Site Allocations DPD Statement of Representations (Pre Submission) 1. Introduction 1.1 Consultation on the Site Allocations DPD Pre-Submission consultation document took place between 27th July and 7th September 2012. Consultation was undertaken in accordance with the Council’s Statement of Community Involvement and in line with regulations of the Town and Country Planning (Local Planning) (England) Regulations 2012. These regulations require the Council to produce a statement (the 'Consultation Statement') setting out the consultation undertaken on the Site Allocations DPD at the Pre-Submission stage, a summary of the main issues raised in response to that consultation, and to detail the Council’s response to comments made. 2. Summary of consultation undertaken on the Site Allocations DPD Pre-Submission consultation document 2.1 On 20th June 2012, Harrow’s Cabinet considered a report on the Site Allocations DPD (see http://www.harrow.gov.uk/www2/documents/g61243/Public%20reports%20pack,%20Wednesday%2020-Jun- 2012%2019.30,%20Cabinet.pdf?T=10). At that meeting Cabinet recommended the DPD be referred to Full Council for approval for consultation. 2.2 On 5th July 2012, Full Council endorsed the Site Allocations DPD Pre-Submission consultation document and resolved to publish the document for consultation for a period of six weeks and, following consultation, submission to the Secretary of State for independent examination in public (see http://www.harrow.gov.uk/www2/documents/g61086/Public%20reports%20pack,%20Thursday%2005-Jul-2012%2019.30,%20Council.pdf?T=10). 2.3 Formal notification of the Site Allocations DPD Pre-Submission publication was given on 27th July 2012, and representations were invited for a six week period ending 7th September 2012. Representations were also invited on the Sustainability Appraisal during this period. 2.4 A formal notice setting out the proposals matters and representations procedure was placed in the ‘Harrow Observer’ newspaper on both the 26th July and 2nd August 2012 (see Appendix A). In addition, on 23rd July 2012, a total of 1,048 notifications (see Appendix B) were sent by post or email to all contacts on the LDF database (see Appendix C), including all appropriate general consultation bodies. Enclosed with the letter was the Statement of the Representations Procedure (see Appendix D). Those emailed were also provided with the web link to the documents on the Council’s consultation portal and LDF web pages. All specific consultation bodies (see Appendix E) were also notified (see Appendix F) on 23rd July 2012. Unless otherwise requested by the consultation body, enclosed with the notification was a hard copy of the Site Allocations DPD Pre- Submission document, the Statement of the Representations Procedure, and the Sustainability Appraisal Report. In accordance with Regulation 21 of the Town and Country Planning (Local Planning) (England) Regulations 2012, a separate letter was also sent to the Mayor of London requesting his opinion on the conformity of the DPD with the London Plan 2011 (see Appendix G). 2.5 Hard copies of the Site Allocations DPD Pre-Submission consultation document, the Sustainability Appraisal Report, the Statement of the Representations Procedure and the response form (see Appendix H) were made available at the Harrow Civic Centre (Access Harrow) and all 1 public libraries across the Borough. Additional copies of the DPD Pre-Submission consultation document were also made available at these locations for short term loan. The documents were also made available to view and download from the LDF web pages of the Council’s website and via the Council’s consultation portal. The consultation portal has the added benefit of enabling respondents to submit their representations online as they review the document. 2.6 A week prior to the close of consultation a reminder e-mail and letter were sent out to those on the LDF consultation database to remind online consultees of the closing date for making their comments. 3. Duty to Cooperate 3.1 Section 110 of the Localism Act inserts section 33A into the Planning and Compulsory Purchase Act 2004. Section 33A imposes a duty on a local planning authority to co-operate with other local planning authorities, county councils and bodies or other persons as prescribed. 3,2 The other persons prescribed are those identified in regulation 4 of The Town and Country Planning (Local Planning) (England) Regulations 2012. The bodies prescribed under section 33A(1)(c) are: (a) the Environment Agency; (b) the Historic Buildings and Monuments Commission for England (known as English Heritage); (c) Natural England; (d) the Mayor of London; (e) the Civil Aviation Authority; (f) the Homes and Communities Agency; (g) each Primary Care Trust (h) the Office of Rail Regulation; (i) Transport for London; (j) each Integrated Transport Authority; (k) each highway authority and (l) the Marine Management Organisation. 3.3 The duty imposed to co-operate requires each person, including a local planning authority, to: (a) engage constructively, actively and on an ongoing basis in any process by means of which activities within subsection (3) are undertaken, and (b) have regard to activities of the persons or bodies (above) so far as they are relevant to activities within subsection (3). 3.4 The relevant activities listed under subsection (3) comprises the preparation of development plan documents/local development documents, and activities which prepare the way for and which support the preparation of development plan documents, so far as relating to a strategic matter. 2 3.5 The Council has and continues to engage constructively with other local planning authorities and other public bodies on the preparation of the DPD, following the approach set out in the NPPF. The mechanisms for and evidence of cooperation and engagement is set out below. Duty to Cooperate – Engagement Undertaken Cross Boundary Consultee How we Cooperated Outcomes Neighbouring authorities (see Letters sent inviting representations on the DPD at both Details of representations received and the Council’s map 1) stages of preparation and responses received. actions as a result are detailed above (See Consultation Statement above) No major cross boundary issues identified. West London Alliance (planning officers group from 6 Updates given by respective Borough’s on Local Plan West London Borough’s). progress and any cross boundary issues raised. Group memorandum of understanding. Memorandum of Understanding signed to give effect to cross boundary cooperation. Meetings to progress the London – Luton growth corridor which will result in a joined up approach to managing London – Luton Corridor Forum and attracting growth in this area. No major cross boundary issues identified arising from this DPD. Planning Officer meetings with Hertsmere Meetings last held in June / July 2012 and are scheduled for every quarter. Planning Officer Meetings with Three Rivers Environment Agency Letters inviting representations on the DPD and Details of representations received and the Council’s responses received. actions as a result are detailed above. Issues raised (See Consultation Statement below) regarding policies dealing with flood risk and management, and river corridors (see above for details) Meetings centred around the Level 1 and Level 2 SFRA Meetings at Council offices (5 in total) extents. Advice given on the wording of flooding policy and the use of SUDS. Resolved to remove 3b designation from previously 3 developed sites. EA provide flood mapping for the Borough. English heritage Letters inviting representations on all Development Plan Details of representations received and the Council’s Documents and responses received. actions as a result are detailed above. (See Consultation Statements for each DPD) Written communications between the Council and Advice on Heritage and Conservation policies given English heritage Heritage policies amended in light of specialist advice Draft copies of heritage policies sent before formal consultation Natural England Letters inviting representations on all Development Plan Details of representations received and the Council’s Documents and responses received. actions as a result are detailed above. (See Consultation Statements for each DPD) Written communications between the Council and Advice on biodiversity policies given Natural England Civil Aviation Authority Letters inviting representations on all Development Plan Details of representations received and the Council’s Documents and responses received. actions as a result are detailed above. No major issues (See Consultation Statements for each DPD) raised. Greater London Authority Letters inviting representations on all Development Plan Details of representations received and the Council’s Documents and responses received. actions as a result are detailed above. (See Consultation Statements for each DPD) Officer from the GLA on secondment to the Local Plan Officer providing advice on policy development to ensure Team there are no conflicts with the strategic London Plan Participation in the London wide SHLAA and SHMA GLA Housing Study meetings and work evidence base studies. Discussions held and advice sent to ensure consistency Liason with specialist officers for policy development with the London Plan. regarding affordable housing and sustainability London Wide Green Grid project Meetings and joint working undertaken to establish a Harrow Green Grid as part of the wider London Green Grid. 4 Primary Care Trust