Local Plan scoping consultation responses Review Planning 23 February 2016 All responses received to the Local Plan Review scoping consultation www.richmond.gov.uk/local_plan_review Consultation from 4 January until 1 February 2016 Published by LBRuT on 23 February 2016 Please note, the responses below are exactly as received from the respondents and have not been edited by the Council. They are not alphabetically ordered or in any other order of priority. Respondent Respondent Name / Organisation Name / Organisation reference no. reference no. 1. Caroline Britton Jonathan Stobbart, CBRE obo The Laboratory of 23. 2. S.J Green the Government Chemist 3. Raakhee Patel, Sport England 24. Jan Gare, Ham Library Friends Group 4. Alice Jean Cousens 25. Andy Sutch, Sport Richmond 5. Lucy Owen, Port of London Authority 26. Bryce Tudball, Royal Borough of Kingston 6. Caroline Brock, Kew Society 27. Andrew Barnard 7. Georg Hoefler 28. Margaret Simpson 8. Ian Walton 29. Richard Geary Shahina Inayathusein, London Underground 30. Kevin Rice 9. Infrastructure Protection 31. Laura Morgan 10. Philip Robin 32. Jane Harrisson 11. Juliet Nolan 33. Jane Morrisson 12. Ross Anthony, Theatres Trust 34. Mary Stephens 13. Neil Wilton 35. Paul Lapham 14. Peter Britton 36. Andree Frieze 15. Fiona McDaniel 37. James Sinclair, Teddington Society 16. Bryony Lodge 38. Krystyna Kujawinska, SCAMPS 17. Karen Skipper 39. Max Millington Murray Smith, Dunphys Chartered Surveyors obo 40. Diana Collins 18. St. Clair Business Centre Rebecca Bilfinger, GVA obo Lady Eleanor Holles 41. James Lloyd, James Lloyd Associates obo Tyton School 19. Properties Limited 42. Andrew Dorrian, Transport for London Planning 20. Ham & Petersham Association 43. Alice Shackleton Andrew Payne, Greater London Authority, Mayor of Rebecca Pullinger, Campaign to Protect Rural 21. 44. London England (CPRE) Kevin Scott, Kevin Scott Consultancy obo Port 45. Ron McEwen 22. Hampton Estates Limited (Platts Eyott) 46. Kathleen Massey 47. Paul Massey All responses received on the Local Plan Review scoping consultation 1 Respondent Respondent Name / Organisation Name / Organisation reference no. reference no. 48. Lizabeth Rohovit James Sheppard, CBRE obo CBRE Global 65. 49. Neill Tughan Investors (‘CBREGI’) RPS Planning and development on behalf of S. 66. Joanna Debs, Harlequin Football Club Ltd 50. Oxley 67. Alex Arrol, Goldcrest Land 51. Tim Catchpole, Mortlake with East Sheen Society Robert Mackenzie, RPS obo Richmond-Upon- 68. 52. Dale Nolan Thames College Tor Barrett, Nathaniel Lichfield & Partners obo Steve Simms, SSA obo Kentucky Fried Chicken 53. 69. West London Mental Health NHS Trust (Great Britain) Limited Cllr Martin Elengorn obo Liberal Dem Group of 70. Andree Gregory, Highways England 54. Councillors Pauline Holmes, Natural England (Thames Valley 71. Peter Dowling, Indigo Planning Limited obo Team) 55. Sainsbury’s Supermarkets Ltd Samantha Davenport , Natural England (Dorset 72. 56. Cllr Liz Jaeger Hampshire Isle of Wight) 57. Katherine Jones, Savills obo Thames Water Lucy Gate, Public Health, London Borough of 73. Katie Brown, Nathaniel Lichfield & Partners obo St Richmond upon Thames 58. Mary’s University Greg Pitt, Barton Wilmore obo UK Pacific Hampton 74. Caroline Wilberforce, Indigo Planning Limited obo Station LLP 59. Ashill Land Limited NHS England , NHS Property Services, Healthy Tanja El Sanadidy, Indigo Planning obo Shepherd 75. Urban Development Unit (HUDU) and Richmond 60. Enterprises Limited CCG Louise Spalding, Defence Infrastructure 76. James Togher, Environment Agency 61. Organisation Ann Holdsworth, Amec Foster Wheeler obo 77. Marie-Claire Marsh, Nathaniel Lichfield & Partners National Grid 62. obo Rugby Football Union 78. Katharine Fletcher, Historic England Daniel Osbourne, Barton Wilmore obo Quantum 79. David Shaw, The Alberts Community Association 63. Group 80. Laura Stritch, Transport for London Property Tor Barett, Nathaniel Lichfield & Partners obo The 64. Harrodian School Table 1: All respondents to the consultation All responses received on the Local Plan Review scoping consultation 2 Detailed comments as received: Ref. no. Name / Organisation Detailed comment 1. Caroline Britton I have looked at the consultation document which I received by email today and am very concerned that the St Michael's Convent site has been listed as an area for development - specifically including affordable housing. Given the price of land near Ham Common, it seems that the only way the site could provide an opportunity for affordable housing is if it were high density. This would be completely at odds with the character of the area, which is a precious oasis of green, quiet and tranquillity. The implications for traffic are also serious. I live in Martingales Close which is a cul de sac, bounded down the whole of one side by the brick Convent wall. The Close is a narrow and twisting road, accommodating 27 family houses. The fact that there is no access into the Close from the Convent site keeps traffic to a manageable level and means it is a relatively safe place for children to play. If that were to change, it would drastically alter the environment for all the local residents. I understand the pressures on the Council and accept there has to be some change, but would urge that this has to be in keeping with the nature of the existing area. 2. S.J Green Under the Green Belt Statement that appears in Appendix 1 it should be made clear that, as stipulated by the Examiner and later set out in the Development, Management Plan, the land at Fulwell Golf Club, Twickenham Golf Club, Squires Garden Centre, the allotments at Sixth Cross Road and Natalie Mews is held under the Green Belt (London and Home Counties Act) and, as such requires Ministerial Consent, which is separate from planning permission for all development on that land. Green Belt Statement Statement to say that the Council relies on CP10, London Plan and national policy guidance with regard to Green Belt 3. Raakhee Patel Thank you for consulting Sport England on the above document. Sport England is the Government agency responsible for Sport England delivering the Government’s sporting objectives. Maximising the investment into sport and recreation through the land use planning system is one of our national and regional priorities. You will also be aware that Sport England is a statutory consultee on planning applications affecting playing fields and a non statutory consultee on planning applications proposing major housing development. Sport England would wish to make the following comments on the above consultation document: Section 4.3: Design and Character Support (with amendments) Sport England recommends that Sport England’s Active Design Guidance http://www.sportengland.org/facilities-planning/planning- for-sport/planning-tools-and-guidance/active-design/ is referenced within this section. Sport England believes that being active should be an intrinsic part of everyone’s life pattern. The master planning of major new housing and mixed use development schemes has a vital role in providing easy access to a choice of opportunities for sport and physical activity, making new communities more active and healthy. Active Design is aimed at urban designers, master planners and the architects of our new communities. Active Design is an innovative set of design guidelines to promote opportunities for sport and physical activity in the design and layout of development. The guidance promotes sport and activity through three key Active Design principles of – improving accessibility, enhancing amenity and increasing awareness. The criteria set out within the Active Design Guidance can be used both as a guide during the planning process, or as a critic for developments that have already been designed. 4.5: Natural Environments, Parks, Open Spaces, Rivers and Sport & Recreation Support (with amendments) Sport England would recommend that this policy is revised in line with the below policy objective (related policy approaches can be found at the following link: http://www.sportengland.org/media/121906/document-7-spatial-planning-for-sport-development-control- All responses received on the Local Plan Review scoping consultation 3 Ref. no. Name / Organisation Detailed comment guidance-note-.pdf) Planning Policy Objective 13 aims to support and promote the use of natural resources for sport in a way which meets sustainable development objectives. Sport England considers that development proposals for sport should be based on the ‘Best Available Place’ principle. This involves a planned approach to the provision and protection of sites and facilities, including the assessment of the impact of any sports use and a commitment to appropriate management measures. Local Plan Evidence Base The National Planning Policy Framework (NPPF) requires each local planning authority to produce a Local Plan for its area. Local Plans should address the spatial implications of economic, social and environmental change. Local Plans should be based on an adequate, up-to-date and relevant evidence base. In addition, paragraph 73 of the NPPF requires that: “Planning policies should be based on robust and up-to-date assessments of the needs for open space, sports and recreation facilities and opportunities for new provision. The assessment should identify specific needs and quantitative deficits or surpluses of open space, sports and recreational facilities in the local area.” Although it is acknowledged that the Council completed a borough-wide Open Space,