardner Nursery Centre 1471 Environmental Protection UK 242 Dover Street Wine Bar 271 Epilepsy Action 1310 DP9 1831 EPR Architects Ltd 2177 DP9 1009 Equality and Human Rights Commisssion 243 DPDS 1442 Equitalk.co.uk Ltd 1610 DPP Consulting Limited 274 Eritrean Community Association 2049 DreamArts 272 Eritrean Muslim Community Association 2252 Drew Planning & Development Ltd 1063 ESA Planning 245 Drink Crisis Centre - Hopkinson House 1403 ESP Electricity Limited 246 Drivers Jonas Deloitte 1245 Essie Graham 2174 Drivers Jonas Deloitte 1365 Esso Exploration Production UK Limited 2178 Drivers Jonas Deloitte 1832 Estates & Agency Holdings plc 1826 Dron & Wright Property Consultants 1834 EU Chinese Journal 1070 DTZ 1591 European Land & Property Ltd 249 Dufours Residents Association 1715 European Youth in Action Programme 1828 Duke of York's Theatre 1835 Eversheds 2237 Dukelease Properties Ltd 1837 Ewing Media 1626 Duncan Collins 1838 F & C Property Asset Management Plc 1184 Duncan Sandys 1841 Fair Share 1830 Dunlop- Hayward's 281 Fairview New Homes Ltd 1360 E.ON Ruhrgas UK Energy Trading Limited 282 Families and Adolescent Service

283 Family Housing Association 1190 Frixos Tombolis 284 Family Space 1297 Fusion Online Ltd 1843 Far East Restaurant 313 Future Energy Solutions 1844 Farrer & Co 1311 G R Planning Consultancy Ltd 1440 Fast.co.uk 314 Gala Group Ltd 1846 Feng Shui Inn 1197 Gambia Madigo Association 1847 Fenwick 1863 Gap 1849 Ferragamo UK Ltd 1748 Garden Square News 1218 Fibrespan 1864 Gardiner & Theobald 1308 Fields in Trust (National Playing Fields Association) 1865 Garrick 1850 Film Distributors' Association Ltd 1866 Gascoyne Holdings 1852 Firmdale Hotels 319 Gateway Club (Westminster) 1584 First Base 320 Gatliff Close Residents' Association 1512 First Great Western 2024 Genesis Housing Group 1854 First Management Services 1867 Gensler 287 First Steps Community Childcare Centre (Sure Start)/ 321 Genuine Empowerment of Mothers in Society Westminster Children's Society 2194 Gerald Eve LLP 1367 First Utility Limited 2196 Gerald Eve LLP 1038 Firstplan 1254 Geraldeve 289 Fisherton Pre-School 1868 Gielgud Theatre 290 Fisherton Street (Club 88) 1416 Gieves and Hawkes 291 Fisherton Street Residents' Association 2134 Gifford 292 Fitzrovia Court Residents' Association 1869 Gillespies LLP 1272 Fitzrovia Neighbourhood Association 326 GL Hearn 1337 Fitzrovia Trust 2175 GL Hearn 1762 Flamboyan Community Association 327 GLA Business & Europe Division 293 Flanders Club 328 Glad Monday Club 294 Fleming Court Residents' Association 1370 Glencore Energy UK Limited 1855 Fletcher Priest Architects Ltd 1189 Glenys Roberts 296 Focus Central London 1239 Global Crossing 2235 Forextra Developments Ltd 1371 Global Natural Gas Limited 1856 Forsters 2181 GMRA Committee 297 Forster's Solicitors 2183 GMRA Committee 1859 Fortune Theatre 1575 GMS Estates Limited 1939 Forza Projects Limited 467 Go Ahead London 1548 Foundation for People with Learning Disabilities 1870 Godfrey Vaughan (FPLD)/ Mental Health Foundation 129 Goldcrest Films international 298 Founders House Club 1871 Golden Gate Grocers 1860 Four Communications 330 Golden Years Club 299 Four Rivers Resident's Association 1872 Golfrate 1756 Four Rivers Resident's Association 1010 Government Office for London (GOL) 300 Fourth Feathers Youth Club 1703 Government Office for London (GOL) 1156 Frances Blois 1873 Grafton Advisors LLP 1611 Fraud Screen 2118 Graham House Planning 1435 Freedom2Surf 1066 Graham Simpkin Planning 1480 Freight Transportation Association 335 Grainhurst Properties Limited 1861 French Connection Retail 336 Great Beginnings Montessori School 1862 Freshfields Bruckhaus Derringer 337 Great Portland Estates 306 Freshwater Court Residents' Association 1874 Great Pulteney Street & Bridle Lane T Assoc 308 Friends of St. Saviours 1042 Greater London Authority 310 Friends of the Earth (London Region)

1494 Greater London Authority 1883 Helical Bar Plc 1571 Greater London Authority 373 Help Advisory Centre 340 Greater London Magistrate's Courts Authority 1582 Henderson Global Investors 1724 GIGL 1923 Her Majesty's Courts Service 345 Grosvenor 1884 Hermes Pensions Management Ltd 1045 Grosvenor 1372 Hess Energy Power and Gas Company 2192 Grosvenor 375 Hide Tower Residents' Association 343 Grosvenor & Regency Management Organisation 1212 Highway Agency 1597 Grosvenor Limited 1339 WCC Highways Planning Team 1875 Grosvenor Securities Ltd 376 Hilton International 1585 Grosvenor Square Limited 377 Hilton London Metropole 997 Groundwork Trust (Camden, Islington & Westminster) 1261 Hinde House Residents Association 1095 Grovesnor Regency Estate Youth Club 1586 Hines 1656 Growth in Victoria workshop - Group 1 379 HM Prison Service Headquarters 1657 Growth in Victoria workshop - Group 2 1885 Hobbs Ltd 1151 Guthrie McKie 1335 HOK International Architects 348 GVA Grimley Ltd 380 Holcroft Community Childcare Centre 1175 Gwyneth Hampson 381 Holcroft Court Residents' Association 350 Halcrow 833 Home Office 351 Hall & Braithwaite Residents' Association 193 Homes and Communities Agency 352 Hall Park Residents' Association 1028 Homes and Communities Agency 353 Hallfield Estate Residents' Association 1886 House of Fraser 1877 Hamilton Associates 1097 Housing 21 Care Options 1878 Hamleys of London Ltd 913 Housing Commissioning 354 Hammerson Properties PLC 1005 Housing Corporation (London Region) 2061 Hand & Lock 1277 Howard de Walden Estates Ltd 1228 Handman and Collis Ltd 1938 Hunza 359 Happybadge Projects Limited 385 Hyde Park Barracks Community Childcare Centre 360 Harp, Sarraf Sheppard Associates 1124 Hyde Park Estate Association 1506 Harrow Road LARP 1162 Ian Adams 2107 Harrow Road Police Station 1170 Ian Rowley 362 Harrowby and District Residents Association 1887 Imperial China 1168 Harvey Marshall 387 Imperial College Day Nursery 1879 Haymarket 1587 Imperial College Healthcare NHS Trust 1880 Haymills 1580 Imperial College London 1881 HBG Construction Ltd 389 In and Around Covent Garden Business Forum 365 HCA Healthcare 1096 In Deep Elderly Group 1270 HCA International Ltd 391 Independent Mothers Pre-School 366 HDG Ltd 392 Independent on Sunday 367 Headway North London Group 329 Indigo Planning Limited 832 Health & Safety Executive (Construction Division) 394 Inner London Group 368 Health & Safety Executive (Local Office) 2254 Inner North West London PCT 1546 Hearing Concern LINK 1420 Inner North West London PCT's 1043 Heart of London Business Alliance 2091 Inner North West London PCT's 1882 Heath Lambert Group Ltd 2220 Inner North West London PCT's 2141 Heather Acton 2222 Inner North West London Primary Care Trusts 370 Heatherside Properties 1523 Institute of Acoustics 371 Heathrow Express 1472 Institute of Air Quality Management 1642 Helen Stanwell 1373 Intergen Energy Trading and Shipping Limited 372 Helical Bar 395 International Club

1374 International Power Fuel Company Limited 1307 Kings College London 398 IQRA Trust 1621 Kit Boukeras 399 Iraqi Community Association 304 Knight Frank 1631 Iris Topp 355 Knightsbridge Under School 1888 ISG Interior Exterior 1899 Kohn Pedersen Fox Associates (Int) 400 ISIS Property Asset Management 1900 Kurt Geiger Ltd 1889 IVG Asticus Real Estate 1027 Kushan and Wakefield 401 J D Wetherspoon Plc 1248 L.S.E. Early years Centre 1286 J Young 1522 LACORS 402 Jacs Club 1618 Lady Kingham 1890 Jaeger Company Ltd 422 Lafarge Redland Aggretates Ltd 1684 James Pye 423 Lancefield Centre 1166 Jan Prendergast 1901 Lancer Property Asset Management Ltd 1891 Janus London 1638 Land Locator Company 1639 JCDecaux 2197 Land Securities 1155 Jean-Paul Floru 2198 Land Securities 1892 Jeffrey Green Russell 425 Land Securities PLC 1917 Jeffrey Green Russell 1721 Land Securities Plc 1707 Jennie Preen 426 Landmark Hotels 1617 Jennifer Cobbing 2112 LaSalle Investment Management 1893 JER Partners 428 Latimer House Relatives Group 403 JMP 431 LCC/CBI London Manufacturing Group 1627 Joan Schor 1444 LDA Olympic Legacy Directorate 404 John Aird Court Residents' Association 1902 Le Meridien Piccadilly 406 John Lewis Partnership 443 Leciester Square Association 1589 John Lyons Charity 1167 Lee Rowley 1037 John Sharkey & Co 434 Legal & General Property Ltd 1894 Joint London Holdings 2062 Legal and General Property 2115 Jonathan Glanz 2102 Leicester Square Association 1898 Jones Lang La Salle (Formerly King Sturge Residential) 2203 Leon 1516 Jones Lang LaSalle 435 Lesser Gang 1937 Joseph Ribkoff 436 LETEC 410 Jubilee Crèche 1226 Level 3 Communications 1895 Jubilee Market Hall 1903 Liberty Plc 1896 Jubilee Market Hall Ltd 2044 Libraries and Culture 1137 Judith Warner 1599 Libraries, Archives and Arts 1700 Julian Anderson 1481 Licensed Taxi Drivers Association 411 Jumbo Nursery School 1904 Lifschutz Davidson Sandlands 1897 Kairos in Soho 438 Lilestone Estate Residents Association 1918 Karl Harrison 2208 Lilington and Longmore Gradens R A 412 Katharine Bruce Day Nursery 439 Lillington & Longmoore Gardens R A 1281 Katherine Hosleyns 440 Lillington Gardens Over 60's Club 413 Kemp House Residents Association 1135 Lindsey Hall 2100 K & C / Westminster Friends of the Earth 1521 linking tables test TES TES TESt 415 Kensington Housing Trust 1068 Linklaters Business Services 1697 Kensington Society 444 Lisson Green Bangladeshi Pensioner, Elderly & 416 Kettners Disabled Association 417 Kiddicare 445 Lisson Green Community Childcare Centre 418 Kids Westminster Home Learning 446 Lisson Green Play Project 1935 Kimko Clothing Company 447 Lisson Green Resource Centre 448 Lisson Green Tenants' & Residents' Association 20

1113 Lisson Grove Health Centre 2185 London Parks & Gardens Trust 449 Little House 1598 London Planning Practice 450 Little Sweethearts Montessori School 478 London Port Health Authority 451 Little Venice Community Childcare Centre 1910 London Residents Association 2087 Little Venice Sports Centre Library 480 London River Services 1905 Live Nation – Lyceum & Dominion Theatres 1115 London Rivers Association 1727 Living Roofs.org and Green Roof Consultancy 1300 London School of Economic and Political Science 1622 Lizzie Dekkers 484 London School of Economics Nursery 452 Lloyds TSB Bank Plc 487 London Travel Watch 1722 Local Development Agency 490 London Underground Ltd 1474 Local Government Association 491 London Voluntary Service Council 453 Loftus Family Property 492 London Wildlife Trust 454 Logic.com Ltd 536 Londonewcastle 2025 London & Partners 1735 London's Swifts 1213 London Ambulance Service 494 Look Ahead Housing Association 1107 London Ambulance Service NHS Trust 495 Friends of Hyde Park 1733 London Biodiversity Partnership 1177 Louise Hyams 1000 London Borough of Brent 2188 Louise Morton Planning Consultancy Ltd/QUADRANT 459 London Borough of Camden TOWN 1495 London Borough of Camden 1912 Lovell's 1508 London Borough of Croydon 1934 Lucia UK 1019 London Borough of Hackney 1022 Lumley Flats Residents Association 460 London Borough of Islington 499 Luxborough Tower Residents Association 1511 London Borough of Islington 1788 LVMH Fashion Group 461 London Borough of Lambeth 1803 Lyceum Theatre 746 London Borough of Southwark 500 Lydford Estate Tenants & Residents Association 462 London Borough of Wandsworth 501 Lydford Senior Citizens Club 1578 London Business School 1320 Lynne Evans 466 London Central Mosque and Islamic Cultural Centre 1804 Lyric Theatre 468 London Chamber of Commerce and Industry 1273 M D Smith 1906 London Chinatown Chinese Association 502 M R Partnership 1907 London Chinese Community 1933 Mac Fashions 469 London City Airport 1076 Mace Macro Ltd 470 London Clubs International Plc 1806 MacFarlanes 1908 London Coliseum 1431 Madasafish 1731 London Conservation Services 1650 Maida Vale Area Forum 471 London Core Trust 504 Maida Vale Estate T & RAssociation 51 London Councils 1453 Maida Vale Library 472 London Cycling Campaign 505 Maida Vale Play Project 1346 London Development Agency 1811 Malcolm Hollis 1215 London Development Authority 506 Malcolm Scott Consultants Ltd 1263 London Diocesan Fund 1814 Managing Agent of 33 Ashsley Place 1011 London Fire and Emergency Planning Authority 507 Manto Group 1216 London Fire Brigade 1815 Marchday Group Plc 475 London First 827 Marcus Cooper Group 1683 London Forum of Amenity & Civic Societies 1164 Margaret Doyle 476 London Historic Parks & Gardens Trust 2251 Marine Management Organisation 477 London Hostels Association Limited 1169 Mark Page 1246 London Jehovah Witnesses 1341 Mark Younger 1909 London Merchant Securities plc 1817 Marshall Street Regeneration Ltd 510 Marsham Street Community Childcare Centre 21

1920 Martin Couchman 539 Mitchells and Butlers plc 1670 Martineau 1836 MLA London 511 Martlett Court Residents' Association 1098 Moberly Monday Group (over 50s group) 512 Mary Paterson Nursery School 1606 Mohammed Janel 2204 Mary Travers 1839 Molton Brown Ltd 2223 Maryland Road Association 541 Mondial Estates Ltd 2226 Maryland Road Community Association 585 Mono Consultants Ltd 514 Marylands Play Project 1210 Montagu Evans LLP 998 Marylebone Association 543 Moorhouse Pre-School 1454 Marylebone Library 544 Moreton Day Nursery and Pre-School 515 Marylebone Police Station 1338 Moreton Triangle Residents Association 1232 Matthew Bennett 546 Moroccan Community Association 1709 Matthew Blades 1840 Morpeth Mansions 518 Maurice Nadeam & Co. 547 Morris House Residents' Association 1825 Maxwell's Restaurant Group 1201 Moshi Moshi Sushi 1455 Mayfair Library 1326 Mosley And Webb 2227 Mayfair Residents Group 1842 Motcomb Estates Ltd 1822 McAleer & Rushe 549 Mother & Baby Group 519 Meanwhile Gardens Play Hut 2171 Motor Cycle Industry Association 1280 Meard and Dean Street 1560 Motor Neurone Disease Association 1827 Media Office Limited 550 Motorcycle Action Group 520 Medical Foundation For The Care Of Victims of Torture 551 Mott MacDonald 1539 Mehfuz Ahmed 1065 Mount Eden Land Ltd 1163 Melvyn Caplan 553 Mozart Estate Tenants & Residents Association 522 Mencap 1845 Mr Kong Chinese Restaurant 1549 Mencap 1569 Mr Levick 1550 Mental Health Foundation 2151 Mrs Saunders 523 Mentorn Barraclough Carey 1559 Multiple Sclerosis Society 526 Metropolitan Police (Central Traffic Unit) 2079 Mummery + Schnelle 524 Met Police (North Westminster) 555 Munro Centre For Complementary Healthcare 525 METROPOLITAN POLICE SERVICE 1558 Muscular Dystrophy Campaign 529 Met Police (Traffic Operational Command Unit) 556 Muslim Advice Centre 530 Metropolitan Public Gardens Association 1848 Nabarro Nathanson 1932 MGB Fashion Ltd 557 Naima Jewish Preparatory School 2186 Michael Bolt 1851 Nathaniel Lichfield & Partners 1138 Michael Brahams 558 Natharro Nathanson 531 Michael Woolf & Co 559 National Assoc for Providers of Activities for Older 1615 Michelle Hughes People 533 Micky Star Play Project 1490 National Asthma Campaign 534 Migrants Resource Centre 560 National Car Parks Ltd 1708 Mike Fairmaner 2211 National Casino Industry Forum 535 Millbank Estate Residents' Association 561 National Coalition for Black Volunteering 1551 Mind - National Association for Mental Health 1614 National Federation of the Blind of the UK 1829 Minerva Corporation plc 2108 National Gallery 1262 Ministry of Justice 562 National Grid 1833 Misato Restaurant 2189 National Gypsy Traveller Federation 1243 Miss Daisy's Nursery School 2109 National Portrait Gallery 537 Miss Morley's Nursery School 566 National Romany Rights Association 538 Miss Willcock's Nursery School 1563 National Wheelchair Housing Association 1924 Mitchells & Butlers 1499 Natural England 1004 Natural England - London Region 22

1729 Natural History Museum 195 One Housing 1853 Neighbourcare St John's Wood & Maida Vale 1448 One Stop Services 1857 Nelson Bakewell 1449 One Stop Services 2250 Network Rail Infrastructure Limited 1450 One Stop Services 1053 Network Strategy South East (Highways Agency) 1100 Open Age 1093 New Avenue Youth Club 586 Org. for the Advancement of African Women 568 New Cameo Club 587 Osborne Group 1241 New West End Company (NWEC) 1686 OSEL 135 NHS London 588 Our Lady of the Assumption & St Gregory Church 1031 NHS London HUDU 589 Out and About Club 1285 NHS Westminster 590 Outdoor Advertising Association 1417 NHS Westminster 2168 Outdoor Media Centre 1291 Nicholas Evans 591 Over 60's Club 1149 Nicholas Yarker 2239 Oxna Limited 1186 Nicola Aiken 1668 Paddington Academy 1112 Nicola King 933 Paddington Arts 2140 Nilavra Mukerji 592 Paddington BID 1438 Nildram 1502 Paddington BID 1858 Nimax Theatres Ltd 595 Paddington Churches Housing Association 1913 Noel Coward Theatre 596 Paddington Citizens Advice Bureau 1590 Noise Abatement Society 1305 Paddington Development Trust 1123 North Paddington Society 597 Paddington Green Police Station 2101 North Paddington Society 1456 Paddington Library 570 North West London Mental Health Trust Carers' 598 Paddington Regeneration Partnership Support Group 1131 Paddington Residents Active Concern on Transport 1914 North West London Strategic Health Authority (PRACT) 572 North Westminster Bengali Women's Association 599 Paddington Society 573 North Westminster Chinese Women's Group 1304 Paddington Waterside Partnership 1117 North Westminster Voluntary and Community Sector 601 Paddington Waterways & Maida Vale Society Forum 1689 Paddington Waterways and Maida Vale Society 574 Norton Rose 603 Paints Pots Montessori School 575 Notcutt House Leaseholders' Association 604 Pakistan Community Organisation 1915 Notre Dame de France 1154 Pamela Batty 1319 Notting Hill Housing Group 605 PAN Westminster 1583 Noved Investment Company 1194 Papya Qureshi 1942 Novus Leisure 606 Parents & Childminders Drop In 1202 NTL (Hampshire office) 607 Park View Lodge Pre-School 2212 O&H Properties Ltd 608 Parkinson's Disease Society 579 Oak Tree House Residents' Association 1336 Parliamentary Estates Directorate 1916 Oasis Stores Ltd 1672 Parliamentary Works 1081 Octavia Housing 609 Parsons House Residents' Association 2238 Odeon UCI Cinemas (Leicester Square Odeon) 610 Passage Day Centre & Night Shelter for Homeless 1943 Odham's Walk Resident Management Ltd People 580 Odhams Walk Residents' Association 1673 Patric Austin 581 Office Bar (The) 2158 Patricia Bras 2216 Office of Rail Regulation 2116 Patricia McAllister 1719 OGC Buying Solutions 2163 Paul and Jeanne Strang 582 Olabisi Olaleye Foundation 611 Paul Davis & Partners 583 Olive Tree Christian Centre 1946 Paul Davis & Partners Architects 584 Olswang 612 Paul Dickinson & Associates 1945 Omega Land Ltd 1171 Paul Dimoldenberg

2240 Paul O'Connell 2092 Policy, Planning and Performance 613 PCCG Licensing Working Party 1953 Polo Ralph Lauren Ltd 614 Peabody Avenue / Close Social Community Group 638 Ponsonby Residents Association 616 Peabody Trust 640 Porchester Estate Residents' Association 617 Peacock & Smith 1051 Port of London Authority 1947 Peacock Theatre 2242 Portland Village Association 2253 Pegasus Planning Group 643 Portobello Trust Crèche 1948 Pell Frischman 1529 Positive Soundscape Team 1949 Pellings Planning Architecture & Surveying 1954 Potter Raper Partnership 1570 Penny Shepherd 644 Powergen plc 2161 Peter Caneparo 1116 Pre - school Learning Alliance 2154 Peter Scheu 2111 Premio Group Holdings Ltd 1950 Pheonix Theatre 1204 Pre-School Learning Alliance- Tiny Tots Under 5 1158 Philippa Roe 1955 Prince Edward Theatre 2159 Phillida Inman 1956 Principles Rubicon Retail 619 Philological Foundation 378 Prison Service Headquarters & Central Services 2165 Phoebe May 2094 Procurement and Suppiler Relationship Mangement 1083 Pimlico & Knightsbridge Labour Party 1581 Project Blue (Guernsey) 621 Pimlico Citizens Advice Bureau 545 Property Merchant Group 1714 Pimlico District Heat Undertaking 2098 Property Services 622 Pimlico Family Workshop 2099 Property Services 624 Pimlico FREDA 2063 Property Week 1609 Pimlico FREDA 1978 Prudential Property Investment 1457 Pimlico Library 1593 PRUPIM 625 Pimlico Playtots 1419 Public Health & Well Being Westminster PCT 626 Pimlico Puffins 1418 Public Health Intelligence (Westminster PCT) 627 Pimlico Street Properties Association 648 Pursuing Indpendent Paths 628 Pimlico Toy Library 2206 Qatari Diar 629 Pimlico Village Play Centre 650 Queen’s Park Community Childcare Centre 1931 Pink Soda (UK) Ltd 651 Queen’s Park Crèche 1951 Pinnger & Partners 652 Queen’s Park Family Service Unit 630 PIP SW1 653 Queen’s Park Play Project 632 Planning Aid for London 649 Queen's Park Bangladesh Association 1283 Planning Bureau Limited 654 Queens Park Court Residents' Association 2097 Planning Commissoning 655 Queens Park Estate Residents' Association 635 Planning Exchange 656 Queen's Park Estate Society 995 Planning Potential 1458 Queen's Park Library 2214 Planning Potential Ltd 657 Queen's Park Neighbourhood Forum 637 Play Mates 658 Queen's Park Youth Club 1952 Playhouse Theatre 659 Queensborough Community Childcare Centre 215 Plc Crown Castle UK Ltd 1979 Quintain Estates & Developments Plc 1427 Plusnet 1623 R Fraiman 1641 Pocket 1630 R Waddon 2241 Pocket Living Ltd 661 RAC 1536 Police Consultative Group 1710 Rachael Ferry-Jones 1537 Police Consultative Group 2142 Rachael Robathan 1058 Policy Innovation & Partnership 1980 Racing Green (Speciality Retail Group) 1602 Policy Innovation & Partnership 1981 Radcliffe's Le Brasseur 1699 Policy Innovation & Partnership 662 Radha Krishna Temple 2093 Policy Innovation & Partnership 1982 Radisson Edwardian Hotels

1983 Ralph Lauren 1658 RSL and CityWest Homes 1315 Rapleys 1991 Rugby Estates Plc 666 Ravenstone House 693 Rugby House Project - Crisis Centre 1984 Really Useful Theatres 1193 Rupert D’Cruz 1985 Redevco UK 694 Russell House Residents' Association 1986 Regent Street Association 1150 Ruth Bush 1579 Regent's College 695 S J Berwin LLP 1987 Reiss Retail Ltd 2180 S&W Design 2187 Reliance Security Group Limited 912 Safer Westminster Network 668 Reliance Security Group plc 696 Sainsbury's Supermarkets Ltd 1661 Residents of Carlton House Terrace 697 Salvation Army - Edward Alsop Court 670 Residents' Society of Mayfair and St James's 698 Salvation Army Central Division 672 Rialto Homes plc 701 Sanctuary Housing Assoc - Dean Abbot House 1753 Richard and Maria Garland 702 Sanctuary Housing Association - Wolfson House 2137 Richard Beddoe 1148 Sarah Richardson 1332 Richard Coleman Consultancy 1992 Savana Studio 2157 Richard Debille 1993 Savant UK ltd 1244 Richard Garland 704 Save London Theatres Campaign 2243 Richard Graham 2064 Savell Bird & Axon 2160 Richard Tarling 2217 Savile Row Bespoke 673 Ringrose Kindergarten (Pimlico) 1466 Savills 674 Ritterman Holdings 1206 Savills Commercial Limited 675 RNJN Architects 1069 Savills Hepher Dixon 1740 RNLI 1726 Sayers Croft Field Centre 676 Road Haulage Association Ltd 1087 Schools & Learning 1160 Robert Davis 1554 SCOPE 1605 Robert Muriel 706 Scope - Inner London Group 2145 Robert Rigby 1634 Scott Brownrigg 679 Robin Bretherick Associates 707 Scott Ellis Gardens Association 1074 Rolfe Judd Planning 708 Scout Association - 2nd City of Westminster Scout 681 Ropemaker Properties Ltd Group 682 Rosary Over 60's Club 709 Scout Association 2132 Rose Doyle 1994 Sedgwick Richardson 1922 Royal Air Force Club 1995 SeeWoo Foods Limited 1876 Royal Albert Hall 712 Selfridges Retail Limited 684 Royal Borough of Kensington and Chelsea 713 Semley House Residents' Association 1496 Royal Borough of Kensington and Chelsea 1540 Sense 685 Royal British Legion - Metropolitan Region 714 Servite Houses 1988 Royal College of Art, Soho Society 1996 Seven Dials 1989 Royal Dragon 710 Shaftesbury PLC 1705 Royal Institue of British Architects 1012 Shaftesbury plc 2179 Royal Institute of Chartered Surveyors 2066 Shape Arts 1268 Royal Mail Group 1152 Sharan Tabari 688 Royal Mail Property Holdings 2138 Sheila D'Souza 1545 Royal National Institute for Deaf People 1997 Sheppard Robson 1541 Royal National Institute of Blind People (RNIB) 717 Shillaman Smith Architects 1990 Royal Opera House 1693 Shire Consulting 689 Royal Society for the Protection of Birds (RSPB) 718 Siddons & Stirling Residents' Association 1694 RPS Group Plc 1930 Sidney Murray Ltd 1629 RPS Planning 719 Sierra Leone Youth Association 2003 Sinclair Knight Merz 25

1998 Sing Tao (UK) Ltd 754 St James Homes 720 Single Homeless Project 2190 St James’s Conservation Trust 2164 Sir Hugh Cortazzi 1282 St James's Conservation Area Trust 1999 Sir Robert McAlpine Ltd 1459 St James's Library 1161 Sir Simon Milton REMOVED FROM MAILING LIST 2015 St James's Property Investment Ltd 2000 Sister 1651 St Johns Wood Area Forum 2001 Sister PR 1460 St John's Wood Library 721 Sisters of Charity - Blandford Street Hostel 2106 St John's Wood Police Station 723 Sixty Plus Group 1126 St John's Wood Society 2002 Skanska Construction UK ltd 2016 St Martins Property Corporation 2004 Slaughter & May 756 St Martins Property Investments Limited 725 Society for the Protection of Ancient Buildings 1318 St Marylebone Society 1760 Society of London Theatre 757 St Mary's Hospital 726 Society of Travelling Peoples 758 St Paul’s NEWPIN 1505 Soho Action Plan 2017 St Paul's Bookshop 2005 Soho Caring Agencies Forum 2018 St Vincent de Paul Primary School 2006 Soho Clubs and Bars 759 St. Andrews Club 727 Soho Community Centre 760 St. Christina’s School (RC) 2007 Soho Estates Ltd 761 St. James’s Pre-School 729 Soho Family Centre 762 St. John’s Montessori Nursery 730 Soho Family Centre Playgroup 763 St. John’s Nursery School 2008 Soho Green 764 St. John’s Wood Adventure Playground 731 Soho Housing Association 766 St. John’s Wood Junior Prep School 2009 Soho Parish School 767 St. John’s Wood Synagogue Kindergarten 732 Soho Society 768 St. John's Guild for the Blind 1644 Soho Society 769 St. John's Housing Association - La Verna House 2010 Soho Theatre 770 St. Jude’s Day Nursery 734 Somali Advisory Bureau 771 St. Judes over 50's Club 735 Somali Westminster Association 772 St. Margaret's Drop-In Centre 736 Somerfield Stores Ltd 773 St. Mark’s Square Nursery School 2012 Sotheby's 774 St. Mary of the Angels Senior Citizens Club 1655 South Area Forum 775 St. Marylebone Health Society 1635 South Central Management Ltd 776 St. Marylebone Society 1127 South East Bayswater Residents Association 777 St. Mary's Hospital Estates & Facilities 740 South Eastern Trains 779 St. Nicholas Preparatory School 742 South Westminster Legal Advice Centre 780 St. Stephen’s Day Nursery 1049 South Westminster Renewal Partnership 781 St. Stephen’s Play Project 743 South Westminster Triangle Association 782 St. Vincent’s Family Project 744 South Westminster User Involvement Group 784 St. Vincent's Hostel 745 South Westminster Victim Support 785 St. Vincent's Over 60's Club 1407 Southern Electric Power Distribution Plc 1757 Stadium Housing Association 748 Spanish and Portuguese Jews Congregation 786 Stagecoach - Selkent 1555 Spinal Injuries Association (SIA) 787 Standard Life Assurance Company 1090 WCC Adult & Community Sevices 2019 Standard Life Investments 1034 Sport England 788 Standing Advisory Committee on Religious 2013 Squire & Partners Education/Westminster Interfaith 751 SSAFA Forces Help (Westminster Division) 2020 Stanhope Plc 2014 St Anselm Development Co Ltd 790 Staying Put Service 752 St George ( PLC) 2067 Steer Davies Gleave 753 St George's Square and Pimlico Square R Assoc 1624 Stefana Scimone 792 Stephenson Harwood Solicitors 26

794 Stepping Stones Community Childcare Centre 1747 The Bat Conservation Trust 1185 Steven Summers 823 The Berkeley Group 1628 Stewart Ross Associates 1972 The Bond Street Association Ltd 795 Stockcredit Ltd 824 The British Hospitality Association 796 Stow Securities 2191 The British Hospitality Association 798 Strategic Planning Advice Ltd 1467 The British Land Company 2229 Strategic Planning Advice Ltd 1973 The Catholic Truth Society Bookshop 799 Street Properties Association 826 The Central London Gurdwara 1556 Stroke Association 1082 The Chelsea Society 800 Stroke Association - Parkside Group 1330 The Church Commissioners 801 Stroke Association - Riverside Group 2078 The Classic Fairytale Company 1968 Structadene Ltd 1345 The Coal Authority 1347 Strutt and Parker 1002 The Crown Estate 1723 Sturgis Associates LLP 2040 The Dalerush Workshop 2077 Subway Gallery 1761 The Delfina Foundation 805 Sudan People’s Support Association 1974 The Duchy of Lancaster Office 803 Sudan People's Association 261 The Egyptians' UK Association 804 Sudanese Community Organisation 1410 The Electricity Network Company Limited 1140 Suhail Rahuja 1493 The Environment Agency 806 Sunrise Pre- School 2054 The Environment Agency (London Office) 1104 Sure Start Parent's Forum 1013 The Environment Agency (Thames Office) 808 Sure Start South Westminster 1323 The Eyre Estate 1159 Susie Burbridge 828 The Flanders Club 1734 Susie Johns 830 The Forestry Commission 809 Sussex Street Play Project 831 The French Nursery School 810 Sustrans 317 The Garden History Society 812 Symonds 1325 The Georgian Group 813 Tachbrook Nursery School 1975 The Gilfillan Partnership 814 Tachbrook Pensions Club 1662 The Grosvenor & Mayfair Residents Association 815 Tachbrook Tenant's Association 349 The Gypsy Council 1576 Taj Hotel Group 1669 The Inland Waterways Association 1437 TalkTalk 356 The Kensington Gardens School 1577 Targetfollow Estates Ltd 419 The Knightsbridge Association 2207 Tate Hindle Architects 834 The Knightsbridge Kindergarten 2244 TCG Bars Limited 1616 The Langham Estate 816 Tea Dance Club 1763 The Man in the Moon Theatre Company 1970 Ted Baker 1592 The Mercers Company 818 Tesco Stores 836 The Mousehole Nursery, UCLH 1436 Tesco Telecoms 1542 The National Federation of the Blind 1105 TfL 1567 The National Society for Epilepsy 819 Thames 21 1557 The Neurological Alliance 1737 Thames Estuary Partnership 1976 The Passage 820 Thames Gateway London Partnership 1977 The Photographers' Gallery 1271 Thames Water Property Services 1446 The Planning Inspectorate 1227 Thames Water Utilities Ltd 1284 The Pollen Estate 1971 The Ambassadors Theatre Group 837 The Portman Estate 821 The Angel Community Childcare Centre 1327 The Portman Group 822 The Association of Licensed Multiple Retailers 838 The Rainbow Children’s Centre 2011 The Aver Consulting Sola Consulting Partnership 1333 The Roman Catholic Diocese Of Westminster 2166 The Basement Design Studio 1957 The Royal Horticultural Halls & Conference Centre

2202 The Royal Parks 1594 Turley Associates 1048 The Royal Parks Agency 1524 UK Noise Association 2041 The Showroom 1484 UK Petroleum Industries 1483 The Society of Motor Manufactureres and Traders 1716 UK Youth Parliament 1925 The Spirit Group 864 Union of Muslim Families 839 The Strand, Aldwych & Trafalgar Square Assoc 1251 Union Railways (north) Limited 1596 The Tate 1965 Uniqlo UK Ltd 1257 The Theatres Trust 2246 Unite Group Plc 840 The Tree Council 1966 United House Ltd 862 The Twentieth Century Society 865 United Women's Homes Association Ltd 1324 The Victorian Society 1266 Universities Superannuation Scheme (USS) 1958 The Westbury Hotel-Mayfair 1717 Universities Superannuation Scheme (USS) 1667 The Westminster Older People's Network 1595 University College London Hospitals (UCLH) 1664 The Westminster Reporter 1287 University of Arts London 1959 Theatre Royal Drury Lane 1530 University of Arts, London 844 Thomas’s London Day Schools 2247 University Of Bath 843 Thomas's London Day Schools 1534 University of Salford 1929 Thorn Lighting Ltd 867 University of Westminster 1921 Thornbury Castle 1513 University of Westminster 845 Thorney Island Society 869 University of Westminster Nursery 847 Threshold Tennant Trust 2248 Urban Evolution 1219 Thus Plc (Demon) 870 Urbium 1960 Tiffany & Co 872 Valpak 1711 Tim Butcher 1967 Vaudeville Theatre 2245 Tim Carnegie 1225 Verizon 1176 Tim Joiner 873 Vestry 1178 Tim Mitchell 1293 Victoria Business Improvement District (BID) 2156 Tim Simpson 1750 Victoria Interchange Group 1961 Timberland Europe Serices Ltd 1461 Victoria Library 1429 Tiscali UK Ltd 1588 Victoria Palace Theatre 849 Toddler’s Inn Nursery School 876 Vincent & Gorbing 850 Toddlers & Mums Montessori 817 Virgin Media 1962 Tokyo Diner 1237 Virgin Media 851 Tollgate Gardens Residents' Association 2021 Virgin Retail Ltd 1432 Toucan Surf 1759 Vital Regeneration 855 Town Planning Consultancy 1092 Voluntary Action Westminster 1214 Town Planning Network Rail 1415 Voluntary Action Westminster (VAW) 856 Townshend Estate Residents' Association 877 Voluntary Service Department 1969 TP Bennett LLP 1094 Volunteer Centre Learning Difficulties 857 TP Consultancy 1928 Voyage Paris Ltd 2224 Traders Association - Harrow Road 2026 W A Ellis 1079 TfL (Operational Property Division) 1485 Walkit.com 1008 Transport for London (TfL) 878 Wand UK 1515 Transport for London (TfL) 2027 Warner Estate Holdings 2096 Transportation Commissioning 879 Warner Village Cinemas 860 Travis Perkins 880 Warwick Crescent Residents' Association 861 Trehearne Architects 881 Warwick Day Nursery 1963 Trevor Estate Ltd 882 Warwick Estate Residents' Association 1298 Tribal MJP 883 Warwick Estate Senior Citizens Club 1964 Tuckerman Commercial Ltd 1532 Warwick University

1077 Washbourne Greenwood Development Planning 902 Westminster Association for Mental Health 2028 Waterman Associates 1084 Westminster Bangladeshi Association 1445 Waterman Environmental 904 Westminster Befriend a Family 884 Watson Farley & Williams 1752 Westminster Befriend A Family 2029 Watts & Partners 905 Westminster Boating Base 1698 WCC Building Operations 2032 Westminster Cathedral 1677 WCC Built Environment 1101 Westminster Central Network 1718 WCC Children's Services Planning & Performance 907 Westminster Children’s Society 1701 WCC City Schemes 909 Westminster Citizens Advice Service 2249 WCC Crossrail & Environmental Sciences 1463 Westminster Faith Exchange 1675 WCC Emergency Planning 1292 Westminster Health and Care Network 1713 WCC Environment & Leisure 2117 Westminster Health and Care Network 1676 WCC Environmental Sciences 1653 Westminster Health and Care Network Business 2209 WCC Libraries 1696 Westminster Housing 2073 WCC Licensing Policy & Strategy 1646 Westminster Housing Stratgy and Performance 2210 WCC Parks and Leisure 914 Westminster Interfaith 1681 WCC Planning & City Development Central Team 2033 Westminster Kingsway College 1679 WCC Planning & City Development North Team 1526 Westminster Licensees Association 1680 WCC Planning & City Development South Team 1464 Westminster Local Involvment Network (LINk) 1706 WCC Planning West End Team 915 Westminster Partnership 1674 WCC Premises Management Delivery Unit 916 Westminster Play Association 1749 WCC Social and Community Services 1663 Westminster Plus Publication (Senior Passport) 885 Weatherall Green & Smith 97 Westminster Police Licensing Team 886 Weatheralls 1255 Westminster Property Association (WPA) 887 WECH under 3s Drop In 1666 Westminster Race Equality Partnership 888 WECH Youth Club 811 Westminster Refugee Consortium 2030 Wereldhave Property Management Co Ltd 1250 Westminster Refugee Consortium 890 Wessex Gardens Residents' Association 1252 Westminster Senior Citizens Forum 892 West and North London Vietnamese Association 1321 Westminster Senior Citizens Forum 1652 West End Area Forum 841 Westminster Society 893 West End Central Police Station 919 Westminster Somali Association 1654 West End LARP 920 Westminster Talking Newspaper for the Blind 895 West London Synagogue 1746 Westminster Transerv 2068 Westbourne LARP REMOVED FROM MAILING LIST 2034 WestOne 896 Westbourne Neighbourhood Association 922 WHICH 1288 Westbourne Neighbourhood Forum 923 Whitbread Plc 1507 Westbourne Neighbourhood Forum 925 Wickham Van Eyck 2 Westbourne Park Residents' Association 2045 Wigmore Hall Trust 2155 Westbourne Park Villas 2035 Willis Ltd 1 Westbourne Residents Association 926 Winbourne Architects 897 Western Charitable Foundation 928 Windmill Montessori Nursery School 2031 Western Heritable Investment 929 Wings of Hope 899 Western Marble Arch Friendship Club 930 Women with Voices 1665 Westminster Academy 931 Women's National Commission 900 Westminster Action Network on Disability 932 Wood Bank 256 Westminster Adult Education Centre 934 Woolwich Development Project Office 1482 Westminster Amenity Societies Forum (WASF) 2036 Works Architecure, Marylebone Association 1659 Westminster Amenity Society Forum (WASF) 554 Workspace Group 901 Westminster Archives Centre 1487 Wrexham, Shropshire and Marylebone Railway 2071 Westminster Arts 2037 Wright & Teague

935 WRVS Darby and Joan Club 941 Youth Information Shop 2150 Yael Saunders 1088 Youth Service WCC 936 Yates Group PLC 942 YWCA 1766 Yellow Earth Theatre Company 2038 Zara UK Ltd 937 Yemeni Community Association 1535 Zoological Society of London 938 York Mansions Residents' Association 944 Zoroastrian Trust Funds Of Europe (Inc) 940 Young England Kindergarten

Appendix 5: Regulation 18 responses

1. Barclays Bank 2. Covent Garden Community Association 3. (The) Crown Estate 4. Environment Agency 5. Highways Agency 6. Judith Warner 7. Knightsbridge Association 8. Mayor of London 9. Natural England 10. Office of Rail Regulation 11. St James’s Conservation Trust 12. Thames Water 13. Theatres Trust 14. Transport for London 15. Verina Glaessner 16. Westminster Property Association

10th May 2012 Our Ref: P-07-289/Westminster 8 Spicer Street, St. ALBANS Hertfordshire AL3 4PQ The Strategic Director Built Environment t: 01727 838455 City of Westminster Council f: 01727 835047 11th Floor City Hall, 64 Victoria Street, e: [email protected] London SW1E 6QP

Dear Sir

PLANNING & COMPULSORY PURCHASE ACT 2004 Revisions to Core Strategy for Westminster – May 2012

1. Introduction and Background As you know we act as planning consultants for Barclays Bank plc (“The Bank”) in respect of the emerging ‘Development Plan’ for Westminster. The Bank is a significant stakeholder within the City, being long- established with a number of branches which have made a substantial contribution to the vitality and viability of Westminster over the years that they have traded. The Bank has actively participated in the process of the emerging LDF submitting representations to various stages of the Core Strategy as well as the City Management Plan (CMP). We also attended and participated in the CMP Workshops in 2009.

We note that the Core Strategy is to be revised, and renamed the ‘Local Plan’, following the release of the National Planning Policy Framework (NPPF) and that the CMP is not to be progressed any further, as we understand that its provisions are to be incorporated into the new ‘Local Plan’. We were notified of these proposed revisions in a letter from Councillor Davis of 1st May 2012. Councillor Davis’s letter advises that “it is not necessary to repeat any comments made at an earlier stage”. The Bank has already submitted very detailed representations (together with supporting evidence) to the CMP earlier in 2012 and so we do not propose to repeat those comments here. However, we thought that it would be helpful if we were to highlight elements of the NPPF, which are relevant to the preparation of planning policies that will impact upon retailers (such as the Bank) who are keen to expand their businesses.

2. Relevant Matters Arising From the NPPF Before proceeding to the specifics of the NPPF it is worth making the general point about the length of the Council’s planning documents. Together the Core Strategy and CMP amount to nearly 600 pages and this cannot be conducive to full and proper stakeholder engagement. NPPF paragraph 155 states:

“Early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential [our underlining]. A wide section of the community should be proactively engaged, so that Local Plans, as far as possible, reflect a collective vision and a set of agreed priorities for the sustainable development of the area, including those contained in any neighbourhood plans that have been made”.

P-07-289-Westminster Revised CS Page 1 of 3 May 2012

CIVIL & STRUCTURAL ENGINEERS BUILDING SURVEYORS TELECOM CONSULTANTS PLANNING CONSULTANTS GEOTECHNICAL ENGINEERS ELECTRICAL ENGINEERS PLANNING SUPERVISORS HEALTH & SAFETY ADVISORS REGISTERED OFFICE: The Chapel Barnsley Hall Road Bromsgrove Worcestershire B61 0SZ. Registered in England 2424982

The National Planning Policy Framework (NPPF) re-emphasises the requirement for a Development Plan to be “sound” when it is submitted for Examination and that in order to be so it must be “Positively prepared, Justified, Effective and Consistent with National Policy”. The Government expects the local plan process to consider alternative strategies before deciding upon the most appropriate, that decision being based on evidence to support the choice (paragraph 182). The NPPF is clear that each LPA should “ensure that the Local Plan is based upon adequate, up-to-date and relevant evidence” and that their assessments and strategies “take full account of relevant market and economic signals” (paragraph 158).

On the matter of policy formulation the NPPF states that for plan-making:

• “local planning authorities should positively seek opportunities to meet the development needs of their area”; and • “Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change” (paragraph 14). The Government is clear that there should be a positive attitude to “proactively drive and support sustainable economic development” and to “respond positively to wider opportunities for growth”. Plans should “take account of market signals” and the needs of business communities (NPPF paragraph 17). “Planning should operate to encourage and not act as an impediment to sustainable growth” and “significant weight should be placed on the need to support economic growth through the planning system” (paragraph 19). Local Planning Authorities “should plan proactively to meet the development needs of business” (paragraph 20) and “Investment in business should not be over-burdened by the combined requirements of planning policy expectations” (paragraph 21). In drawing up Local Plans, local planning authorities should set out a clear economic vision and strategy which “positively and proactively” encourages sustainable economic growth; and should “support existing business sectors, taking account of whether they are expanding or contracting”. The NPPF confirms that “Policies should be flexible enough to accommodate needs not anticipated in the plan and to allow a rapid response to changes in economic circumstances” (paragraph 21). In his Foreword to the NPPF the Minister for Planning is very clear that “Development means growth” and that “Sustainable development is about positive growth”, emphasising that “Planning must be a creative exercise in finding ways to improve the places in which we live our lives”. This reflects HM Treasury’s commitment that “the default answer to development is yes” in its ongoing ‘Plan for Growth’, which was launched at the time of the Budget in 2011, reinforced in the 2012 Budget and now underpins the NPPF.

Specifically in relation to town centres the NPPF, like its various Government policy predecessors, recognises the wider role played by town centres than a pure shopping function. Government Policy in PPS6, PPS4 and now in the NPPF particularly emphasises the importance of economic growth and the promotion of town centre vitality and viability. Paragraph 23 requires that “Planning policies should be positive” and states that local planning authorities should “promote competitive town centres that provide customer choice” and allocate a range of sites because it is important that needs for retail, leisure, office and other main town centre uses “are met in full”. The clear message is that “local planning authorities should plan positively for their future to encourage economic activity”.

P-07-289-Westminster Revised CS Page 2 of 3 May 2012

In fact there is nothing in Government policy that recommends or supports imposing restrictions upon acceptable town centre uses at all and indeed, as noted above, paragraph 21 of the NPPF requires flexibility in policies in order to allow a rapid response to changes in economic circumstances. It is therefore essential that Development Plan policies should facilitate the positive approach required by the NPPF.

3. Concluding Remarks Within the NPPF the Government has reconfirmed its commitment to HM Treasury’s ‘Plan for Growth’ and its determination that planning policies and their implementation must facilitate economic investment and growth. It is imperative that the Council uses the opportunity of the preparation and revision of its new Development Plan to ensure that its planning policies are consistent with National Policy and fully justified by robust evidence. Up-to-date development plans are an essential element in providing the support for economic growth and the Council must revise its policies accordingly, so as to provide that support for investment by stakeholders such as our Client.

One of the Government’s stated reasons for producing the NPPF was to cut down upon the amount of planning policy and in order to create a usable document which allows and promotes genuine participation by the wider community, Westminster’s new Local Plan must be much more concise, as well as positive in its tone, than the existing planning documents. Essentially, this will mean reducing the number of policies and extraneous verbiage.

In view of the likely requirement for improved provision of banking services in Westminster during the life of the forthcoming Local Plan, the Bank would like to confirm its continued interest in the process and in that regard we would be grateful if the Council will continue to notify us of the progress of this consultation.

Yours sincerely

Michael Fearn of Shireconsulting On behalf of BARCLAYS BANK PLC

P-07-289-Westminster Revised CS Page 3 of 3 May 2012

42 Earlham Street, Covent Garden, London WC2H 9LA Tel. 020 7836 5555 email: [email protected] website: www.CoventGarden.org.uk Facebook: TheCGCA Twitter: @TheCGCA Registered charity no. 274468

15th June 2012 Sent via e-mail Westminster City Council Development Planning Westminster City Hall 64 Victoria Street London SW1E 6QP

ATTN: Lisa O’Donnell

RE: Revisions to the Core Strategy

Dear Ms O’Donnell,

We attach the Covent Garden Community Association’s response to the Consultation covering what local stakeholders would like to see in Westminster’s Local Plan, and explain briefly our ethos for Covent Garden that has led to the requests we are making.

Covent Garden has a large and vibrant residential community and sustaining it should be a clear part of making all development sustainable. There is a balance between commercial and residential interests that makes our area very desirable as a tourism, shopping and entertainment destination and, for the most part, a very attractive place to live. Preserving this balance is essential to the appeal of the area to all interested parties.

We see an increasing number of planning applications to Westminster (and Camden) for conversions from office use to residential and the majority of new residential units being built are one-bedroom flats. We are very concerned that these units are being bought for short-term rental which contributes absolutely nothing of merit to the neighbourhood and, in our opinion, do not constitute sustainable development as demanded by the NPPF. Furthermore the S106 contributions that result disappear into a pot for borough-wide use and we would like to see these contributions being aggregated and used to provide social housing within Covent Garden. Ever-increasing property prices risk turning the area into a rich man’s ghetto with an increasingly high proportion of rental accommodation.

Entertainment constitutes a sizeable proportion of Covent Garden’s commercial activity and consequently noise pollution is a major concern in our area. This arises inter alia from late night opening of entertainment venues and, particularly annoyingly, night-time glass collection. Hours of operation of this type of venue need to be strictly controlled. Our attached response expands upon noise pollution.

We are very supportive of the idea of an enforcement plan (NPPF para. 207) to formalize the Council’s policy leading to clearer understanding and better accountability.

Page 1 of 6 Covent Garden Community Association, continued...

Please let us know if you have any questions or if we can provide any additional information. We look forward to continuing to work with Westminster City Council in developing a Core Strategy that protects and enhances the vibrancy and attractiveness of Covent Garden as a place to live, work and visit.

Yours sincerely,

Meredith Whitten pp Michael Leeson Chair, CGCA Planning Sub-Committee

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Comments Regarding Revisions to Westminster’s Core Strategy 15th June 2012

Although Covent Garden is an international tourist destination and one of London’s most sought- after areas, it remains first and foremost a neighbourhood with residents and local businesses. Indeed, it is the vibrant local community that contributes to the attractiveness of Covent Garden as a destination. Protecting this vibrancy and the integrity of the local, historic assets within the Covent Garden Conservation Area should remain a priority in the Core Strategy. This means adopting policies that are specific to the needs of Covent Garden. In particular, protecting the area’s unique character, as well as the amenity of local residents, is essential and should be spelled out.

The Covent Garden Community Association’s comments regarding the Core Strategy, including points from the National Planning Policy Framework as well as points from the existing Core Strategy, follow below.

1. National Planning Policy Framework – The CGCA suggests that the Core Strategy should incorporate the following points from the NPPF (NPPF policy number in brackets):

Local people, and particularly local residents, should be empowered to shape their surroundings (17).

The Core Strategy and planning permissions should take account of the different roles and character of different areas, including the Covent Garden Conservation Area (17).

Conserve heritage assets in a manner appropriate to their significance, so future generations can enjoy them, as well (17).

Deliver high-quality homes and affordable housing (47).

Avoid the long-term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose (21).

Develop robust and comprehensive policies that set out high-quality design requirements. These policies should be spelled out in detail for the Covent Garden Conservation Area (58).

Promote and reinforce local distinctiveness (60). Again, specific policies related to the conservation area are needed.

Advertisements should be subject to stricter control in the conservation area, with the impact on the character of the area and nearby buildings and historic assets (67).

Page 3 of 6 Covent Garden Community Association, continued...

Area of Special Control Order may be approved if an area justifies a degree of special protection on the grounds of amenity. Amenity organisations, including the CGCA, should be consulted (68).

Guard against the unnecessary loss of valued facilities and services, and ensure that established shops, facilities and services are able to develop and be retained for the benefit of the community (70). This is critical in Covent Garden, where the independent businesses and local facilities and services are essential for maintaining the character of Covent Garden. Such businesses, facilities and services are necessary to maintain the residential population, which is what gives the conservation area its continued vibrancy.

Protect and enhance public rights of way and access (75). In particular, permissions for use of the public highway for use, such as tables and chairs usage, should consider the unique situation of the conservation area. Located in the centre of London, Covent Garden experiences high footfall and vehicular traffic throughout the year. The ability of local residents, as well as visitors, to move about the conservation area safely should be a priority.

Set out a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats (126-141).

Great weight should be given to a designated heritage asset’s conservation (132).

Consent should be refused if a development would lead to substantial harm or total loss of significance of a designated heritage asset (133). In particular, alterations and extensions should enhance, not harm, the conservation area’s buildings or historic assets.

In situations where substantial harm or total loss of significance of a designate heritage asset is less likely, the harm should be weight against the public benefits of the proposal (134).

Look for opportunities for new development within conservation areas to enhance or better reveal their significance (137).

Provide early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses (155).

Local planning authorities should have a clear understanding of housing needs in their area (159).

Maintain a clear understanding of business needs in the area (160).

Maintain up-to-date evidence about the historic environment and use it to assess the significance of heritage assets and the contribution they make to their environment (169).

Work collaboratively on planning issues that cross administrative boundaries (178). This is a particular concern for the Covent Garden Conservation Area, which lies in both Westminster and Camden.

Page 4 of 6 Covent Garden Community Association, continued...

Neighbourhood plans should determine decisions on planning applications and should be aligned with the local plan (183-185).

Communities can use Neighbourhood Development Orders and Community Right to Build Orders to grant planning permission (201-202).

Apply and enforce conditions, or planning obligations, on development as means of addressing unacceptable impacts (203-206). Use of planning conditions and obligations are important in the conservation area and are often necessary to manage cumulative impacts of entertainment and food and beverage offerings. Because “reasonable,” “enforceable” and “necessary” are subjective, the Core Strategy should be specific in how this will be determined. The perspective of the community is critical in these definitions.

We are very supportive of the idea of an enforcement plan to formalize the Council’s policy leading to clearer understanding and better accountability (207).

2. National Planning Policy Framework – The CGCA has the following suggestions regarding the existing Core Strategy (Core Strategy policy number in brackets):

Mixed-Use in the CAZ (CS1) – Increasing residential uses will contribute to the vibrancy of Covent Garden, which is first and foremost a residential community.

Housing Needs and Affordable Housing (CS15 & CS16) – Affordable housing is a significant concern in Covent Garden, as is the loss of residential units – particularly affordable housing units – through conversion or change of use. Covent Garden is one of the most expensive parts of London in which to live, so great care should be taken to ensure the area continues to offer housing opportunities to a diverse range of residents. Indeed, the diversity of local residents is a primary factor in the international attraction of appeal of the Covent Garden area. Providing an appropriate mix of housing units, in terms of size, type and tenure, is critical to attracting a mix of residents, including families. It is also important to provide an environment that encourages long-term residents, including long-term lets.

Commercial Development (CS18) – Commercial uses should be of an appropriate scale and use in the conservation area.

Retail (CS20) – To retain the unique and historic character of the Covent Garden Conservation Area, attention should be given to the size of retail unit sizes, as well as the amount of retail versus other uses.

Tourism, Arts & Culture (CS21) – While the arts and cultural uses attract international visitors to Covent Garden, art and cultural facilities should fit in with the local context and benefit the local community as well. Central London and specifically the West End and Covent Garden areas are known for their entertainment offerings, but the cumulative impacts on local residents and businesses should be minimized. This involves issues such as the types and quantity of food and

Page 5 of 6 Covent Garden Community Association, continued...

beverage vendors. Late-night vendors should be greatly limited. Large-scale entertainment uses should not be allowed in the conservation area.

Heritage (CS24) – Detailed policies for each type of heritage asset must be set out. Any refurbishments, alterations or upgrades in the conservation area should only occur if they do not diminish the conservation area’s heritage assets and do not negatively impact on the local residential amenity.

Design (CS 27) – The special needs of the Covent Garden Conservation Area should be spelled out. In particular, understanding the “local distinctiveness” is imperative when addressing the building stock. While recognising that the built environment must be fit to meet the challenges of the future, including climate change, there should also be recognition of the integrity and role that the existing built environment has in the historic fabric of the conservation area. The design of new developments as well as alterations and extensions to existing sites should coalesce with the historic character of Covent Garden. Local guidelines regarding appropriate facia treatment should reflect the distinctiveness and character of the area.

Health, Safety and Well-Being (CS28) – The built environment in the conservation area should not just fit into the character of the area, it should enhance the residential amenity and improve the residential environment. Ensuring residents’ safety includes limiting late-night licenses, as the dispersal of loud, and often drunk, visitors can cause concern among residents.

Noise (CS31) – Whilst recognising that Covent Garden lies in the heart of London and attracts a large number of visitors, it is first and foremost a residential community. Noise is inevitable in such a popular area, but residential amenity must be protected as excessive and disturbing noise has an impact on residents’ health and well-being. Air-conditioning units, extract ducts and plant facilities associated with restaurants, cafes, public houses and other business and retail establishments has a detrimental impact on residential amenity, particularly with the cumulative effects of a proliferation of units. Planning applicants should be required to produce evidence that residential amenity (including noise and vibrations) will not be affected. Permission should be granted only after sufficient evidence has been provided. In addition, conditions limiting the hours of usage (such as overnight) and specifying regular maintenance and upkeep should be standard to protect residential amenity.

Misc.: Enforcement – Because Covent Garden is a popular destination throughout the year and at all times of the day, strict enforcement must be taken to deal with breaches of planning control to protect the character of the area and historic assets.

Page 6 of 6

Dear Lisa

Revisions to Westminster’s Core Strategy in light of the NPPF

Thank you for consulting us on your revision of your core strategy in light of the NPPF. We think the core strategy policies we have commented on previously (e.g. CS29, CS44, CS27) are compliant with the NPPF in that they are founded on an evidence base and a sequential approach has been taken to flood risk.

Paragraphs 94 and 99 of the NPPF advise how local policies can play a role in climate change adaptation and we suggest this is an area where the Core Strategy and the City Management Plan flood risk policies should be strengthened. We suggest reference is made to the need for adaptation to climate change in policies CS44 and CS29. This is particularly important for CS44 as Tidal flood defences may have to be raised and water attenuation/conveyance features enlarged to accommodate for climate change.

The fact that some types of Sustainable Drainage System improve water quality as well as reducing runoff should also be recognised when revising your policies. Improving the quality of runoff in new developments will make an important contribution to the objectives of the Thames River Basin Management Plan. We appreciate that the policy on SuDs is contained in the CMP not the core strategy, however we did not highlight this particular aspect of SuDs when we commented on the CMP.

We highlight the importance of including outputs from Drain London and your Surface Water Management Plans (SWMP) when reviewing and updating any planning policies.

We would be happy to have a meeting with yourselves about using your SWMP and flood risk in general if you felt this would be helpful.

If you have any questions on our advice above please contact me.

Yours sincerely

Mr Matthew Arthur Planning Liaison Officer

Telephone: 020 7091 4081 E-mail: [email protected] Based at: Eastbury House, Albert Embankment Postal address: FAO Planning Liaison, London Team, Apollo Court, 2 Bishops Square Business Park, St Albans Road West, Hatfield, AL10 9EX From: Blake, Patrick Sent: 29 May 2012 17:20 To: LDF Cc: Benham, Paul; Atiq, Nawal Subject: Westminster City Council Core Strategy Revisions Consultation

Dear Lisa O'Donnell

Thank you for your email on 1 May 2012 inviting the Highways Agency (HA) to comment on the Westminster City Council Core Strategy Revisions Consultation.

The HA is an executive agency of the Department for Transport (DfT). We are responsible for operating, maintaining and improving England’s strategic road network (SRN) on behalf of the Secretary of State for Transport.

The HA will be concerned with proposals that have the potential to impact the safe and efficient operation of the SRN.

We have reviewed the consultation and do not have any comment at this time.

I hope this is helpful.

Your sincerely

Patrick Blake Highways Agency | Federated House | London Road | Dorking | RH4 1SZ Tel: +44 (0) 1306 878363 Web: http://www.highways.gov.uk GTN: 3904 8363

Safe roads, Reliable journeys, Informed travellers Highways Agency, an Executive Agency of the Department for Transport.

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From: . Sent: 01 May 2012 13:33 To: O'Donnell, Lisa Subject: RE: Westminster City Council Core Strategy Revisions consultation

Strategy Revision St Johns Wood Abbey Road Ward

Basements

The City Council has gone on record saying that our policy on Basements demonstrates more control than other Local Authorities. This may be so - except that there are very few with the volume of applications which we experience not only in Westminster, but St Johns Wood ( basements are expensive). How many basement applications are there in Brent or Redbridge each year ?

The issue is not a comparision between boroughs - but - the type of dwelling - and the impact on the surroundings which is not being recognised. A basement under a free standing detatched house with a large garden has less of an impact than a basement under a narrow Terrace dwelling - with other dwellings in the same street also installing basements - pepper potting the street (and turning the street into a perpetual building site).

One size does not fit all - even in Westminster and this should be recognised in the Planning Policy changes.

We do not seem to be listening to the Ministers view that a local approach may be taken.

Building Control - Domestic Developments

The privatisation of Building Control has resulted in a hands off approach. The developers / applicants may be obliged to self regulate, however in St Johns Wood we see evidence of building work which did not have consent. ( I live between two buildings which were altered without Westminsters Planning Department approval). Where the City Council has a regulatory role - it must be applied to the highest standard - whether provided by the state or the private sector. At the moment there is no professional independent and adequate building control in the domestic sector. For an increasing number of people this results in a loss of confidence in the Planning Process.

These issues remain important in this community, and are not likely to diminish without a recognition ,that domestic dwellings are not all the same, and have a different impact on their surroundings when basement work - particuarly on a large scale and with great frequency in the same streets is permitted .

Please look at this aspect of policy again.

Judith Warner

THE KNIGHTSBRIDGE ASSOCIATION 6 Montpelier Street, London SW7 1EZ Tel: 020 – 7823 9103 Fax: 020 – 7581 3130 www.knightsbridgeassociation.org.uk

LDF Revisions.

We are grateful for the opportunity to influence the current stage of planning policy making. Inevitably given the considerable passage of time since the beginning of the LDF process there are some matters which seem to us new and not sufficiently taken into account by planning policy. Other matters have been raised by us before but, in our view, continue to need greater attention in the documents.

1. Distorting effect of the market in housing as investment material.

It has been evident for some time that at the top of the housing market properties are being bought as investments and not inhabited or occupied very infrequently. This is not a new phenomenon in housing or in other property categories. The empty Centre Point office block, held vacant for its appreciating investment value, is an example from another era. In response to this inflated investment value of offices the City Council developed planning policy to control the dominance of offices over other perfectly viable uses.

We have always fervently supported the City Council in its belief that a key element in the success of Central London is that people from all walks of life live in it. We also willingly recognize that it is natural for many residents of a great capital city with multiple international connections to have other homes in Britain and abroad. What is dangerous and distorting of the City’s mix of uses is that housing is being bought as an investment or a trophy rather than for living in.

We believe that the Council should develop policy in response to this stage in the economic development of Central London. We suggest that this response might include  Protection for hotels? In Knightsbridge as in other parts of Westminster hotels are a key part of the urban scene. One of their functions should be to provide the luxurious medium and short term accommodation that London’s wealthy require. So long as their sites are less valuable in hotel use than in residential, hotels will be at risk.  Protection for offices? It appears that all classes of office accommodation can be replaced with housing. In many cases this removes an unsuitable use in a residential street and provides a valuable addition to the housing stock. But Westminster neighbourhoods need small offices and the Council’s very long standing small office policies need reexamination. But equally large office sites are capable of being turned into residential accommodation. We ask that the Council considers, with the benefit of hindsight, whether the Bowater House site would have served the City better had it remained in office use.  Protection for service uses? Westminster’s residents and businesses need services – repairers, suppliers, builders – a huge variety of needs. Most of the sites in Westminster once used by such activities as timber yards and motor servicing have been changed to other uses, very often residential. Those that remain are worth preserving. Shopping policy was the main basis for the Council winning an appeal against refusal of change of use from builder’s yard to residential at the Travis Perkins Pimlico Road site some years ago but few other sites could be protected in this way.  Housing mix policy? Many residential developments at the top of the market are designed in ways that would not appeal to a working family. In particular the units are too large to be

President: The Lord Marshall of Knightsbridge Vice-President: The Lady Grade Chairman: Winston Fletcher, CBE Vice-Chairman: E Davies-Gilbert Hon. Secretary: Carol Seymour-Newton, Hon. Treasurer: Phyllis Lusher.

affordable to any but those with surplus capital to invest. The Council should consider a housing mix policy to help suit units to those needing permanent accommodation. 2. Size of buildings. The Council will be aware of our previous representations to the effect that policies concerned with the height and bulk of buildings have been watered down in successive policy reviews and need to be made stricter. 3. Basements. Our paper, submitted to the Council, on the control of subterranean development should also be taken into account in these revisions. We are aware that many of the actions we believe to be necessary would be taken under highway, environmental health and housing legislation rather than that of town planning. We believe however that in the interests of ‘joined up government’ the thrust of these actions should be discussed in the plan. The administration of licensing in recent years is a good example of the benefits of a ‘joined up’ approach. 4. Knightsbridge. We have pointed out in the past failures in coordination of policy at the boundary between the City and the Royal Borough. These should be avoided in the current round of policy- making. 5. Transport, pollution etc. We have made extensive representations on the need to improve air quality, comply with limit values and address other environmental matters related to transport. These should also be taken into account in the revisions. 6. Royal Parks. The increasing commercialization of the Royal parks and their use for mass events rather than to provide a haven of tranquility at the centre of the City has been an unfortunate feature of recent years. Planning policy should be strengthened to help reduce such use. 7. Knightsbridge Barracks. We understand that the Ministry of Defense intends to end military use of Knightsbridge Barracks and to sell the site. We believe that the future use of the site should be considered in the revisions with the aim of achieving a reuse more effectively than at the Chelsea Barracks site. This is particularly important because the site brings together many of the policy questions that we have considered above. In our view the present buildings should not have been permitted because the tower is too high and intrudes upon the Park. On the other hand, architecturally, the design by Sir Basil Spence is distinguished, is unlikely to be matched, let alone improved upon, by a new design and should be retained if low rise development cannot be required. The best use of these buildings is residential but they could very easily end up in the same unproductive investment sector of the market as One Hyde Park if the matters we have outlined above are not addressed.

Date: 12 June 2012

Our ref: Your ref:

Westminster City Hall (11th Floor), 3rd floor Guildbourne House, 64 Victoria Street Chatsworth Road, Worthing London. West Sussex BN11 1LD

Dear Lisa O’Donnell

FREEPOSTRevisions (LW43) to Westminster’s core strategy

Lewes BN7 1BR Thank you for consulting Natural England on the revisions to Westminster’s core strategy. Natural England welcomes the opportunity to comment. l We welcome many of the policies contained within the core strategy particularly those concerned with protecting the natural environment, namely CS35-CS37. These policies regard the valuable greenspace and wildlife within Westminster.

FRThese policies comply with the following paragraphs within the NPPF 2012 which cites:

109 Planning should contribute to enhance the natural and local environment by

Recognising the wider benefits of ecosystem services Minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the government’s commitment to halt the decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures.

117 Planning policies should:

Identify and map local ecological networks including the hierarchy of international, national and locally designated sites of importance for biodiversity, wildlife corridors and stepping stones that connect them and areas identified by local partnerships for habitat restoration or creation

Promote the preservation restoration and re-creation of priority habitats, ecological networks and the protection and recovery of priority species populations linked to national and local targets and identify suitable indicators for monitoring biodiversity in the plan

Comments and suggested amendments:

We welcome the inclusion of strong policy regarding the requirement to provide wildlife corridors and inter-connected habitats for wildlife. This aids the provision of gains for biodiversity to adapt to climate change and bolster genetic exchange and viability of habitats and species into the future.

Natural England would like to see more emphasis on the health and wellbeing benefits that multifunctional networks of natural habitats bring. Access to nature has a positive impact on health and wellbeing and such networks can provide such positive impacts. Natural England would advise that the importance of access to nature is included in this section. Furthemore strategies such as the Blue Ribbon which include cycleways, recreation and biodiversity can if appropriately managed, provide truly multifunctional access to the natural environment.

We support the inclusion of ecology as the priority when managing SINCs.

We also support the cited greening of the area via roof gardens etc. Green roofs can do much to improve the biodiversity of an area especially ones which contain a high proportion of built infrastructure. Allotments for example can also benefit wildlife and nature conservation.

Please do not hesitate to contact me should you wish to discuss the above in more detail.

Yours sincerely

Rebecca Pearson Lead Adviser Land Use Services Team Tel: 0300 060 4090

From: Faux, Sarah On Behalf Of CCT Contact Sent: 15 June 2012 11:13 To: O'Donnell, Lisa Subject: RE: Westminster City Council Core Strategy Revisions consultation

Dear Lisa,

Thank you for your email of 1st May inviting this office to comment on revisions made to Westminster City Council’s Core Strategy.

I can confirm that the Office of Rail Regulation (ORR) does not have any comments to make on the revisions.

Thank you for contacting ORR.

Yours sincerely

Sarah Faux Customer Correspondence Team Office Of Rail Regulation (ORR)

BEW/ Plan/ 08/06/12

8th June 2012

Mrs.Lisa O’Donnell Special Planning Manager LDF Team Westminster City Council 64 Victoria Street London SW1E 6QP

Dear Mrs O’Donnell

St James’s Conservation Trust- Revisions to Westminster’s Core Strategy Reference: Cllr Robert Davis’ letter dated 1st May 2012

Please find at Appendix ‘A’ the Trust’s response to the City Council’s consultation

Yours sincerely

Brian Woodham Administrator to the St James’s Conservation Trust

Appendix ‘A’ Response to the consultation.

Cc: Cllr Louise Hyams Cllr Tim Mitchell Cllr Cameron Thomson

Appendix ‘A’: St James’s Conservation Trust Revision to Westminster’s Core Strategy Response to the City Council’s consultation.

General

1 Set out below is the St James’s Conservation Trust response to the City Council’s consultation which includes comments on:-

The NPPF The Core Strategy The draft CMP The draft SPG for entertainment uses in St James’s

2 The NPPF: The Trust acknowledges the economic, social and environmental factors on which the NPPF depends and which are interdependent. The core area of St James’s has a unique and special character which means that the amount of weight that can be given to any one of these factors will depend on the character of its area. There are many references in the NPPF to neighbourhood plans and the Trust believes they could be most useful for explaining the special character and planning needs of a small distinct area such as the core area of St James’s. Although the Trust is presently investigating the possibility of setting up a neighbourhood forum in St James’s, this cannot proceed until funds becomes available to finance it.

3 The Trust has no further comments to make on the Core Strategy beyond those it made for its consultation. It is acknowledges the significant benefits resulting from the introduction of the St James’s Special Policy area which has been expanded in the draft City Management Plan. The Trust can see scope for expanding the St James’s SPA to include planning protection against the cumulative impact of A3, A4 and A5 uses in St James’s and this will be explained below.

4 The Trust is generally content with the draft CMP except for the lack of protection for St James’s against inappropriate applications for A3 and A4 uses set out in the draft November 2011 CMP compared to the protection afforded by the January 2011 draft CMP and requests the protection set out in the January 2011 version is reinstated in the final version. . 5 The 2006 draft SPG for Entertainment Uses in St James’s is a good example of the planning protection needed in this fragile area. In 2009, it learnt that the SPGs would become Supplementary Planning Documents. However, it not clear, since the introduction of the NPPF, whether or not SPDs will still be produced

National Planning Policy Framework (NPPF)

6 The three dimensions to sustainable development, which are the key stones to the NPPF, cannot be considered in isolation because they are mutually dependent.(8) These three dimensions are set out in full below to highlight parts of each that are commendable and other parts which might be difficult to implement in St James’s because of local factors:-

An economic role- contributing to building a strong, responsive and competitive economy, by ensuring that sufficient land of the right type is available in the right places and at the right time to support growth and innovation; and by identifying and coordinating development requirements, including the provision of infrastructure.

Comments Sufficient land for development There are no conventional brown-field sites in the core area of St James‟s. However, there are unlisted buildings that could be demolished for new developments. The Trust would encourage this sort of development provided such a building is not a building of merit and that the replacement building was built in accordance with the 8 principles in the Trust‟s Study “Architecture suitable for St James‟s. 2008”.

Provision of infrastructure The finance sector in St James‟s, including the Hedge Fund managers, makes a significant contribution to the country‟s economy and require modern services to operate effectively. These services include water, electricity, telephone, fibre optic broad band and some are inadequate in St James‟s. For example, in May 2012, UK PN had to dig up a large part of Jermyn Street to enable electricity to be fed into „St James‟s Gateway‟, the new Crown Estate development. Progress was hindered because of a plethora of badly mapped services in Jermyn Street.

A social role-supporting strong, vibrant and healthy communities, by providing the supply of housing required to meet the needs of present and future generations; and by creating a high quality built environment, with accessible local services that reflect the community’s needs and support its health, social and cultural well-being.

Comment It is a major desire of the St James‟s Conservation Trust that there should be an increase in the residential population within the core area of St James‟s, even to the detriment of other uses. A neighbourhood plan would be useful for demonstrating the special character of the area where the price of residential property and rental values are amongst the highest in London and wealthy people who are attracted to the area depend on high quality retailers and restaurants. Conversely, housing and shops for people of lesser means are not available in St James‟s.

An environmental role-contributing to protecting and enhancing our natural, built and historic environment, and, as part of this, helping to improve biodiversity, use natural resources prudently, minimise waste and pollution, and mitigate and adapt to climate change including moving to a low carbon economy

Comment

The Trust commends this statement. Westminster has some of the poorest air quality in the country (Core Strategy Section 5.29) and St James‟s is not immune from this problem. Figure 44 in the Core Strategy indicates that, for St James‟s, the 2010 modelled annual average pollution exceedances for Nitrogen Dioxide was about 45-52 microgrammes per cubic metre and for particulates was 26.3-28 mirogramme per cubic metre. However, by main roads it was much higher. Even the lower figures indicate a serious health hazard in St James‟s.

The core area of St James‟s benefits greatly from having Green Park on its western side and St James‟s Park on its southern side. These wide open spaces, together with St James‟s Square garden act as the lungs of St James‟s and provide a rich and varied bio-diversity.

The Trust has commissioned a new study entitled “St James’s Rooftop Study” which will investigate the mechanical plant on rooftops which contributes to aspects of environmental and noise pollution in the area.

7. Pursuing sustainable development involves seeking positive improvements in the quality of the built, natural and historic environment, as well as in people’s quality of life, including:-

Replacing poor design with better design.(9)

Comment: The Trust commends this statement

8 All plans should be based upon and reflect the presumption in favour of sustainable development, with clear policies that will guide how the presumption should be applied locally. (15) The application of the presumption will have implications for how communities engage in neighbourhood planning.(16)

Comment: The Trust is considering forming a Neighbourhood Forum, However, it is aware of the need for staff to manage a forum and to draft a Neighbourhood Plan but cannot proceed until finance is available from the Department of Communities and Local Government.

9. Among the 12 core planning principles is:-

Conserve heritage assets in a manner appropriate to their significance, so that they can be enjoyed for their contribution to the quality of life and future generations.(17)

Comment. The Trust commends this statement

10 Promoting sustainable transport . This includes the statements:-

Give priority to pedestrian and cycle movements, and have access to high quality public transport facilities.(35)

Create safe and secure layouts which minimise conflicts between traffic and cyclists or pedestrians, avoiding street clutter….(35)

Comment. The Trust commends these statements.

11 Planning policies and decisions should aim to ensure that developments inter alia :-

Respond to local character and history, and reflect the identity of local surroundings and materials, while not preventing or discouraging appropriate innovation.(58)

Are visually attractive as a result of good architecture and appropriate landscaping.(58)

Comment. The Trust commends this statement,

12 Although visual appearance and the architecture of individual buildings are very important factors, securing high quality and inclusive design goes beyond aesthetic considerations. Therefore, planning policies and decisions should address the connections between people and places and the integration of new development into the natural, built and historic environment.(61)

Comment. The Trust considers the design of a building, in the core area of St James‟s, should be in accordance with the eight principles set out in the Trust‟s document “ Architecture suitable for St James’s” 2008.

13 Conserving and enhancing the historic environment. Local planning authorities should set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats. In doing so, they should recognise that heritage assets are an irreplaceable resource and conserve them in a manner appropriate to their significance. In developing this strategy, local planning authorities should take into account inter alia:-

The desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation.

The wider social, cultural, economic and environmental benefits that conservation of historic environment can bring.(126)

The desirability of new developments making a positive contribution to local character and distinctiveness.(126)

Opportunities to draw on the contribution made by the historic environment to the character of the place. (126)

Comment: The Trust commends these statements.

14 In determining planning applications, local planning authorities should take account of:-

The desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation.(131)

The positive contribution that conservation of heritage assets can make to sustainable communities including their economic vitality.(131)

The desirability of new development making a positive contribution to local character and distinctiveness,(131)

Comments. The Trust commends these statements.

The City Management Plan (CMP)

14 A3 and A4 uses. The Trust has studied the draft CMP dated January 2011 and the draft CMP dated November 2011 and regrets that the November 2011 version provides weaker protection from entertainment uses. The relevant policies in the January 2011 CMP are set out below:-

Policy Option 22.7: Restaurants, cafes and other A3 Uses. Policy Option 22.10: Pubs, Bars and other A4 Uses These policies referred to A3 and A4 uses in the St James‟s SPA.

15 These have been removed from the November 2011 draft CMP and replaced by paragraph1.5.19 which includes the sentence “There are areas adjoining stress areas, such as the core area of St James’s, which may experience pressure for growth in entertainment uses, and will therefore be kept under review” Comment; The Trust considers the January 2011 CMP provided strong protection against inappropriate A3 and A4 uses whereas the November 2011 CMP statement is considered weak and likely to provide little protection. It is most important for the protection of the core area of St James‟s against inappropriate applications for A3 and A4 uses that the January 2011 CMP version is used in the final version of the CMP.

16 St James’s Special Policy Area (SPA) The core area of St James’s is vulnerable from applications for inappropriate A3 and A4 uses and recommends that the St James’s SPA is amended to include “ A3 and A4 Uses- cumulative impact. No further A3 or A4 Uses will be permitted in the SPA where a saturation of either of these uses would occur if more were permitted”,

Supplementary Planning Guidance 17 The Trust recommends that Draft Supplementary Planning Guidance: Entertainment Uses 4.2 St James’s dated 26th July 2006 is completed as a Supplementary Planning Document to support the policy approach set out in the Core Strategy and developed in more detail in the CMP in accordance with the City Council’s letter dated 5th November 2009.

LDF Team Thames Water Property Services City Planning Development Unit Your ref Our ref LA9/WS/8/DMD/Options Sent by email: [email protected] Name Carmelle Bell Phone 0203 577 7799 E-Mail townplanningpolicy@thameswater. co.uk

15 June 2012

Dear Sir/Madam

Revisions to Westminster City Council’s Core Strategy

Thank you for advising Thames Water of the City Council‟s intention to revise its Core Strategy (adopted in January 2011) and for inviting comments on what the revised document should contain as the Local Plan for the City of Westminster.

The proposed revisions are as a result of the recently published National Planning Policy Framework (NPPF), the London Plan 2011, and will also incorporate the policies from the draft City Management Plan (CMP). We trust that the following comments are useful and will be taken into consideration by the City Council when revising its Core Strategy.

National Policy Statements and the National Planning Policy Framework

As you are aware, we are proposing a construction site for the Thames Tunnel within the City of Westminster on the Victoria Embankment. The Thames Tunnel is needed to significantly reduce the amount of untreated sewage overflowing into the River Thames as a result of the existing overloaded Victorian sewerage system.

The National Policy Statement (NPS) for Waste Water has now been designated (March 2012) and sets out Government policy for the provision of major waste water infrastructure. It will be used by the Planning Inspectorate and the decision makers (the relevant Secretaries of State) as the primary basis for considering and determining Development Consent Order applications for waste water developments that fall within the definition of Nationally Significant Infrastructure Projects (NSIP), as defined in the Planning Act 2008 (the Act).

The Government has recently laid before Parliament an Order made under Section 14(3) of the Act. An effect of the Order is that, owing to the significance

Page 1 of 4

Page 2

of the Thames Tunnel project, development consent for the project will be dealt with under the Act. .

The Thames Tunnel project is included in the NPS as a nationally significant project for which need has been demonstrated as detailed in Section 2.6 of the NPS. Once the Order is made and the Thames Tunnel project is brought within the direct scope of the Act the Planning Inspectorate and Secretary of State will determine the application for development consent for the Thames Tunnel in accordance with the NPS unless one of a limited number of exceptions to that position apply (see section 104(3) of the Act). Chapter 4 of the NPS details the generic impacts of nationally significant waste water infrastructure.

It is important to recognise that that there is a particular planning process that applies to NSIP‟s which needs to be reflected in the way in which local policy is framed and applied.

The NPPF states – ‘National policy statements form part of the overall framework of national planning policy’ (paragraph 3). It also states – ‘Local planning authorities should work with other authorities and providers to: take account of the need for strategic infrastructure including nationally significant infrastructure within their areas’ (paragraph 162).

With regards to plan making, paragraph 178 of the NPPF states that „Public bodies have a duty to cooperate on planning issues that cross administrative boundaries, particularly those which relate to the strategic priorities set out in paragraph 156.‟ Paragraph 156 includes the provision of infrastructure for waste water.

The NPPF also states in relation to Local Plans – ‘Local planning authorities will be expected to demonstrate evidence of having effectively cooperated to plan for issues with cross-boundary impacts when their Local Plans are submitted for examination. This could be by way of plans or policies prepared as part of a joint committee, a memorandum of understanding or a jointly prepared strategy which is presented as evidence of an agreed position. Cooperation should be a continuous process of engagement from initial thinking through to implementation, resulting in a final position where plans are in place to provide the land and infrastructure necessary to support current and projected future levels of development’ (paragraph 181).

In the light of paragraphs 3, 178 and 181 of the NPPF, it is clear that the Council needs to demonstrate how it has co-operated on the progression of the Development Consent Order for the Thames Tunnel. Existing policy CS45 could therefore be slightly adjusted to read as follows

Page 3

“The Council will work with Thames Water and the relevant other planning authorities to support the timely implementation of the Thames Tunnel project, including the connection of combined sewer overflows in the city"

It is suggested that the supported text could make reference to the Memorandum of Understanding the Council has entered into with Thames Water and to the regular meetings which have taken place between the Council and Thames Water to discuss planning consents and other associated matters.

Draft City Management Plan

We note that Thames Water have responded to two stages of consultation on the draft City Management Plan (CMP) (letters dated 1st March 2011 and 11th April 2012). It is understood that all previous representations received on the draft CMP are considered by the City Council to still apply and will be taken into account as it is incorporated into the Core Strategy.

In the previous response letters we made representations on several items including the following.

Air Quality – seeking clarity on Air Quality assessment; Blue Ribbon Network – seeking policy support for the Thames Tunnel and recognition of the National Policy Statement (NPS) for Waste Water; Heritage - in support of the creation of additional locations to view and appreciate the World Heritage Site Planning Obligations – with regards to Thames Tunnel being essential infrastructure funded by the bill payer and therefore not appropriate for an additional levy; Public Art – considered unreasonable for the project to contribute 1% for public art due to the project being funded by the bill payer; Road improvements – regarding planning obligations for road improvements being required only when directly related to the development; and Views – in support of the provision of additional locations to appreciate the World Heritage Site.

We would like to reiterate our previous comments on the following points:

Blue Ribbon Network / NPS

Draft Policy CMP 6.10: Development built into or over the Blue Ribbon Network (City Management Plan Consultation Draft November 2011)

We welcome the recognition in the draft policy that the Thames Tunnel proposals may be an acceptable form of development in or over the Blue Ribbon Network,

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given the support for the Thames Tunnel project in the London Plan and in Core Strategy Policy CS45.

The accompanying text, paragraph 6.3.12, includes the caveat “only if the strategic justification is sufficient to rule out other options”. However the Waste Water NPS has since been published and states on page 8:

“The examining authority and the decision maker should start its consideration of any applications submitted to it relating to these two projects on the basis that the strategic need for improvements at Deephams and the combined sewer overflows into the Thames has been demonstrated.”

The NPS constitutes the strategic justification and therefore the policy and accompanying text should not introduce any different or additional requirement in this regard. We would therefore request that the second sentence is altered to read:

Development required for strategically agreed major water‐related infrastructure, such as proposals to implement the Thames Tunnel project, will be acceptable, subject to suitable mitigation works and suitable strategic justification such as a designated National Policy Statement.

Planning Obligations

Draft Policy CMP 7.1: Planning Obligations (City Management Plan Consultation Draft November 2011)

It is requested that essential infrastructure funded by the bill payer is not subject to additional costs except to mitigate direct impacts. This should also apply to public utilities which are funded by the bill payer.

We trust the City Council will take account of our comments when preparing its Core Strategy. Please do not hesitate to contact me should you require further details about Thames Water‟s activities including the Thames Tunnel project.

Yours faithfully

Mark Mathews Town Planning Manager Thames Water Property Services

From: Rose Freeman Sent: 30 May 2012 15:00 To: LDF Subject: CMP Revision

Our Ref.: RF/4255

CMP Revision

Thank you for your email of 1 May consulting the Theatres Trust on revisions to the City Management Plan before incorporation into the Core Strategy to make a new document – the Local Plan for Westminster.

We suggest the whole of section 1.4 Tourism, Arts and Culture be transferred from the CMP to the Core Strategy to provide fully comprehensive guidelines for this topic and including our comments made in March this year regarding Policy 1.27 Theatres.

Remit: The Theatres Trust is The National Advisory Public Body for Theatres, safeguarding theatre use or the potential for such use; we provide expert advice on integral new theatre design, heritage, property and planning. Established by The Theatres Trust Act 1976, we exist to ‘promote the better protection of theatres’. The Trust delivers statutory planning advice on theatre buildings and theatre use in England through The Town and Country Planning (Development Management Procedure) (England) Order 2010 (DMPO), that requires the Trust to be consulted on planning applications which include ‘development involving any land on which there is a theatre.’ The Act defines a theatre as ‘any building or part of a building constructed wholly or mainly for the public performance of plays’, and therefore applies to theatres, playhouses, arts centres, ciné-varieties or buildings converted for theatre use, old and new, in other uses or disused. We are also a consultee on Neighbourhood Development Orders and Community Right to Build Orders, and encourage local authorities, parish councils and local groups to consult the Trust on Local and Neighbourhood Development Plans.

Rose Freeman Planning Policy Officer The Theatres Trust 22 Charing Cross Road London WC2H 0QL Tel: 020 7836 8591 Fax: 020 7836 3302 [email protected]

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Learn more about theatres with our online resource 'Exploring Theatres' Check out your local theatre on The Theatres Trust 'Theatres database'

*************************************************************************************************** The contents of this email are intended for the named addressee(s) only. It may contain confidential and/or privileged information, and is subject to the provisions of the Data Protection Act 1998. Unless you are the named addressee (or authorised to receive it for the addressee you may not copy or use it, or disclose it to anyone else. If you receive it in error please notify us. From: Fielding Katie Sent: 13 June 2012 11:52 To: LDF Subject: Westminster City Council Core Strategy Revisions consultation

Dear Lisa,

I apologise for the delay in responding to the consultation above, please find my response below.

The Planning Advisory Service (PAS) has produced a checklist to help Local Planning Authorities assess the content of their local plans against requirements in the NPPF. TfL therefore would encourage the Council to use this tool to assess whether its Local Plan is in compliance with the NPPF. A schedule of changes could be produced to outline any alterations. At the heart of the NPPF is a presumption in favour of sustainable development, which should be seen as a “golden thread” running through both plan making and decision taking. The NPPF sees three mutually dependent roles for the planning system: an economic role; a social role; and an environmental role.

Promoting Sustainable Transport

NPPF states that in preparing Local Plans, local planning authorities should support a pattern of development, which where reasonable to do so, facilitates the use of sustainable modes of transport (para. 30). Therefore Strategic Policy should focus on promoting sustainable travel and making sure all development is properly integrated with all forms of transport.

TfL would expect Westminster to develop strategies that support the London Plan and the Mayor’s Transport Strategy in order to support sustainable development. In addition Local plans may also need to safeguard land for transport in order to meet the Mayor’s strategic policy objectives in order to be consistent with the NPPF.

The NPPF also requires the use of Transport Statements, Assessments and Travel Plans for development to establish: the opportunities for sustainable modes of transport; access for all; and improvements to the transport network that limit the significant impacts of development. For large-scale residential development in particular, mixed use development should also be promoted.

The NPPF states that local parking standards are optional. TfL expects parking standards to be in line with London Plan standards or promotes higher levels of cycle parking or lower cars parking levels. When setting standards, local planning authorities should take into account, the accessibility of the development; the type, mix and use of the development; the availability of and opportunities for public transport; local car ownership levels; and an overall need to reduce the use of high-emission vehicles.

CORE STRATEGY REVISIONS TO TAKE ACCOUNT OF THE NATIONAL PLANNING POLICY FRAMEWORK PUBLISHED 27th MARCH 2012

Lisa O’Donnell Email [email protected]

Westminster City Council,

City Hall, Victoria Street,

London SW1E 6QP

Thank you for inviting suggestions for necessary revisions to City Council’s Core Strategy and to the City Management Plan to take account of the NPPF.

I have already suggested revisions to the City Management and a brief list of policy points within the NPPF which support these suggested revisions follows on page 2.

I believe the NPPF, through its definition of sustainability and the emphasis given all three aspects (at 8) of this definition, ‘These roles should not be taken in isolation, because they are mutually dependent.’ and at 9 where quality of life is emphasised, allows some of the concerns which are voiced in Westminster City Council’s Core Strategy to be given more clarity and emphasis.

Concerns City Council, rightly, raises reflect the physical and environmental effects of over-crowding and over intense and inappropriate development. The need to avoid the risk of flooding from surface water and sewage (Core Strategy 5.21). The recognition that Westminster already has some of the poorest air quality in the country (5.28).The note policy takes of the conflict between the large percentage of its residential provision which serves London’s status as a ‘world city’ (accommodation that is largely left empty or only intermittently occupied) and the requirement for long term residential, affordable and key worker housing provision of a high standard.

The NPPF ( point 19) suggests that the planning system should ‘do everything it can’ to support economic growth. Gus O’Donnell in his speech at the LSE on 1st May noted that ‘Every time there is a recession… there is a call for more ‘structural reforms’ Top of the list is always the planning system. It is blamed for holding back growth and development.’ This he sees as a failure of government, an example of lack of clarity about the precise outcome desired. If the aim is’ to boost GDP the South East can be concreted over’. But that is not what is wanted. His remarks suggest a conservative interpretation of NPPF point 19.(The Government is committed to ensuring that the planning system does everything it can to support sustainable economic growth…encourage…not act as an impediment to sustainable growth.) He suggests recognition that unrealistic expectations of the economic effect of placing ‘significant weight’ on achieving growth through the planning system are not in order

The Core Strategy already hints at this, despite its nods to growth and its acceptance of projections for population increase in London, in its recognition that successful and popular places can, without careful management, become stress areas. Core Strategy Page 101 states ‘growth ‘in the Westminster context means mixed use areas and sites, infill development and high density living. ’ The risks are low quality accommodation, increasing waste disposal problems and the issues suggested above: a fine balance needs to be maintained which the tripartite definition of sustainable development recognises. The Core Strategy shows an awareness of the exceptional nature of the City of Westminster, home to the institutions of national government and the responsibilities this brings. This exceptional character can be seen as a material consideration, in NPPF terms, in decisions relating to density and growth as well as to heritage.

City Council can find support for the retention of open spaces in the NPPF paragraph 17 (unnumbered point 9) which recognises that ‘open land’ is not simply a development opportunity but may ‘perform many functions.’ This supports my comment on page 7.

Heritage

The strengthened sections on Heritage in the NPPF necessitate a clear and unambiguous amendment of those sections of the City Management Plan. The idea of irreplaceability and recognition of the requirement to take the long view, suggest that, in order to comply, policy should be revised. Point 133 is especially important as it is made clear that all four points listed are to be understood as applying.

The NPPF and my consultation response to the Draft City Management Plan

The NPPF definition of sustainable development with its equal emphasis on the economic role, the social role, and the environmental role which are stated to be ‘mutually dependent’ is exemplified in my remarks made under General Points, likewise responding to the City Management Plan’s section on Sustainable and Unique Place, Tall buildings and Views.

My comments on Design (my page 4) find support in NPPF paragraph 60, and 61.My comments on Heritage can be supported with reference to NPPF paragraphs 126-128 and 131,132,133 and 139.

My Detailed Comments point to the close connection between environmental issues and housing quality, especially my comments, page 7, on New infill and large scale development also finds support.

I hope these comments clarify some ways in which City Council’s Core Strategy and City Management Plan, as they stand could be seen not to comply fully with the National Planning Policy Framework. This government policy remains, of course, to be tested at appeal.

Best wishes,

Verina Glaessner

Westminster City Hall, 64 Victoria Street, London SW1E 6QP Planning helpline: 020 7641 2513 www.westminster.gov.uk/ldf