London Plan 2019 Inspector's Report
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Report to the Mayor of London by Roisin Barrett BSc (Hons) MSc Dip UD Dip Hist Cons MRTPI IHBC William Fieldhouse BA (Hons) MRTPI and David Smith BA (Hons) DMS MRTPI Members of the Panel appointed by the Secretary of State Date: 8 October 2019 Greater London Authority Act 1999 (as amended) Part VIII Report of the Examination in Public of the London Plan 2019 The Examination in Public was held between 15 January 2019 and 22 May 2019 File Ref: PINS/SDS0026 London Plan Examination in Public: Panel Report October 2019 Contents Page Abbreviations used in the report 4 Non technical summary 5 Introduction 6 • The draft new London Plan and the Mayor’s minor and further 6 suggested changes • Examination in public and Panel recommendations 6 • National planning policy 7 Legal, Procedural and General Matters 9 • Cooperation and public participation 9 • Sustainability appraisal 11 • Habitat regulations assessment 12 • Equality of opportunity 13 • Climate change 14 • Spatial Development Strategy 15 Assessment of Soundness 19 • Vision, objectives and Good Growth 19 • Resources, viability and delivery 21 • Strategic approach to accommodating development 25 • Wider south east 28 • Opportunity Areas and Regeneration Areas 30 • Housing need 33 • Housing and Good Growth 34 • Housing targets 35 • Gypsy and traveller accommodation 43 • Affordable housing 45 • Other housing policies 49 • Housing quality and standards 58 • Design policies 60 • Heritage and culture policies 71 • Social infrastructure policies 75 • Central Activities Zone 81 • Town centres, retail and other main town centre uses 83 • Industrial development 88 • Freight 91 • Low cost and affordable business space 92 • Green infrastructure policies 94 • Green Belt and Metropolitan Open Land 96 • Zero carbon city, air quality and water infrastructure 99 • Digital connectivity infrastructure 102 • Waste management 102 • Aggregates 106 • Hydraulic fracturing 108 2 London Plan Examination in Public: Panel Report October 2019 • Flood risk management 108 • Waterways 110 • Transport schemes and car and cycle parking 113 • Aviation 120 • Monitoring implementation of the Plan 122 • Future review of the Plan 123 • Next steps before the Plan is published 124 Overall Conclusion and Recommendation 125 Appendix: Panel Recommendations The Examination Library contains numerous documents submitted by the Mayor and representors along with those issued by the Panel. Where necessary, reference is made in this report to relevant documents by their unique number (for example NLP/CD/1, NLP/EX/7.3, NLP/AD45, etc). 3 London Plan Examination in Public: Panel Report October 2019 Abbreviations used in this report 2004 Act Planning and Compulsory Purchase Act 2004 2011 Act Localism Act 2011 AMR Annual monitoring report ANPS Airports National Policy Statement Assembly Greater London Assembly CAZ Central Activities Zone including Isle of Dogs (north) EELGA East of England Local Government Association FALP Further Alterations to the London Plan GLA Greater London Authority GLA Act The Greater London Authority Act 1999 (as amended) HMA Housing Market Area HRA Habitats Regulations Assessment IIA Integrated Impact Assessment for the draft new London Plan (November 2017) and Addendum (July 2018) KPI Key Performance Indicators LDS Local Development Scheme Local plan Any development plan document adopted under the 2004 Act LPVS London Plan Viability Study and Technical Report (December 2017) and Addendum (November 2018). LSIS Locally significant industrial sites LVMF London View Management Framework Mayor The Mayor of London MDC Mayoral Development Corporation MHCLG Ministry of Housing, Communities and Local Government MTS Mayor’s Transport Strategy MOL Metropolitan Open Land NPPF National Planning Policy Framework OAN Objectively assessed need (for housing) OLC Outer London Commission PPG Planning Practice Guidance PPTS Planning Policy for Traveller Sites PSED Public Sector Equality Duty PTAL Public transport access level (0-6, a higher number indicating better access to the public transport network) Regulations The Town and Country Planning (London Spatial Development Strategy) Regulations 2000 RFRA Regional Flood Risk Appraisal SA Sustainability Appraisal SCI Statement of Community Involvement SEEC South East England Councils SHLAA Strategic housing land availability assessment SHMA Strategic housing market assessment SIL Strategic industrial locations SINC Sites of Importance for Nature Conservation VBC Vacant Building Credit WHS World Heritage Site WMS Written Ministerial Statement 4 London Plan Examination in Public: Panel Report October 2019 Non-Technical Summary This report concludes that the draft new London Plan published for public consultation in December 2017 provides an appropriate basis for the strategic planning of Greater London provided that it is amended to reflect the Mayor’s minor suggested changes (August 2018), the Mayor’s further suggested changes (July 2019), and our recommendations set out in this report. Our recommendations, which are set out in full throughout the report and listed in the attached Appendix, can be summarised as follows: • Include all minor and further suggested changes unless otherwise recommended in this report. • Reduce the ten year small site housing targets for boroughs to give a total of 119,250 dwellings (rather than 245,730) and as a consequence reduce the overall housing targets for boroughs to give a total of 522,850 dwellings (rather than 649,350). • Delete the Mayor’s further suggested change policy H2A small housing developments. • Add to reasoned justification to policy H2 to clarify that borough small site targets can be taken to amount to a reliable source of windfall sites. • Delete policy H9, in relation to the disapplication of the vacant building credit. • Delete part C of policy H12 in relation to boroughs setting prescriptive area wide dwelling size mix requirements for market and intermediate housing. • Delete part B of policy H16 relating to boroughs undertaking gypsy and traveller accommodation needs assessments and add reasoned justification setting out a commitment for the Mayor to lead a London-wide assessment as part of the next review of the London Plan. • Add reasoned justification to policy G2 to refer to the Mayor leading a strategic and comprehensive review of the Green Belt in London as part of the next review of the Plan. • Modify policies G2 and G3 relating to Green Belt and Metropolitan Open Land so that they are consistent with national policy. • Before finalising the Plan, the Mayor should give further consideration to the categorisations of boroughs in Table 6.2 (management of industrial floorspace) to provide a more positive strategic framework for the provision of industrial capacity. • Add reasoned justification to policy E4 to refer to boroughs considering whether the Green Belt in their area needs to be reviewed to provide additional industrial capacity, and also to refer to consideration being given to identifying locations for industrial development as part of a future London-wide Green Belt review. • Delete policy SI11 hydraulic fracturing (fracking). • Delete policy T8 airports, and add northwest runway at Heathrow Airport to Table 10.1 (indicative list of transport schemes). • Reduce the cycle parking requirements for specialist older persons accommodation and purpose built student accommodation. • Modify policy DF1 to make it clear that the requirements relating to site specific viability assessments only apply where relevant policies in local plans are up to date. • Modify various other parts of the Plan to ensure that it is effective, justified and consistent with national policy. 5 London Plan Examination in Public: Panel Report October 2019 Introduction 1. This is our report following the examination in public (“examination”) of the London Plan held in accordance with the terms of the Greater London Authority Act 1999 (as amended) (“GLA Act”) and the Town and Country Planning (London Spatial Development Strategy) Regulations 2000 (“the Regulations”). The draft new London Plan and the Mayor’s Minor and Further Suggested Changes 2. The London Plan is the statutory spatial development strategy for Greater London prepared by the Mayor of London (“the Mayor”) in accordance with the GLA Act and Regulations. The Mayor published a draft new London Plan, which looks ahead to 2041, for public consultation in December 2017. The consultation period ended on Friday 2 March 2018 by which date over 20,000 representations had been received from around 7,400 individuals and organisations. 3. In response to those representations, and to improve clarity and update matters of fact, the Mayor published “minor suggested changes” to the draft London Plan on 13 August 20181. A consolidated version of the Plan, incorporating all of those minor suggested changes was published in August 20182. This was the version of the Plan that we based our matters upon and was discussed at the hearing sessions. 4. Further changes to the Plan were suggested by the Mayor during and following the examination hearing sessions in accordance with procedures that we set out in one of our Panel Notes3. A comprehensive schedule of all of the Mayor’s further suggested changes, along with a further consolidated version of the Plan incorporating all of the minor and further suggested changes, were published in July 20194. Other than where we indicate to the contrary elsewhere in this report, we consider that all of the Mayor’s minor and further suggested changes help