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London Borough of Hammersmith and Fulham

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London Borough of Hammersmith and Fulham London Borough of Hammersmith and Fulham Representations to the Proposed Submission Local Plan Regulation 19 Consultation (including Council responses) 16th September to 28th October 2016 Contents 1. General………………………………………………………………………...1-72 2. Introduction & Hammersmith and Fulham………………………………..73-89 3. Spatial Vision & Strategic Objectives……………………………….........90-101 4. Delivery & Implementation………………………………………………102-105 5. Regeneration Area Strategies…………………………………………..106-185 6. Meeting Housing Needs & Aspirations……………………………….. 186-235 7. Economy & Employment……………………………………………….. 236-250 8. Town & Local Centres………………………………………………….. 251-273 9. Community Facilities, Leisure & Recreation…………………………..274-286 10. Green & Public Open Space…………………………………………….287-306 11. River Thames……………………………………………………………..307-319 12. Design & Conservation…………………………………………………..320-339 13. Environmental Sustainability…………………………………………….340-363 14. Transport & Accessibility…………………………………………………364-375 15. Planning Contributions & Infrastructure………………………………...376-381 16. Glossary……………………………………………………………………382-383 17. Appendices………………………………………………………………...384-389 1. General No. Name/Org Section Comments Suggested amendments by representor Officer response Map AD5 Parsons Green Lane Neighbourhood Parade Comments have been noted. There is no evidence base to support this suggested This designation should extend beyond the bridge to the transition. Parsons Green The draft Plan does not meet the test of soundness as it is not effective in meeting Proposed north and include the retail shops and cafes on the west Depot Tenants the local needs of small business enterprises and privately run facilities that meet a Submission of Parsons Green Lane and 31 Parsons green Lane on the and the community need which were identified in the evidence base. Furthermore the No change required. 111 Local Plan east (see map below). These properties make an Andrew chosen strategies do not reflect all the options available to the Borough to protect September important contribution to the neighbourhood and it is Robson Bridge these uses even though they are acknowledged as making an important contribution 2016 perverse that they are not included within this designation Club to the social and economic well being of the Borough. as they meet all the tests described within the draft plan and should be afforded the same protection for parades as defined under policy TLC4. On pages 115 &116 of the Sustainable document Policy CF1 Supporting Community Comments noted. Facilities and Services there would appear to be some serious contradictory observations when it comes to para (4) Supporting the continued presence of major No change required. public football, particularly when it is stated later in the sustainability documents that 'In general the proposed policy is considered to have a neutral impact on sustainability objectives' For example in the CF1 table it is deemed the football clubs get ticks for contributing to: Social Equity Mr Proposed Submission Health 115 Nicolas Local Plan Education and Skills September Crosthwaite 2016 Social Cohesion Satisfying Work Heritage Sustainable Economy This seems to be at odds with the conclusion reached in CF4 I look forward to receiving any comments you may have to the above 1 No. Name/Org Section Comments Suggested amendments by representor Officer response Evidence base Comments have been noted. These issues have been addressed in the relevant The NPPF requires each Local Plan to address the spatial implications of economic, chapters. However, the council are satisfied social and environmental change based on an adequate, up-to-date and relevant that the Parks and Open Spaces Strategy and evidence base. The NPPF, at paragraph 73, requires that: the open space audit, together with other studies carried out on an annual basis to “Planning policies should be based on robust and up-to-date assessments of the review the boroughs stock of open space needs for open space, sports and recreation facilities and opportunities for new gains and losses are sufficient in identifying provision. The assessment should identify specific needs and quantitative deficits or demand. Some amendments have been surpluses of open space, sports and recreational facilities in the local area.” To overcome the objections raised Sport England made to the text within the Community facilities chapter to clarify this point. Sport England acknowledges the Sports and Physical Activity Strategy but does not recommend that the Council develop Playing Pitch and consider this to be a robust and up-to-date assessment of the supply and demand of Built Facility Strategies to establish a clear and robust sport and recreation facilities and opportunities for new provision. The document evidence base and strategy for playing pitches and built sport facilities and revise the Community Facilities and Proposed does not appear based on a thorough and collaborative assessment of current and Services Policy to fully reflect Sport England’s policy to Submission future playing field and built facility supply and demands setting out key protect, enhance and provide. 117 Sport England Local Plan recommendations and actions. In addition, the Sports and Physical activity Strategy September appears at least five years old therefore Sport England considers this document to Sport England also strongly advise the rewarding of the 2016 be out of date. As a result the policies contained in the in the Submission Local Area open space policy, the glossary and references to sport are unsound as they are not fully justified by an up-to-date and robust evidence facilities and the regeneration area policies as explained in base and strategy as required by the NPPF. the preceding text. Sport England would be happy to provide further advice on how the Council can strategically plan for sports facilities. There are a number of tools and guidance documents available, which can be found on Sport England’s website at: http://www.sportengland.org/facilities-planning/planning-for-sport/forward- planning/ . In addition, Sport England has a web based toolkit which aims to assist local authorities in delivering tailor-made approaches to strategic planning for sport. This can be found on Sport England’s website at:http://www.sportengland.org/facilities-planning/planning-for-sport/planning- tools-and-guidance/assessing-needs-and-opportunities-guidance/ 122 Proposed Comment noted. Hammersmith The Society welcomes the format and organisation of the latest document, which is Submission 2 No. Name/Org Section Comments Suggested amendments by representor Officer response Society Local Plan a considerable improvement over the previous split policy documents. The current situation is that the Government September has indicated its support for a third runway 2016 We are pleased to note that many of our suggestions/proposals made at the at Heathrow, but that this is still subject to January 2015 draft stage have been incorporated. further consultation and development of a National Policy Statement. If the third We welcome that much of previous policy texts have been rewritten or laid out in a runway is built, it would not be operational clearer format. until around 2025 so its potential impacts are outside the timescales of the proposed Local We note the extraction since the 2015 draft of the Old Oak and Park Royal area Plan. since it was declared a Mayoral Development Corporation in April 2015 : Our members have continued to take an active role in consultation of matters relating to Should the proposal go ahead, the Council the OPDC, particularly as they affect Hammersmith. will seek comprehensive mitigation measures, including public transport and air We suggest that the Proposed Submission Local Plan and the final Local Plan could quality improvements. benefit form a detailed contents breakdown (or index) with numbering so that it is easy to reference individual policies. No change required. Please can the Proposal Maps be part of the main document as an Appendix? We request that there be a revised borough wide map as part of the Final Plan. We note that there is little reference to the potential effects of the Heathrow expansion in the current draft but we assume that now the Government has made a decision in favour, the Plan will be updated in terms of the potential effects on the A4, the Piccadilly Line and Air Quality in Hammersmith. It would be helpful for the policies to have lettered or numbered bullets for ease of Comments noted. Proposed reference in planning committee reports. Old Oak and Submission Agreed. Amend Paragraph 5.5 – see minor Park Royal 184 Local Plan It would be helpful for the document to include an explanation of the role of OPDC change MC32 Development September as the local planning authority within its boundary. Corporation 2016 Natural Proposed Strategic Environmental Assessment (SEA) Comments noted. 224 England Submission Local Plan Natural England notes that a thorough and detailed SEA has been carried out and 3 No. Name/Org Section Comments Suggested amendments by representor Officer response September has no specific comments to make regarding this assessment. 2016 Should the plan be amended in a way which significantly affects its impact on the natural environment, then, please consult Natural England again. I am responding to the invitations to Peterborough Road & Area Residents' Comments noted. Support welcomed. Association and myself, Mr Anthony Williams, to comment on this updated Plan. Proposed
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