Director of Planning and City Development

Core Strategy Publication Draft Consultation Statement (Regulation 27)

Local Development Framework

November 2009

Table of Contents

1.0 Introduction………...... 1 2.0 Consultation under Regulation 25 (2004) – Issues and Options...... 2 2.1 Consultation Responses...... 3 3.0 Consultation under Regulation 26 (2004) – Preferred Options...... 5 3.1 Follow-up consultation...... 5 3.2 WPOA Preferred Alternative Options...... 6 3.3 Consultation Responses...... 7 4.0 Sustainability Appraisal...... 9 5.0 Health & Equalities Impact Assessments...... 9 6.0 Transitional Provisions...... 10 Appendix 1 Issues and Options letter to the general consultation bodies...... 11 Appendix 2 Contacts in the LDF consultee database...... 13 Appendix 3 Specific consultation bodies...... 29 Appendix 4 Issues and Options letter to the specific consultation bodies...... 31 Appendix 5 Issues and Options response form...... 33 Appendix 6 Locations of distribution...... 43 Appendix 7 Article in Westminster Reporter Issue 82, July 2007...... 45 Appendix 8 Article in City of Westminster Planning Newsletter, Summer 2007...... 47 Appendix 9 Issues and Options meetings minutes...... 49 Appendix 10 Issues and Options Area Forums feedback...... 71 Appendix 11 Formal notice setting out the Proposals Matters...... 75 Appendix 12 Preferred Options letter to the general consultation bodies...... 77 Appendix 13 Preferred Options notice of the Proposals Matters...... 79 Appendix 14 Summary of subjects covered in the Preferred Options document...... 81 Appendix 15 Preferred Options response form...... 83 Appendix 16 Preferred Options letter to the specific consultation bodies...... 87 Appendix 17 Preferred Options online article...... 89 Appendix 18 Article in Westminster Reporter Issue 90, November 2008...... 91 Appendix 19 Article in City of Westminster Planning Newsletter, Autumn 2008...... 93 Appendix 20 Preferred Options meeting request letter...... 95 Appendix 21 Recipients of Preferred Options meeting request letter...... 97 Appendix 22 Preferred Options meetings minutes...... 99 Appendix 23 Preferred Options Area Forums feedback...... 131 Appendix 24 Preferred Options letter to disability organisations...... 135 Appendix 25 Disability organisations consulted at the Preferred Options stage...... 137 Appendix 26 WPOA Preferred Alternative Options...... 139 Appendix 27 Council response to WPOA Preferred Alternative Options...... 147

1.0 Introduction

This Consultation Statement has been prepared in accordance with Regulation 27 of The Town and Country Planning (Local Development) (England) Regulations 2004 as amended, and forms part of the proposed submission documents, the requirements for which are set out in Regulation 24 of same Regulations.

The Statement details the consultation measures undertaken by Westminster City Council (‘the council’) during the development of its Local Development Framework (LDF) Publication Draft Core Strategy Development Plan Document (DPD). In addition, appended to this Statement is a summary of the key issues raised during consultation, including the council’s responses to these issues (Schedule 1).

Consultation was carried out in compliance with Regulations 25 & 26 of The Town and Country Planning (Local Development) (England) Regulations 2004 as originally made. Consultation was also carried out in compliance with the council’s Statement of Community Involvement (SCI, adopted January 2007), thus meeting Planning Inspectorate (PINS) procedural soundness test ii, which stipulates that a DPD must be ‘prepared in compliance with the Statement of Community Involvement (SCI), or with the minimum requirements set out in the regulations where no SCI exists’.

In accordance with the 2004 Regulations, the Core Strategy DPD was subject to two rounds of pre-submission consultation; the first round of consultation was for the Issues and Options document (Regulation 25), which took place between 14th May and 11th September 2007. Consultation on the Sustainability Appraisals Scoping Report also took place during this period. The second round of consultation was for the Preferred Options document (Regulation 26), which took place between 24th July and 4th December 2008. Consultation on the Sustainability Appraisal, Health Impact Assessment, and Equalities Impact Assessment also took place during this period.

The council’s LDF consultee database was created in April 2007 and was initially populated with contact information from the Unitary Development Plan (UDP) consultee database. Consultee contact information was updated on a continual basis, with contacts being added, removed or amended on request. All written representations and meeting minutes were recorded in the LDF consultee database.

1 2.0 Consultation under Regulation 25 (2004) – Issues and Options

Consultation on the Core Strategy Issues and Options document was initially scheduled to run from 14th May to 29th June 2007, for a period of just under seven weeks. Particular importance was placed on ‘front loading’ community involvement and promoting a process of continuing dialogue, as opposed to carrying out a series of one-off formal consultations. In order to ensure a sufficiently broad level of community involvement the consultation period was informally extended to 11th September 2007, giving a total consultation period of just over seventeen weeks.

On 14th May 2007 a total of 826 letters (see Appendix 1) were sent by post or email to all contacts in the LDF database (see Appendix 2), including all appropriate general consultation bodies and Members of the council. In addition, the specific consultation bodies (see Appendix 3) were sent a letter (see Appendix 4) that included the Issues and Options document and the consultation response form (see Appendix 5). In accordance with the council’s SCI these documents were available on request in large copy print, audio cassette, Braille or languages other than English.

Copies of the Issues and Options document and the consultation response form were made available at Westminster City Hall and all council One Stops and libraries during normal working hours (see Appendix 6). These documents were also made available through the Council’s LDF webpage: www.westminster.gov.uk/environment/planning/ldf, which was launched on 11th May 2007.

An article was placed in the July 2007 issue of the Westminster Reporter (see Appendix 7), which is a full colour council publication direct-mailed to all homes and businesses throughout Westminster six times a year. In addition, an article was placed in the Summer 2007 issue of the City of Westminster Planning Newsletter (Appendix 8), which is the Department of Planning and City Development (now the City Planning Delivery Unit) e- newsletter and is available through the council’s website.

Meetings were held with Government Office for London, Greater London Authority, Westminster City Partnership, thematic networks, Local Area Renewal Partnerships, amenity societies, business organisations, property owners (including the Westminster Property Owners Association), and officers also attended public Area Forum meetings. Internal meetings were held with the council’s Development Planning Services teams, the Community Protection team and the Housing Department (see Appendix 9 for meeting minutes and Appendix 10 for Area Forum feedback).

2 2.1 Consultation Responses

The council received 88 written representations on the Issues and Options document. Issues raised most frequently include:

The Central Activities Zone (CAZ) Boundary discussions on areas that should, or should not be included within CAZ. Should maintain the existing UDP boundary and Mayors indicative CAZ boundary. Growth in CAZ and the impact on residential amenity.

Mixed Use in the CAZ Need to allow greater flexibility in the CAZ. Residential should / should not always be required as part of any increases in commercial floorspace.

Paddington Opportunity Area Boundary discussions on areas that should be included in the area.

Victoria Opportunity Area Re-designate as Opportunity Area rather than Area of Intensification.

Tottenham Court Road Opportunity Area Re-designate as Opportunity Area rather than Area of Intensification. Should designate an Opportunity Area to improve investment.

West End Special Retail Policy Area (WESRPA) Where such an area should be designated and what the policy framework should include.

The North Westminster Economic Development Area (NWEDA) Whether or not greater flexibility for non-retail should be allowed in Church Street and Harrow Road. Seek affordable business space in the area.

Affordable housing Proportions of social rented / intermediate housing, and the proposed new threshold based on floorspace.

Specialist housing Family housing may not always be suitable in Westminster.

Entertainment uses Need to address the adverse impacts of late night activities.

Infrastructure Proposed uses of s106. Concerns about the ability of infrastructure to support growth.

3 Social and Community Facilities A wider range of social and community facilities need to be provided at the issues and options stage.

Transport Promote public transport, cycling and walking. Car parking standards and residential parking standards.

Waste Should be addressed through waste issues. Concern about lack of space and suitable sites in Westminster.

Green Infrastructure A wider range of green infrastructure need to be included at the Issues and Options Stage. Seek opportunities to create open space and promote physical activity.

Health, Safety and Well-being Health is a cross cutting theme. Mental health should be a policy consideration. Safety and Crime is a key issue omitted at the Issues and Option Stage. Addressing the urban heat island is a key issue.

Noise Noise impacts on sustainability need to be included in the policy approach. Road and Vehicle noise is a key issue in Westminster. Need to control both new development and reduce existing ambient noise levels.

Air Quality Construction works and meeting national air quality objectives is a key issue. Pedestrians and cyclist should be given priority to improve air quality.

Design Private and social housing should have the same criteria as required by the Housing Corporation and for Code for Sustainable Homes Levels. Should ‘require’ or ‘encourage’ sustainability measures. Low carbon and renewable energy sources should be required on large schemes. Concerns about CHP networks. Fuel sources for CHP should be informed by air quality, local pollutant emissions and deliveries. Any targets for renewable energy sources should be viable and realistic. Provide guidance on living roofs.

A full summary of the key issues raised during consultation, including the council’s responses to these issues, is set out in Schedule 1.

4 3.0 Consultation under Regulation 26 (2004) – Preferred Options

Consultation on the Core Strategy Preferred Options document was initially scheduled to run from 24th July to 30th September 2008, for a period of nine weeks. However, due to sustained interest from a number of organisations and community groups the consultation period was informally extended to 4th December 2008, giving a total consultation period of nineteen weeks.

A formal notice setting out the proposals matters was placed in both the ‘London Informer’ and the ‘Paddington, Marylebone & Pimlico Mercury’ newspapers on 24th July 2008 (see Appendix 11). On 24th July 2008 a total of 1,039 letters (see Appendix 12) were sent by post or email to all contacts in the LDF database, including all appropriate general consultation bodies and all Members of the council, which included notice of the ‘proposals matters’ (see Appendix 13), a summary of the subjects covered in the Preferred Options document (see Appendix 14) and the consultation response form (see Appendix 15). In addition, the specific consultation bodies were sent a letter (see Appendix 16), which included a summary of subjects covered in the Preferred Options document and the consultation response form, together with notice of the proposals matters, the Preferred Options document, the Sustainability Appraisal Report, the Initial Equality Impact Assessment and the Initial Health Impact Assessment. Copies of these documents were also sent to Planning Sub-Committee (Planning Briefs and Local Development Framework) members and the Cabinet Member for Built Environment. In accordance with the council’s SCI these documents were available on request in large copy print, audio cassette, Braille or languages other than English.

Copies of the notice of proposals matters, the Preferred Options document and the consultation response form were made available at Westminster City Hall and all council One Stops and libraries during normal working hours. These documents were also made available through the council’s LDF webpage, which included an online response mechanism. In addition, on 4th August 2008 an online article on the Core Strategy Preferred Options consultation was added to the ‘Latest News’ section of the council’s website (see Appendix 17), which was available via a link from the City of Westminster homepage, and remained live for one and a half weeks.

An article inviting representations on the Core Strategy and informing the public about upcoming Area Forums was placed in the November 2008 issue of the Westminster Reporter (see Appendix 18). In addition, an article was placed in the Autumn 2008 issue of the City of Westminster Planning Newsletter (see Appendix 19).

3.1 Follow-up Consultation

On 18th August 2008 a letter (see Appendix 20) was sent out to the 35 consultation bodies (see Appendix 21), both specific and general, who had submitted representations at the Issues and Options stage but had not yet submitted representations at the Preferred Options stage. These consultees were invited to meet with council officers and discuss any issues or concerns they had relating to the Core Strategy. If a consultee failed to respond to this letter then they were contacted directly by telephone, and as a result 18 of the 35 consultees

5 agreed to meet with council officers. Minutes from the meetings held at the Preferred Options stage can bee seen in Appendix 22, and feedback from the Area Forums can be seen in Appendix 23.

Following comments by Councillor Keen at the Built Environment Policy and Scrutiny Committee, a letter (see Appendix 24) was sent out on the 8th September 2008 to 29 national disability organisations (see Appendix 25), inviting them to submit written representations on the Preferred Options.

3.2 WPOA Preferred Alternative Options

As part of the consultation on the Core Strategy Preferred Options document, officers held a series of meetings with the Westminster Property Owners’ Association (WPOA), now the Westminster Property Association (WPA). At these meetings, it was suggested that WPOA might wish to put forward their own alternative policy options, in order to clarify their strategic approach.

It was agreed that these Preferred Alternative Options (see Appendix 26) would be published on the council’s website together with the Preferred Options document so that they could be subject to public scrutiny, and indeed further comment from interested parties, which would also be considered in the consultation process. Shaftesbury Plc, Land Securities, Covent Garden London Ltd, Grosvenor Ltd, Howard de Walden Estates, and the Portman Estate all commented on the WPOA Preferred Alternative Options.

The WPOA alternative ‘Preferred Options’ focus on a Strategic Objective (in relation to commercial development), housing, mixed use, retail, design quality, affordable housing, business floorspace and hotels.

In particular, these alternative options highlight the desire for greater flexibility in the application of policy, especially in relation to mixed use and affordable housing requirements, as well as greater priority for commercial development and consideration of site viability. Many of the WPOA options focus on the requirements of individual sites and do not necessarily contribute to a spatial vision or strategy for the city. For the most part, the issues raised in the alternative policies are ones which will be taken into account when applying policies to particular schemes, and it is in these negotiations on individual sites that the council will need to apply policies with an appropriate degree of flexibility by taking into account issues of material consideration, such as overall scheme viability.

However, a number of the WPOA key themes are shared by the council, such as good design, whilst others, such as affordable housing, will be addressed in the City Management Plan.

The council’s response to the WPOA Preferred Alternative Options is set out in Appendix 27.

6 3.3 Consultation Responses

The council received 101 written representations on the Preferred Options document. Issues raised most frequently include:

Central Activities Zone Boundary of Central Activities Zone. Distinction between different parts of the Central Activities Zone. Need for greater emphasis on commercial uses. Mixed use developments – proportion of housing should not be more than 50%. Mixed use policy requirements impact on development viability. Need for more flexibility in the application of mixed use policy, and greater clarification on threshold level. Boundary of WESRPA and priority given to retail uses.

Opportunity Areas Boundary of Victoria Opportunity Area. Victoria Opportunity Area not appropriate for tall buildings. Boundary of Paddington Opportunity Area. Justification needed for inclusion of health facility, new open space and developing heat and power network.

Special Policy Areas Discussion of boundaries and priority given to uses within the individual SPAs.

North Westminster Economic Development Area Economic development should not be prioritised at the expense of housing, or infrastructure.

Commercial Uses Need to further support office capacity to prevent market constraint. Small office/affordable workspace not supported. Requirement for small/affordable retail units could be offset against other requirements. Need flexibility to allow for changes in retail sector. Tourism uses should be supported. Location of new hotels. Should be supportive of evening and night time economy. Entertainment uses should be of an appropriate scale. Entertainment uses should not be unduly restricted, dependent upon impact.

Housing Priority for housing should vary dependent upon area (eg CAZ, WESRPA, St James). Mix of size and tenure should be determined on a site by site basis. Loss of residential units may be appropriate to create larger units, family houses or in listed buildings.

7 Affordable housing threshold. Proportion of affordable housing provided. Issue of sequential approach: on-site, off-site, vicinity, payment in lieu of affordable housing.

Infrastructure Loss of social and community facilities could be allowed if better facilities provided elsewhere, or better planning benefits can be achieved. Need clear overarching transport policy. Issue of provision of infrastructure against other planning obligations. Servicing. Promote use of river. Need to identify how the London Plan waste apportionment target will be met. Difficult to provide new open space due to site constraints. Should include balconies, roof terraces and off-site provision.

Health and safety Likely to be impact upon residential amenity. Protection against noise. Air quality.

Design Need to take into account sustainable drainage, Mayor’s energy hierarchy and greenhouse gas emissions. Need realistic sustainability targets taking into account viability and feasibility Prevention of subterranean development.

Heritage Policy approach is too restrictive. Approach to tall buildings and views should be in line with London Plan. Tall buildings should be considered outside Victoria and Paddington Opportunity Area.

A full summary of the key issues raised during consultation, including the council’s responses to these issues, is set out in Schedule 1.

8 4.0 Sustainability Appraisal

The first stage in the Sustainability Appraisal (SA) process was the production of the Sustainability Appraisal Scoping Report, which sets out the context and baseline information in order to provide a starting point from which to appraise the effects of implementing the LDF. The Draft Sustainability Appraisal Scoping Report was agreed by the Cabinet Member for Planning in February 2007 and underwent five weeks of consultation from 23rd April 2007, with the final version being published in August 2007. The council received 7 responses to consultation on the Sustainability Appraisal Scoping Report, details of which are included in Appendix 1 of the Publication Draft Sustainability Appraisal Report.

An SA of the Issues and Options was undertaken to ensure that the range of possible policy options set out at this initial stage helped to achieve the aim of sustainable development. This was set out in the initial Sustainability Appraisal Report (SAR), which was agreed for public consultation in a Cabinet Member Report dated 30th August 2007, with the consultation lasting six weeks from 14th September to 26th October 2007. The council received no responses to consultation on the initial SAR.

This second stage SA of the Core Strategy was carried out against the Sustainability Framework as set out in the Scoping Report. Consultation for the second stage SAR was carried out alongside Core Strategy Preferred Options document, initially from 24th July to 30th September 2008, and informally extended to 4th December 2008. The consultees concluded that the methodology was sound and broadly the assessments were satisfactory and scorings appropriate. The council received 2 responses to consultation on the second stage SAR, details of which are included in Appendix 1 of the Publication Draft Sustainability Appraisal Report.

5.0 Health & Equalities Impact Assessments

Whilst there is no statutory requirement to undertake a Health Impact Assessment (HIA), the Government has clearly expressed a commitment to promoting HIAs at a policy level in a variety of policy documents and they are increasingly being seen as best practice. Health Impact Assessment is a combination of procedures, methods and tools by which a policy, programme or project may be judged as to its potential effects on the health of a population, and the distribution of those effects within the population. There are several different types of HIA; the one that was carried out on the Core Strategy Preferred Options is a prospective HIA. This type of assessment is conducted before a policy is implemented.

In accordance with the legal requirements of The Race Relations Act 1976, Race Relations (Amendment) Act 2000, Disability Discrimination Act 1995 & 2005, Equal Pay Act 1970, Sex Discrimination Act 19975 and Equalities Act 2006, the council is by law required to assess the impact of all its existing and proposed policies and practices. An Equality Impact Assessment (EqIA) examines an existing or proposed policy, strategy, function, project or activity to identify what effect its implementation may have on different groups in the community. Both the HIA and EqIA were consulted on between 24th July and 30th September 2008.

One response was received on the HIA, which taken into account in preparing the Publication Draft Core Strategy. No responses were received on the EqIA, and so a further questionnaire was placed on the Voluntary Action Westminster website to stimulate comments on any equalities issues emerging from the Preferred Options and EqIA. However, no comments were received. Equalities issues were raised in response to the Preferred Options document itself and were taken into account in preparing the Publication Draft Core Strategy. A further EqIA will be carried out on the Publication Draft Core Strategy to demonstrate how the council has taken equalities into account in developing policies, which will be published when the Core Strategy is submitted to the Secretary of State.

6.0 Transitional Provisions

On 27th June 2008 The Town and Country Planning (Local Development) (England) (Amendment) Regulations 2008 came into force. The new Regulations seek to streamline the consultation process for DPDs and make it more targeted and appropriate to the circumstances. Subsequently, Regulations 25 and 26 (2004) are superseded by Regulation 25 (2008), which removes the requirement for two separate rounds of pre-submission consultation in favour of a more flexible, ongoing consultation process measured against the five key consultation principles set out in the revised Planning Policy Statement 12 (2008).

Regulation 3 (4) of the 2008 Regulations sets out the transitional provisions, which enables consultation under the 2004 Regulations to satisfy the consultation requirements of the 2008 Regulations, provided that Regulations 25 and 26 (2004) are complied with before 27th June 2008 and 1st September 2008 respectively. As the council complied with both Regulation 25 and 26 (2004) within the allotted timeframe, consultation under these Regulations can be deemed to satisfy the requirements of Regulation 25 (2008).

10 Appendix 1 – Issues and Options letter to the general consultation bodies

Rosemarie MacQueen – Director of Planning and City Development

Your ref: Please reply to: Gillian Dawson My ref: Direct Tel. No: 020 7641 2457 Direct Fax No: 020 7641 3050 Email : [email protected] «Name» «Address» City Planning Group Department of Planning and City Development Westminster City Hall 64 Victoria Street London SW1E 6QP

Date: 14th May 2007

Dear «Salutation»

Planning and Compulsory Purchase Act 2004 Westminster Local Development Framework Core Strategy Development Plan Document: Issues and Options

The City of Westminster is preparing a new development plan called the Local Development Framework. The first document within this framework is called the Core Strategy and it will set out the spatial vision for Westminster over the next two decades.

The City Council is seeking the views of local and regional groups, other stakeholders and statutory consultees on those issues and options which affect you and which concern you most. Extensive consultations on this document will be taking place over the next few months.

The complete document ‘Core Strategy - Issues and Options’ is available to view and print off from our website www.westminster.gov.uk/ldf or you can request a paper copy by phoning 020 7641 3052 /2503 /2457. You can also e-mail the ldf team, [email protected]. Copies of the document are available for inspection at Westminster’s libraries and One Stop Services planning desks.

The 6 key issues which we have identified are:

1. How can we mitigate against climate change and ensure that the City plays its part in delivering sustainable development? 2. How and where should growth be directed and how can we maintain economic diversity and vitality? 3. How can the balance be made between growth in housing and employment whilst still meeting our housing challenges and targets?

Appendix 1 – Issues and Options letter to the general consultation bodies 4. How can we support Westminster’s role as a world class City while maintaining local distinctiveness? 5. How do we build more cohesive, tolerant and neighbourly communities? 6. How can we balance the needs of the night-time economy with a large and growing residential population and the needs of the day-time economy?

Are these the right issues? Are there other issues which we have overlooked? What options should we pursue to tackle these issues?

A response form is enclosed to assist you in replying, but you are welcome to e-mail, write separately or simply call if you want to discuss anything relating to the preparation of the Core Strategy and the Issues and Options stage.

Please return your written comments to us by the 29th June 2007.

Yours sincerely,

Barry Smith Head of City Planning Group (Policy)

One Stop Services, 62 Victoria Street, London SW1E 6QP: Monday – Friday 8.30 a.m. to 7.00 p.m.; Saturday 9.00 a.m. to 1.00 p.m.

One Stop Services, 313 Harrow Road, London W9, Monday – Friday 8.00 a.m. to 5.00 p.m.

One Stop Services, 91- 93 Church Street, London NW8, Monday – Friday 8.00 a.m. to 5.00 p.m.; Saturday 9.00 a.m. to 1.00 p.m.

Appendix 2 – Contacts in the LDF consultee database

Ref Name of Organisation/Individual Ref Name of Organisation/Individual

1236 51 Degrees 34 Amberley Road Centre

1625 A Liammari 35 Ambika House Limited

7 Abbey Arts 36 American School in London

8 Abbey Community Centre 37 Anchor Trust - Norton House

10 Abbots Manor Community Childcare Centre 38 Ancient Monuments Society

11 Abbots Manor Tenants' Association 1147 Andrew Havery

12 Abercorn School Nursery 1182 Angela Harvey

13 Abou Zaki Holding Company 1141 Angela Hooper

1238 Abovenet 39 Anthony Bowhill & Associates

14 Academy Crèche 1157 Antony Devenish

1349 Accord Energy Limited 1430 AOL UK Ltd

16 Acorn Nursery 45 Aquila Street Residents' Association

17 Acorns Parent & Toddler Group 41 Arab Welfare Advisory Centre

1565 Action for the Blind 1348 Arcadia Petroleum Limited

1566 Action Trust for the Blind 42 Archdeacon of Charing Cross

18 Acton Housing Association 1274 Area One Steering Group Covent Garden Trust (trustee)

1632 Adams Hendry 44 Arlington Care Association

1350 AEP Energy Services Ltd 1562 Arthritis Care

1351 AES Barry Limited 1331 ARUP

20 African Joy 46 Ascot & Windsor Residents' Association

21 African Refugee Project 47 Ash Design Consultant Ltd

22 Afro-Carribean Mental Health Association 1604 Ashley Gardens Residents Association

1613 Age Concern / Westminster Senior Citizen's Forum 48 Ashmore Pre-School Group

1014 Age Concern Westminster 49 Asset Consultants Ltd

23 Ainslie O'Connor 1561 Association for Spina Bifida and Hydrocephalus

24 Air Transport Users Council 50 Association of Blind Asians

25 Al Madina Nursery School 1671 Association of British Insurers

992 Alan Baxter & Associates 1269 Atisreal UK

1265 Alan Bradley 1223 Atkins on behalf of Cable & Wireless & Energis

1165 Alastair Moss 1143 Audrey Lewis

26 Albanian School Kosovo 55 Avenue Gardens Residents' Association

1179 Alexander Nicoll 1099 Avenues Over 50s Focus Group

27 Alexander Reece Thompson 56 A-Z Restaurants

28 All Stars Youth Club 1146 Aziz Toki

1313 Alliance Planning 1443 B Sky B Holdings Limited Alpha International Overseas Telecommunications Services 1423 Ltd 1195 Babygrow

31 Alsop Verrill 60 Baker & McKenzie

1552 Alzheimer's Society 1050 Ballymore Properties Ltd

32 Amberley Club 1144 Barbara Grahame

33 Amberley Residents' Association 1574 Barclays Bank Plc 13

Appendix 2 – Contacts in the LDF consultee database

Ref Name of Organisation/Individual Ref Name of Organisation/Individual

61 Barnardo's Young Women's Project - Girlzone 1357 British Gas Trading Limited

1173 Barrie Taylor 110 British Geological Society

62 Barrow Hill Pre-School 1547 British Institute of Learning Difficulties

1422 Barton Willmore 111 British Motorcycle Federation

1329 Barton Wilmore 1433 British Telecommunications Plc

1608 Barton Wilmore 112 British Transport Police

66 Bayswater Families Centre 1648 British Waterways

67 Bayswater Residents Association 1075 British Waterways London

74 Beauchamp Lodge Settlement 114 Broadway Malyan

75 Beethoven Centre 1264 Broadwick (Stirling Court) Management Company Ltd

76 Beginnings 115 Bronwen Court Residents' Association

993 Belgravia Police Station 116 Brook in Euston

77 Belgravia Residents Association 117 Brownie Guide Unit 6th East Paddington

79 Bengali Cultural Association 119 Brunel Estate Residents' Association

81 Bengali Institute 120 Brunel Family Centre

82 Bengali Women's Group 121 Brunswick & Dalkeith Residents' Association

1636 Bennett Urban Planning 1217 BT Open Reach

83 Bereavement Support Group 123 Building Research Energy Conservation Support Unit

84 Berkeley Street Club 124 Building Research Establishment (BRE)

63 Berkely Group Holdings Plc 1314 Building Schools for the Future

86 Berwin Leighton 125 BUJ Architects

1352 BG Gas Services Limited 127 Business Link for London

88 Biomedic Foundation 130 Camden and Westminster Refugee Training Partnership

89 Blandford Estate Residents' Association 131 Cameron McKenna

90 Blue Cross Animals' Hospital 1256 Campaign for Clean Air (in London)

91 BME Westminster 140 Campaign to Protect Rural England

94 Body Shop International Plc 138 Cardinal Hume Centre

1114 Boodle Hatfield 1253 Carers Network Westminster

96 Boots the Chemist 1359 Cargill PLC

98 Bosnia & Herzegovanian Organisation 139 Caribbean Hindu Society

1355 BP Exploration Operating Company Limited 141 Carlton Hill

1110 Brent Planning Service 5 Carlton Hill Residents' Association

1139 Brian Connell 1501 Carol Joyce-Walsh

101 Bridge House Housing Association (Dean Street Hostel) 1142 Carolyn Keen

104 Brindley Community Association 1353 Carron Energy Limited

105 British Arab Resource Centre 1334 Cathedral Area Residents Group (CARG)

106 British Beer and Pub Association 144 Caxton Youth Trust

107 British Buddhist Association 1328 CB Richard Ellis

108 British Casino Association 1447 CB Richard Ellis

1544 British Deaf Association 1568 CBRE

1356 British Energy Generation Limited 146 Central and Cecil Housing Trust 14

Appendix 2 – Contacts in the LDF consultee database

Ref Name of Organisation/Individual Ref Name of Organisation/Individual

147 Central and Cecil Housing Trust - Dora House 175 Churchill Gardens Elderly Handicapped Club Churchill Gardens Estate, Thorney Island Society, 148 Central and Cecil Housing Trust - Edna House Westminster Society, London Forum of Amenity & Civic 1056 Societies Residents 149 Central London Dysphasic Group 176 Churchill Gardens Lessees Association 1500 Central London Forward 177 Churchill Gardens Residents' Association 150 Central London Law Centre 178 Churchill Gardens Youth Club 151 Central London Partnership 179 Cinema Exhibitors Association 152 Centre for Ecology & Hydrology 180 Circle 33 Housing Association 153 Centre for Health and Healing 181 City & West End Development Ltd 154 Centrepoint - Central Office 1296 City Of London (Planning & Transport Dept) 155 Centrepoint - Drury Lane Project 1067 City of Westminster Archive Centre 1362 Centrica Storage Limited 1309 City of Westminster College 525 CGMS (on behalf of Metropolitan Police Authority) 1111 City Planning Test 158 Charing Cross Community Childcare Centre 1465 City Property Association 1451 Charing Cross Library 1057 City West Homes 159 Charing Cross Police Station 184 Cliff Walsingham & Co. 1258 Charlotte Street Association 1678 Cllr Andrew Smith 160 Charter Hospitals 185 Club Xpress After School Club 161 Chelsea Bus-Stop Counselling Service for Young People 187 Clubs and Vice Unit Metropolitan Police Service 162 Cherubs Parent & Toddler Group 1020 Cluttons LLP 1354 Chevron North Sea Limited 1196 Clyder Enterprises Limited 163 Chic Bingo Club 1153 Colin Barrow 164 CHICL Communities and Homes in Central London 1647 Colliers CRE 165 CHICL Communities and Homes in Central London 1073 Collingwood Environmental Planning 1295 Children and young peoples Strategic Partnership Board 1221 Colt 642 Childrens Centres Commission for Architecture and the Built Environment 168 Chinatown Unit 1015 (CABE)

1040 Chinese Community Associaton 191 Commission for New Towns & English Partnerships

1039 Chinese Community Centre 1016 Commission for Racial Equality

167 Chinese Community Office 192 Communal Welfare Centre for Refugees

169 Chippenham Housing Co-operative Limited 193 Communities and Homes in Central London

1364 Chive Fuels Limited 195 Community Housing Association Community Involvement Manager Voluntary Action 999 Chris Thomas Ltd 196 Westminster

1188 Christabel Flight 198 Confide

170 Christian Union Almshouses 199 Connaught House School

1322 Christopher Hill Planning, Development & Regeneration 213 Consolidated Real Estate Management Services Ltd

171 Church Street Children's Centre 200 Consortium of Bengali Associations

172 Church Street Drop-In Centre 1358 Corona Energy Retail Limited

1452 Church Street Library 1001 Corporation of London

1086 Church Street Neighbourhood Management WCC 202 Cosmic - Children of St. Mary's Intensive Care

173 Churches Conservation Trust 203 Cotes House Tenants & Residents Association

1036 Churches Together in Westminster 204 Council for British Archaeology 15

Appendix 2 – Contacts in the LDF consultee database

Ref Name of Organisation/Individual Ref Name of Organisation/Individual

1276 Covent Garden Area Trust 237 Diocesan Board of Finance

205 Covent Garden Area Youth Club 1426 Direct Save Telecom (DST)

206 Covent Garden Community Association 238 Disability Network

1278 Covent Garden London Limited 1009 Disability Rights Commission

207 Coyne & Co 1017 Disabled Persons Transport Advisory Committee

211 Crawford Buildings Residents' Association 1633 DLA Piper

212 Crawford Mansions Tenants' & Residents' Association 240 Dorothy Gardner Nursery Centre

1267 Cross London Rail Links Ltd 242 Dover Street Wine Bar

1303 Cross River Partnership (Lambeth Office) 1310 DP9

214 Crown Castle 1612 DP9

215 Crown Castle UK Ltd 243 DPDS

1002 Crown Estate 1610 DPP

1643 Crown Plaza London St James 245 Drink Crisis Centre - Hopkinson House

217 Croxley Project 246 Drivers Jonas

218 Crypt Youth Club 247 DTLR

270 Crystal Palace National Sports Centre 1070 DTZ

1601 Cunnane Town Planning 249 Dufours Residents Association

1136 Cyril Nemeth 1626 Duncan Collins

219 Daisies Day Nursery and School 1184 Duncan Sandys

1174 Daniel Astaire 1360 E.ON Ruhrgas UK Energy Trading Limited

1183 Danny Chalkley 1220 Easynet

1192 David Boothroyd 251 Eaton House School

222 David Hicken Associates 252 Eaton Square Private (and Nursery) Schools Ltd

224 Davis Coffer Lyons 256 Ebury Bridge Centre

1543 Deafblind UK 258 Ebury Bridge Residents Association

225 Defence Estates 1425 Eclipse Internet Home

1645 Defence Estates 259 Eden House Residents' Association

1439 Demon 1224 EDF Energy

227 Densham House Residents' Association 1361 EDF Energy Plc

228 Department of Culture, Media & Sport 260 Edgware Road Association

229 Department of Environment, Food & Rural Affairs (defra) 1187 Edward Argar

1106 Department of Health 1363 ELF Exploration UK Plc

1119 Department of Media, Culture and Sport 262 Elgin Pre-School

230 Department of Trade & Industry 265 Emmanuel Pre-School Group

994 Department of Transport 1564 Employers Forum on Disability

1553 Depression Alliance 266 Empty Homes Agency

1637 Derek Horne & Associates 267 English Churches Housing - King George's Hostel

231 Derwent Valley Holdings PLC 268 English Churches Housing - Queen Mary Hostel

232 DfES 1006 English Heritage

233 DGAA - Homelife 1028 English Partnerships

234 Dibdin Pre-School 1089 Environment & Leisure WCC 16

Appendix 2 – Contacts in the LDF consultee database

Ref Name of Organisation/Individual Ref Name of Organisation/Individual

271 Epilepsy Action - North Westminster Support Branch 310 Friends of the Earth (London Region)

1018 Equal Opportunites Commission 1190 Frixos Tombolis

1442 Equitalk.co.uk Ltd 1297 Fusion Online Ltd

272 Eritream Muslim Community Association 313 Future Energy Solutions

274 Eritrean Community Association 1311 G R Planning Consultancy Ltd

1063 ESA Planning 314 Gala Group Ltd

1403 ESP Electricity Limited 1197 Gambia Madigo Association

1245 Essie Graham 317 Garden History Society

1365 Esso Exploration Production UK Limited 319 Gateway Club (Westminster)

1441 Euphony Communications Ltd 320 Gatliff Close Residents' Association

1591 European Land & Property Ltd 321 Genuine Empowerment of Mothers in Society

281 Fairview New Homes Ltd 1254 Geraldeve

282 Families and Adolescent Service 1416 Gieves and Hawkes

283 Family Housing Association 326 GL Hearn

284 Family Space 327 GLA. Business & Europe Division

1440 Fast.co.uk 328 Glad Monday Club

285 Fibbens Fox Associates 1370 Glencore Energy UK Limited

1218 Fibrespan 1189 Glenys Roberts

1584 First Base 1239 Global Crossing

287 First Steps Community Childcare Centre 1371 Global Natural Gas Limited

1367 First Utility Limited 1575 GMS Estates Limited

1038 Firstplan 129 Goldcrest Films international

289 Fisherton Pre-School 330 Golden Years Club

290 Fisherton Street (Club 88) 1010 Government Office for London (GOL)

291 Fisherton Street Residents' Association 1066 Graham Simpkin Planning

292 Fitzrovia Court Residents' Association 335 Grainhurst Properties Limited

1272 Fitzrovia Neighbourhood Association 336 Great Beginnings Montessori School

1337 Fitzrovia Trust 337 Great Portland Estates

293 Flanders Club 1042 Greater London Authority

294 Fleming Court Residents' Association 340 Greater London Magistrate's Courts Authority

296 Focus Central London 343 Grosvenor & Regency Management Organisation

297 Forster's Solicitors 1045 Grosvenor Estates

1548 Foundation for People with Learning Disabilities (FPLD) 345 Grosvenor Group

298 Founders House Club 1597 Grosvenor Limited

299 Four Rivers Residents' Association 1585 Grosvenor Square Limited

300 Fourth Feathers Youth Club 997 Groundwork Trust (Camden, Islington & Westminster)

1156 Frances Blois 1095 Grovesnor Regency Estate Youth Club

1611 Fraud Screen 1151 Guthrie McKie

1435 Freedom2Surf 348 GVA Grimley Ltd

306 Freshwater Court Residents' Association 1175 Gwyneth Hampson Gypsy Council for Education, Culture, Welfare & Civil 308 Friends of St. Saviours 349 Rights 17

Appendix 2 – Contacts in the LDF consultee database

Ref Name of Organisation/Individual Ref Name of Organisation/Individual

350 Halcrow Fox 1277 Howard de Walden Estates Ltd

351 Hall & Braithwaite Residents' Association 385 Hyde Park Barracks Community Childcare Centre

352 Hall Park Residents' Association 1124 Hyde Park Estate Association

353 Hallfield Estate Residents' Association 1162 Ian Adams

354 Hammerson Properties PLC 1339 Ian Morrison

1228 Handman and Collis Ltd 1170 Ian Rowley

1414 Hanson Consulting 1191 Ian Wilder

359 Happybadge Projects Limited 387 Imperial College Day Nursery

360 Harp, Sarraf Sheppard Associates 1587 Imperial College Healthcare NHS Trust

362 Harrowby and District Residents Association 1580 Imperial College London

1168 Harvey Marshall 389 In and Around Covent Garden Business Forum

363 Have A Go Holiday Project 1096 In Deep Elderly Group

365 HCA Healthcare 391 Independent Mothers Pre-School

1270 HCA International Ltd 392 Independent on Sunday

366 HDG Ltd 329 Indigo Planning Limited

367 Headway North London Group 394 Inner London Group

832 Health & Safety Executive (Construction Division) 1373 Intergen (UK) Energy Trading and Shipping Limited

368 Health & Safety Executive (Local Office) 395 International Club

1546 Hearing Concern LINK 1374 International Power Fuel Company Limited

1043 Heart of London Business Alliance 398 IQRA Trust

370 Heatherside Properties 399 Iraqi Community Association

371 Heathrow Express 400 ISIS Property Asset Management

1642 Helen Stanwell 401 J D Wetherspoon Plc

372 Helical Bar 1286 J Young

373 Help Advisory Centre 402 Jacs Club

1582 Henderson Global Investors 1166 Jan Prendergast

1372 Hess Energy Power and Gas Company (UK) Limited 1639 JCDecaux

375 Hide Tower Residents' Association 1155 Jean-Paul Floru

1212 Highway Agency 1617 Jennifer Cobbing

376 Hilton International 403 JMP

377 Hilton London Metropole 1627 Joan Schor

1261 Hinde House Residents Association 404 John Aird Court Residents' Association

1586 Hines 406 John Lewis Partnership

378 HM Prison Service 1589 John Lyons Charity

379 HM Prison Service Headquarters 1037 John Sharkey & Co

1335 HOK International Architects 1301 Jon Dingle

380 Holcroft Community Childcare Centre 408 Jones Lang La Salle

381 Holcroft Court Residents' Association 1516 Jones Lang LaSalle

833 Home Office 410 Jubilee Crèche

1097 Housing 21 Care Options 1137 Judith Warner

1005 Housing Corporation (London Region) 411 Jumbo Nursery School 18

Appendix 2 – Contacts in the LDF consultee database

Ref Name of Organisation/Individual Ref Name of Organisation/Individual

412 Katharine Bruce Day Nursery 445 Lisson Green Community Childcare Centre

1281 Katherine Hosleyns 446 Lisson Green Play Project

1424 KCOM Group Plc 447 Lisson Green Resource Centre

413 Kemp House Residents Association 448 Lisson Green Tenants' & Residents' Association Kensington and Chelsea with Westminster Friends of the 414 Earth 1113 Lisson Grove Health Centre

415 Kensington Housing Trust 449 Little House

416 Kettners 450 Little Sweethearts Montessori School

417 Kiddicare 451 Little Venice Community Childcare Centre

418 Kids Westminster Home Learning 1622 Lizzie Dekkers

1307 Kings College London 452 Lloyds TSB Bank Plc

1621 Kit Boukeras 453 Loftus Family Property

304 Knight Frank 454 Logic.com Ltd

1600 Knight Frank 1213 London Ambulance Service

355 Knightsbridge Under School 1107 London Ambulance Service NHS Trust

1027 Kushan and Wakefield 1000 London Borough of Brent - Environment and Planning

1248 L.S.E. Early years Centre 459 London Borough of Camden

1618 Lady Kingham 1019 London Borough of Hackney

422 Lafarge Redland Aggretates Ltd 460 London Borough of Islington

423 Lancefield Centre 461 London Borough of Lambeth

1638 Land Locator Company 746 London Borough of Southwark

425 Land Securities PLC 462 London Borough of Wandsworth

426 Landmark Hotels 1578 London Business School

428 Latimer House Relatives Group 466 London Central Mosque and Islamic Cultural Centre

431 LCC/CBI London Manufacturing Group 468 London Chamber of Commerce and Industry (LCCI)

1444 LDA Olympic Legacy Directorate 469 London City Airport

443 Leciester Square Association 470 London Clubs International Plc

1167 Lee Rowley 471 London Core Trust

434 Legal & General Life Assurance Society Ltd 51 London Councils

435 Lesser Gang 472 London Cycling Campaign

436 LETEC 1346 London Development Agency

1226 Level 3 Communications 1215 London Development Authority

1599 Libraries, Archives and Arts 1263 London Diocesan Fund

1087 Lifelong Learning WCC 1011 London Fire and Emergency Planning Authority

438 Lilestone Estate Residents Association 1216 London Fire Brigade

439 Lillington & Longmoore Gardens Residents Association 475 London First

440 Lillington Gardens Over 60's Club 467 London General Transport Services Limited

1135 Lindsey Hall 476 London Historic Parks & Gardens Trust

442 Linklaters 477 London Hostels Association Limited

1068 Linklaters Business Services 1246 London Jehovah Witnesses Lisson Green Bangladeshi Pensioner, Elderly & Disabled 1598 London Planning Practice 444 Association 478 London Port Health Authority 19

Appendix 2 – Contacts in the LDF consultee database

Ref Name of Organisation/Individual Ref Name of Organisation/Individual

480 London River Services 518 Maurice Nadeam & Co.

1115 London Rivers Association 1455 Mayfair Library

1519 London School of Economics 519 Meanwhile Gardens Play Hut

483 London School of Economics and Political Science 1280 Meard and Dean Street

484 London School of Economics Nursery 520 Medical Foundation For The Care Of Victims of Torture

487 London Travel Watch 1539 Mehfuz Ahmed

490 London Underground Ltd 1163 Melvyn Caplan

491 London Voluntary Service Council 522 Mencap

492 London Wildlife Trust 1549 Mencap

536 Londonewcastle 1550 Mental Health Foundation

494 Look Ahead Housing Association - Head Office 523 Mentorn Barraclough Carey

495 Look Out Environmental Centre (Friends of Hyde Park) 526 Metropolitan Police (Central Traffic Unit)

1177 Louise Hyams 1619 Metropolitan Police Authority (Central Area)

1300 LSE Estates Division 524 Metropolitan Police Authority (North Westminster)

1022 Lumley Flats Residents Association 1620 Metropolitan Police Authority (South Area)

499 Luxborough Tower Residents Association 527 Metropolitan Police Service (TP HQ)

500 Lydford Estate Tenants & Residents Association 529 Metropolitan Police Service (Traffic)

501 Lydford Senior Citizens Club 528 Metropolitan Police Service (West End Central)

1320 Lynne Evans 530 Metropolitan Public Gardens Association

1273 M D Smith 1138 Michael Brahams

502 M R Partnership 531 Michael Woolf & Co

1076 Mace Macro Ltd 1615 Michelle Hughes

1431 Madasafish 533 Micky Star Play Project

504 Maida Vale Estate Tenants & Residents' Association 534 Migrants Resource Centre

1453 Maida Vale Library 535 Millbank Estate Residents' Association

505 Maida Vale Play Project 1551 Mind - National Association for Mental Health

506 Malcolm Scott Consultants Ltd 1262 Ministry of Justice

507 Manto Group 1243 Miss Daisy's Nursery School

1164 Margaret Doyle 537 Miss Morley's Nursery School

1514 Mark Henderson 538 Miss Willcock's Nursery School

1169 Mark Page 539 Mitchells and Butlers

1341 Mark Younger 1098 Moberly Monday Group (over 50s group)

510 Marsham Street Community Childcare Centre 540 MOD Defence Estates

1670 Martineau 1606 Mohammed Janel

511 Martlett Court Residents' Association 541 Mondial Estates Ltd

512 Mary Paterson Nursery School 1210 Montagu Evans LLP

514 Marylands Play Project 543 Moorhouse Pre-School

998 Marylebone Association 544 Moreton Day Nursery and Pre-School

1454 Marylebone Library 1338 Moreton Triangle Residents Association

515 Marylebone Police Station 545 Morley Property and Property Merchant Group

1232 Matthew Bennett 546 Moroccan Community Association 20

Appendix 2 – Contacts in the LDF consultee database

Ref Name of Organisation/Individual Ref Name of Organisation/Individual

547 Morris House Residents' Association 1112 Nicola King

1201 Moshi Moshi Sushi 1438 Nildram

1326 Mosley And Webb 1123 North Paddington Society North West London Mental Health Trust Carers' Support 549 Mother & Baby Group 570 Group

1560 Motor Neurone Disease Association 572 North Westminster Bengali Women's Association

550 Motorcycle Action Group 573 North Westminster Chinese Women's Group North Westminster Voluntary and Community Sector 551 Mott MacDonald 1117 Forum 1065 Mount Eden Land Ltd 574 Norton Rose 553 Mozart Estate Tenants & Residents Association 575 Notcutt House Leaseholders' Association 1603 Mr D Howard-Budd 1319 Notting Hill Housing Group 1607 Mrs Carolyn Rayment 1583 Noved Investment Company 1631 Mrs Iris Topp 1202 NTL (Hampshire office) 1630 Mrs R Waddon 579 Oak Tree House Residents' Association 1559 Multiple Sclerosis Society 1081 Octavia Housing 555 Munro Centre For Complementary Healthcare 580 Odhams Walk Residents' Association 1558 Muscular Dystrophy Campaign 581 Office Bar (The) 1172 Mushtaq Qureshi 582 Olabisi Olaleye Foundation 556 Muslim Advice Centre 583 Olive Tree Christian Centre 557 Naima Jewish Preparatory School 584 Olswang 558 Natharro Nathanson 1448 One Stop Services National Association for Providers of Activities for Older 559 People 1449 One Stop Services

560 National Car Parks Ltd 1450 One Stop Services

561 National Coalition for Black Volunteering 1100 Open Age National Federation of the Blind of the UK (Transport and 1614 Environment Committee) 1428 Orange

562 National Grid 585 Orange Personal Communications Services Limited

1308 National Playing Fields Association 586 Organisation for the Advancement of African Women

566 National Romany Rights Association 587 Osborne Group

1563 National Wheelchair Housing Association 588 Our Lady of the Assumption & St Gregory Church

1004 Natural England - London Region 589 Out and About Club

1214 Network Rail 590 Outdoor Advertising Association

1053 Network Strategy South East (Highways Agency) 591 Over 60's Club

1093 New Avenue Youth Club 933 Paddington Arts

568 New Cameo Club 592 Paddington BID Paddington Churches Housing Association - Sheltered 1241 New West End Company (NWEC) 595 Housing

135 NHS London 596 Paddington Citizens Advice Bureau

1031 NHS London Healthy Urban Development Unit (HUDU) 1305 Paddington Development Trust

1420 NHS Westminster 1456 Paddington Library

1291 Nicholas Evans 597 Paddington Police Station

1149 Nicholas Yarker 598 Paddington Regeneration Partnership Paddington Residents Active Concern on Transport 1186 Nicola Aiken 1131 (PRACT)

Appendix 2 – Contacts in the LDF consultee database

Ref Name of Organisation/Individual Ref Name of Organisation/Individual

599 Paddington Society 635 Planning Exchange

1304 Paddington Waterside Partnership 995 Planning Potential

601 Paddington Waterways & Maida Vale Society 637 Play Mates

603 Paints Pots Montessori School 1427 Plusnet

604 Pakistan Community Organisation 1641 Pocket

1154 Pamela Batty 638 Ponsonby Residents Association

605 PAN Westminster 640 Porchester Estate Residents' Association

1194 Papya Qureshi 1051 Port of London Authority

606 Parents & Childminders Drop In 643 Portobello Trust Crèche

607 Park View Lodge Pre-School 644 Powergen plc

608 Parkinson's Disease Society 1116 Pre - school Learning Alliance

1090 Parks & Leisure WCC 1204 Pre-School Learning Alliance- Tiny Tots Under 5

1336 Parliamentary Estates Directorate 1581 Project Blue (Guernsey)

1672 Parliamentary Works 1413 Project SRSG

609 Parsons House Residents' Association 1593 PRUPIM

610 Passage Day Centre & Night Shelter for Homeless People 1419 Public Health & Well Being Westminster PCT

1673 Patric Austin 1418 Public Health Intelligence (Westminster PCT) Pursuing Indpendent Paths- students with learning 611 Paul Davis & Partners 648 difficulties

612 Paul Dickinson & Associates 650 Queen’s Park Community Childcare Centre

1171 Paul Dimoldenberg 651 Queen’s Park Crèche

613 PCCG Licensing Working Party 652 Queen’s Park Family Service Unit

614 Peabody Avenue / Close Social Community Group 653 Queen’s Park Play Project

616 Peabody Trust 649 Queen's Park Bangladesh Association

617 Peacock & Smith 654 Queens Park Court Residents' Association

1158 Philippa Roe 655 Queens Park Estate Residents' Association

619 Philological Foundation 656 Queen's Park Estate Society

1083 Pimlico & Knightsbridge Labour Party 1458 Queen's Park Library

621 Pimlico Citizens Advice Bureau 657 Queen's Park Neighbourhood Forum

622 Pimlico Family Workshop 658 Queen's Park Youth Club

624 Pimlico FREDA 659 Queensborough Community Childcare Centre

1609 Pimlico FREDA 1623 R Fraiman

1457 Pimlico Library 661 RAC

625 Pimlico Playtots 662 Radha Krishna Temple

626 Pimlico Puffins 665 Rapleys

627 Pimlico Street Properties Association 1315 Rapleys

628 Pimlico Toy Library 666 Ravenstone House

629 Pimlico Village Play Centre 1579 Regent's College

630 PIP SW1 668 Reliance Security Group plc

632 Planning Aid for London 1661 Residents of Carlton House Terrace

1283 Planning Bureau Limited 670 Residents' Society of Mayfair and St James's

634 Planning Consultants 672 Rialto Homes plc 22

Appendix 2 – Contacts in the LDF consultee database

Ref Name of Organisation/Individual Ref Name of Organisation/Individual

1332 Richard Coleman Consultancy 706 Scope - Inner London Group

1244 Richard Garland 1634 Scott Brownrigg

673 Ringrose Kindergarten (Pimlico) 707 Scott Ellis Gardens Association

674 Ritterman Holdings 708 Scout Association - 2nd City of Westminster Scout Group Scout Association - Paddington and St. Marylebone Scout 675 RNJN Architects 709 District

676 Road Haulage Association Ltd 712 Selfridges & Co.

1160 Robert Davis 713 Semley House Residents' Association

1605 Robert Muriel 1540 Sense

679 Robin Bretherick Association 714 Servite Houses

1074 Rolfe Judd Planning 710 Shaftesbury Estate

681 Ropemaker Properties Ltd 1012 Shaftesbury plc

682 Rosary Over 60's Club 1152 Sharan Tabari

684 Royal Borough of Kensington and Chelsea 717 Shillaman Smith Architects

685 Royal British Legion - Metropolitan Region 718 Siddons & Stirling Residents' Association

1268 Royal Mail Group 719 Sierra Leone Youth Association

688 Royal Mail Property Holdings 720 Single Homeless Project

1545 Royal National Institute for Deaf People 721 Sisters of Charity - Blandford Street Hostel

1541 Royal National Institute of Blind People (RNIB) 723 Sixty Plus Group

1048 Royal Parks 725 Society for the Protection of Ancient Buildings

689 Royal Society for the Protection of Birds 726 Society of Travelling Peoples

690 RPS 727 Soho Community Centre

691 RPS Chapman Warren 729 Soho Family Centre

1629 RPS Planning 730 Soho Family Centre Playgroup

693 Rugby House Project - Crisis Centre 731 Soho Housing Association

1193 Rupert D’Cruz 732 Soho Society

694 Russell House Residents' Association 1644 Soho Society Planning and Environment Committee

1150 Ruth Bush 734 Somali Advisory Bureau

695 S J Berwin & Company 735 Somali Westminster Association

696 Sainsbury's Supermarkets Ltd 736 Somerfield Stores Ltd

697 Salvation Army - Edward Alsop Court 1635 South Central Management Ltd

698 Salvation Army Central Division 1127 South East Bayswater Residents Association

701 Sanctuary Housing Association - Dean Abbot House 740 South Eastern Trains

702 Sanctuary Housing Association - Wolfson House 1092 South Westminster Community Network Group

1148 Sarah Richardson 742 South Westminster Legal Advice Centre

704 Save London Theatres Campaign 1049 South Westminster Renewal Programme

1340 Savills 743 South Westminster Triangle Association

1466 Savills 744 South Westminster User Involvement Group (SWUIG)

301 Savills (incorporating Hepher Dixon) 745 South Westminster Victim Support

1206 Savills Commercial Limited 1407 Southern Electric Power Distribution Plc

1069 Savills Hepher Dixon 748 Spanish and Portuguese Jews Congregation

1554 SCOPE 1555 Spinal Injuries Association (SIA) 23

Appendix 2 – Contacts in the LDF consultee database

Ref Name of Organisation/Individual Ref Name of Organisation/Individual

1034 Sport England 790 Staying Put Service

751 SSAFA Forces Help (Westminster Division) 1624 Stefana Scimone

752 St George ( PLC) 792 Stephenson Harwood Solicitors St George's Square and Pimlico Square resident's 753 Association 794 Stepping Stones Community Childcare Centre

754 St James Homes 1185 Steven Summers

1282 St James's Conservation Area Trust 1628 Stewart Ross Associates

1459 St James's Library 795 Stockcredit Ltd

1460 St John's Wood Library 796 Stow Securities

1126 St John's Wood Society 798 Strategic Planning Advice Ltd

756 St Martins Property Investments Limited 1211 Strategic Rail Authority

757 St Mary's Hospital 799 Street Properties Association

758 St Paul’s New Pin 1556 Stroke Association

759 St. Andrews Club 800 Stroke Association - Parkside Dysphasia Support Group

760 St. Christina’s School (RC) 801 Stroke Association - Riverside Dysphasia Support Group

761 St. James’s Pre-School 1347 Strutt and Parker

762 St. John’s Montessori Nursery 805 Sudan People’s Support Association

763 St. John’s Nursery School 803 Sudan People's Association

764 St. John’s Wood Adventure Playground 804 Sudanese Community Organisation

765 St. John’s Wood Centre 1140 Suhail Rahuja

766 St. John’s Wood Junior Prep School 806 Sunrise Pre- School

767 St. John’s Wood Synagogue Kindergarten 807 Superintendent Belgravia

768 St. John's Guild for the Blind 1104 Sure Start Parent's Forum

769 St. John's Housing Association - La Verna House 808 Sure Start South Westminster

770 St. Jude’s Day Nursery 1159 Susie Burbridge

771 St. Judes Club 809 Sussex Street Play Project

772 St. Margaret's Drop-In Centre 810 Sustrans

773 St. Mark’s Square Nursery School 811 SWETA

774 St. Mary of the Angels Senior Citizens Club 812 Symonds

775 St. Marylebone Health Society 813 Tachbrook Nursery School

776 St. Marylebone Society 814 Tachbrook Pensions Club

1318 St. Marylebone Society 815 Tachbrook Tenant's Association

777 St. Mary's Hospital Estates & Facilities 1576 Taj Hotel Group

779 St. Nicholas Preparatory School 1437 TalkTalk

780 St. Stephen’s Day Nursery 1577 Targetfollow Estates Ltd

781 St. Stephen’s Play Project 816 Tea Dance Club

782 St. Vincent’s Family Project 817 Telewest Communications

784 St. Vincent's Hostel 818 Tesco Stores

785 St. Vincent's Over 60's Club 1436 Tesco Telecoms

786 Stagecoach - Selkent 1105 TfL

787 Standard Life Assurance Company 819 Thames 21

788 Standing Advisory Committee on Religious Education 820 Thames Gateway London Partnership 24

Appendix 2 – Contacts in the LDF consultee database

Ref Name of Organisation/Individual Ref Name of Organisation/Individual

1271 Thames Water Property Services 1667 The Westminster Older People's Network

1227 Thames Water Utilities Ltd 1249 Theatre Museum

821 The Angel Community Childcare Centre 1664 TheWestminster Reporter

822 The Association of Licensed Multiple Retailers (ALMR) 843 Thomas’s Kindergarten

823 The Berkeley Group 844 Thomas’s London Day Schools

824 The British Hospitality Association 845 Thorney Island Society

825 The British Land Company 847 Threshold Tennant Trust

826 The Central London Gurdwara 1219 Thus Plc

1082 The Chelsea Society 1176 Tim Joiner

1330 The Church Commissioners 1178 Tim Mitchell

1345 The Coal Authority 1429 Tiscali UK Ltd

827 The Cooper Group 849 Toddler’s Inn Nursery School

261 The Egyptians' UK Association 850 Toddlers & Mums Montessori

1410 The Electricity Network Company Limited 851 Tollgate Gardens Residents' Association

1013 The Environment Agency (Thames Regional Office) 1432 Toucan Surf

1323 The Eyre Estate 855 Town Planning Consultancy

828 The Flanders Club 856 Townshend Estate Residents' Association

830 The Forestry Commission 857 TP Consultancy

831 The French Nursery School 858 Traffic Committee for London

1325 The Georgian Group 1515 Transport for London

1662 The Grosvenor & Mayfair Residents Association 1079 Transport for London (Operational Property Division)

1669 The Inland Waterways Association 1008 Transport for London (TfL)

356 The Kensington Gardens School 860 Travis Perkins

419 The Knightsbridge Association 861 Treherne Architects

834 The Knightsbridge Kindergarten 1298 Tribal MJP

1616 The Langham Estate 1596 Trustees of the Tate Gallery

1592 The Mercers Company 1594 Turley Associates

836 The Mousehole Nursery, UCLH 862 Twentieth Century Society

1542 The National Federation of the Blind 1366 TXU Europe Limited

1567 The National Society for Epilepsy 864 Union of Muslim Families

1557 The Neurological Alliance 1251 Union Railways (north) Limited

1446 The Planning Inspectorate 865 United Women's Homes Association Ltd

1284 The Pollen Estate 1266 Universities Superannuation Scheme (USS)

837 The Portman Estate 1595 University College London Hospitals (UCLH)

1327 The Portman Group 1287 University of Arts London

838 The Rainbow Children’s Centre 1513 University of Westminster

1333 The Roman Catholic Diocese Of Westminster 867 University of Westminster

839 The Strand, Aldwych and Trafalgar Square Association 869 University of Westminster Nursery

1257 The Theatres Trust 870 Urbium

840 The Tree Council 872 Valpak

1324 The Victorian Society 1289 Verina Glaessner 25

Appendix 2 – Contacts in the LDF consultee database

Ref Name of Organisation/Individual Ref Name of Organisation/Individual

1225 Verizon 902 Westminster Association for Mental Health

873 Vestry 1084 Westminster Bangladeshi Association

1461 Victoria Library 904 Westminster Befriend a Family

1588 Victoria Palace Theatre Trust 905 Westminster Boating Base

1293 Victoria Partnership 1101 Westminster Central Network

876 Vincent & Gorbing 907 Westminster Children’s Society

1237 Virgin Media 909 Westminster Citizens Advice Service

1415 Voluntary Action Westminster (VAW) 1292 Westminster City Council - Community Protection Westminster City Council - Policy & Performance (Chief 877 Voluntary Service Department 1058 Executives Office)

1094 Volunteer Centre Learning Difficulties 1064 Westminster City Council's Property Division

878 Wand UK 910 Westminster Education Business Partnership

879 Warner Village Cinemas 1463 Westminster Faith Exchange

880 Warwick Crescent Residents' Association 1285 Westminster Health and Care Network

881 Warwick Day Nursery 913 Westminster Housing

882 Warwick Estate Residents' Association 1646 Westminster Housing

883 Warwick Estate Senior Citizens Club 914 Westminster Interfaith

1077 Washbourne Greenwood Development Planning 1464 Westminster Local Involvment Network (LINk)

1445 Waterman Environmental 915 Westminster Partnership

884 Watson Farley & Williams 1417 Westminster PCT / Community Protection

1675 WCC Emergency Planning 916 Westminster Play Association

1674 WCC Environmental Health 1663 Westminster Plus Publication (Senior Passport)

1421 WCC Finances & Resources (Property) 97 Westminster Police Licensing Officer

1602 WCC Policy and Performance (Local Area Agreements) 1255 Westminster Property Association (WPA)

885 Weatherall Green & Smith 1666 Westminster Race Equality Partnership

886 Weatheralls 1250 Westminster Refugee Consortium

887 WECH under 3s Drop In 1252 Westminster Senior Citizens Forum

888 WECH Youth Club 1321 Westminster Senior Citizens Forum

890 Wessex Gardens Residents' Association 1468 Westminster Senior Citizens Forum

892 West and North London Vietnamese Association 917 Westminster Senior Citizens' Forum

893 West End Central Police Station 841 Westminster Society

895 West London Synagogue 919 Westminster Somali Association

896 Westbourne Neighbourhood Association 920 Westminster Talking Newspaper for the Blind

1288 Westbourne Neighbourhood Forum 922 WHICH

2 Westbourne Park Residents' Association 923 Whitbread Plc

1 Westbourne Terrace Residents' Association 925 Wickham Van Eyck

897 Western Charitable Foundation 926 Winbourne Architects

899 Western Marble Arch Friendship Club 928 Windmill Montessori Nursery School Westminster (Police) Headquarters / Safer Westminster 912 Network 929 Wings of Hope

1665 Westminster Academy 930 Women with Voices

900 Westminster Action Network on Disability 931 Women's National Commission

901 Westminster Archives Centre 932 Wood Bank 26

Appendix 2 – Contacts in the LDF consultee database

Ref Name of Organisation/Individual Ref Name of Organisation/Individual

934 Woolwich Development Project Office 940 Young England Kindergarten

554 Workspace Group 941 Youth Information Shop

935 WRVS Darby and Joan Club 1088 Youth Service WCC

936 Yates Group PLC 942 YWCA

937 Yemeni Community Association 1535 Zoological Society of London

938 York Mansions Residents' Association 944 Zoroastrian Trust Funds Of Europe (Inc)

Appendix 3 – Specific consultation bodies

Mayor of London Corporation of London London Borough of Lambeth London Borough of Camden London Borough of Brent London Borough of Wandsworth London Borough of Southwark Royal Borough of Kensington & Chelsea Environment Agency Highways Agency English Heritage Natural England The Coal Authority Department for Transport/Network Rail London Development Agency Government Office for London NHS London NHS Westminster NHS London Healthy Urban Development Unit Westminster Primary Care Trust (PCT) Public Health Intelligence (Westminster PCT) Public Health & Well Being (Westminster PCT) EDF Energy Plc Southern Electric Power Distribution Plc Thames Water Utilities Ltd Thames Water Property Services Westminster City Council - Housing Westminster City Council - Community Protection

Appendix 4 – Issues and Options letter to the specific consultation bodies

Rosemarie MacQueen – Director of Planning and City Development

Date: 14th May 2007

Dear «Salutation»

Planning and Compulsory Purchase Act 2004 Westminster Local Development Framework Core Strategy Development Plan Document: Issues and Options

The ‘Core Strategy - Issues and Options’ paper is enclosed and we are seeking your views. There is a response form for you to fill out at the back of the document with a reply pre-paid envelope. In particular, we would like to know:

Are these the right issues? Are there other issues which we have overlooked? What options should we pursue to tackle these issues?

You can also view and print off the document and response form on our website www.westminster.gov.uk/ldf or request more copies by phoning 020 7641 3052/2503/2457. You can also e-mail: [email protected]. Copies of the document are also available for inspection at Westminster’s libraries and One Stop Services planning desks.

Please return your written comments to us by 29th June 2007.

Appendix 4 – Issues and Options letter to the specific consultation bodies

Yours sincerely,

Barry Smith Head of City Planning Group (Policy)

One Stop Services, 62 Victoria Street, London SW1E 6QP: Monday – Friday 8.30 a.m. to 7.00 p.m.; Saturday 9.00 a.m. to 1.00 p.m.

One Stop Services, 313 Harrow Road, London W9, Monday – Friday 8.00 a.m. to 5.00 p.m.

One Stop Services, 91- 93 Church Street, London NW8, Monday – Friday 8.00 a.m. to 5.00 p.m.; Saturday 9.00 a.m. to 1.00 p.m.

Appendix 5 – Issues and Options response form

CITY OF WESTMINSTER LOCAL DEVELOPMENT FRAMEWORK

ISSUES AND OPTIONS, MAY 2007

If you have any comments on the issues raised in this paper, please fill in the questionnaire below, attaching extra sheets if necessary, and return by the 29th June 2007. Thank you

Name:

Group/organisation (if relevant):

Address post code

e-mail:

telephone: fax: ______1. Do you agree that the issues identified in the document are generally the main issues that the City Council should be concentrating on? (please circle YES / NO / DON’T KNOW and write any comments in the spaces provided. Please use more sheets if necessary)

Climate Change and sustainable development

1 (A ) The UDP currently has policies to encourage sustainable measures in buildings. Should this approach continue, or should the policies be made stronger, requiring sustainable measures without which applications will be refused permission? For example:

Appendix 5 – Issues and Options response form

………………………………………………………………………………………… ………………………………………………………………………………………… …………………………………………………………………………………………

(i) Should we require large new commercial and residential schemes to demonstrate low energy demand and that the energy they do use is from low-carbon sources. YES/ NO/ DON’T KNOW ………………………………………………………………………………………… ………………………………………………………………………………………… …………………………………………………………………………………………

(ii) Should there be more specific and stronger polices making it mandatory for all developments over a certain size to incorporate Sustainable Urban Drainage Systems and other means to reduce the risk of flooding? YES/ NO/ DON’T KNOW

(iii) Should we introduce criteria-based polices for water efficiency in buildings or specific design-led polices to ensure effective adaptation of buildings to climate change? YES/ NO/ DON’T KNOW ………………………………………………………………………………………… ………………………………………………………………………………………… ………………………………………………………………………………………….

(iv) Should we require living roofs, where practicable, in all or just certain parts of Westminster. YES/ NO/ DON’T KNOW

1 (B) The Mayor of London is aiming to reduce carbon dioxide emissions by 20% by 2010 as the crucial first step on a long-term path to a 60%

Appendix 5 – Issues and Options response form

reduction by 2025. The draft further alterations to the London Plan states that Boroughs should, therefore, set targets for the generation of renewable energy and establish at least one ‘showcase’ renewable energy project in their area in order to raise the profile of renewable energy best practice. Do you have any comments on a renewable energy target? …………………………………………………………………………………………. …………………………………………………………………………………………. ………………………………………………………………………………………….

(i) Should Westminster introduce a target, together with policies requiring that a specific % of a new building’s energy requirement be derived from on-site renewables? YES/ NO/ DON’T KNOW ………………………………………………………………………………………… ………………………………………………………………………………………… …………………………………………………………………………………………

(ii) Should the City Council actively seek and designate development sites for new community heating combined heat and power (CHP) stations, and require such facilities on future large development sites? YES/ NO/ DON’T KNOW ………………………………………………………………………………………… ………………………………………………………………………………………… …………………………………………………………………………………………

1 (C) Should the City Council seek to allocate sites for waste management within Westminster or work more closely with other Boroughs in London to seek a sub-regional waste management solution? YES/ NO/ DON’T KNOW ………………………………………………………………………………………… ………………………………………………………………………………………… …………………………………………………………………………………………

1 (D) How should new parking for residential developments be provided in the future? For example:

Appendix 5 – Issues and Options response form

(i) Bearing in mind the high level of access to the public transport network across most of Westminster, should the City Council introduce policies for encouraging car-free housing developments in specific areas and/or specific schemes? YES/ NO/ DON’T KNOW ………………………………………………………………………………………… ………………………………………………………………………………………… …………………………………………………………………………………………

(ii) Should the City Council introduce different parking standards for different types of housing (taking into account number of bedrooms /tenure, i.e. market / social housing) or by different geographical areas? YES/ NO/ DON’T KNOW ……………………………………………………………………………………….. ……………………………………………………………………………………….. ……………………………………………………………………………………….. …………………………………………………………………………………… Central Activity Zones Central Activity Zones 2 (A) Should we extend the CAZ boundary as proposed in the draft further alterations to the London Plan? YES/ NO/ DON’T KNOW …………………………………………………………………………………………. …………………………………………………………………………………………. ………………………………………………………………………………………….

Opportunity Areas

2 (B) Should the Victoria and Tottenham Court Road ‘Areas of Intensification’ be re-designated ‘Opportunity Areas’’ as proposed in the draft further alterations to the London Plan and can the projected increase in jobs and homes be accommodated? YES/ NO/ DON’T KNOW ………………………………………………………………………………………………… ………………………………………………………………………………………………… ………………………………………………………………………………………….………

Economic Activity in North Westminster

Appendix 5 – Issues and Options response form

2 (C) In order to encourage economic activity in the north of the City, should we: (i) Extend the Paddington Special Policy Area to include the North Westminster Community School and Dudley House sites? YES/ NO/ DON’T KNOW …………………………………………………………………………… ……………………………………………………………………………. ……………………………………………………………………………. (ii) Extend the Edgware Road and Marylebone Road CAZ Frontage designations? YES/ NO/ DON’T KNOW ……………………………………………………………………………. …………………………………………………………………………… ……………………………………………………………………………. (iii) Allow greater flexibility for non-retail commercial uses in the Church Street and Harrow Road District Shopping Centres? YES/ NO/ DON’T KNOW …………………………………………………………………………… …………………………………………………………………………… …………………………………………………………………………… (iv) Designate an ‘Enterprise Zone’ in the north-west of the City where ‘affordable business space’, similar to affordable housing, should be provided in certain schemes? YES/ NO/ DON’T KNOW ……………………………………………………………………………… ……………………………………………………………………………… ………………………………………………………………………………

Housing and Employment

3 (A) Should the City Council allow for greater flexibility in the consideration of the residential component of commercial mixed-use schemes? For example:

(i) By not always requiring residential use as the first requirement when an increase in commercial floorspace triggers the application of the mixed use policy? YES/ NO/ DON’T KNOW ………………………………………………………………………………………… ………………………………………………………………………………………… …………………………………………………………………………………

Appendix 5 – Issues and Options response form

(ii) By not requiring the residential component to be provided ‘in the vicinity’ of the mixed-use scheme but anywhere within Westminster? YES/ NO/ DON’T KNOW ……………………………………………………………………………………….. ……………………………………………………………………………………….. ….……………………………………………………………………………………..

3 (B) How could the City Council increase the supply of affordable homes? Should we:

(i) Require an affordable housing contribution on all developments, including those below 10 units? YES/ NO/ DON’T KNOW …………………………………………………………………………………….. …………………………………………………………………………………….. ……………………………………………………………………………………..

(ii) When a proposed housing scheme contains exceptionally large units, calculate the affordable housing requirement based on a floorspace proportion rather than the current approach that uses a unit based proportion? YES/ NO/ DON’T KNOW ……………………………………………………………………………………… ……………………………………………………………………………………… ………………………………………………………………………………………

(iii) Reassess the proportion of affordable housing that is assigned to intermediate housing and social housing? YES/ NO/ DON’T KNOW ………………………………………………………………………………………. ………………………………………………………………………………………. ……………………………………………………………………………………….

Family Sized Homes

3(C) Should the City Council reduce, maintain or increase the proportion of family-sized homes in new residential schemes?

Appendix 5 – Issues and Options response form

YES / NO/ DON’T KNOW ……………………………………………………………………………………….. ……………………………………………………………………………………….. ……………………………………………………………………………………….. Local Distinctiveness

4 (A ) Should we designate a West End Special Retail Policy Area (WESPRA) as proposed by the Mayor in the draft further alterations to the London Plan? If so what should the WESPRA seek to do? YES/ NO/ DON’T KNOW ……………………………………………………………………………………. ……………………………………………………………………………………… ……………………………………………………………………………………… Other Special Policy Areas

4 (B) Should we define more Special Policy Areas (SPAs) for areas that have a special local distinctiveness e.g. Savile Row, St. James’s, etc? YES/ NO/ DON’T KNOW ……………………………………………………………………………………….. ………………………………………………………………………………………. ………………………………………………………………………………………. Building Communities

5 (A) How can the Core Strategy support the work of the Local Area Renewal Partnerships (LARPs)? What would be the implications for areas outside of the LARPs? ……………………………………………………………………………………… ……………………………………………………………………………………… ………………………………………………………………………………………

5 (B) Can you think of ways in which the City Council could work better with key organisations like the Primary Care Trust , Colleges, Universities, Police ,the London Fire and Emergency Planning Authority and the utility companies, to better deliver their services to Westminster's communities? ………………………………………………………………………………………… …………………………………………………………………………………………

Appendix 5 – Issues and Options response form

………………………………………………………………………………………… ……………………………………………………………………………… Night Time Economy

6 (A) Should the City Council expand the West End Stress Area or create new Stress Areas to include areas inside the CAZ adjacent to the main entertainment areas (e.g. parts of St. James’s, Mayfair and Fitzrovia)? YES/ NO/ DON’T KNOW ……………………………………………………………………………………….. ……………………………………………………………………………………….. ………………………………………………………………………………………. ……………………………………………………………………………………….

6 (B) Should the City Council designate areas which are either away from the main residential locations and which would benefit from complimentary low impact entertainment uses (e.g. the upper floors of premises on the Prime Retail Frontages of Oxford Street, Regent’s Street and Bond Street or along Victoria Street) or are in need of regeneration, e.g. Harrow Road and Church Street, where cafes and restaurants would add to the retail mix? YES/ NO/ DON’T KNOW …………………………………………………………………………………. …………………………………………………………………………………. …………………………………………………………………………………. 6 (C) Should the City Council adopt a strict policy approach of ‘no more’ entertainment uses in areas or parts of areas where entertainment uses have come to predominate or seek a reduction in high impact uses in some areas? YES/NO/DON’TKNOW …………………………………………………………………………………. …………………………………………………………………………………. ………………………………………………………………………………….

Appendix 5 – Issues and Options response form

Are there other issues that we should be looking at?

Which issues are of most concern to you, and why?

Do you have any other comments you would like to make?

THANK YOU ______

Appendix 5 – Issues and Options response form

When you have completed your questionnaire, please cut it from this document and return it in the pre-paid envelope provided by 5 p.m. on 29thth June 2007 to :

The LDF Team Core Strategy City Hall, 11th Floor 64 Victoria Street, LONDON SW1E 6QP

If you have any queries or comments, please contact the LDF by e-mail: [email protected]

Or telephone 020 7641 2457 / 2503 / 3154 / 2860

More details about the Local Development Framework can be found on the City Council’s website at

www.westminster.gov.uk/ldf

Data Protection

The personal information you provide will be used only for the purpose of consulting on the new planning documents for Westminster. All comments received by the City Council can be seen by members of the public and may be attributed to named individuals or organisations.

Appendix 6 – Locations of distribution

One Stop Services Westminster City Hall, 62 Victoria Street, London SW1E 6QP (Mon - Fri 8.30am - 7.00pm / Sat 9.00am - 1.00pm)

One Stop Services 313 Harrow Road, London W9 3RS (Mon, Wed, Thurs, Fri 8.00am - 5.00pm / Tues 8.00am - 7.00pm)

One Stop Services 91- 93 Church Street, London NW8 8EV (Mon, Tues, Weds, Fri 8.00am - 5.00pm / Thurs 8.00am - 7.00pm / Sat 9am - 3pm)

Charing Cross Library 4 Charing Cross Road, London WC2H 0HF (Mon 9.30am - 8.00pm / Tues, Thurs, Fri 9.30am - 7.00pm / Weds 10.00am - 7.00pm / Sat 10.30am - 2.00pm / Sun 11.00am - 5.00pm)

Church Street Library Church Street Library, Church Street, London NW8 8EU (Mon 9.30am - 8.00pm / Tues, Thurs, Fri 9.30am - 7.00pm / Weds 10.00am - 7.00pm / Sat 9.30am - 5.00pm)

Maida Vale Library Maida Vale Library, Sutherland Avenue, London W9 2QT (Mon 9.30am - 8.00pm / Tues, Thurs, Fri 9.30am - 7.00pm / Weds 10.00am - 7.00pm / Sat 9.30am - 5.00pm)

Marylebone Library 109-117 Marylebone Road, London NW1 5PS (Mon, Tues, Thurs, Fri 9.30am - 8.00pm / Weds 10.00am - 8.00pm / Sat 9.30am - 5.00pm / Sun 1.30pm - 5.00pm)

Mayfair Library Mayfair Library, 25 South Audley Street, London W1K 2PB (Mon - Fri 11.00am - 7.00pm / Sat 10.30am - 2.00pm)

Paddington Library Porchester Road, London W2 5DU (Mon, Thurs, Fri 9.30am - 10.00pm / Tues 9.30am - 9.00pm / Weds 10.00am - 9.00pm / Sat 9.30am - 5.00pm / Sun 11:00am - 5.00pm)

Pimlico Library Rampayne Street, London SW1V 2PU (Mon 9.30am - 8.00pm / Tues, Thurs, Fri 9.30am - 7.00pm / Weds 10.00am - 7.00pm / Sat 9.30am - 5.00pm / Sun 1.30pm - 5.00pm)

Appendix 6 – Locations of distribution

Queen's Park Library 666 Harrow Road, London W10 4NE (Mon 9.30am - 8.00pm / Tues, Thurs, Fri 9.30am - 7.00pm / Weds 10.00am - 7.00pm / Sat 9.30am - 5.00pm)

St James's Library 62 Victoria Street, London SW1E 6QP (Mon, Tues, Thurs, Fri 9.00am - 7.00pm / Weds 10.00am - 7.00pm / Sat 9.30am - 1.00pm)

St John's Wood Library 20 Circus Road, London NW8 6PD (Mon, Tues, Thurs 9.30am - 7.00pm / Weds 10.00am - 7.00pm / Fri 9.30am - 8.00pm / Sat 9.30am - 5.00pm / Sun 11.30am - 3.00pm)

Victoria Library 160 Buckingham Palace Road, London SW1W 9UD (Mon 9.30am - 8.00pm / Tues, Thurs, Fri 9.30am - 7.00pm / Weds 10.00am - 7.00pm / Sat 9.30am - 5.00pm)

Appendix 7 – Article in Westminster Reporter Issue 82, July 2007

Appendix 8 – Article in City of Westminster Planning Newsletter, Summer 2007

Appendix 9 - Issues and Options meetings minutes

Meeting: WPOA/WCC Meetings on LDF Mixed Use Development

Date of meeting: 2 May 2007

Attendees: Barry Smith WCC Graham Hadley WCC Sally Alderman WCC Sarah Gatehouse WCC Hugh Bullock WPOA Keith Hearn WPOA Paul Houston WPOA

Apologies:

Contact: Sally Alderman

Extension: 020 7641 6063

1. Introduction

BS advised that this was the first Core Strategy Issues and Options consultation meeting as part of the ‘frontloading’ exercise. He presented a factsheet on office led mixed use schemes 2000- 2007. Explained the tests of soundness and that No. 7 most appropriate in this instance (i.e. appropriate policies, alternatives considered and robust and credible evidence base for policy approach chosen). Advised that the new LDF system less adversarial than the UDP process.

BS explained that the Core Strategy Issues and Options paper had been approved by the Cabinet Member for Planning on 2 May but is subject to a five day call in period and will be available as a public document on 11 May 2007. Copies of the AMR 2005-2006 were handed out, as was the report to the Westminster City Partnership on the LDF.

KH and HB queried offices fact sheet floorspace figure, HB requested a CAZ only figure for mixed use/office schemes, also that we double check the number of residential units completed which seemed low. Also noted the Housing Commission report and importance of how many homes are produced per scheme. HB also questioned the housing trajectory in the AMR and that it will not meet targets.

HB advised that housing figures require a 15 year trajectory as evidenced in the London Plan. And that the documents produced by WCC should be evidenced based with future projections.

Action

WCC to check the figures in the Mixed Use fact sheet, the Housing Trajectory in the AMR and PPS 3 requirements.

Appendix 9 - Issues and Options meetings minutes

2. Mixed Use – Issues and Options

BS advised on the details of Issues and Options and presented maps including the Mayor’s proposed CAZ boundary and noted that most of the business growth was in the CAZ and Opportunity Areas. Paddington, Victoria and Tottenham Court Road are now all Opportunity Areas. BS advised on WCCs aspiration to encourage economic activity into the North West of the borough and that the Leader was keen to accommodate affordable business space and some of this could be provided in the central part of the City in addition to the north west. Overall projections were of more jobs and housing and accommodating this would be a key challenge for the LDF.

BS handed out copies of draft consultancy project brief – Assessing the importance of the historic environment to the office market in Westminster. The successful consultant would be required to discuss this issue with WPOA.

HB advised on the general complexity of the current situation with the interaction between mixed use, the requirement for housing and affordable housing and size of residential units (see below). He also commented on the possibility of JR’s for Action Plans if they include exceptions to policy without sufficient hooks within the main policy documents.

HB advised on sustainable development being of the highest priory and suggested that there is evidence that the Market is already delivering this and in some instances are ahead of the game. He also queried whether the principle of housing being the highest priority in the UDP had been revisited by Members. HB commented that the threshold value of existing assets was an important consideration in realising long term value. He noted the impact that WCC’s strict height criteria and BRE daylight/sunlight adherence/ interpretation can have on this. In particular, loss of light to one of two windows can result in refusal of scheme and this needs to be taken in context in delivering mixed use development. Do we need a special policy to address this matter? Also important in terms of any proposed increase in density. He advised on the numerous issues (including security, sharing means of escape, etc.) associated with mixed use developments and the impact this has on net/gross floorspace. Also expressed concern about inclusion of plant and car parking areas as gross floorspace. Plant areas are increasing in size to house sustainable/renewable technology.

SG advised that a legal view would be required in terms of use of conditions to control the potential use of plant areas as offices.

HB/KH suggested a meeting with Members (under Chatham House Rules) to seek some clarity on priorities (balancing say need for commercial development with affordable/family housing and car parking policies with sustainable development – see below) and to enable WPOA to explain the impact of interlocking policies on mixed use schemes.

Action BS to speak to Cabinet Member to see if he would be amenable to such a meeting/workshop

3. Mixed Use – Housing

HB stated that the Issues of affordable housing and size of units needs to be explored. In particular, considers the policy requirement for 33% family sized accommodation is misguided. HB referred to national statistics showing an increase in single person households and decrease in family households. Also that families do not want to live in flats in central London. The 33% policy results in under occupation of residential dwellings in Westminster. HB advised that his evidence to the WCC Housing Commission showed 14 different types of residential occupation in central London.

HB reiterated WPOA concern on reducing 10 unit criteria for affordable housing contribution and growing issue of large footplate residential units. WPOA supportive of City Council’s view that housing pressures need to be strategically managed and that answers may lie outside the borough boundary.

Appendix 9 - Issues and Options meetings minutes

HB raised the issue of existing residential parking policy and advised on a recent successful appeal in Harley Street.

HB requested meeting/workshop with Members (including Cabinet Member for Planning) to discuss these issues (and above) at an early stage.

Action As above BS to speak to relevant Members to see if they would be amenable to such a meeting/workshop.

Appendix 9 - Issues and Options meetings minutes

Meeting: WPOA/WCC Meetings on LDF Offices

Date of meeting: 15 May 2007

Attendees: Barry Smith WCC Graham King WCC Graham Hadley WCC Hugh Bullock WPOA Robert Noel WPOA Paul Houston WPOA

Apologies:

Contact: Graham Hadley

Extension: 020 7641 2503

1. Introduction

BS/GH distributed copies of the Core Strategy Issues and Options paper, a revised mixed use fact sheet and an analysis of Office schemes permitted and completed 2002 to 2007. All agreed these were useful overviews and that a robust evidence base needs to underpin the LDF and in the light of this early sharing of evidence from all parties was to be encouraged.

2. Offices discussion

RN advised: the current vacancy rate (4.6% in the West End market) was below the 5% level that should be a minimum to aim for the economic life of an office building was 20 years on average recent Knight Frank stats illustrated that 92% of transactions in the West End market were for offices of less than 10,000 sq ft in size and this accounted for 64% of the value of transactions Employment densities (amount of floorspace per worker) in London were lower than in New York There was demand for large office floorplates in the right locations e.g. Cardinal Place example Headline prime rents mentioned in the media of £100+ per sq ft were only in relation to a handful of sites in the West End. Average rental levels are about £45 per sq ft . High rental growth currently though Office market more dynamic then 10 -15 years ago and a broader demand base. Emerging and high demand from Eastern Europe and China for HQ and/or representative offices in the West End.

Appendix 9 - Issues and Options meetings minutes

GK commented: Private sector generally occupies office space at lower densities (i.e. more space per worker) than the public sector Victoria office market will be affected by future relocations by TfL and the civil service What future capacity is there in post war buildings through redevelopment and/or refurbishment across Westminster? Paddington largely spoken for and have good idea of its capacity Need greater understanding of the capacity of Victoria and West End (ORB action plan area). Achieving larger floorplate buildings should not be at the expense of displacing variety of use, character and function in the West End.

BS mentioned the intention to promote more economic activity in NW Westminster and the proposed Enterprise Zone

HB commented: Need to assess the higher growth rates of Westminster’s economy and the offices demand that creates and how to cater for that Need to consider how to re-incentivise the development process at the margins Raised concern at the cumulative impact of policy requirements, e.g. mixed use approach, affordable housing and on site plant requirements, in affecting the extent of development brought forward Need to reassess the strict no increase in offices outside CAZ policy approach of the UDP to help provide additional space.

Action RN/HB agreed to provide WCC with any relevant information on employment densities and occupation of office space

3. Small offices

HB/RN considered that the small offices approach of the UDP should be revised as there was no shortage of small office space in Westminster and that there had been a marked expansion in the serviced offices sector since the policy was first drafted. Regent Street direct was a good recent example of flexible and multi-let space. GH/GK stressed that 70% of businesses in Westminster had less than 5 employees BS/GK queried how the needs of the creative industries could be met in this context and referred to the creative industries study that WCC has commissioned

Action RN agreed to supply information to WCC on recent trends in the serviced office sector in Westminster.

4. Other aspects

RN mentioned that there were increasing levels of vacant institutional uses in the Portland Place SPA and that office uses should be allowed for in Park Crescent specifically.

RN mentioned that there were increasing levels of vacant showroom uses in East Marylebone and the rag trade was contracting further. The UDP policy approach of the protection of showrooms for the rag trade should be reviewed.

Action RN agreed to provide information to WCC on the use of showrooms in Great Portland Estate portfolio and offered officers a walkabout of the E Marylebone area. GH/BS to follow up after receipt of this information.

Appendix 9 - Issues and Options meetings minutes

Meeting: WPOA/WCC Meetings on LDF Retail Forecasts – Demand/the International Centres

Date of meeting: 18 May 2007

Attendees: Barry Smith WCC Graham King WCC Keith O’Malley WCC Hilary Skinner WCC Hugh Bullock WPOA Robert Noel WPOA

Apologies:

Contact: Hilary Skinner

Extension: 020 7641 2531

1. Introduction:

BS/HS distributed copies of a ‘Retail Use Schemes’ fact sheet and analysis of retail schemes permitted and completed 2002-2007

2. Discussion:

Based around retail in the West End International Centre and the Primary Frontages.

RN highlighted changing trends in customer activity, and informed us; that retail is now seen as a leisure activity more than it was in the past that retail is more location sensitive than other land uses that increasing the amount of retail in places such as train stations may make them too overcrowded by attracting non-commuter customers as well as already heavy volumes of commuters. of traffic flow issues, where certain shopping frontages may not be frequented by pedestrians as they are less accessible as others, for example, pedestrians may not want to cross main roads (such as from Harrods to retail uses across Knightsbridge) of changes to freight/delivery patterns, and internet shopping, where retailers may be making more deliveries to private homes than they did in the past.

RN stated that; there is demand for new stores/flagship stores in this area, and from new companies including some from Eastern Europe department stores do work if they are unique and offer something the others don’t. BS highlighted the council’s concerns that such uses are being lost to non-retail uses, even though they occupy key sites in the West End

Appendix 9 - Issues and Options meetings minutes

RN explained there is proven demand for units of approx. 10,000 square feet, split between ground and first floor levels on the main shopping frontages, with smaller properties located elsewhere. In his view there is no demand from retailers to occupy upper floors in the Primary Frontages

Actions WCC need to define our position and explain what we want to happen and review Shopping and Services policies as the benefits of an entrance to upper floors at the expense of loss of retail at ground floor may be beneficial overall

WCC to analyse size of retail schemes and the number of them – cutting off the largest and smallest to show average sizes

3. New floorspace/uses

BS emphasised our reluctance to develop a cloned centre like White City in Oxford Street east, and our reluctance to miss opportunities to allow retail growth

BS suggested potential for: short-term lets/temporary sleeping accommodation/time-shares as the mixed-use element on the upper floors of Oxford Street east as there is a demand for such uses, and this would help reduce drain on regular housing stock elsewhere in the city

RN/HB highlighted; our need to make new floorspace available to meet the existing demand rather than to allow new uses coming in to force existing uses out and to supply larger floor-plates using land assembly to help meet need (although we would need to show the viability of these) the potential for hotels/development at Piccadilly, including in Devonshire House which was originally built for residential

4. Going forward

Other issues raised related to; reversibility i.e. the ability to change back to original uses if new uses are not successful being innovative – if we can’t test things in Oxford Street where can we? what we might be missing – i.e. what would suit upper floors in these locations as we don’t want to miss out on major opportunities cross-borough working with neighbouring boroughs including Camden

Action WCC to look into RN/HB suggestion to use Retail Group for research purposes – to discuss retail/leisure mix: Paul Freighter Based on German Street Tel: 020 7439 1234 Mobile: 07753 824 042

Appendix 9 - Issues and Options meetings minutes

South Westminster Steering Group Meeting Minutes 24th May 2007, CityWest Homes

Attendees Emma Beals (EB) South Westminster Renewal Partnership Karen Clark (KC) Westminster City Council Keith Cookson (KC) CityWest Homes Ruth Duston (RD) Victoria Partnership Ltd Graham Hadley (GH) Westminster City Council Sue Hannah (SH) South Westminster Renewal Partnership Carol Hayton (CH) Threshold Housing David Parker (DP) Westminster City Council Andrew Ralph (AR) Westminster City Council John Ryan (JR) Abbey Community Centre Susie Schwartz (SS) Westminster City Council Heidi Stuetzel (HS) Westminster Primary Care Trust Susannah Wilks (SW) Cross River Partnership Emma Wilson (EW) A Moveable Feast

Apologies Jane Buttiegieg (JB) South Westminster Community Network Dee Hazeldene Lloyd GRMO Patricia Alert Sure Start Children’s Centre

1) Introductions and apologies

2) Victoria Partnership Ltd – Ruth Duston

3) Overview of Westminster’s Local Development Framework – Core Strategy – Graham Hadley

Copies of Westminster’s Local Development Framework were tabled.

GH explained the main points from the previously circulated briefing note. Planning in Westminster is about finding ‘balance’. The Local Development Framework (LDF) is a 3 year programme comprising of planning documents, including the Core Strategy which is a 15 year plan. The Core Strategy must align with the Mayor’s London Plan and have regard to national planning policies.

The Council is currently in the Issues and Options stage with the Core Strategy, which has an emphasis on consultation and community involvement. They are keen to find out the needs of all partners and users etc, and build on priorities. The consultation runs until early July.

6 strategic issues have been identified that the Core Strategy will address. The SWRP need to understand the implications involved of the relevant spatial options raised. Some discussion was held around these. Commentary explanations can be found in the LDF.

Appendix 9 - Issues and Options meetings minutes

Option 2A – p18 The proposed extension of the Central Activity Zone (CAZ) boundary would result in pressure for increased commercial activity over residential activity. WCC do not see the logic in this. This would have an effect on affordable housing provision (affordable housing within the CAZ is 30%, and outside CAZ is 50%).

Option 2B – p19 The proposed ‘Opportunity Area’ extension covers the Chelsea Barracks – again this would have an effect affordable housing.

Option 3B – p24 SH to submit the SWRP response to the Housing Strategy

Option 5A – p30 WCC are eager to align with the LARP priorities.

Action: SH to provide GH with revised SWRP priorities SWRP’s response to the Housing Strategy SWRP’s headline issues regarding the relevant spatial options by 3rd week of June

WCC will produce a preferred options document in the autumn, with policy developed for comment in spring 2008. GH emphasised that the views of residents and the public will be incorporated into the Council’s lobbying.

4) Minutes and matters arising

5) Projects update

6) Community Survey

7) Updates from Sure Start and A Moveable Feast

8) Updates from Community Network and Renewal Partnership sub groups

9) AOB

Next Meeting 19th July, extended time 10am – 1pm – Chair: Carol, Minutes: John. Venue to be confirmed

Appendix 9 - Issues and Options meetings minutes

Minutes

Status Draft

Meeting PSPA Developers Liaison Meeting

Date and Venue of Meeting 12th June 2007, Paddington First Office

Attendees Roger Bloom (RB) WCC Graham Hadley (GH) WCC Don Murchie (DM) WCC James Birkett (JB) Land Securities PLC Howard Wright (HW) European Land Kay Buxton (KB) PWP Cathy Davies (CD) PWP Alison Shields (AS) Paddington Central Helen Fisher (HF) Development Securities Karen Lee (KL) WCC Tim Butcher (TB) WCC

Apologies Graham King

Item Action 1. Introduction and Apologies

RB welcomed members to the meeting. Graham King sent his apologies.

2. Core Strategy GH gave a presentation on the Core Strategy (CS) Issues and Options Paper.

Background The UDP (Unitary Development Plan) was adopted in January 2007 and will be effective till the LDF emerges in 2010. LDF is a folder of documents with the emphasis on constant review and great flexibility to respond to developing planning issues nationally, regionally and locally. It focuses on community involvement and spatial planning to incorporate the interests and objectives of stakeholders to define WCC’s vision for the future development of Westminster. The LDF includes the CS, the adopted plan, Development Plan Documents (DPDs) and Supplementary Planning Documents (SPDs). The CS is the most important document of the framework. It forms the main strategic umbrella for the development of the LDF and all documents must be consistent with the CS. The CS for Westminster, once adopted, will be effective till 2025. The CS questions the Mayor’s London Plan (further alterations) and the role Westminster should play in the wider London context. The Examination in Public (EiP) for the London Plan starts on 18th June for 10 days.

Appendix 9 - Issues and Options meetings minutes

Context of the CS Issues and Options The CS presented at this meeting is the initial consultation document. It is anticipated that the final document will be ready for submission in Spring 2008. There is a high failure rate (50%) of the ‘soundness’ test of the CS hence there is a strong emphasis on active engagement and consultation of stakeholders in the policy design and delivery processes. Unlike the UDP, there is no further leeway to change the CS after adoption. The Issues and Options paper is structured around six key strategic issues, providing 17 set of options. 1. climate change and sustainable development 2. accommodate growth and change while maintaining economic diversity and vitality 3. balance between growth in housing and employment whilst meeting housing challenges 4. support Westminster’s role as a world class City while retaining distinctiveness (this is a test where a number of earlier CSs have failed) 5. sustainable communities 6. night time economy. The CS consultation formally ends on the 29th June. GH is happy to receive comments till mid July. KB queried the difference between the CS and the City Plan. GH noted that the Westminster City Plan 2006 – 2016 is the Community Plan of Westminster and the CS is the spatial expression of the City Plan till 2025. A further difference between the CS and the City Plan is the CS is subject to sustainability appraisal.

Discussion

Option 1A – should we ‘require’ or ‘encourage’ sustainable measures in buildings? RB noted that Westminster and the British Property Federation are jointly developing guidance on sustainability issues for commercial properties instigated by Department of Communities and Local Government. HW outlined his views based on his experiences in developing the Merchant Square proposals: 1. it is difficult to formulate detailed policy advise due to the rapid technological changes which might produce more effective and flexible solutions to enhance sustainability e.g. changes in building methods. 2. European Land is happy to invest in the reduction of the carbon footprint of buildings since it makes sound commercial sense. He quoted Merchant Square as an example and noted that their organisation is happy to invest in renewable energy solutions and sustainable buildings. However the market implications of alternative solutions need to be clearly explored. 3. a constraint had been in some cases the quality of the engineering advice and solutions on offer. 4. guidance needs to concentrate on the effective solution, for example encouraging heat reduction through reusing water vapour to cool down buildings rather than necessarily the portion of renewable energy used. 5. he suggested the Council could encourage the use of renewable sources by sourcing a reliable biomass supply and using WCC’s powers of coordination to ensure a smooth generation of the market. 6. while it is important to explore the potential to buying offsite power supply, exploring the benefits of generating the energy on site should be encouraged to achieve carbon neutral development, e.g. at Merchant Square, five generating plants are present and generate

Appendix 9 - Issues and Options meetings minutes

23% of energy on site for the development HF supported the comments HW made and further emphasised that any sustainable measures target adopted needs to allow flexibility between sites and their varying scale, proposed uses and constraints. Some mixed use sites may be appropriate for a combined heat and power system but single use sites such as the future phases of PaddingtonCentral would not be able to accommodate this as they have no use for the waste heat. It would be difficult to expect all sites with their varying constraints and proposed land use to conform to a single set target and each site should instead be looked on a case by case basis to optimise sustainability measures in their development. HW stressed the importance of using by-products resulting from energy consumption efficiently to reduce further resources consumption, e.g. investing in Environmental Management Systems and utilise energy from exhaust to cool down the operations on the development. JB noted that a bore hole was installed at the Eastbourne Terrance development as part of the sustainable measures. This had however, led to concerns during the period of prolonged drought. JB highlighted potential problems with the heating of the local water table using this method.

Option 1D – car parking

HW reported that they have suffered a big loss on delivering the required car parking spaces at Hermitage Street. Each space could only be sold at well below the costs of provision. He noted that the car parking provision formulae should be reviewed as per the nature of different developments. He had forwarded a paper to GK which covered this issue in greater detail. HW noted that residents choose on street parking rather than pay for an off site space. HW questioned the requirement to seek a minimum of one or 20% of parking spaces, whichever is the greater, as disabled car parking in developments. In his experience, they were not taken up by disabled residents but wealthier residents who would make use of the extra width. He quoted one example in which only one disabled car parking space was sold in a 800 flat development and emphasised that the policy has no direct linkage to the nature and characteristics of developments. He noted that in the Merchant Square application they have offered an alternative arrangement in which three disabled car parking spaces will be provided in each car park where they will remain for rent permanently and on a first come first serve basis. HW also noted that they would like to see policies being more flexible to allow a better mix of motorbike spaces and cycling storage with car parking facilities as the demand for these facilities varies for different developments.

Option 2C(i) – extending the PSPA boundary to include the North Westminster Community School and Dudley House sites

KB noted it is sensible to extend the boundary to cover the two sites.

Option 2C(iv) – ‘enterprise zone’ in the north west of the City

HW remarked that they were proposing 4,000 sqm of subsidised office space to encourage business startups in the Merchant Square development. The letting is free for the first three years of 10 years subsidised tenancy, with a 75% discount for the next 2 years, and 25% for the last five years. 60

Appendix 9 - Issues and Options meetings minutes

Option 3B – affordable housing

HW emphasised that the economic implications of providing affordable housing were of major concern to developers. He had found the difference in emphasis between WCC and the Mayor in dealing with major schemes. The developer was not always clear when financial contributions were made instead of on site provision that the money resulted in increased provision of affordable housing. He expressed the view that the large amount of listed buildings in Westminster hindered the provision of affordable housing as the redevelopment and maintenance cost will be more expensive. He also noted that the UDP policy to provide mixed use commercial and residential meant that affordable housing units to be provided under policy were also after a small proportion of the total development policy management issues difficult for R.S.Ls. HW further highlighted that WCC does not refund the S106 obligations if the affordable housing cannot be delivered.

3. S106 and Social and Community Fund Account (S&CFA) 4. Paddington Station and Environs Planning Brief 5. Progress on Current Proposals/ Projects 6. Paddington BID, Paddington First and Time for Paddington 7. AOB 8. Date of next meeting

18th September 2007, with special focus on PATS and PATEMS review.

Appendix 9 - Issues and Options meetings minutes

Westminster Community Network 14 June 2007

Attendees Name Network or organisation Maryam Zonouzi Disability Network Chris Reed Westminster Volunteer Centre Daniel Mapp Voluntary Action Westminster Mostafa Ragab BME Network Pamela Park Voluntary Action Westminster Mary Nicholas Westminster Federation of Residents’ Associations Margaret Handovsky Westminster City Council Collette Willis Westminster City Council Somru Miah North Westminster Community Network

NB Daniel Mapp included a note on the Core Strategy consultation on the news section of the VAWS website and emailed members to alert them to it.

Margaret Handovsky and Collette Willis attended this meeting on behalf of the City Planning Group. Margaret discussed the Local Development Framework and the role of the Core Strategy in the new plan making system. Then Collette introduced option 5B How can the Core Strategy best assist Westminster City Partnership agencies.

Other options highlighted of interest were regarding affordable and family housing, but the group felt they had already recently responded to the Housing Department on these issues. NB Look at Housing Strategy consultation responses.

A copy of the Core Strategy Issues and Options and summary note had been emailed with the agenda beforehand. Further copies of the Issues and Options document were handed out and attention brought to the questionnaire at the rear of the document, and the deadline of the end of July.

The chair of the group Maryam Zonouzi and Pamela Park offered to oversee the coordination of the response.

Comments Lack of affordable nursery provision for working parents was raised.

The issue of affordable space for community groups to work from and meet was raised as a key issue, particularly for smaller organisations . Chris Reed (Westminster Volunteer Centre) mentioned that some work on identifying needs for premises space had been carried out and would forward this to us.

Pamela Park (VAW) said that the LARPs and groups such as SureStart should be contacted regarding identifying needs as they seek views on this already. Maryam Zonouzi (WCN Chair) said they were a lot of community networks we could tap into to seek views on community needs including premises and facilities, and would provide contact details.

Mostafa Ragab (BME Network) raised the issue of capacity building and supporting, ie funding and resourcing community groups was key to encouraging community involvement and participation.

Maryam Zonouzi thought that the lack of affordable, flexible use spaces for community groups to meet, meet each other, and operate from was a major barrier to building cohesive, tolerant, and neighbourly communities. Provision of such facilities was missing from policy and S106 agreements which concentrated on more tangible services like doctors’, dentists, leisure facilities, schools and

Appendix 9 - Issues and Options meetings minutes nurseries. She also asked that on major development proposals there should be more community involvement from inception through to completion (rather than just at inception).

Minutes from WCN:

Local development framework Margaret Handovsky and Collette Willis attended the meeting to seek input from the WCN committee on the local development framework (a document that reflects the City Plan, interpreting it in a spatial sense).

In the initial stage there will be wide consultation on the document. A second stage will seek feedback on preferred options.

Maryam commented that it was difficult to be too specific without a through understanding of the scope of the plan. What are the limits of its power?

The WCN made the following comments: o In terms of the sector, office space is a real concern. Particularly for smaller organisations. Chris Reed commented that there has been ongoing work on premises – but without any concrete application from planning. Margaret Handovsky commented that Westminster City Council was getting better at responding to demands for a particular site. But there is a need to embed needs into structures and planning, so that they’re widely applicable. In terms of seeking community engagement, infrastructure organisations are a good place to start.

There is a need for flexible community space – at an affordable rent. Social benefit can offset the lower rent.

DM to forward contact details for James Murray. Best way to consult is to contact community groups directly. There is a need to ensure that consultation structures are adequately resourced.

Maryam recommended Margaret and Collette review the WEMNA report, contact James Murray at Hanson Consulting, and engage with local umbrella groups.

Section 106 money needs to include resources for community and voluntary sector, embedded into policy.

It is important not to repeat consultation – regarding housing, there is the housing strategy.

Maryam and Pamela to meet to prepare a WCN response.

Appendix 9 - Issues and Options meetings minutes

Meeting: Meeting on LDF Core Strategy with the Westminster Amenities Society Forum

Date of meeting: 3 July 2007

Attendees: Chairman - Matthew Bennett – Soho Society Barry Smith - WCC Graham Hadley -WCC Simon Walton – SEBRA Tom Ball - Thorney Island Society Anne von Bennigsen – LV & MUS Martin Ford - Harrowby & District John Villiers - St John’s Wood Society Peter Handley - Westminster Society Cynthia Poole - St Marylebone Society Yoram Blumaln - Fitzrovia Neighbourhood Association June Stubbs - Thorney Island Society and Friends of St James’s Park and Green Park Verina Glaessner– Thorney island Society John Walton – PRACT/SEBRA Carl Upsall - Marylebone Association Mary Nicholls – Queen’s Park Estate John Zamit – SEBRA & BRA Max Neufield – Charlotte Street Association K Smalley – North Paddington Society Stephen Quinn – Marylebone Association Stefania von Kories zu Goetzen – Mayfair and St James’s

Apologies: Max De Trense, Peter Denton, Elizabeth Virgo, David Bieda

Contact: Graham Hadley

Extension: 020 7641 2503

1. Introduction

Copies of the LDF Core Strategy issue and options paper, the Annual Monitoring Report, the CD- ROM version of the UDP and the summary version of the UDP were handed out.

BS gave an introduction, with reference to the briefing note that had been circulated to WASF members in advance, and outlined the new plan making system – the Local Development Framework (LDF) – and the statutory processes the Council has to go through in preparing the Core Strategy - which is the principal document of the LDF.

He explained: The intention that the LDF will replace the current Unitary Development Plan (UDP) by early 2010, but that the UDP’s policies will remain in force until then.

Appendix 9 - Issues and Options meetings minutes

The Government’s greater emphasis on spatial planning which is wider than just raditional land use matters and allows WCC to integrate and align City management policies within the new LDF e.g. in relation to planning and licensing. The greater emphasis on community involvement and partnership with other agencies and service providers that can help deliver the Council’s spatial planning strategy The relationship between the LDF and the London Plan, that the Mayor was currently revising, and the difference in procedures between the two. The importance of a robust evidence base to underpin the Council’s preferred approach and the ‘tests of soundess’ which the independent Government inspector would be assessing the LDF against during its public examination stage in 2009. The difficulties all London local authorities were facing in implementing the new plan making system, giving the example of Islington recently having to withdraw its Core Strategy due to a shortfall in its housing target compared with the Mayor’s London Plan.

2. Discussion

The key points raised by WASF members in discussion were: Objections to the Mayor’s plan to extend the Central Activities Zone to cover predominantly residential parts of Westminster in Marylebone and Pimlico and the Royal Parks The intensification and ‘densification’ of development proposed by the Mayor in the London Plan in central London and its implications for living and working in Westminster and how this is being imposed on the City Council Questioning why Westminster should accommodate more growth The ‘process’ rich nature of the new plan making system and the unlikelihood of the timetable being followed especially given the potential policy ‘conflicts’ with the Mayor The need for additional transport and social infrastructure to support the current working and living populations let alone to accommodate any forecast additional population The need to assess the capacity of Westminster to accommodate future growth and its impacts on quality of life, open space. A social audit as part of the evidence base in relation to community and health needs should be carried out. It was queried if the review of the Statement of Licensing Policy would be part of the LDF. BS explained that the Core Strategy would not replace other strategies the Council produced but that the Core Strategy would reflect the aspirations and strategic approach of such other strategies. It was suggested the London Boroughs should be more proactive in challenging the new plan making system There was concern about the impact of buy to let mortgages and their impact in properties not being available for more permanent residents. How would the LDF express and maintain local distinctiveness? How would action plans like the draft Oxford Street, Regent Street and Bond St (ORB) link with the LDF? BS explained the relationship. The LDF needs to embrace adapting to climate change otherwise the West End may become much less attractive as a destination. The University of Westminster are doing some scoping research into this aspect. The LDF needs to more explicitly recognise the issue of improving air quality in Westminster and how to address this. The Portman and Grosvenor Estates are doing some research into making their areas more pedestrian friendly and this should feed into the LDF evidence base

3. Action Points

BS/GH to circulate to WASF members, comments received to date on the LDF Core Strategy from the Government Office for London, the Greater London Authority and the Westminster Property Owners Association. BS/GH to circulate an electronic version of the questionnaire that is at the back of the Core Strategy consultation document for WASF members use. WASF members, who wish to, to send their written responses on the LDF Core Strategy – issues and options consultation before the end of July.

ITEM 1

Appendix 9 - Issues and Options meetings minutes

CYPSP Board meeting minutes 6th July 2007

Board members present: Steve Farnsworth (Chair), Kerry Crichlow, Mike Potter, Bernard Collier, Paul Jenkins, Suzanne Parry, Jackie Rosenberg, Chris Wright, Chief Supt Dean Ingledew, Valerie De Angelis (second Primary School representative), Eugene Moriarty (interim secondary schools representative), Judith Barlow (for Joe Gannon), Rebecca Ireland (for Greg Roberts), Lynda Hassell (St Mary’s Hospital representative), John Vaughn (CNWL representative). Also present: Jane Derbyshire, Ann-Marie Smith, Helena Merriott, Gillian Dawson, Phillip Berechree, Hilary Barnard, Kerry Russell (minutes).

Board members apologies: Jo White, Debra Okitikpi, June O'Sullivan, Michael O'Connor, Julie Jones, Greg Roberts, Joe Gannon

ACTIONS Item 1 The nominated Deputy Chair is the Director of Schools and Learning. SF introduced himself and welcomed new members of the board and those representing Board members. Items 3 & 4 Minutes and Matters arising Item 5 VAW report on partnership working Item 6 CYPP Review of Year 1 and Refresh for Year 2 Item 7 Core Strategy of the Local Development Plan

Gillian Dawson and Helena Merriott from WCC’s Planning dept gave a presentation on the Local Development Plan (LDP) portfolio of documents, this includes a Statement of Community Involvement and a Core Strategy. The Board members to LDP replaced the Unitary Development Plan (UDP) in 2004. It sets out complete development in the borough. questionnaire at back GD and HM had prepared a summary paper listing the 7 options of change of the document. which are most relevant for cyp. The CYPSP Board were asked to feed in issues that would effect cyp. The consultation end 31st July. Members agreed GD and HM to meet to respond on behalf of their own agencies, rather than submitting a thematic with individuals over network response. The Board considered the consultation timely given that specific issues. the NHS are examining their property portfolio, WCC children’s services and children’s centres are localising and the Met. are focusing on neighbourhood policing. PCT will feed in via Property Development Group (chaired by Marion Harrington). PJ informed us that Health for London will be published in July with proposals for multi-agency health one stop style shops. WCC Directors

Appendix 9 - Issues and Options meetings minutes will be consulted individually BC asked that VCS be listed as an agency under Option 5B. He informed that lack of available premises is one of VCS’ biggest issues. Board members were concerned about Marylebone Rd. It’s the biggest polluting road in England and adjacent to our 2 most deprived wards. GD confirmed air quality be included in Core Strategy. Open play space for cyp must be a priority in Westminster, particularly in all new build plans To regenerate the NW of Westminster, LDP could consider having a north hub for council workers situated there, out of City Hall. BSF investment of c. £330m to be a main consideration in Core Strategy LSC are investing £150m in FE estates Board would like any money made from the sale of educational establishments to be reinvested in educational services. GD and HM to return SF summarised that there were important strategic issues for CYP involved to CYPSPB to discuss which require further discussion. further at next stage. GD and HM will evaluate responses, appraise them and issue preferred options in Oct/Nov 07.

Item 8 An Anti-Bullying Strategy for the Partnership Item 9 CAMHS needs assessment and new strategy document Item 10 Terms of reference for Children’s Strategic Commissioning Group Item 11 Post JAR, EYI and YOT inspections Item 12 Westminster City Partnership summer workshop AOB

The next CYPSP meeting will be Wed 26th September, 3-5pm in Committee Rooms 5/6, 17th floor, City Hall.

Appendix 9 - Issues and Options meetings minutes

Westbourne Neighbourhood Forum (Westbourne LARP) LDF Consultation 18th July 2007

Key issue 1: Sustainable Development

Q1 – Should the City Council be less strict about protecting open spaces, providing the proposed use is of benefit to the local community, e.g. by providing affordable housing and/or community uses?

1) Only open spaces and only is the community agrees (every single one) 2) Only for local residents 3) No, protect all open spaces  green no  brown OK New homes need new open space.

Use instead: Wharf Road Fire Station Edgware Road

Q2 – How should new parking for residential development be addressed in the future? For example:

(i) Should the City Council continue to protect all off-street residential parking spaces? Would it be acceptable to use some garaging and spaces for new homes?

1) Yes. 2) No, only if not being used  are they safe? Maybe they would be if safe.

(ii) Should the City Council introduce policies to encourage car-free housing developments in specific schemes?

Yes, providing cannot apply for resident parking permits.

Key issue 2: Housing and Employment

Q3 – How could the City Council increase the supply of affordable homes (both rented for residents in need and intermediate housing for key workers and others on low to medium incomes) and ensure that what is built is what is most needed? Should it for example:

(i) Require an affordable housing contribution on all developments, including those below 10 units?

Possibly

(ii) When a proposed housing scheme contains exceptionally large units, should it calculate the affordable housing requirement based on a floorspace proportion rather than the current approach that uses a unit-based proportion?

Yes

(iii) Reassess the proportion of affordable housing that is assigned to intermediate housing and social housing?

Appendix 9 - Issues and Options meetings minutes

70:30 – if widened to include those other than key workers

(iv) Reduce, maintain or increase the proportion of family-sized homes in new residential schemes?

1) More family 2) Yes, increase in number

Q4 – Should the City Council allow greater flexibility when considering the residential component of commercial mixed-use schemes by not requiring the residential component to be provided ‘in the vicinity’ of the mixed-use scheme but anywhere within Westminster?

Be flexible but keep mixed use in CAZ  don’t just dump affordable housing in the North.

Key issue 3: Encouraging Growth and Economic Opportunity

Q5 – Should the City Council designate an ‘Enterprise Zone’ in the North-West of the City where ‘affordable business space’ (similar to affordable housing), should be provided in certain schemes?

[No response]

Key issue 4: Night Time Economy

Q6 – Would you support such a designation in Harrow Road?

1) No. 2) Bad idea – would like more shops. 3) Desperately in need of regeneration. 4) Yes, maybe in some areas, but doesn’t seem to be profitable (use Salsbury Road as a model).

Appendix 10 - Issues and Options Area Forums feedback

Marylebone Area Forum Newsletter Summer 2007 Feedback on meeting of 7th June 2007

Appendix 10 - Issues and Options Area Forums feedback

West End Area Forum Newsletter Summer 2007 Feedback on meeting of 12th June 2007

Appendix 10 - Issues and Options Area Forums feedback

Maida Vale Area Forum Newsletter Summer 2007 Feedback on meeting of 26th June 2007

Appendix 10 - Issues and Options Area Forums feedback

St John’s Wood Area Forum Newsletter Summer 2007 Feedback on meeting of 27th June 2007

Appendix 11 – Formal notice setting out the Proposals Matters

Appendix 12 – Preferred Options letter to the general consultation bodies

Rosemarie MacQueen Director of Planning and City Development

Please reply to: The LDF Team

«Name» Direct Line / Voicemail: 020 7641 2503 «Address» Fax: 020 7641 3050 Email: [email protected]

Consultee Reference Number:

Date: 24th July 2008

Dear «Salutation»

Planning and Compulsory Purchase Act 2004 Westminster Local Development Framework Core Strategy Development Plan Document: Preferred Options

Westminster City Council is preparing a new development plan called the Local Development Framework. The first policy document within this framework is called the Core Strategy and it will set out the council’s spatial vision for Westminster over the next two decades.

In May last year, the City Council sought the views of local residents and businesses, local and regional groups, statutory consultees and other stakeholders on those issues and options which affect and concern people. In accordance with the Town and Country Planning (Local Development) (England) Regulations 2004 we have used the comments and feedback from that consultation to draw up our Preferred Options for the Core Strategy. We have also drawn up alternatives to these options, where the people we consulted wanted something different to our preferences. All of these options are set out in the ‘Core Strategy – Preferred Options’ document, together with the reasons why we have or have not chosen each option.

Please note that the ‘Core Strategy - Preferred Options’ document contains a number of options, including the City Council’s preferred options. It remains open for you to express a preference for any option, including those we suggest are alternative options, or to put forward another option that is not included in the document. All options will be considered for the final Core Strategy to make sure it reflects the best strategy for Westminster.

The complete document ‘Core Strategy – Preferred Options’ is available to view and print off from the planning pages of our website www.westminster.gov.uk/ldf or you can request a paper copy by phoning 020 7641 2503. You can also e-mail the LDF team, [email protected]. Copies of the document are available for inspection at Westminster’s libraries and One Stop Services, as stated in the enclosed notice of the ‘proposals matters’.

Other documents will also be available on the council’s website and at libraries and One Stop Services planning desks to help you respond to the Preferred Options document. These are:

Appendix 12 – Preferred Options letter to the general consultation bodies

A Sustainability Appraisal report, which assesses how well each of the options meet environmental, social and economic objectives. An initial Equality Impact Assessment, which examines each section of the Preferred Options report to identify what effect its implementation will have on different groups in the community. An initial Health Impact Assessment, which looks at the potential health impacts of the various options, and the distribution of these health impacts within the population.

From 1st August we will also be making available for public inspection a schedule of how each of the comments received at Issues and Options stage have been addressed by the Preferred Options document. This will be available on the council’s website, at libraries and at One Stop Services.

If you have any comments on the ‘Core Strategy – Preferred Options’ document or on any of the other 3 documents listed above, please send them to us in writing by close of business on the 30th September 2008.

Please note that the City Council will also be carrying out consultation on the Issues and Options for the draft Air Quality Strategy and the Issues and Options for the draft Noise Strategy during this consultation period. Consultation on these documents will be during August and September. For more information, please contact Nina Miles, (020) 7641 1883, e-mail: [email protected] for the Air Quality Strategy, or Sara Dilmamode, (020) 7641 3983, e-mail [email protected] for the Noise Strategy.

Yours sincerely,

Rosemarie MacQueen Director of Planning and City Development

Enclosures: Notice of the ‘proposals matters’ Summary of subjects covered in the Core Strategy – Preferred Options document Consultation Response Form

Appendix 13 - Preferred Options notice of the Proposals Matters

City of Westminster Planning and Compulsory Purchase Act 2004 Town and Country Planning (Local Development) (England) Regulations 2004 Town and Country Planning (Local Development) (England) (Amendment) Regulations 2008

Core Strategy for Westminster

The City of Westminster is publishing a Core Strategy Preferred Options document, which sets out options for a spatial vision, strategic objectives, and a strategy to deliver this across the City of Westminster. The Core Strategy Preferred Options document, together with the Sustainability Appraisal report, Initial Health Impact Assessment and Initial Equality Impact Assessment for the Core Strategy Preferred Options, is available for inspection free of charge at the following locations:

Website: www.westminster.gov.uk/ldf Phone: 020 7641 2503 e-mail: [email protected] Westminster libraries during normal working hours One Stop Services, 62 Victoria Street, London SW1E 6QP: Monday – Friday 8.30am to 7.00pm and Saturday 9.00am to 1.00pm One Stop Services, 313 Harrow Road, London W9 3RS, Monday – Friday 8.00am to 5.00pm One Stop Services, 91- 93 Church Street, London NW8 8EV, Monday – Friday 8.00am to 5.00pm and Saturday 9.00am to 1.00pm

Representations on the Core Strategy Preferred Options must be sent (so as to arrive by the close of business on 30th September 2008) to: LDF Team, City Planning Group, Westminster City Council, 11th floor, City Hall, 64 Victoria Street, London SW1E 6QP; or by email addressed to '[email protected]'.

Representations may be accompanied by a request to be notified at a specified address of any of the following: that the Core Strategy has been submitted to the Secretary of State for independent examination under section 20 of the above Act, the publication of the recommendations of any person appointed to carry out an independent examination of the Core Strategy, and the adoption of the Core Strategy.

R MacQueen Director of Planning and City Development 24th July 2008

Appendix 14 – Summary of subjects covered in the Preferred Options document

Summary of subjects covered in the Core Strategy – Preferred Options Document

Chapter 1: Introduction

Chapter 2: Westminster’s Spatial Vision Spatial Vision Spatial Objectives Key Diagram

Chapter 3: Delivering Westminster’s Spatial Vision Managing change Phasing growth and infrastructure, planning obligations and partnership working Delivery and implementation mechanisms Creating sustainable communities

Chapter 4: Central Activities Zone Mixed use in the Central Activities Zone

Chapter 5: International Retail Centres West End and Knightsbridge West End Special Retail Policy Area

Chapter 6: Opportunity Areas Victoria Opportunity Area Paddington Opportunity Area Tottenham Court Road Opportunity Area

Chapter 7: Promoting Economic Activity in North Westminster

Chapter 8: Special Policy Areas Harley Street East Marylebone wholesale showrooms Cultural Quarters River Thames Portland Place Savile Row St. James’s Alternative options for Special Policy Areas

Chapter 9: Health, Safety and Well-Being

Chapter 10: Design Principles Sustainable design Heritage Views and tall buildings Continued overleaf

Appendix 14 – Summary of subjects covered in the Preferred Options document

Chapter 11: Infrastructure Energy infrastructure Movement and transport Sustainable waste management Green infrastructure Social infrastructure

Chapter 12: Pollution Air Quality Noise

Chapter 13: Housing Meeting housing needs Protecting existing homes Increasing the supply of affordable housing Protecting affordable housing Quality of residential accommodation

Chapter 14: Commercial Development Business floorspace Retail Hotels Tourism-related, arts and cultural uses Entertainment uses

The document includes maps to illustrate where particular options relate to (if it is not the whole of the City of Westminster). It also sets out the plans, strategies, reports, legislation and other documents that have helped inform the Preferred Options.

Appendix 15 – Preferred Options response form Town and Country Planning (Local Development) (England) Regulations 2004 City of Westminster Local Development Framework Core Strategy – Preferred Options

Consultation Response Form July 2008

Your Details:

Consultee Reference Number: Please enter your 4 digit Customer Ref No. if known (If you have one, this will be on the letter we sent you)

Name:

Title:

First Name:

Surname:

Existing consultees – Please update the following contact details if anything needs changing from the letter we sent you:

Organisation Details (where relevant):

Job Title:

Organisation Name:

Organisation Type: (For example Residents’ Group, Local Business, Government Department)

Department Name:

Contact Details:

Postal Address:

Post Code:

Email Address:

Telephone number:

Preferred Contact Method: Email: Post:

Appendix 15 – Preferred Options response form Representations on the Core Strategy Preferred Options must be sent (so as to arrive by close of business on the 30th September 2008) to:

LDF Team, City Planning Group, Westminster City Council, 11th floor City Hall, 64 Victoria Street, London SW1E 6QP

Representations may be accompanied by a request to be notified at a specified address of any of the following: that the Core Strategy has been submitted to the Secretary of State for independent

examination (section 20 of the Planning and Compulsory Purchase Act 2004)

the publication of the recommendations of any person appointed to carry out an

independent examination of the Core Strategy, and

the adoption of the Core Strategy.

Please tick the relevant box if you would like to be notified of any of the above, and provide us with the address you would like to be notified at if it is different to that overleaf:

Alternative Address:

Alternative Post Code:

Alternative Email Address:

Alternative Telephone number:

Preferred Contact Method: Email: Post:

Please note which document/s you are commenting on:

Core Strategy Preferred Options document

Attached form and/or

Separate sheet

Sustainability Appraisal report (separate sheet)

Initial Equalities Impact Assessment (separate sheet)

Initial Health Impact Assessment (separate sheet) 84

Appendix 15 – Preferred Options response form Your Comments: Please use a separate sheet for each subject area you are commenting on.

Section/Chapter: For example Chapter 4 Central Activities Zone

Subject: For example Mixed Use in the Central Activities Zone

Preferred Option: For example Preferred Option 8

Paragraph/Section: (use only if your comment relates to the text of the document and not the Preferred or Alternative Option itself)

Please state whether you are: supporting objecting or commenting

Your comments: (Please include page/section numbers for specific references)

If you are objecting to any part of the document, or feel there is something missing, please supply your suggested alternatives/wording below: (Please include section references – where you feel something is missing, and/or where you think your suggested alternatives should go)

If you have suggested an alternative or suggested wording, please list the evidence you have to support this, including any website references. (If the evidence is not available publicly, please provide a copy of the evidence with your consultation response)

Please photocopy this page as necessary and use a separate sheet for each subject area you are commenting on.

Appendix 16 – Preferred Options letter to the specific consultation bodies

Rosemarie MacQueen Director of Planning and City Development

Please reply to: The LDF Team

«Name» Direct Line / Voicemail: 020 7641 2503 «Address» Fax: 020 7641 3050 Email: [email protected]

Consultee Reference Number:

Date: 24th July 2008

Dear «Salutation»

Planning and Compulsory Purchase Act 2004 Westminster Local Development Framework Core Strategy Development Plan Document: Preferred Options

Westminster City Council is preparing a new development plan called the Local Development Framework. The first document within this framework is called the Core Strategy and it will set out the spatial vision for Westminster over the next two decades.

In May last year, the City Council sought the views of local residents and businesses, local and regional groups, statutory consultees and other stakeholders on Issues and Options for the Core Strategy. We have now used the consultation responses to draw up our Preferred Options for the Core Strategy. We have also drawn up alternatives to these options, where consultees wanted something different to our preferences. All of these options are set out in the ‘Core Strategy – Preferred Options’, together with the reasons why we have or have not chosen each option.

The complete document ‘Core Strategy – Preferred Options’ is enclosed and we are seeking your views. There is a response form for you to fill out enclosed with this letter. We have also enclosed copies of the Sustainability Appraisal report, an initial Equality Impact Assessment and an initial Health Impact Assessment of the Core Strategy – Preferred Options.

You can also view and print off these documents from our website www.westminster.gov.uk/ldf or you can request more copies by phoning (020) 7641 2503, or e-mailing [email protected]. Copies of the document are also available for inspection at Westminster’s libraries and One Stop Services.

From 1st August we will also be making available a schedule of how each of the comments received at Issues and Options stage have been addressed. This will be available on our website or you can request a paper copy by phoning (020) 7641 2503.

Appendix 16 – Preferred Options letter to the specific consultation bodies

Please return your written comments to us by the 30th September 2008.

Yours sincerely,

Rosemarie MacQueen Director of Planning and City Development

Enclosures: Notice of the ‘proposals matters’ Summary of subjects covered in the Core Strategy – Preferred Options document Consultation Response Form Core Strategy – Preferred Options document Sustainability Appraisal report Initial Equality Impact Assessment Initial Health Impact Assessment

Appendix 17 – Preferred Options online article

Core Strategy - Preferred Options Consultation

What is your vision for Westminster? What will Westminster look like in 2010, or 2020? This is your chance to tell us.

Westminster’s Core Strategy will guide change and development over the next 20 years. The Core Strategy will be used to determine planning applications, but it is also wider than that – setting out the Council’s priorities and linking together with the plans and strategies of the Council and our partners such as the Primary Care Trust and the Metropolitan Police.

The Core Strategy includes: Areas where different types of development will be focussed – shops, homes, offices, and community facilities to support our residents and visitors. Setting out our priorities for transport, parks, public spaces and tall buildings. Finding ways to make sure the buildings we build today serve us into the future – taking account of climate change, and making places that are attractive and easy to use for everyone. Thinking about how we deal with noise and air pollution, and entertainment uses. Looking at what is special about Westminster, and what we want to protect and improve.

If any of these issues affect you, or you want to have your say on Westminster’s future, click here.

The City Council is consulting on the preferred options from 24th July to 30th September 2008. If you would like planning officers to come and talk to your group / organisation, or for more information please email [email protected] or telephone (020) 7641 2387.

Appendix 18 – Article in Westminster Reporter Issue 90, November 2008

Appendix 19 – Article in City of Westminster Planning Newsletter, Autumn 2008

Appendix 20 - Preferred Options meeting request letter

CITY OF WESTMINSTER

FROM: COUNCILLOR ROBERT DAVIS DL Deputy Leader of the City Council Cabinet Member for the Built Environment Chairman: General Purposes Committee

Westminster City Council 64 Victoria Street London SW1E 6QP

18th August 2008 Dear *********

As you may be aware, Westminster City Council is currently consulting on the Local Development Framework (LDF) Core Strategy Preferred Options planning document. This document sets out the City Council’s spatial vision for Westminster over the next two decades, and follows on from the Core Strategy Issues and Options document that was produced and consulted on last year.

As part of the consultation process, planning officers would be willing to meet with your organisation in relation to any relevant Core Strategy topic areas that you may wish to discuss. Officers from the LDF team would be happy to attend one of your regular meetings, or if you’d prefer, a special meeting can be arranged. The closing date for the consultation exercise is 30th September 2008, although officers would be happy to meet until the end of October.

The Core Strategy preferred options are available for inspection at Westminster’s libraries and One Stop Service, and can also be viewed on-line at: http://www.westminster.gov.uk/environment/planning/ldf/dpds/corestrategy/preferred- options.cfm

Appendix 20 - Preferred Options meeting request letter

If you would like an officer to come to one of your meetings, please contact Tom Kimber on 020 7641 3478 or by e-mail at [email protected].

Yours sincerely

COUNCILLOR ROBERT DAVIS DL

Appendix 21 – Recipients of Preferred Options meeting request letter

British Waterways London Church Street Neighbourhood Management City West Homes Corporation of London English Heritage Environment Agency Harrow Road LARP Heart of London Business Alliance London Borough of Brent London Borough of Camden London Borough of Lambeth London Borough of Southwark London Borough of Wandsworth London Fire and Emergency Planning Authority Metropolitan Police Authority Natural England New West End Company NHS London Healthy Urban Development Unit Paddington BID Port of London Authority Public Health & Well Being Westminster PCT Public Health Intelligence (Westminster PCT) Queen's Park Neighbourhood Forum Royal Borough of Kensington and Chelsea South Westminster Renewal Programme Sustrans Thames Water Utilities Ltd Theatre Trust Victoria Partnership Westbourne Neighbourhood Forum Westminster Action Network on Disability Westminster Amenity Societies Forum Westminster PCT at WCC Community Protection Westminster Primary Care Trust (PCT) Westminster Refugee Consortium

Appendix 22 – Preferred Options meetings minutes

Minutes from meeting with the Westminster Property Owners Association (WPOA) 11th August 2008 Core Strategy Preferred Options

Attendees: Hugh Bullock - Gerald Eve David Silverman - Derwent Robert Noel - gpe Colette O'Shea – Land Securities Paul Houston - WPOA Keith Hearn – cbre A. Penfold – British Land Nick Brindley – Gerald Eve

Keith O‟Malley – City of Westminster Barry Smith – City of Westminster Tom Kimber – City of Westminster Margaret Handovsky – City of Westminster

Issues Raised:

1. PO 8 – Mixed Use in the CAZ Is a vicinity test for residential necessary in Core CAZ? Why can‟t it be anywhere in Core CAZ?

2. PO 37 – Affordable Housing WPOA explained the financial modeling exercise that is undertaken when considering an office to residential scheme i.e. the effective loss of 30% of the development. Accepted floorspace rather than units but sought clarification as to how the proportion would be calculated and whether staircasing would remain (WCC informed it would). Also, not keen on a 100 sq m (x 10) threshold – thought it should be greater to reflect the typical unit size in Westminster. Asked if there were potential for weighted average dependent upon location in Westminster? WPOA also wanted greater clarification over the process if can‟t provide on-site – sequential approach or „leapfrog‟ approach based on a more explicit financial test? WCC explained priority for a/h was onsite; then offsite, and only as a last resort PiL. WCC said would look again at the off-site vicinity test (possibly maybe OK to have Core CAZ, north CAZ, or South CAZ??), and could on occasion waive if there are substantial planning benefits. WPOA suggested offsite should be anywhere within WCC except in areas dominated by social housing. WCC said flexibility was effectively spelt out in last para of p 240 which reads:

In cases where on-site affordable housing is not viable, the affordable housing should be provided on an alternative site in the vicinity; this will again ensure socially balanced communities. If this is not a viable option, the council will expect off-site affordable housing on a site elsewhere in the city, in these circumstances, the council will expect to take into account the differing land values between the donor site and the affordable housing site when calculating the number of off-site affordable units to be provided.

WPOA pointed out that this flexibility was more than that set out in PO 37. WCC pointed out that PO 37 referred to housing generally and not just a/h – hence the difference.

WPOA asked if there were only a small number of units whether they could provide a social and community facility instead; or whether RSLs/CityWest Homes would accept money for refurbishment instead.

WPOA - Issues over procurement/viability test – role of Valuation Office Agency to short cut process?

Appendix 22 – Preferred Options meetings minutes

3. Mixed Use in Outer CAZ WPOA raised the issue of c.o.u. from one commercial use to another. WCC stated probably OK in outer CAZ, policy would only „welcome‟ c.o.u. to residential. Re PO 8 – „higher proportion of housing outside Core CAZ‟ WCC stated that the CMP will need to specify proportion of housing in the different parts of CAZ to reflect character and function of those sub-areas.

4. Swaps and Credits WPOA asked for clarification on how and when you could draw down credit – if it‟s a less valuable site, should you need to draw down more credits? WCC stated a report was being presented to Committee in October seeking members‟ views on land use credits.

5. Creative Industries WPOA (HB) not completely convinced by Creative Industries report and the need to protect these uses in Westminster.

6. Main Conclusions WPOA‟s main concern was that the mixed use policy should be more flexible regarding the location of offsite residential. It should not be required to be „in the vicinity‟ particularly in the case of affordable housing.

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Minutes of meeting with Greater London Authority (GLA) Monday 29th September 2008

Attendees: Kim Hoffman GLA Martin Scholar GLA Barry Smith WCC Lisa O‟Donnell WCC Margaret Handovsky WCC Tom Kimber WCC

WCC comments in italics

Intentional difference in tone within the Mayor‟s response to the Core Strategy, between the covering letter, report and Appendix 1 (table of detailed comments). The letter more in line with the new Mayor‟s approach, whilst Appendix 1 more „London Plan‟.

Central Activities Zone GLA concern that we are too restrictive within CAZ towards new office uses, and that CAZ could stagnate. Worry about precedent for Central Activities Zone in other boroughs. Need to ensure we don‟t restrict commercial development. Westminster CAZ is very different to CAZ in other London Boroughs. Our approach to the CAZ enables growth in Paddington, where larger floorplates can also be located. Support our approach to local distinctiveness and predominantly residential areas within the CAZ. Concern over GLA response to the Core Strategy in relation to mixed use (mixed use approach not supported, where this will stifle quantitative and qualitative improvements to the strategic retail and leisure offer of the Central Activities Zone). Concern that developers will use this against us, and concern over exactly what the priority uses are? However “priority is always residential” over retail.

Opportunity Areas Need to mention that London Plan figures for the Opportunity Areas are „minimum‟ residential figures. May be worth having a separate discussion on the boundaries of the Opportunity Areas. For example much of the southern part of the Victoria Opportunity Area have already been developed. GLA concerned that they don‟t want Nine Elms to be cut off. In relation to Paddington, Royal Oak only has limited potential.

Issue of SRDFs – why are GLA referring to these documents?

Housing WCC justification for 1000sqm affordable housing threshold seems reasonable. Mayor is still striving towards 50% London wide target. Will shortly be a revised SPG on housing. Our 30%50% inside/outside CAZ approach is likely to remain acceptable. We will still be having staircasing approach to the proportion of affordable housing provided.

Views/Tall Buildings Still not sure about WCC setting out guidance on Metropolitan Views. GLA about to start work on views, so WCC should wait for GLA.

Energy Trying not to repeat the London Plan Energy is a high profile topic for Mayor We’re producing a position statement on biofuel/biomass, and have also commissioned a consultant to map CHP and potential for further networking opportunities

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Waste Very difficult issue for Westminster. Even if some land is available is it really the most suitable use of land in central London? Concern that dealing with waste within Core Strategy/City Management could be too „top heavy‟. We should think about producing a separate DPD. Should work on our justification as to why it‟s difficult to meet our waste apportionment targets within Westminster. Can add up our depots to contribute towards our apportionment hectarage.

Planning Obligations Use of development to fund Crossrail is one of the first likely alterations to the London Plan. Committed to s105 SPG

SFRA/Housing in the flood plain We would like some advice on this. GLA will get back to us.

LDS Regulation 26 – should say Regulation 28 May be have a different key for different regs

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Minutes of meeting with Westminster Health and Care Network Business Groups 29th September 2008 Update of LDF process / Preferred Options – introducing key questions re service provision

Attendees: Zena Deayton (Chair) Natascha Hermann Richard Barker John Higgins Cecily Herdman Rachel Chapman Selina Douglas Steve Barnes Hugh Cole John Burchill Gayle Muers Chris Nicholas (representing Lisa Henschen) Steve Barnes Cindy Fletcher Sarah Rushton Helena Merriott Hilary Skinner Ros Blackwood Susana Oguntoye

Apologies : Cath Attlee Amjad Taha Richard Drew Emma Wilson Tessa Lindfield Elaine Malloy Gez Kellaghan Lisa Henschen Garry Alessio Mary Russell

LDF Housing Strategy/needs identified – implications for types of housing required How easy is it for disabled people to get around [HM explained that MH has spoken to them – and that additional feedback is welcomed] Raised issue of implications of development

Linda and Tessa in PCT study suggested as a good source of information to inform development of our options.

ZD (chairwoman) excited by the document LDF – key questions to be on agenda for partners‟ meetings where possible Individual comments from partner organisations – will also be reported back on 24th via Natascha HM referred to forthcoming WAND event No further feedback received during the meeting

Updates from partners Service provision gaps - £2million over the next 2 years (NH) Proposals welcomed for this until end of October Worklessness + family recovery focus

Strategy – April 2009 for 3 years (John)

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Services Needs Strategy to be completed in the new year Alcohol Strategy April 2009 Needs Study November – January

„Macroan‟ Index – deprivation / homelessness

Non-LDF specific notes: One Point of Access to Health Project Targeting poor housing in the Harrow Road ward Includes Harrow Road LARP as a partner

Healthy futures – moving to Harrow Road – to target every household in 3 streets in Harrow Road Health Checks Promotion and activity Wider components of health

Simple referral forms housing to health Electronic referral link to Environmental Health – 2 GPs involved – no specific incentive for them – potential for wider use – includes links on GPs‟ desktops

Consultation continues after the project Regular communication required

Health care services should provide choice – facilitated to self-assess Reablement Reference to Sustainable Communities White Paper Work with those not in need to ensure they don‟t get into need – help maintain independence Essex has given service users power

„Community Build Program‟ 500 new homes on existing council ground 2,700 people in temporary accommodation – target to reduce by half by 2010 27 years 7 month wait for 4 bedroom house City West homes have met Decent Homes Standard Approx 4,500 supported housing units in Westminster

Temporary accommodation (private sector leasing managed by housing association) – 3,000-1,000 of which are outside the borough

Access to information is key

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Minutes of meeting with RSL and CityWest Homes 1st October 2008 @ City Hall Core Strategy Preferred Options

List of attendees: Margaret Handovsky: WCC Fergus Coleman: WCC Tom Kimber: WCC

Dave Woods: Octavia Claire Bennie : Peabody Robert Greene : A2 Dominion Group Barry Richards : A2 Dominion group Janet Mussington : Sanctuary HA Julie de Sennville : One Housing Group Russell Purvis : Soho HA Richard Birchett : CityWest Homes Melanie Twyford : CityWest Homes Julie Day : CityWest Homes Paul Gatrill : CityWest Homes

Italics refer to comments/clarifications made by WCC officers.

Preferred Option 8 – Mixed Use

Issue of seeking health, education, social, community or cultural use before payment in lieu o Only works if benefits can be in the north where they are needed, i.e. health uses may not be appropriate in Central areas. o May be difficulties in financially equating a social and community type use to housing use o Social and community use would have to be what is needed rather than just what the developers want to provide.

Vicinity o Shouldn‟t be too close to parent scheme as this could be restrictive, but should be within the broad area. o Should the City Council define what meant by „in vicinity‟? o If give developers the option, they may just push the housing up to the north of Westminster o Intermediate may not always work in central areas o Aim is to build in flexibility, can always waiver if a material consideration, such as provision of more and better units.

Land Use Credits o generally supported as might mean better, easier managed housing and schemes which will be delivered earlier.

Preferred Option 35 – Housing Need o detail will be in CMP o query regarding issue of sustainability/code for sustainable homes – covered in other preferred options and SPD. o What about schemes where RSL may just want to provide „older people‟ housing for example, rather than meeting all size and tenure requirements? – we won’t expect everything on each site. CMP will set out approach to specialist housing. o Many RSLs supply specific need rather than generic need.

Preferred Option 35i – Gypsy and Traveller sites o Explained that we do not have any sites at present in WCC and have not been allocated any in the recent GLA study. o No comments

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Preferred Option 36 – Protecting all residential uses, floorspace and land o Slightly different approach from UDP which also, protects units except for affordable housing and the family housing areas o What meant by „more suitable‟? o Need to make provision for not only small scale amalgamations for „individual occupiers‟ but for wholesale estate redevelopment where there is a reduction in the number of units on site , though the floorspace may increase.

Preferred Option 37 – Maximising Affordable Housing o Isn‟t the Mayor getting rid of the 50% target?

Threshold issue o Are the threshold floorspace figures net or gross? Is the GLA‟s 66sqm net? (66 sq m is net) o Strong preference that areas quoted should be gross areas otherwise developers will manipulate them o Why doesn‟t the City Council take the average over the last ten years? o Because it will still be greater than 100 sq m o May be worth having a look at what Kensington and Chelsea do. o The City Council will have to be make sure we have a proper justification for our threshold

Affordable proportion in floorspace o Support. Good way of doing it, but may need to reduce the proportion.

On-site/off-site in vicinity/payment in lieu in exceptional circumstances o Westminster wants affordable housing rather than money, and are trying to stop developers providing money at the outset. However, current grant is inadequate and we use affordable housing fund to top this up. o How define „exceptional circumstances‟? – we don’t o Community Build/CityWest homes – often don‟t have capacity for additional affordable units to give to others

o Are the City Council still working on the presumption that just RSL‟s provide affordable housing? It is recognised that market housing is often necessary to fund the affordable housing. o What about other non-RSL organisations delivering a/h, such as Pocket? We will allow for this in line with PPS3 guidance- PPS3 has removed ‘low cost market housing’ from the affordable definition; and also ‘Pocket’ type developments would not fulfil the criteria for social housing, so this would still need to be provided. o UDP worded so that RSL‟s provide 100% affordable. Will this still be the case? RSL‟s often need to provide market housing in order to make their schemes viable. o It is recognised that Market housing is often necessary to fund the affordable housing. 100% has never been a requirement.

Preferred Option 38 – Protecting affordable housing and floorspace o So can the number of affordable units be reduced? o Yes, but must replace the a/h floorspace o Issue of charities accommodation/HMOs etc – also refer to PO 36 but point taken that policy needs to allow for loss of units if the new units are affordable units. o Real need for extra care units in Westminster.

Preferred Option 39 – Well designed, high quality, sustainable housing o Can WCC include „and well managed‟ within the wording? Could management issue could be enshrined in planning policy, especially as Core Strategy is the „umbrella‟ document. o WCC has a choice based lettings plan o Not about setting out lettings within planning policy, but flagging up the management issue. o Buy to let units can be problematic in terms of management – this isn’t normally the case within Westminster.

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o We need to look at affordability of service charging –this could be part of the management plan agreed in advance o Developers sometimes use „service charging‟ issue to not provide affordable units, due to viability. o May be legal issues with capping service charges. o Higher service charges often means better managed, so is about achieving a balance.

City Management Plan Discussion:

Intermediate Housing – How to ensure affordability? o Real issue for RSLs because lenders currently won‟t lend! o RSLs have started converting to intermediate rental units. o Shared Ownership can work but is difficult. o Who should we target intermediate at? We need to implement specific income bands, but without being too prescriptive. o Want to avoid all intermediate housing being at top £60,000 level.

Payments in Lieu – How to calculate rate? o Normally update TCI figures, flat rate at the moment, with the exception of ‘higher value’ areas o What element is land and what element is build costs? o Build costs are very site specific. Would estimate land costs at present to be around 35% to 40%, so 40% would be a good to apply in Westminster.

Other points raised o Safety issue – „secured by design‟ standard is difficult to achieve in Westminster.

o Would be good if WCC officers could walk round some schemes to highlight issues. Yes, agree that would be useful.

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Minutes of meeting with Camden Council 2nd October 2008 Discussing cross-borough issues and approach to CS and POs

Camden Council – David Joyce, Lisa and Hilary

WCC, Camden

W Explained residential flexibility and residential unit credits C Not familiar with credit system C Tottenham Court Rd Opportunity Area – includes sites that would be treated differently – just because a site is in an area doesn‟t mean that it has to be treated the same way W We could use the same wording C Continue balanced approach to mixed-use W CAZ mixed-use – housing priority with balance C reluctant to promote commercial – same as us W GLA need to state priority is housing C polycentric approach makes sense – where commercial uses are spread throughout Greater London and res is able to locate in the centre (and vice versa) C high rents are pushing commercial activity out W targets from London Plan in Tottenham Court Rd Opportunity Area C met some targets in St. Giles already for homes W joint statement – e.g. “between us and Camden we are satisfied we meet…” C GOL advice to take ownership – site allocations document reference to address that – we have planning briefs C joint work on public realm improvements should be included W join Camden‟s boundary on both CAZ and Tottenham Court Rd Opportunity Area C update of housing needs study has happened – our one hasn‟t W joint mini SHMA – may be covered by strategic document C met GLO Ken Bean to discuss timetable delay – CS and Devt policies running together Para 1.12 re sites in Opportunity Areas Consultation docs from next Thursday C Tottenham Court Rd Central London Frontage – not WESRPA as in LP No alternatives in the plan – only preferred and rejected options Res off commercial same as us – not same scale devt (in particular retail) we may have had Retail requirements met by Kings X, Euston, Tottenham Court Rd Limited opportunities to bring forward new floorspace Mixed of uses Specialist electronics etc in Tottenham Court Rd Fragmented land ownership Have SPG to protect areas with A1 special Unintended effects of good public realm Affordable units – problem where we own properties with high rents Need details from the Mayor re: affordable retail units – same as us C retail study immanent Lines to show how boundary goes into WCC WC CAZ/wider CAZ discussion – to match our boundary C avoid LP terminology – not CAZ, Opportunity Areas, “Growth Areas”, not stating done because London Plan says so W requesting minutes from GLA/GOL meetings „for our records‟ C treating tall buildings each on its merits W GOL suggested Tottenham Court Rd for tall buildings C Tottenham Court Rd – each on its merits – not committed one way or another – locally distinctive character of areas prevents this WC residential amenity reference not in national guidance therefore for now has to be in our Core Strategy C quality of life protection is key C waste sites – in the north London waste collection area group North London boroughs already have waste.. Not want us or the City to join them at this late stage

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W we don‟t have sites – cant meet apportionment C should be London wide W our apportionment cant be met elsewhere C asked about GOL comments W views – outside borough – should be done at regional level C would be stronger protection W shows where we would reject – include blue sky views behind views C GOL comments on affordable housing sqm – seemed ok Comments on delivery side of infrastructure vs growth strategy W projects to be prioritised through CIL Working on structure to deal with Crossrail C infrastructure table needs to be linked back to growth strategy from GOL W PTAL so hight devt can be supported anyway – regardless of Crossrail C Crossrail sites – priority for residents isn‟t Crossrail – is still local / public realm etc C all boroughs should be contributing to Crossrail W outer London boroughs will benefit more Increased land values – Tottenham Court Rd have limited devt opportunity C Richmond Plan – too generic and too much description W Wandsworth – not locally distinctive

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Minutes of meeting with Westminster Health and Care Network Monday 13th October 2008, 10:00am

Attendees: Michael Scott, CE PCT Marian Harrington, Director Adult Social Services, WCC Margarete Guy, Director of Public Health, PCT Marco Torquati, LARP Manager Church Street Gayle Muers, VAW, LINk Co-Ordinator Bernard Collier, CE VAW Paul Kirwan, Carers Network Westminster Daniel McCarthy, Head of Housing Strategy, WCC Tessa Lindfield, AD Public Health, PCT and WCC And myself

Apologies: Cath Attlee, AD Joint Commissioning, PCT and WCC Paul Jenkins, Director Joint Commissioning, PCT Amjad Taha, BME Health Forum, PCT Brian Coleman, AD Equality and Diversity, PCT

HM introduced the LDF structure and process. Reminded attendees of its role as the spatial expression of the key stakeholder‟s strategies and programmes, and the focus on infrastructure delivery.

HM drew out relationships between the current work on health strategies, particularly the Health Inequalities Strategy, and how the Core Strategy and City Management Plan can contribute towards meeting these objectives. Examples given were worklessness and training e.g. Paddington First; housing quality, community gardens; encouraging physical activity as part of daily routine through high quality public realm and looking at the spaces between buildings and movement, including prioritising pedestrian movement above all else; stress areas and the management of entertainment uses with relationships to tackling crime, fear of crime, alcohol and drug abuse, and noise disturbance; CMP contribution e.g. air-conditioning units outside bedroom windows; and the role of private healthcare.

Comments from the Board: Note that many of the board members have been involved in the consultation independently, including discussions and written responses. Emphasise how important the LDF is in tackling health inequalities. Need to give consideration to the role of the private sector in healthcare provision. PCT does not have direct controls. Need to think about how and if controls through the planning system could be used, and what this might mean. Emphasise the need to make the environment less obese-genic. Need to consider the relative responsibilities for tackling this and interventions. Need a joined up approach and really need to encourage walking. E.g. given of TfL posters relating to walking. Also consider matters such as the visibility of stairs in new buildings to encourage use rather than lifts. Highlight opportunities for change, and look strategically at asset management, identifying possibilities of levering in other resources and match-funding. Use of Section 106. Also take into consideration the voluntary sector and their needs. A strategic approach is needed for the voluntary sector particularly in relation to availability of floorspace (LOD encouraged to also be involved in CIL work). Possibility of a cycle route through north west Westminster – acknowledged severance issues, and also key area RE health inequalities. Reference to the emerging draft Asset Plan/Estate Strategy in tandem with Linda Capri. Concerns regarding the prevalence of bookmakers in these areas suffering deprivation, and shops giving cigarettes and alcohol on credit. Acknowledgement that bookmakers are A1 and therefore no control through Use Classes Order, but linkages to licensing could be investigated as this is a significant health issue. Also, some of the premises are Council-owned.

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HM/LOD requested to attend the next meeting on the 9th February to discuss the City Management Plan and for members of the group to be involved in the City Management Plan

Other items on the agenda Current consultation by PCT on „It‟s your choice – the Westminster Health Debate. Key point raised in that consultation is that people want all social services under one roof. Homelessness Strategy – whole spectrum that may require different responses from hostel accommodation through to over-crowding. Data is presented separately for rough sleepers; and for refugees and asylum seekers. Use of housing waiting lists as an indicator of health issues. Study being prepared into the private rented sector and the role it plays in Westminster‟s housing market (the largest private rented sector of all London authorities). A significant amount of very expensive rental properties but also at the bottom end there are over-crowding issues. Over- crowding has significant implications for health, including mental health, TB etc The new Housing Act brings in over-crowding as a duty of the LA, not just rough sleeping etc. LOD Highlight the importance of the spaces between buildings in new build e.g. community build / City West Homes which can provide a pressure valve where people can get away from each other / children play etc, and the access to community facilities e.g. physical severance problems from GP etc LOD noted CMP work on retrofitting through S106 funding where developments cannot meet specified Code level and relationship with warm homes and fuel poverty. Work with City West Homes for example. Strong correlation between housing and health, need joint working, but also on the ground with housing officers helping to recognise people at risk in terms of health. Need cross-representation on the network boards.

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Minutes of meeting with Environment Agency Thursday 23rd October 2008

Attendees: Ian Blackburn, Liz Lightbourne, Katie Arthur (Environment Agency), Sally Alderman, Dianne James, Lisa O‟Donnell (City of Westminster – City Planning Group), Claragh McSweeney, Julia Kennedy (City of Westminster – Development Planning Services)

WCC drew attention to Preferred Option 1(d) and Alternative Option 1-D, noting that AO 1-D related to the EA‟s comments, and that the EA had not picked up on these matters in their consultation response to the Preferred Options.- Core Strategy. The EA had reviewed A0 1-D and noted that it does outline various pressures Westminster face however it does not fully address our concerns. The point we were trying to make at the meeting was that the Sequential Test can still be applied as you need to make the case that there are no reasonably available sites. This needs to be demonstrated so that rather than just providing us with the end answer we can see how you have come to this decision. This ensures that the locations for development in high risk flood zones is justified and not open to challenge at the submission stage.

WCC advised that Preferred Option 1 (d) sets the context for the Sequential Test in Westminster. Most major proposals sites in Westminster (with the exception of those set aside for transport infrastructure) have residential as a preferred use and all these residential sites are required to meet our housing targets. Because of this it is not possible to carry out the Sequential Test ,as set out in PPS 25, because sites in lower flood risk zones are already „designated‟ for residential purposes.anyway. This is set out in detail in the draft SFRA, which will be used as part of our evidence base to in the Core Strategy Policy for Flooding. EA comments as above regarding the Sequential Test. This should not only consider residential but all proposed development in Zones 2&3. So if there are proposals for commercial etc this will need to be looked at as well. As we have not yet seen the SFRA we cannot as yet comment about the evidence that will be provided. The EA noted that their comments on the Core Strategy did not take the SFRA into account. It was clarified at the meeting that this was being produced.

WCC advised that they will have considerable difficulty meeting housing target s even with the sites in AO 1-D the GLA accepted the unique circumstances in Westminster and have allowed us to use „windfall sites‟ as part of our assessment towards meeting our housing capacity targets.. For this reason it is not possible to apply the sequential approach test (the Sequential approach on site may still be applied with information from the SFRA, and site layout as part of the Flood Risk Assessment ie locating more vulnerable in areas of least flood risk on site and through design) to windfall sites, and this is set out in detail in the emerging draft SFRA. Comments as above. Again as noted in my email we need to see this evidence provided as part of the Sequential Test assessment. As you are dealing with Windfall sites it is important to have this assessment to provide more certainty for your Development Control Team. Ie once the Sequential Test has been produced they can reference the document as part of the planning application that the ST has been applied for sites within Flood Zone 3. The Exception Test is still applicable (refer to previous email dated 19 November).

Criteria for windfall sites will also be set out in the City Management Plan (the detailed DC policy DPD). As above.

The informant in the Halcrow report has allowed the City Council to explore the Sequential Test in Flood Zone 3 by setting out how many homes each Opportunity Site is likely to deliver within the rapid inundation zone, the residual risk area and the other parts of Zone 3. This analysis is contained in the emerging draft SFRA.

The City Management Plan will be out to consultation soon. It will be developed through a different process, essentially of stakeholder workshops. WCC encourage EA to attend the relevant workshops. EA were supportive of this approach and would be available to attend these meetings.

WCC will l take every opportunity to reduce risk through design, which will be detailed in the CMP e.g. attenuation targets. Can also look at the descriptions for the Opportunity Sites and state that residential will not be allowed on the ground floor, for example. Also can look at applying the

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sequential test approach (as described above) at site level, e.g. if there are areas of higher ground.

Queen Alexandra Hospital site remains most contentious. Need to ensure we give consistent message about this site, and similar sites, to developers. DPS to work with EA project officers to discuss as near stage requiring pre-application advice. EA noted that they have two major project officers within the team who are available to attend pre application meetings to discuss issues further.

Although Halcrow only recommend no basement development in the residual risk area, the Preferred Options states all of Flood Zone 3. EA note that it should be all Flood Zone 3 in order to meet PPS25. WCC to use the EA definition of basements (self contained as described in the PPS25 Practice Guide) and other highly vulnerable uses. Preferred Option 1(c) is not permitted in any case, therefore the wording needs to be stronger than „direct‟.

WCC thought Wandsworth had an interesting approach and would like to do similar. EA officers had not seen this to date and explained that Wandsworth was not a Council within the North London Team. Please advise of the „approach‟ Westminster are referring to and the EA can provide comments.

Surface water flooding is set out in the SFRA, including identification of areas. Halcrow‟s recommendations are there for discussion, and this should be the basis of a separate meeting. Policy approach likely to include attenuation targets through the CMP. In the spirit of the guidance notes for PPS25 relating to sequential testing for other flooding sources Halcrow have made recommendations regarding the Sequential test for the 19 areas identified as „areas of critical surface water flooding‟. It is unlikely however that the city council will be able to comply with this as the same proviso applies regarding Westminster‟s difficulty in meeting its housing targets. The EA advised this should be discussed in more detail as part of the Sequential Test assessment and justified as to why the SFRA recommendations will not be acted upon.

EA consider it suitable that the detailed information is set out in the SFRA. WCC note that the Core Strategy will be very concise and is not the appropriate document for significant evidence and detail. The EA did encourage at the meeting that there needed to be a clear link to the SFRA for the development of policies within the Core Strategy and CMP (point 3 & 4 of previous email).

The SFRA will be going out to public consultation very soon. It will be subject to fairly wide consultation. Will the EA see this before the public consultation? This would ensure that points made within the document are technically correct in terms of flood risk issues.

WCC have not been able to identify a site to meet its waste apportionment and it is likely that none exist as Westminster does not have industrial land. WCC are also trying to work with other boroughs who may have capacity, however this has not been successful to date. The EA noted that the comments made were from our Waste Officer who requested to be involved in any further consultations on Waste Strategies for Westminster.

Reference to the North London Rivers Strategy, which identifies part of the Grand Union Canal. EA to advise if there are any major projects that should be included in the Core Strategy, although this tends to be British Waterways in relation to canals. Further email sent regarding this issue to Dianne James.

EA doing State of Environment reports for each borough. Also re-worked advice on green roofs and standing flood risk advice. State of Environment summaries for each borough are due out in February of next year.

EA noted that they are available to come out and discuss flood risk issues with the Development Control Team.

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Minutes of meeting with New West End Company 24th October 2008 Discussing partners‟ objectives, the Core Strategy and Preferred Options

NWEC – Nicola Rollason, Richard Dickinson (CEO) WCC – Hilary Skinner, Margaret Handovsky, Mike Fairmaner

Retail in the West End Foresee long-term growth for the West End despite current financial climate because of its international offer. There may be a short term dip, but overall growth will follow, however there are problems which need addressing:

Constraints Competition from new developments especially Westfield, Brent Cross and Stratford – potential for 8-10% decrease in visitors to Oxford Street/the West End – despite large numbers of visitors to the area, the margin is so tight that this will be a problem Conservation Areas, listed buildings, multiple ownership Crossrail – potential unwillingness to develop ahead of Crossrail construction/opening

Mixed uses with residential flexibility Need flexibility to allow the right developments at the right time. Do not support the mixed use policy on the main shopping streets as residential just pushes up costs and makes the project unviable. Off–site residential provision may be an option, but not for sites in East Oxford Street.

East end of Oxford Street In need of revitalisation – Regeneration agenda is needed for eastern Oxford Street. NWEC want to differentiate the area so it is not a clone high street. Would benefit from one or two anchor stores – i.e. 60-70,000 sq ft store Chain stores – e.g. Zara etc make economics stack up, but consider this will not happen before Crossrail. In the interim period before Crossrail there is the potential for cosmetic improvements for 2012 and the flexibility to make them stack up economically. High footfall means that landowners do not have an incentive to improve their units.

East Marylebone Special Policy Area This needs a review – consider the „rag trade‟ wholesale showrooms are in decline – they are not adding to the vibrancy of the area and would like to see them go. West End fashion economy can work without the showrooms. Potential for media uses to move into the East Marylebone SPA and make it more like Market Place.

Retail Studies Recent retail analysis shows the West End is losing brands. Already losing 8-10% to competitor centres. NWEC has details of retailers‟ requirements.

Boundary WESRPA requires clearer definition. Need to be clearer about exactly what the SPA designation means i.e. what does it mean and what does it strive to achieve? NWEC bid area is the 3 main streets plus the other major retail areas for example Savile Row, Brownheart Gardens, Langham Place, South Molton Street. Need to review whether to include north Regent Street as this is a developing area. Would support Langham Place being included in WESRPA – especially over 15 year timescale. Different boundaries for the SPA and the BID area may be more appropriate.

Tottenham Court Road Opportunity Area Conflict between London Plan policies i.e. priority for retail and the homes target. Need to balance housing with the other priorities for central London. Question the appropriateness of housing in Oxford Street. For the Opportunity Area to work may need a joint venture vehicle or use of CPO. CPO could then lead to a better more coherent land ownership which in turn would enable control over occupiers of shop units.

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CPO is difficult because the units are trading successfully, but they are dilapidated. Lots of crime and drug dealing in East Oxford Street. Helpful to include a much wider area in the OA. It should include all buildings with a frontage to Oxford Street in Eastern Oxford Street.

General Ideas for the West End Requirement for flexibility to ensure viability Want Oxford Street to be a destination, not just a thoroughfare. Potential to recognise key clusters of retail activity – including the potential for retail areas Link to University site – could be potential for fashion academy Designate „quarters‟ off the main drag, e.g. Luxury quarter (to the south west of Oxford/Bond Street) Top of Bond Street (at junction with Oxford Street) needs to be highlighted in some way to set tone for the street. Could include planning conditions to insist on shop window displays in this area. Gateways are important especially at the extremes i.e. Marble Arch and Tottenham Court Road. They act as a welcome and indication that people have arrived at a special place. Possibly something like banners or flags – would need to consider whether this would be OK in planning terms Important to encourage independent retailers to east Oxford Street or themed areas for example could create Camden type feel to the area Need to consider whether the Mayor‟s affordable business unit scheme could be used for the small row of units on the south side of eastern Oxford Street

Sex Uses Reduce the sex uses area boundary so it does not abut Oxford Street. Move it south to Greatt Marlborough Street. Need to have a joint policy with Licensing. Maybe could only have them in the interior of the area, not the main thoroughfares. Do not like sex uses or the activities they attract because it conflicts with the shopping character and mums and 15 year olds as an example, going shopping comfortably.

Street Trading Suggest clustering the stalls in a few areas Twin track approach needed to get better kiosks and receptacles, and review positioning, especially the one in Argyle Street Need to provide a higher quality offer, maybe a commodity list Stall holders should be ambassadors and stalls should be clean and tidy. Bad ones need to be got rid of. Consider potential for stalls to pack up at night Legal aspects need to be looked at If you want a decent destination you need a professional and attractive environment. The quality of stall offer is awful. They could be franchised brands for example coffee shop or John Lewis branded tourist goods Could have information stalls selling tickets, Oyster cards etc. Could do a pilot project to encourage good practice

Sum up: Number 1 key issue

Viability issue is crucial. Planning must be carried out in a holistic and integrated way to reflect the vision in the ORB Plan.

AOB Carbon Charter – share expertise and work together to reduce carbon emissionsd in the area – mainly existing buildings‟ energy use. – Could ask the NWEC members, would be pleased to investigate further.

Mike Fairmaner/Bridie Gunn from Westminster‟s Go Green team, to send Victoria proposals re: ongoing operations produced for the Victoria BID area.

Data available from „Springboard‟ regarding visitors to upper floors – NWEC will pass on to WCC.

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Notes on meeting with Thames Water Utilities Ltd 27th October 2008

Discussion points for meeting

1) Set out what TW's roles and responsibilities are as a statutory water and sewage undertaker for Westminster.

2) Main areas of interest for TW - infrastructure capacity / new utility infrastructure / water efficiency / sewer flooding

3) TW seek policy support for infrastructure capacity - development should be brought forward in line with infrastructure provision.

4) TW seek policy support for utilities infrastructure development - land maybe required by TW for new infrastructure & support for provision of additional utility infrastructure.

5) Water efficiency – TW seek policies that support water efficiency; at least code for sustainable homes level 3.

6) TW support drainage hierarchy (as set out in London Plan).

7) TW seek greater policy support for water quality improvements to rivers.

8) No reference to sewer flooding in Core Strategy. TW feel basement developments should be avoided in areas at risk of flooding.

9) TW seek policy support for Tideway Tunnel.

Post meeting Actions a) TW to provide water efficiency policy examples. b) TW to provide sewer flooding data for Westminster. c) TW to set out which if any areas of Westminster have capacity issues. d) TW to provide update on Tideway Tunnel project .

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Date: November 3rd 2008 Meeting: Westminster Amenity Society Forum (WASF) with Westminster City Council City Planning Group Date of meeting: October 31st 2008

Attendees: Elizabeth Virgo, Peter Denton, Verina Glaessner, Hilary Skinner, Dianne James (Minutes), plus 7 other members of WASF Apologies: Tom Kimber (WCC), John Zamit (WASF)

Contact: Tom Kimber

Telephone: 020 7641 3478 Action Points: Action 1 Minutes of last meeting and matters arising No minutes were available. 2 Local Development Framework Background HS introduced WASF to the LDF process, the background to changes in regulations and explained where we are in the process and what would happen next.

WASF were thanked for their contributions to the draft preferred options consultation document that have been received so far.

3 Westminster’s Core Strategy Preferred Options document HS explained that the Core Strategy was the Strategic Plan for Westminster, what it covered and the timetable for its delivery.

WASF were encouraged to engage in the process and to discuss their issues.

Summaries of the Core Strategy Preferred Options were circulated, along with timetables for the documents‟ production. Further copies will be sent to WASF HS members in due course.

Key issues Format and size EV expressed concerns over the format and size of the preferred options consultation document, as it would not fit through the letter box and had to be collected from the post office. It was suggested that future iterations should be smaller and thought be given to how consultees could distribute relevant chapters to key partners. HS explained that future Core Strategy documents will be smaller as they will not contain the alternative and rejected options, and that the consultation process for the City Management Plan would be very different, with information being distributed by subject as required.

Mayor’s London plan Questions were posed on the conformity of the Core Strategy with the London plan and how the Core Strategy would be impacted upon in light of changing priorities within the Mayor‟s office/the Greater London Authority (GLA). HS explained that Westminster is working closely with the GLA to address issues such as tall buildings, strategic views and affordable housing. HS explained that the Mayor had produced a document – „Planning for a Better London‟ which outlines the key priorities for the new administration. WASF asked if WCC could provide timely updates on consultations happening at a regional level. HS to arrange.

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WASF were encouraged to consider other consultees‟ responses, and were handed copies of Westminster Property Association (WPAs) comments and alternative Preferred Options. Additional copies will be sent to WASF. WASF were also requested to provide evidence, for example case studies to support HS their comments/options. HS explained the importance of evidence and how it could be use in the public inquiry.

Subterranean Development HS Concerns were raised over the scale and implications of extensive subterranean development and that it was not an issue dealt with in the Core Strategy Preferred Option. WCC will take this into consideration in its development of the City Management Plan. WASF mentioned Kensington and Chelsea have an SPD on this matter. Issue of underground rivers was also raised with view of getting location information. DJ provided details to WASF.

CAZ HS was asked to define Core and Outer CAZ as the centre for large-scale economic growth and potential areas for greater growth where appropriate, respectively. The scale and extent of growth will be defined in greater detail in the City Management Plan. WASF were concerned that the policy boundaries should not represent areas where development will definitely be allowed. HS explained each case would be decided on its merits.

HS was asked if we had trialled the policy approaches we were proposing, and emphasised their development processes, and that we had been working closely with the GLA, GOL, other interest groups and partners, and have had an Inspector in to review our progress.

VG suggested the Summary preferred options be circulated to WASF planning committees for comment by end of November 2008

PD suggested further consideration be given the CAZ map 7. Regeneration areas, non-coloured areas on Map 7, need to be defined as economic growth areas, for example North West Westminster, Harrow Road, emphasising cross borough boundary re-development area. HS explained this area is the focus of several Planning Briefs, and is covered by other Preferred Options including the North Westminster Economic Development Area (Preferred Option 14).

Actions for WASF Circulate Statement encouraging WASF comments on preferred options and evidence supporting options. Timetable for Core Strategy and City Management Plan Other consultee responses, for example, WPA LDF background briefing note Templates for questionnaires URL‟s for documents on WCC website. Contact details for LDF enquiries and comments. Any other business Nothing raised

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Meeting: Westminster Faith Exchange, Westminster City Hall Time & Date: 6.30 on 4 November 2008 Officer Presenting: Helena Merriott

Key Points Helena Merriott (Principal Planning Officer, City Planning Group) introduced herself and gave an overview of where the council were with preparing two key LDF Documents: o Core Strategy DPD which provides the overarching spatial planning framework) o City Management DPD, which provides detailed planning policies that will be applied to individual applications. These policies will cover a range of matters including sustainable design and access.

Helena advised that consultation on the Core Strategy Preferred Options report closed at the end of September but that officers were continuing to engage with stakeholders to capture views to inform the preparation of the submission version of the Core Strategy. Helena further advised that the consultation on the City Management Plan had begun and a series of consultation workshops were being planned for early next year.

Helena referred to a note circulated in advance of the meeting (set out in full from page 3 of this note onwards).The note highlighted some key policy areas and issue where the input of the Faith Exchange would be particularly valuable. The main issues were:

o Understanding demand for community facilities used by faith groups – Are these facilities at capacity, are more needed, are they in the right geographical location currently and into the future, given the time horizon of the Core Strategy o Understanding the particular requirements for these facilities. o Any current plans / projects for new provision of religious facilities o How best to collate the above information

Helena explained that this type of information would help inform planning approaches in the Core Strategy and City Management Plan and would also be relevant to work going on in anticipation of the introduction of a community infrastructure levy which would replaced the current system of planning obligations (sometimes known as section 106)

Councillor Keen (Chair) said that it was important faith communities had input into this very important issues and highlighted that the various newsletters and websites of the forum itself and of individual groups represented could be a useful vehicle.

Nazia (?) highlighted that consultation on these documents had been publicised in this way but response had been limited to date.

It was commented that some of the questions on the circulated note were quite difficult, even impossible to answer, particularly as there was not much available information. It was also commented that it is rather difficult to predict needs.

It was commented that most information was fairly anecdotal and for example a different preacher could skew demand significantly (i.e. a more popular preacher leading to much larger congregations in a short timeframe).

Helena said that even seemingly anecdotal information could be of value and suggested that the group may want to offer comments after the meeting, having had a chance to consider the questions and points set out in her note and indeed other issues.

It was reported that use of halls (particularly Church of England Church halls) for other community uses, including use by other church groups, can be quite intensive. This was important in understanding need but quite difficult to get a handle on.

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Providing funding to make buildings more accessible or requiring facilities with new development was suggested. Helena said that this was something that could be considered through work on the City Management Plan. Helena advised there is sometimes potential for this type of benefit but often not enough suggestions and firm plans to enable this type of benefit to be secured.

Helena said that it was as important to understand current demand as well as thinking about additional need. Nazia said that some work on auditing facilities had already been undertaken and could be made available.

Helena said that she would very much welcome any comments from the Faith Exchange as a collective or individually by mid December. This timeline was to ensure views considered as part of work on developing the final (submission) version of the Core Strategy. Helena said she appreciated it was quite a lengthy document and would be happy speak further with anyone and answer any further questions.

Councillor Keen (Chair) re-emphasised the importance of engagement with Core Strategy consultation and process in general and particularly because of its relevance to younger and future generations.

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Minutes of Meeting with Westminster PCT Westminster PCT Next Steps 6th November 2008

Attendees Tessa Lindfield (Joint Assistant Director Public Health and Well Being Westminster PCT) Hayley Sullivan (Public Health Coordinator Westminster PCT) Linda Capri (Head of Capital Planning & Property) Lisa O‟Donnell ( LDF Lead Officer) Helena Merriott (Principal Planner)

Purpose of the meeting was to discuss the next steps in the development of the Local Development Framework. The PCT were keen to ensure that had enough officers assigned to help with the LDF, in light that HS is off on maternity leave for a year. TL will cover HS responsibilities in the short term with colleagues, but needed sometime to identify who will feed into ensure planning can get the most of PCT as an organisation.

TL/HS: asked who else had responded to the Core Strategy Preferred Options and suggested that contact is made with the APO (the provider arm of the PCT) Claire Holloway CEO and CNWL Central North West London Mental Health Trust – Ian McClintyre and PPC – commissioning and link to the GP clusters.

Action: TL to forward contact names HM to organise letters and meeting. TL/HM TL advised that a number of documents have been published which are helpful for the development of the LDF these include:

Strategic Service Development Plan 2008-2013 published September 2008 Providing information on the estates condition NHS and GP services Estates Strategy 2008-2013 published September 2008 PCT Estates properties to owned and rented includes K&C, Brent and WCC The Strategic Plan (due 28th Nov). This will discuss the hub and spoke co location model poly systems.

Action: LC/TL to forward all documents. LC/TL

HM/LOD: This information will useful be for LDF, especially if some locations for hub/spoke models can be identified, there are particular areas where we expect there to be significant growth is the Opportunity Areas therefore there will be need for healthcare provision in these locations. Officers will await these document then review and discuss.

Action: HM to review documents (and polyclinics systems study) in relation to identifying healthcare requirements and the Imperials scheme for St Mary‟s subsequent meeting may be required to discuss approach to healthcare to inform the SPD on planning obligations. HM and others

PCT are working on a new health inequalities strategy. HM offered to join the steering group for this work. TL to forward HM contact details to Lisa Henschen.

Action: TL to forward HM details. TL

Discussion followed around the health inequalities experienced in Westminster and the need to ensure that data that reflects inequalities is captured in the LDF. In particular the linear relationship between life expectancy and income. The Public Health Annual Report 2006/07 does have some information which we can be used, but only when the document is published. TL advised that the report is currently at the printers and copies of the document will be available shortly. TL to ensure the City Planning Group receive a copy.

Action: TL to forward a copy of the PHAR 2006/07 TL

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Action: HM/LOD to review the PHAR 2006/07 HM

Issues like the linkages between housing and health alongside the need to be proactive and prioritise actions to deliver health benefits to people. It is about getting the tenure mix right, the LDF Policy approach will look at this mix in more detail. There are Pilot projects securing health benefits. One example is the Harrow Road a one point access to health, through GPS and Environmental Health to solve some of the poor quality housing that is a wider determinants of health. The HHSRS scheme identifies housing issues like damp, condensation and GPs can provide cross referrals. PCT are working with Community Protection to underline that the project is more than just about good quality housing also important healthy considerations. The policy approach for North West Westminster in the LDF and the Church Street Master Planning work will also identify some opportunities to re configure spaces in the area using CPO‟s to bring forward development sites and better facilities and housing.

In the PCTs response there was reference to DDA and doing more, what does this mean? all public buildings need to be accessible by law. The concern old buildings which are publicly accessible sometimes do not provide easy access, so it is about ensure better quality access, ensuring the retrofitting of properties in not a fudge, improving design in planning briefs and at all levels in the planning system. All future health facilities should be on the ground floor.

Preferred Option 32 was not answered in the PCT response was there a reason for this as all other options were addressed. This is the most important option as it refers to protecting and securing new health care provision in Westminster. This was an omission. The PCT explained that they needed to protect and secure, better models of care and facilities, there has been shift in the way the PCT provides services to meet needs and provide the most appropriate model of care and changes in need. Co location with other services is an important element of this approach. There is unmet need and need is changing, growth in consumerism means more people visit their GP surgeries these integrated models of healthcare need to be taken into consideration. PCT & WCC worked on wording a response to PO32.

A discussion took place regarding the location of any further facilities and whether there may be a need to CPO land in order to bring forward sites for development, LOD asked the PCT to identify any possible areas or to let the authority know if they are likely to need to use Compulsory Purchase Powers. If this is the case could LC was asked to identify that the PCT may wish to use CPO powers in the future and to detail this in a written response to the Core Strategy.

Action: HM to forward PO32 response to TL/HS/LC to review. HM/TL/LC Action: LC/HS/TL to consider whether the use of CPO powers, are required by the PCT and to draft a written response if necessary. LC/TL

Discussions took place around the City Management Plan (CMP) and how the PCT can be involved in the next steps of developing the LDF. The PCT agreed to ensure they were present at the relevant workshops. For example one area up for discussion was how the Planning can capture benefits from private health care for other healthcare provision in Westminster or for the community. Currently this is grey area in policy terms as the policy approach identifies all healthcare facilities are a social and community facility benefit. Discussions took place about the projections of needs in Westminster and whether private healthcare is in demand, PCT advised it was difficult to judge the demand for private healthcare as they have little to do with this type of healthcare provision. Further questions where asked about how much the NHS might share private facilities, the PCT where not sure on this point. Therefore, there needs to be an understanding by WCC of how private healthcare facilities work, whether they currently offer any community benefits or whether we should be securing funding from these schemes to invest back into the community.

There were also discussions around the possible gaps in healthcare provision due to the transient populations and the pressure group places on health care. The main problem with this is the uncertainty over population projections, as it is difficult to project the influx of people, to their knowledge there is not a huge influx in people placing pressure on services. But do these with ill

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Action: TL/HS to review the CMP letter and identify suitable members in the PCT to attend workshops and to identify any issues they feel need to be included in these discussions. TL/HS

Action: HM to organise a meeting to discuss population projections with Aylif Kingston, (the soon to be published Public Health Annual Report will also be discussed at this meeting to be sure the correct facts are detailed in the LDF evidence base). HM

HUDU model was discussed at the meeting by LC PCT asked if it was worth using the revised HUDU model to identify the provision of facilities in Westminster. HM The planning department considered using the original model, however, the assumptions around population projections were not considered relevant to Westminster due to the unpredictable population projections. LOD explained that in regional planning meetings with other boroughs some felt that the existing HUDU did not maximise the levels of investment into healthcare. In some instances the existing s106 model did more. The department had not yet considered the new model. The provision of healthcare and investment into future healthcare provision is an issue which is currently considered by the consultants URS who are working on the Community Infrastructure Levy work.

Helena Merriott City Planning Group.

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Minutes of meeting with Transport for London Monday 10th November 2008

Attendees: Lisa Webb (Transport for London), Graham King, Barry Smith, Sean Dwyer, Ian Morrison, Lisa O‟Donnell, Alex Willey (Westminster City Council)

TfL concerned about the short timescales imposed for consultation response. WCC note that the statutory 6 weeks is available and therefore this lies with internal GLA processes. Historically asked to forward all documentation through GLA rather than directly to TfL. WCC to email City Management Plan (CMP) documentation directly to LW at TfL.

Note that many of the issues raised by TfL are not Core Strategy matters and would be more appropriately addressed in the CMP e.g. cycle and car parking. Note that the Core Strategy will not be set out like a Unitary Development Plan (UDP) by topic area. Rather it will tell the story of Westminster, the opportunities, the constraints and the objectives, and the policies will be slotted into this. Therefore there will not be a “Transport” section as such. What is crucial is why the need for the policy arises e.g. servicing as set out below, or road safety which is a sub-set of broader health, safety and well-being objectives and policy. This accords with PPS12 and advice from GOL and PINs about new spatial planning documents. WCC also note the need for matters to be locally distinctive, and not repeat national and regional guidance. There is no need for cross-referencing, and this would not accord with the new style of policy document sought by the government.

WCC note local distinctiveness of servicing due to mix of uses including significant commercial element, dense environment, historic built fabric and pressure on highway space. Note joint plan for servicing by the New West End Company, TfL and WCC as an example. Do not consider freight to be locally distinctive, particularly as Westminster does not have industrial areas. Therefore, only include servicing and deliveries, not the wider issue RE freight. WCC note there are not the opportunities for water-based freight movement within Westminster. Note the Code of Construction agreed for Crossrail, and looking at this through the CMP. However, note that this is not a specific „Transport‟ matter, but relates to controlling adverse effects such as air quality, noise, safety and congestion, which are locally distinctive to Westminster.

WCC note that TfL‟s comments relate more to policy than infrastructure delivery. As a major delivery agency, partner and stakeholder, further comment is sought from TfL about what infrastructure is planned for Westminster over the next 15-20 years, the relationship to growth projections, areas and priorities, and the impact on existing communities and local residents and occupiers. WCC note that generic comments from TfL are not useful and may not even relate to Westminster, especially given TfLs role as a delivery agency for major infrastructure. For example, the reference to „Land for Transport‟ (March 2007) – do TfL need something? If so, what and where? If not, then do not include the reference. TfL to review its response and include specific comments relating to Westminster including any specific site requirements if there are any, proposed transport infrastructure, the timing, delivery and responsibilities for this and identification of risk and contingency. A full list of transport infrastructure priorities to be provided in accordance with PPS12 so WCC can consider for the Core Strategy – which already sets out priorities for transport infrastructure. TfL to also review those priorities already set out in the Core Strategy Preferred Options, in light of the „Way to Go‟ document, and provide comments. Discussion about “Way to Go”, the Direction for Travel for Transport by the Mayor of London. WCC seek TfL written comment on safeguarding particularly in relation to Crossrail 2 and the Cross River Tram as a matter of urgency. WCC do not wish to remove the safeguarding as this appears to be a very short-term approach that undermines decades of planning for the future and the need to address plan period i.e. 2012 – 2025/30 for the Core Strategy. WCC interested in the weight GLA/TfL will give to infrastructure projects if all relevant boroughs continue to support and safeguard them (e.g. CRT) TfL to provide advice regarding safe-guarding key transport infrastructure routes.

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WCC officers do not currently support a tunnel under Park Lane for reasons of congestion, biodiversity, heritage, air pollution and car parking. Request evidence base for reconsidering this when it was previously abandoned for good reasons. Relationship between shared highway space, safety and servicing/deliveries noted. The review of the bus network and signals is welcomed particularly in relation to Oxford Street. WCC seek comment from TfL about addressing Oxford Street and the allocation of highway space which is over-capacity and needs to be resolved. WCC support the cycle land along Victoria Embankment in principle, but note competing demands for highway capacity particularly with the proposed increased capacity of the piers and relationship with coach parking. There needs to be prioritisation and realism as to what can be safely accommodated.

WCC seek comment from TfL as to what they intend to do to improve air quality around TfL roads. Note the 6 roads responsible for EU air quality standard (PM10) exceedences within Westminster, of which 4 are TfL roads – Marylebone Road/Westway, Park Lane/Marble Arch/Hyde Park Corner, Edgware Road, and Knightsbridge/Brompton Road. Therefore, as a partner organisation WCC are looking to TfL for their proposals to address this issue. TfL to advise on proposals to address air quality . RE the Westway – also creates significant severance problems, and the relationship with Church Street and Harrow Road, two of Westminster‟s most deprived areas. The poor environment created by the Westway, severance, and it‟s decaying physical structure all need to be looked at. If diesels are phased out of Paddington Station, the environmental damage created by the Westway will come further to the fore as the background noise and air pollutants associated with the diesel engines are removed.

WCC consider coach parking needs to be addressed at a regional / sub-regional level.

WCC note that there are only two priorities in the Core Strategy Preferred Options – housing and pedestrians. We are seeking to provide for those who “live, work, and visit” Westminster.

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Minutes of meeting with Healthy Urban Development Unit (HUDU) 18th November, 2pm Westminster City Hall. Core Strategy Preferred Options

Attendees Malcom Souch – HUDU Neil Blackshaw – HUDU Lisa O‟Donnell – Westminster City Council Helena Merriott – Westminster City Council

Points raised in accordance with HUDU‟s agenda.

LDF Update Consultation continues on the Core Strategy, period extended from July to November 2008.City Management Plan consultation started in November. Initial letter to all stakeholders asking them about topics they feel need to be included in the City Management Plan – positive response to date. Westminster City Partnership (LSP) networks and sub networks have provided the forum for many of our consultation meetings.

City Management Plan - relationship with the Core Strategy The CS was the spatial strategy, identifying the type and location of development in Westminster. The CMP contains detailed policies identifying how development is managed in Westminster it identifies where, who and how this will take place. Strategic sites allocations These will be included in the Core Strategy.

Partnership working – how is it going Meetings held with PCT and LDF Team – who are your contacts at the PCT. Tessa Lindfield ( Joint Assistant Director Public Health and Well Being, Westminster PCT) Hayley Sullivan (Public Health Coordinator Westminster PCT) Natascha Hermann (Health and Well Being Manager) Lisa Henschen (Interim Head of Health Inequalities Public Health Directorate) Linda Capri (Head of Capital Planning & Property) Aylif Kingston (Head of Intelligence Westminster PCT) Officers explained that they have a close working relationship with members of the PCT discussing issues by email, telephone or by holding meetings. Letters and all correspondence goes to Michael Scott the Chief Executive of Westminster PCT. He has reviewed and signed off the response from the PCT on the Core Strategy.

PCT’s involvement in Health Impact Assessment Westminster PCT have been involved in the development of the HIA for the Core Strategy. They have made comment on the draft HIA and these comments where considered an points developed in the initial HIA which was produced to accompany the CS.

Role and relationship LSP & Reflect City Plan SCS health ‘goal’. We are working closely our colleagues in Policy and Performance to review the Sustainable Community Strategy (SCS), so that by early next year we will have the same shared vision and objectives for Westminster. At present the LSP are just starting the review of the SCS so the timelines are different, however, we ensure the objectives are consistent by the end of this year. We are also working together on the Comprehensive Area Agreements for local areas to ensure that priorities of areas detailed in the LDF are the same. The result should be the alignment of the CS and SCS sharing the same vision and objectives for Westminster.

Delivery of local infrastructure, joint asset / property strategy work Westminster has recently commissioned URS to undertake the Westminster Infrastructure Plan. This plan forms part of a wider piece of work known as the Central London Infrastructure Study signed up to by Central London Forward. It will provide an overarching infrastructure plan for the City of London, The Royal Borough of Kensington & Chelsea, London Borough of Camden, London Borough of Islington and London Borough of Southwark. The aim of the approach is to deliver infrastructure

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Appendix 22 – Preferred Options meetings minutes priorities and requirements in a holistic way. Westminster will be getting more out of this work than other boroughs as in accordance with the Community Infrastructure Levy, we have asked them to develop a charging schedule for Westminster.

HUDU asked that a copy of the study be sent to them. LOD: whatever is publicly available will be sent to HUDU.

Use of LAA targets as used in Option 5 The LAA targets where assessed in the initial drafting of the policy approach. These have informed the development of the key objectives of the Core Strategy. In the initial version of the Core Strategy we provided a diagram which outlined the relationship between the LAA and LDF objectives.

HUDU RESPONSE TO CS Vision and strategic objectives Reflect City Plan SCS health ‘goal’. (see comments above) Alignment with PCT vision and priorities The Core Strategy preferred options documents includes the health issues and priorities for Westminster PCT. This information was provided by the PCT. SMART objectives that can be monitored – work with PCT to identify targets Not raised by HUDU at the meeting. Post meeting note We will be reviewing the Public Health Annual Report and seeing if there are any key areas where planning can assist to bring forward a policy approach to improve health in Westminster, we will identify specific targets. We will also monitor our existing UDP approach in the Annual Monitoring Report. The 2007/08 AMR focuses on monitoring against policies.

Evidence and policy options Use of JSNA information in the Core Strategy The JSNA work has provided the LDF Team with another avenue to promote, discuss the LDF and the JSNA will help to add to the evidence base for the LDF on Health and other areas. It is still early days for the JSNA and data collection is still ongoing with data sets being validated by officers. The group recognises the importance of having a shared data set. The JSNA working group is likely to be spilt up into 3 groups over the next few months, JSNA Steering group, Rolling programme / oversight group and Information group and to ensure that the JSNA data and strategies can be developed further.

Use of Health Impact Assessments WCC feel health services and well-being is a cross cutting issue and a high priority. WCC has reflected this in different chapters and in the HIA. HUDU had concerns that the publication document seems to segregate health and well being out as a separate chapters. The rewrite of the Core Strategy is likely to reflect issues in more detail highlighting the issues, like worklessness, poor housing, physical environment and health.

Work with PCT (and HUDU – as suggested by GOL) WCC to check GOL‟s response on this issue.

Infrastructure Planning Infrastructure audit / assessment welcomed Need for a consistent, holistic approach to infrastructure across the borough based on evidence of needs, funding requirements ( reflects GOLs concern). Both points dealt with under partnership working – deliver of infrastructure. Alternative Option 8-G HUDU wanted to discuss the wording of Alternative Option 8 – G Mixed use in the Central Activities Zone. The concern raised was that this alternative option pre judged the outcomes of the infrastructure planning work and precluded any s106 contributions. LOD: explained the alternative option and advised that this was purely an alternative option (not the City Council‟s preferred option) it aim was to ensure social and community floorspace is part of the mix. The option was presented by the health and care board to try and prioritise the relevant healthcare infrastructure in Westminster to support new development. The infrastructure planning work will be the key piece of work to identify 127

Appendix 22 – Preferred Options meetings minutes the property requirements across the council and this identify the priorities. LOD encouraged HUDU to write in if they has strong views on this alternative option.

Other issues raised: GIS Capabilities of the City Council The City Planning Group has its own GIS Team this team known as I&I Information and Intelligence have the expertise to meet the departments specialised mapping requirements.

Conformity with the London Plan HUDU raised concerns about the conformity with the London Plan, there seems to be a lack of overview of the policies in the London Plan within the Core Strategy. WCC has received guidance from a number of different places to say that we should not repeat regional or national guidance in the CS, locally distinctive issues will be reflected in the document. We are also mindful that London Plan policies may disappear by 2012.

Accessibility Modelling HUDU asked whether in considering the location of new healthcare facilities we would use TfL accessibility modelling, LOD: explained that all parts of Westminster in are in PTAL range 6 therefore this approach is not feasible for the Westminster to apply. Our Colleagues in the PCT Linda Capri were discussing using this model we discussed our concerns at our last meeting.

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Appendix 22 – Preferred Options meetings minutes

Comments from West End LARP (Soho Caring Agencies) 20th November 2008 HS & TK

Retail Have we taken account of the Soho Action Plan? What about including Carnaby Street within the WESPRA? East End of Oxford Street is currently blighted by Crossrail. Wold like clarification over what is happening with Crossrail? There is a need for small shops at this end of Oxford Street. Retail likely to be heavily affected by current market conditions. Have we taken economic situation into account? The change in void rates (payable after 3 months) may blight the area.

Entertainment It is often the outside space that causes is problems/noise etc Issue over late licences granted. Can sometimes be better for entertainment uses to stay open until 6am rather than disrupt at 3am. Need for more „local feel‟, smaller independent uses (think this comment was directed at retail uses as well) Need for more consistent enforcement Issue of tables and chairs – can cause problems in terms of disruption

Issue of „A‟ boards. Not happy that have been asked to remove by the Council – many have been in place for years and years – deemed consent? Not just commercial uses, but also churches, for example.

Transport/access Lines of buses along Oxford Street is seen as a problem. Issue with pavements/road layout/lorries in Shaftesbury Avenue. Was a fatality recently. Need for more dropped curbs – disabled access etc

Some informal views expressed during break Issues regarding smoking ban – means people outside creating noise. Pedestrianisation not always seen as a good thing. Will impact upon passing trade (by car), and will make deliveries very difficult. Reference to potential pedestrianisation in Kingly Street – shop owner against.

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Appendix 23 – Preferred Options Area Forums feedback

South Area Forum Newsletter Winter 2008 Feedback on meeting of 15th October 2008

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Appendix 23 – Preferred Options Area Forums feedback West End Area Forum Newsletter Winter 2008 Feedback on meeting of 23rd October 2008

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Appendix 23 – Preferred Options Area Forums feedback Bayswater Area Forum Newsletter Winter 2008 Feedback on meeting of 3rd November 2008

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Appendix 23 – Preferred Options Area Forums feedback Maida Vale Area Forum Newsletter Winter 2008 Feedback on meeting of 4th November 2008

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Appendix 24 – Preferred Options letter to disability organisations

Councillor Robert Davis DL Deputy Leader Cabinet Member for Built Environment

Please reply to: Helena Merriott

Direct Line / Voicemail: 020 7641 2860 Fax: 020 7641 3050 Email: [email protected]

Date: 8th September 2008 Dear Sir/Madam

Planning and Compulsory Purchase Act 2004 Westminster Local Development Framework Core Strategy Development Plan Document: Preferred Options

We are writing to notify you of Westminster City Council’s Core Strategy – Preferred Options which we are currently consulting on. It will set the direction for Westminster for the next 15- 20 years, managing development and change.

Westminster contains many areas of national and international importance including the West End, Theatreland, Oxford, Regent and Bond Street, major public spaces such as Trafalgar and Parliament Squares, the Royal Parks and many other internationally known attractions. It has almost 50,000 businesses, 40% of London’s hotel bedspaces and 3,000 places to eat and drink, dance and socialise. Therefore our policy direction can have a more than local effect.

We have contacted disability groups locally, but because of the significant numbers of people that come into Westminster to work or visit, we have decided to extend this to national disability organisations.

The Core Strategy – Preferred Options document is available at www.westminster.gov.uk/ldf. Other documents to help you respond to the Preferred Options document are also available, including an initial Equality Impact Assessment and an initial Health Impact Assessment. Please contact Helena Merriott 020 7641 2860 to discuss further or to request a hard copy of any of these documents.

If you would like to view a paper copy of the consultation documents, please see details on the back of this letter.

Yours faithfully,

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

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Appendix 24 – Preferred Options letter to disability organisations

Core Strategy for Westminster

R MacQueen Director of Planning and City Development 24th July 2008

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Appendix 25 – Disability organisations consulted at the Preferred Options stage

Action for Blind People Action Trust for the Blind Age Concern Alzheimer's Society Arthritis Care Association for Spina Bifida and Hydrocephalus British Deaf Association British Institute of Learning Difficulties Deafblind UK Depression Alliance Employers Forum on Disability Foundation for People with Learning Disabilities Hearing Concern Mencap Mental Health Foundation Mind Motor Neurone Disease Association Multiple Sclerosis Society Muscular Distrophy Campaign National Federation of the Blind National Society for Epilepsy National Wheelchair Housing Association Neurological Alliance Royal National Institute for Deaf People Royal National Institute for the Blind Scope Sense Spinal Injuries Association Stroke Assocation

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Appendix 26 – WPOA Preferred Alternative Options

Westminster City Council Local Development Framework

Core Strategy Preferred Options (July 2008)

WPOA Preferred Alternative Options

Introduction

This document contains WPOA’s preferred alternative options for the Westminster City Council LDF Core Strategy in respect of a select number of preferred options. It follows a series of meetings between WCC and WPOA, a detailed note of which is attached. The note highlights the justification for the WPOA preferred alternative options upon a select number of preferred options contained within the WCC consultation document.

Where appropriate proposed text for supporting paragraphs to the preferred alternative options have been highlighted.

In agreement with WCC, WPOA have set out preferred alternative options in accordance with the objectives of PPS12 to ensure public consultation and scrutiny of the alternative options at as early a stage in the LDF process as possible.

Where the preferred alternative option in part includes the same wording as the WCC preferred option the proposed revisions are highlighted in bold.

Preferred Alternative Option 1 – Strategic Objectives

To accommodate the projected growth for Westminster in a sustainable balanced manner through:

a) Actively encouraging and directing commercial development to the wider Central Activities Zone and in particular to the Core CAZ and Opportunity Areas, and the North Westminster Economic Development Area and retail uses to the West End Special Retail Policy Area and designated shopping centres.

b) Identifying sites for housing development to meet the 6,800 housing target between 2007/8 and 2016/17 and ensuring that the number of residential units on sites is optimised;

c) Equal priority for encouraging commercial and residential development in Core CAZ reflecting the need to ensure adequate capacity to meet future demand for new commercial space within the country’s most important strategic office location

d) Ensuring that residential, commercial and other development of all forms is of the highest quality in relation to amenity, function, useable space for occupier requirements, and sustainability in all respects;

e) Directing highly vulnerable uses away from Flood Risk Zone 3 and ensuring that more vulnerable uses take in to account the risk of flooding in this zone, in particular those areas in Flood Zone 3 that are shown to be most at risk of rapid inundation;

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Appendix 26 – WPOA Preferred Alternative Options

f) Identifying major proposals sites for development, as set out in Appendix 1 and shown on Map PO 1d.

Supporting Paragraphs

The City Council will encourage densification and maximising development capacity subject to respecting existing character and context, to encourage rather than restrain all forms of commercial and residential development. Within the Opportunity Areas and East Oxford Street, the City Council will positively encourage and facilitate delivery of development which would result in sustainability, design and land use benefits.

The City Council recognise the highly complex nature of mixed-use development including affordable housing in Core CAZ including

The economics of development; Achieving excellent design Heritage constraints

And that mixed-use policy must be sufficiently flexible to encourage rather than restrain new development.

Key themes

Support for sustainable economic growth Equal priority for residential and commercial development in Core CAZ reflecting strategic objectives; Shift of emphasis to more explicitly encourage commercial forms of development; Quality and function considerations for commercial development;

Preferred Alternative Option 3 – Housing

To encourage the provision of more homes by ensuring that planning obligations and mixed- use and affordable housing policy requirements facilitate rather than constrain housing delivery, for example by cushioning the impact of mixed-use and affordable housing policies so as not to discourage development on existing residential sites or on sites with a high existing asset value where commercial use is an acceptable alternative.

Supporting paragraphs

Recognition that via mixed-use policy in Core CAZ commercial development including offices, retail, hotels and other uses, enables the provision of additional housing development and should be actively encouraged.

The City Council recognises the highly complex nature of mixed-use development in Core CAZ including the economics of development, achieving excellent design and heritage constraints upon densification. Strategically, the City Council’s policies need to encourage rather than restrain housing delivery which requires a flexible approach to mixed use and affordable housing policy and an understanding of the economics of development to achieve strategic sustainability, design and land use benefits.

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Appendix 26 – WPOA Preferred Alternative Options

Financial appraisals will be required to demonstrate that continued or alternative commercial use is an acceptable alternative.

Key themes

Flexibility in mixed-use and affordable housing policy requirements Equal priority for commercial and residential uses in Core CAZ; Recognition of existing asset values and development thresholds; Complexities of mixed-use development in Core CAZ

Preferred Alternative Option 8 – Mixed-Use Policy

Maintain and enhance the mixed use character of the Central Activities Zone by seeking broadly the equivalent provision of housing when increases in commercial floorspace are proposed in Core CAZ either:

a) on-site where this is practical or appropriate; or

b) off-site elsewhere within the City via a land use swap or previously agreed land use credit which deliver better housing solutions in terms of quantity, quality and delivery than could be delivered on site; and

c) If this is not appropriate or practical, health, education, social, community, cultural or other uses should be provided which contribute to the character and function of that part of the Core CAZ and/or contribute to the needs of the local community.

A higher proportion of housing will be sought outside of Core CAZ.

Exceptions will be appropriate in major commercial schemes in the following locations:

a) Paddington Opportunity Area; b) Victoria Opportunity Area; c) Tottenham Court Road Opportunity Area; d) Oxford Street east of Oxford Circus e) Crossrail Over-Site Developments

Where this is necessary to facilitate substantial planned infrastructure improvement of benefit to the local community in accordance with the priorities set out in preferred options 10-13. In such cases the provision of substantive transport improvements and/or public realm will be considered the priority and offset some or all of the requirement to provide housing.

Within the Opportunity Areas and Oxford Street east of Oxford Circus the City Council will actively encourage and facilitate redevelopment to achieve regeneration, commercial, housing, exceptional design and sustainability objectives.

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Appendix 26 – WPOA Preferred Alternative Options

Supporting Paragraphs

Practical and appropriate should be clearly defined including reference to quality and function of proposed uses, external and internal design considerations, quality of residential amenity and environment and relationship with adjoining commercial uses. It also needs to have full regard to the economics of development.

Mixed-use policy contains recognition of:

The complexities of mixed-use development in Core CAZ; The economics of development and high development thresholds The need to actively encourage and deliver major new development in the Opportunity Areas The objective of delivering exceptional design quality The need for flexibility of mixed-use policy to deliver strategic objectives

Removal of the practical and appropriate tests for off-site solutions

Removal of the vicinity test to facilitate housing delivery objectives

Need to formulate flexible mixed-use policy to deliver better housing solutions

Key themes

Flexibility in mixed-use policy to deliver better quality housing solutions Recognition of commercial investment decisions Priorities in Opportunity Areas

Preferred Alternative Option 10 – Retail

To designate a West End Special Retail Policy Area (WESRPA) with regard to the London Plan, as shown on Map PO 10 (at the end of this chapter).

Within the WESRPA area the following will take priority:

retail growth provision of enhanced quality and function of retail space throughout WESRPA improved pedestrian environment including the creation of “Oases” of open space, and the reduction of pedestrian and vehicular congestion; improved public transport provision and access to it; improved linkages to and from the surrounding shopping areas and visitor attractions including the British Museum and Covent Garden

In accordance with ORB objectives the City Council will encourage and, where appropriate, actively facilitate public realm and regeneration enhancements on Oxford Street and other locations within the WESRPA.

At the eastern end of Oxford Street, the Council will offset some or all of the residential requirement where this is necessary to deliver substantial transport improvements and/or public realm improvements of benefit to the local community.

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Appendix 26 – WPOA Preferred Alternative Options

Where existing building stock is refurbished, including the provision of new ground floor entrances for upper floor uses, the City Council will have regard to the benefits of enhanced entrances and use of the upper floors.

Key themes

Enhanced quality and function of retail floorspace Revised emphasis to facilitate regeneration Certainty in land use priority in WESRPA Refurbishment of existing stock – new entrances to the upper floor uses can impact upon existing retail floorspace at ground floor level;

Preferred Alternative Option 18 – Design Quality

Development should be of exemplary standards of sustainable inclusive urban design and architecture, innovative architecture which respects the context of Westminster’s unique local distinctiveness and adds to its world class city status is encouraged. Exemplary design should relate to external, internal and functional aspects of design and the City Council recognise the requirements for flexibility in land use policy requirements in delivering world class architecture and quality accommodation.

Key themes

Most buildings of exceptional design quality cannot accommodate more than 2 uses; Flexibility in formulating mixed-use policy is required to deliver exceptional buildings that function properly and deliver the quality of accommodation that occupiers require from a world class location.

Preferred Alternative Option 37 – Affordable Housing

To work towards a target of 50% of new housing provision being affordable housing throughout the City and 30% maximum provision in Core CAZ, and maximise the provision of affordable homes by:

a) Requesting affordable homes on housing developments of 10 or more additional units or 1,290 square metres or more of additional residential floorspace;

b) Securing the relevant proportion of the net additional residential accommodation as set out within the City Management DPD by calculating the proportion of affordable housing required in floorspace. An average weighted unit size of 129 square metres should be used to calculate private and affordable housing capacity or alternative notional size based upon local market evidence;

c) Expecting affordable housing to be provided on site or off-site within the City of Westminster via land use swaps or credits;

d) Exceptions, including financial contributions in lieu, will only be acceptable where it can be demonstrated that

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Appendix 26 – WPOA Preferred Alternative Options

The affordable units cannot be transferred for management by an RSL or other appropriate body; and/or Affordable housing cannot be provided on or off site; or Insistence upon affordable housing on site would result in a scheme not proceeding or prejudicing other planning benefits; Other planning advantages would accrue; Where not appropriate or practical health, education, social, community, cultural or other uses should be provided which contribute to the needs of the local community;

e) Financial viability appraisals will be required to demonstrate that the level of affordable housing represents the maximum reasonable amount having regard to the Council’s affordable housing target, the need to encourage rather than restrain residential development, and the individual circumstances of the site.

Supporting paragraph

Confirmation that the 129 square metre figure is based upon WCC research of decisions between 2005 and 2007

In relation to off site affordable housing solutions the City Council will ensure that the proposed off site solution does not result in an over-concentration of a specific tenure or socio-economic or demographic profile.

Removal of the vicinity test and practical and appropriate tests for off-site housing solutions

Clarification of where financial contributions in lieu of affordable housing provision will be deemed appropriate.

Confirmation that staircasing will be retained between 10 and 25 additional units in Core CAZ.

Key themes

Flexibility in land use policy Benefits of land use swaps and credits in delivering better housing solutions Recognition of high asset values and development thresholds

Preferred Alternative Option 40 – Business Floorspace

The City Council will seek a range of flexible business floorspace of all sizes to maintain economic resilience, improve accessibility to business opportunities and premises within Westminster, and support the Creative Industries sector. New business floorspace should be of the highest quality in terms of quality and function to meet occupier requirements.

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Appendix 26 – WPOA Preferred Alternative Options

Key themes

Evidence base does not support major intervention in planning system for affordable workspace; Recognition of quality of commercial floorspace;

Preferred Alternative Option 41 – Retail

Deletion of final sentence which states:

“The Council will seek to secure small/affordable shop units through S106 contributions as recommended by the Mayor” and replace with:

“The Council will seek to encourage a range of retail unit sizes within retail developments”

Key themes

The revised wording reflects PPS6 objectives in encouraging a mix of unit sizes including smaller retail units. The market will dictate the mix of retail unit sizes which will differ subject to the specific characteristics of the locality (eg: Covent Garden). There is no evidence to demonstrate a need for imposing a restriction upon developers to provide smaller retail units and this will create a two tier retail market.

If the City Council retain the requirement for Section 106 contributions these need to be off-set against other objectives including housing and affordable housing benefits.

Preferred Alternative Option 44 - Hotels

New hotel development will be directed to the Core Central Activities Zone and the Opportunity Areas.

Existing hotels that have appropriate servicing provision and do not have adverse effects on residential amenity will be protected throughout Westminster except where:

a) loss of the hotel would not prejudice the tourism vision to achieve 40,000 additional hotel beds by 2026 based upon evidence of supply and demand trajectory; and b) the existing hotel character and function does not make a positive contribution to tourism objectives in the City of Westminster; and c) the loss of the hotel would result in increased housing supply in Westminster; d) in Bayswater and Pimlico where the conversion of hotels to residential will be encouraged

Key themes

Hotel trajectory in relation to demand and supply; Land use priorities

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Appendix 27 – Council response to WPOA Preferred Alternative Options

WPA preferred alternative options are without prejudice to WPA representations upon the Core Strategy Preferred Options. Proposed revisions are highlighted in bold.

WPA Preferred Alternative Options WCC Response Preferred Alternative Option 1 - Strategic Objectives To accommodate the projected growth for Westminster in a The concept of sustainable and balanced development is considered to be part of sustainable development, set out sustainable balanced manner through: in one of the key strategic objectives. In development of the Publication Draft, Westminster’s role in providing employment has also been highlighted. a) Actively encouraging and directing commercial development to a) The Publication Draft highlights the importance of commercial development. The drafting of the Core Strategy the wider Central Activities Zone and in particular to the Core CAZ and does not use terms such as ‘actively encourage’ except in specific circumstances as this often does not add to the Opportunity Areas, and the North Westminster Economic usefulness of policies in determining planning applications, particularly the relative balance of priorities. Rather, an Development Area and retail uses to the West End Special Retail area-specific approach is taken to what types of uses and development are appropriate in specific areas. This accords Policy Area and designated shopping centres. with comments by the Government Office for London who felt that it was important to say what was expected for each of the different areas. c) Equal priority for encouraging commercial and residential c) Long-term data indicates that the amount of office floorspace has continued to increase within the Core CAZ over development in Core CAZ reflecting the need to ensure adequate the past 25 years, and the relative proportion of office floorspace has fluctuated by only 3% (50% in 1983, 51% in capacity to meet future demand for new commercial space within 1990 and 48% in 2008). Coupled with this, evidence shows that Westminster is only just meeting its housing target the country’s most important strategic office location every year and that a significant proportion of this housing is from sites within the Core CAZ (45% of the housing units delivered between 2004-2007/08, and 47% of the housing target for that period). The current UDP approach prioritises housing above other uses and, as evidence suggests this is delivering an appropriate balance of development, it is considered that this is the most appropriate strategy for Westminster. d) Ensuring that residential, commercial and other development of d) There is no differentiation between the quality of healthy, safe, sustainable and inclusive design required for all forms is of the highest quality in relation to amenity, function, different uses. There are separate policies for specific requirements for residential accommodation and protection of useable space for occupier requirements, and sustainability in all residential amenity. This arises from specific needs that may not necessarily be otherwise met and which are respects; necessary for a healthy and comfortable living environment, and will be particularly relevant for the affordable housing sector where people have very restricted choices. PPS3 emphasises the importance of achieving high quality housing; there is no need to refer to quality in this context. It is acknowledged that workplace conditions are likewise important, however employers have greater choice about their accommodation and commercial development is considered to be adequately covered by the general design policy approach. Supporting Paragraphs In general terms, the Publication Draft Core Strategy encourages appropriate development. However, it would not The City Council will encourage densification and maximising be appropriate to state this in every policy. A statement that the council will “encourage rather than restrain all development capacity subject to respecting existing character and forms of commercial and residential development” is inappropriate as this must be caveated in all cases by the need context, to encourage rather than restrain all forms of commercial to meet the policies within the development plan, which will obviously restrain development in order to meet and residential development. Within the Opportunity Areas and East appropriate planning objectives and address challenges. This is the purpose of the planning process as set out in Oxford Street, the City Council will positively encourage and facilitate PPS1, “a system of plan preparation and control over the development and use of land” to “get the right delivery of development which would result in sustainability, design development in the right place at the right time”. and land use benefits.

147 Appendix 27 – Council response to WPOA Preferred Alternative Options

The City Council recognise the highly complex nature of mixed use development including affordable housing in Core CAZ including The economies of development; Achieving excellent design; Heritage constraints And that mixed use policy must be sufficiently flexible to encourage rather than restrain new development. Preferred Alternative Option 3 - Housing To encourage the provision of more homes by ensuring that planning Preferred Option 3 sought a policy steer on the policy approach to planning obligations and affordable housing obligations and mixed-use and affordable housing policy policy, and was not intended to be translated into a policy in its own right. Preferred Option 2 on planning obligations requirements facilitate rather than constrain housing delivery, for (including affordable housing) notes that these should not compromise overall delivery of appropriate development. example by cushioning the impact of mixed-use and affordable The mixed use preferred policy option (Preferred Option 8) also includes a cascade of options for those housing policies so as not to discourage development on existing circumstances where it is not possible to provide the mix of uses sought on site. Regarding the specific points raised residential sites or on sites with a high existing asset value where regarding mixed use and affordable housing policies and sites with high existing asset values: commercial use is an acceptable alternative. - the publication draft Mixed Use policy is intended to facilitate housing development where none would otherwise have occurred. It is also cushioned by having a 200 sq m threshold (or 400 sq m in some cases). Supporting paragraphs The cascade of alternative options where on-site is not considered appropriate and practical, will be Recognition that via mixed-use policy in Core CAZ commercial covered in the City Management Plan. development including offices, retail, hotels and other uses, enables - the publication draft of the affordable housing policy requires on-site affordable housing where this is the provision of additional housing development and should be practical and viable; there are other alternatives where on-site provision is not considered practical or actively encouraged. viable. The proportions of affordable housing required will be addressed in the CMP but is likely to take into account the size of the development and its existing and alternative use values. The City Council recognises the highly complex nature of mixed-use This statement misses other aims of the council such as its commitment to affordable housing provision, and in development in Core CAZ including the economies of development, compliance with PPS3 and the London Plan, to seek affordable housing on site wherever possible; and its aim to achieving excellent design and heritage constraints upon maintain and enhance the mixed use character and function of CAZ, which is the primary purpose of the mixed use densification. Strategically, the City Council’s policies need to policy. Off-site provision, especially when it is beyond the vicinity, and even more so when it is outside the CAZ has a encourage rather than restrain housing delivery which requires a detrimental effect on the mixed use character of localities in CAZ. flexible approach to mixed use and affordable housing policy and an understanding of the economics of development to achieve strategic sustainability, design and land use benefits. Financial appraisals will be required to demonstrate that continued or The council only requires financial appraisals when the applicant claims that it is not possible to comply with policy. alternative commercial use is an acceptable alternative. Such appraisals can then be considered as a material consideration when assessing planning applications. WPA’s Preferred Alternative Option 8 – Mixed use policy Maintain and enhance the mixed use character of the Central ‘Broadly’ is not an acceptable term because it is fairly meaningless and implies an unacceptable degree of flexibility Activities Zone by seeking broadly the equivalent provision of housing and (downward) negotiation from the term ‘equivalent’ which is definite and certain. when increases in commercial floorspace are proposed in Core CAZ either: WPA’s alternative option suggests equal weight be given to provision of housing on-site or off-site elsewhere in the a) on site where this is practical or appropriate; or City. This would defeat the aim of the policy which is to maintain and enhance the mixed use character of b) off-site elsewhere within the City via a land use swap or Westminster’s CAZ, which is formed by the mix of uses in individual buildings, streets, and localities. It is therefore previously agreed land use credit which deliver better crucial for this policy’s success for the residential units which are so instrumental in contributing to mixed use and

148 Appendix 27 – Council response to WPOA Preferred Alternative Options

housing solutions in terms of quantity, quality and delivery vibrancy, to be provided, as preference, alongside the commercial increase on the site. If this cannot be achieved, the than could be delivered on site; and Preferred Option requires it to be provided off-site in the vicinity, to prevent office dominated streets or areas c) if this is not appropriate or practical, health, education, developing within the CAZ. Providing the housing ‘elsewhere within the City’ would lead to incremental change in the social, community, cultural or other uses should be provided character of the CAZ to one dominated by offices. However, the cascade of other options when on-site residential is which contribute to the character and function of that part not considered appropriate or practical will now be included in the City Management Plan. of the Core CAZ and/or contribute to the needs of the local community.

A higher proportion of housing will be sought outside of Core CAZ. Exceptions will be appropriate in major commercial schemes in the A degree of discretion will still be required by the council as it may be possible in some cases to provide the mixed following locations: use on site while still providing the public transport/public realm improvements, and likewise the council would wish a) Paddington Opportunity Area; to be satisfied that the scale of the improvements were sufficient to warrant the off-setting of the mixed use b) Victoria Opportunity Area; requirements. c) Tottenham Court Road Opportunity Area; d) Oxford Street east of Oxford Circus; e) With the exception of Bond Street, the Crossrail sites are within the Paddington and Tottenham Court Road e) Crossrail Over-Site Developments Opportunity Areas where additional housing should be provided in accordance with the Mayor’s London Plan. As above, a degree of discretion will be required when applying the mixed-use policy as it may be possible in some cases to provide the mixed use on site, and in other cases off site, to allow for the provision of the necessary Crossrail infrastructure. The detailed policy approach to Crossrail Over-Site Development is set out in the Adopted Crossrail Planning Briefs, September 2009. Where this is necessary to facilitate substantial planned infrastructure This is provided for in the wording of area-based policies where it applies. improvement of benefit to the local community in accordance with the priorities set out in preferred options 10-13. In such cases the provision of substantive transport improvements and/or public realm will be considered the priority and offset some or all of the requirement to provide housing. Within the Opportunity Areas and Oxford Street east of Oxford This is not considered to add anything to the policy, and detracts from other areas by implying that these are only Circus the City Council will actively encourage and facilitate objectives within the stated areas. For example, all of these matters would equally apply to the Economic redevelopment to achieve regeneration, commercial, housing, Development Area or large areas within Core CAZ. Exceptional design and sustainability objectives are subject to exceptional design and sustainability objectives. cross-cutting policies that apply across Westminster – not just the Opportunity Areas and parts of Oxford Street.

The City Council recognise the complexities of mixed-use development in Core CAZ including the economics of development and heritage/design constraints. Mixed-use policy has been formulated to be sufficiently flexible to facilitate not restrain new development. Supporting Paragraphs Practical and appropriate should be clearly defined including reference The detail of what comprises ‘practical and appropriate’ is more appropriate within the City Management Plan or to quality and function of proposed uses, external and internal design even Supplementary Planning Guidance. considerations, quality of residential amenity and environment and

149 Appendix 27 – Council response to WPOA Preferred Alternative Options

relationship with adjoining commercial uses. It also needs to have full The existing policy framework operates very effectively in delivering a mix of uses, contributing to Westminster’s regard to the economics of development. unique CAZ area (within the Core CAZ in particular) and those other aspects that the evidence indicates are so important to Westminster’s attractiveness and economic resilience, including its mix, vitality and heritage (Drivers Mixed-use policy contains recognition of: Jonas, 2007). The complexities of mixed-use development in Core CAZ; The economics of development and high development The policy approach does provide for flexibility in appropriate circumstances. thresholds; The need to actively encourage and deliver major new development in the Opportunity Areas The objective of delivering exceptional design quality The need for flexibility of mixed-use policy to deliver strategic objectives

Removal of the practical and appropriate tests for off-site solutions

Removal of the vicinity test to facilitate housing delivery objectives

Need to formulate flexible mixed-use policy to deliver better housing solutions Preferred Alternative Option 10 - Retail To designate a West End Special Retail Policy Area (WESRPA) with regard to the London Plan, as shown on Map PO 10 (at the end of this chapter)

Within the WESRPA area the following will take priority: retail growth provision of enhanced quality and function of retail space This has been incorporated. Improved retail space is listed as a priority within the WESRPA. throughout WESRPA improved pedestrian environment including the creation of “Oases” of open space, and the reduction of pedestrian and vehicular congestion; improved public transport and access to it; improved linkages to and from the surrounding shopping areas and visitor attractions including the British Museum and Covent Garden In accordance with ORB objectives the City Council will encourage This has been incorporated. The WESRPA policy sets out the objectives of the ORB Action Plan, and is designed to and, where appropriate, actively facilitate public realm and maintain and enhance the Oxford Street and the wider West End area. regeneration enhancements on Oxford Street and other locations within the WESRPA. At the eastern end of Oxford Street, the Council will offset some or all This emphasis would be inappropriate. Residential remains a priority throughout Westminster, and would be

150 Appendix 27 – Council response to WPOA Preferred Alternative Options

of the residential requirement where this is necessary to deliver acceptable and encouraged at upper floors at the eastern end of Oxford Street where appropriate. The WESRPA substantial improvements and/or public realm improvements of policy has been drafted to allow flexibility in the application of the mixed-use policy where this is necessary to deliver benefit to the local community. substantial transport and/or public realm improvements. This is not to say that residential will not be permitted in this area. The council would need to be satisfied that the scale of the improvements was enough to warrant the Where existing building stock is refurbished, including the provision of offsetting of any residential requirement. new ground floor entrances for upper floor uses, the City Council will have regard to the benefits of enhanced entrances and use of the upper floors. Preferred Alternative Option 18 – Design Quality Development should be of exemplary standards of sustainable This policy approach has been provided for in the health, safety and well-being policy and design policy within the inclusive urban design and architecture, innovative architecture which Core Strategy. In particular the design policy supports imaginative modern architecture that enriches Westminster’s respects the context of Westminster’s unique local distinctiveness and world-class city environment. It also requires the provision of flexible floorspace that can adapt to changing adds to its world class city is encouraged. Exemplary design should circumstances and uses over time. The approach to different land uses is set out in other Core Strategy policies. The relate to external, internal and functional aspects of design and the second part is contrary to government advice: terms such as ‘normally’ and the like are not necessary as it is the City Council recognise the requirements for flexibility in land use nature of the planning process for all policies to be taken into account and assessed against each other in policy requirements in delivering world class architecture and determining planning applications. quality accommodation. Preferred Alternative Option 37 Affordable Housing To work towards a target of 50% of new housing provision being This reference would be inappropriate. The 50% affordable housing reference is Westminster’s overall target for affordable housing throughout the City and 30% maximum provision affordable housing provision from all sources, including RSL and CityWest Homes own developments. Policy 3A.9 of in Core CAZ, and maximise the provision of affordable housing by: the London Plan clearly sets out the definition of the 50% target and notes the difference between this target and the amount to be sought on individual schemes. The 30% is a reference to site-specific negotiations for affordable housing. Site-specific proportions of affordable housing will be set out in the City Management Plan. a) Requesting affordable homes on housing development of 10 (a) The evidence for this 1,290sq m threshold, as set out in the supporting text, relates to the average floorspace of or more additional units or 1,290 square metres or more of residential units across Westminster in one particular 12 month period. Not only is this subject to significant additional residential floorspace fluctuation, it also reflects average floorspace area not site capacity, which London Plan policy 3A.11 states that the threshold should reflect. The appropriate floorspace threshold is based on the floor area capable of accommodating 10 or more residential units In considering the unique circumstances of Westminster, it is considered that a threshold of 1,000 sqm represents the most appropriate response to affordable housing thresholds, taking account of both the London Plan and the type of housing that typically comes forward within Westminster. b) Securing the relevant proportion of the net additional b) There is no need to quantify an average unit; the City Management Plan will assess affordable requirement on a residential accommodation as set out within the City floorspace proportion. Having a separate reference to an alternative notional size would introduce an unacceptable Management DPD by calculating the proportion of degree of uncertainty, particularly over time, into the requirement and delivery of affordable housing. This is also affordable housing required in floorspace. An average considered to be contrary to Planning Policy Statement 3 requirement for DPDs to set out the range of circumstances weighted unit size of 129 square metres should be used to in which affordable housing will be required. calculate private and affordable housing capacity or alternative notional size based upon market evidence; c) Expecting affordable housing to be provided on site or off- c) This would be contrary to paragraph 29 of Planning Policy Statement 3 which states that “the presumption is that site within the City or Westminster via land use swaps or affordable housing will be provided on the application site so that it contributes towards creating a mix of housing. credits; However, where it can be robustly justified, off-site provision or a financial contribution in lieu of on-site provision...”.

151 Appendix 27 – Council response to WPOA Preferred Alternative Options

The Secretary of State directed the London Borough of Southwark in relation to their Unitary Development Plan requiring them to remove explicit reference to payments in lieu on the basis that the presumption should be for on- site affordable housing. The same principle would apply in this case and it is expected that the Secretary of State would find such a policy unsound on the basis of inconsistency with national policy guidance.

However, the draft submission policy provides guidance as to the circumstances where off-site provision may be acceptable. d) Exceptions, including financial contributions in lieu, will only be acceptable where it can be demonstrated that: The affordable units cannot be transferred for management by an RSL or other appropriate body; and/or is a City Management Plan issue. Affordable housing cannot be provided on or off payment in lieu will be accepted when on or off-site has been thoroughly explored and proved impractical site; or or unfeasible. Insistence upon affordable housing on site would “insistence upon…” and “other planning advantages” are inappropriate as they imply that affordable result in a scheme not proceeding or prejudicing housing is of a lesser priority than other planning objectives or obligations. This is not the case, and where other planning benefits; there are competing demands and delivery of all demands would make a scheme unviable, this would Other planning advantages would accrue; need to be negotiated on a site-by-site basis. In many cases it is anticipated that the requirement for Where not appropriate or practical health, affordable housing would take priority over other matters. education, social, community, cultural or other is considered incorrect as, if a site is suitable for residential accommodation and hence generate the uses should be provided which contribute to the requirement for affordable housing, it is therefore appropriate for affordable housing. Social and needs of the local community; community uses will be requested as appropriate to support new residential developments.

e) Financial viability appraisals will be required to e) Detail regarding financial viability appraisals is more appropriate for the City Management Plan, particularly as this demonstrate that the level of affordable housing will set out the proportion sought in different circumstances and locations. It is also noted that the Development represents the maximum reasonable amount having Plan Documents should not repeat national or regional guidance, and much of this wording is from Policy 3A.10 of regard to the Council’s affordable housing target, the need the London Plan. to encourage rather than restrain residential development, and the individual circumstances of the site.

Supporting paragraph Confirmation that the 129 square metre is based upon WCC research of decisions between 2005 and 2007.

The City Council will have full regard to the economics of development in relation to the provision of affordable housing and will require financial viability assessments to demonstrate that the maximum reasonable level of affordable housing is provided. In relation to off site affordable housing solutions the City Council will ensure that the proposed off site solution does not result in an over-

152 Appendix 27 – Council response to WPOA Preferred Alternative Options

concentration of a specific tenure or socio-economic or demographic profile.

Removal of the vicinity test and practical and appropriate tests for off- site housing solutions

Clarification of where financial contributions in lieu of affordable housing provision will be deemed appropriate.

Confirmation that staircasing will be retained between 10 and 25 additional units in Core CAZ. Preferred Alternative Option 40 – Business Floorspace The City Council will seek a range of flexible business floorspace of all “all sizes” is covered by the term “a range”, but “to seek” does not reflect the Council’s intention which is to ensure sizes to maintain economic resilience, improve accessibility to business that in appropriate circumstances, schemes will include a range of business floorspace including: affordable opportunities and premises within Westminster, and support the workspace; workshops and studios; and flexible workspaces. Provision for affordable workspace and workshops and Creative Industries sector. New business floorspace should be of the studios has been omitted, but are necessary to ensure Westminster’s continued economic resilience and diversity highest quality in terms of quality and function to meet occupier and support a range of business activities and employment opportunities. requirements. Quality of commercial development is considered to be adequately covered by the general design policy approach. Preferred Alternative Option 44 – Hotels New hotel development will be directed to the Core Central Activities The Publication Draft Core Strategy is wider in scope and directs hotels to the Core CAZ, the Opportunity Areas, Zone and the Opportunity Areas. specified locations within Marylebone and Fitzrovia, the Knightsbridge Strategic Cultural Area and the North Westminster Economic Development Area. Including specified locations within Marylebone and Fitzrovia includes Existing hotels that have appropriate servicing provision and do not existing Unitary Development Plan CAZ Frontages, and the policy also allows scope to contribute to regeneration in have adverse effects on residential amenity will be protected the Economic Development Area. throughout Westminster except where:

a) loss of the hotel would not prejudice the tourism vision to The Publication Draft Core Strategy protects existing hotels throughout Westminster where there are no significant achieve 40,000 additional hotel beds by 2026 based upon adverse effects on residential amenity. Within Pimlico, Bayswater and Queensway where there are over- evidence of supply and demand trajectory; and concentrations of hotels, the change of use of hotels to residential will be encouraged where the existing hotel is not b) the existing hotel character and function does not make a purpose built and is causing amenity problems. The WPA Preferred Alternative Option 44 proposes further criteria to positive contribution to tourism objectives in the City of allow for the loss of hotels - however, it is considered that these criteria would allow an unacceptable loss of hotels Westminster; and within Westminster, of detriment to Westminster’s role in the visitor economy, and would not be in conformity with c) the loss of the hotel would result in increased housing the London Plan. supply in Westminster; and d) in Bayswater and Pimlico where the conversion of hotels to residential will be encouraged.

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