Summaries of responses received to the Pre-Publication Local Plan consultation and the Council’s response Note that responses, as received (in full), have been published on the Council’s website, and the system for numbering of comments has been retained within this document for ease of reference. 1. List of all respondents to the public consultation Please note, the responses below are not alphabetically ordered or in any other order of priority. Name / Organisation Name / Organisation Caroline Brock, Kew Society Cllr Martin Elengorn, Environment Spokesperson Richmond upon Thames Jenine Langrish Liberal Democrat Councillors Group Myrna Jelman Rob Gray, Friends of the River Crane Environment (FORCE) Cllr David Linnette Liz Ayres, Richmond Clinical Commissioning Group Richard Geary Wendy Crammond, Co-Chair Kew Residents Association Heather Mathew, Richmond CVS Ben Mackworth-Praed, on behalf of the Barnes Community Association Helene Jelman Kevin Goodwin, RPS CgMs for Goldcrest Land Dale Greetham, Sport England Sarah Stevens, Turleys for British Land Katharine Fletcher, Historic England Paul Massey Charles Pineles, Planning Spokesman, Richmond Society Tim Lennon, Borough Coordinator Richmond Cycling Campaign Peter Willan, Old Deer Park Working Group Matthew Eyre, RPS CgMs on behalf of Historic Royal Palaces (HRP) Celeste Giusti, Greater London Authority on behalf of Mayor of London Brian Willman, Chair Ham and Petersham Neighbourhood Forum Robert Leadbetter, Hon. Director Hampton and Kempton Waterworks Mike Allsop, Committee member Strawberry Hill Residents' Association Railway Geoff Bond, Chair Ham and Petersham Association Robert Deanwood, Amec Foster Wheeler on behalf of National Grid George Burgess, Indigo Planning on behalf of Beechcroft Developments Alison Mackay, Colliers on behalf of Greggs Plc Ltd Tom Sadler, Bilfinger GVA on behalf of Defence Infrastructure Neil Henderson, Gerald Eve on behalf of Reselton Properties Ltd Organisation Alice Roberts, CPRE London Judith Livesey, NLP Planning on behalf of St Paul's School Janet Nuttall, Natural England James Togher, Environment Agency Tim Sturgess, Bilfinger GVA on behalf of The Lady Eleanor Holles School William Mortimer Unity Harvey Tim Catchpole, Planning Representative Mortlake with East Sheen Society David Taylor Andrew Dorrian, Transport for London Sam Hobson, Quantum Group Rachel Botcherby, Planning Advisor, London and South East National Trust Richard Barnes, The Woodland Trust Lucy Owen, Port of London Authority All responses received on the Local Plan Pre-Publication Consultation 1 Name / Organisation Name / Organisation Kevin Scott, Kevin Scott Consultancy Ltd on behalf of Port Hampton Dinesh Vitharanage Estates Limited Cllr Liz Jaeger Sarah Dixey, London Borough of Wandsworth Fabio Galvano Katharine Harrison, Surrey County Council Caroline Britton Mike Mills, Firstplan Ltd on behalf of Maxicorp Ltd Peter Britton Tanja El Sanadidy, Indigo on behalf of Shepherd Enterprises Limited Kathleen Massey Maria Walker Jane Morrison Stephen Rankin Ray Morrison Sally Arnold, Planning Potential Ltd on behalf of Power Leisure Laura Stritch, Transport for London Bookmakers Jane Bond Ross Anthony, The Theatres Trust Savills on behalf of Thames Water Mel Barlow-Graham, London Fire and Emergency Planning Authority Martin Kirrage Bethany Evans, NLP Planning on behalf of The Harrodian School Anna Smith Krystyna Kujawinska David Yates Steve Simms, SSA Planning Limited on behalf of Kentucky Fried Chicken Geoff Bond, Chair Martingales Close Residents' Association (Great Britain) Limited Dale and Juliet Nolan Michelle Hatton-Smith Andrew & Bryony Barnard Spelthorne Borough Council Gilda Rogner Helen Harris, Cushman and Wakefield on behalf of Royal Mail Group Ltd Tess Pinto, 20th Century Society James Sheppard, CBRE on behalf of LGC Ltd Peter Dowling, Indigo Planning on behalf of Sainsbury's Supermarkets Ltd Strategic Planning Team, Royal Borough of Kingston Charlotte Gibb, St Mary's University Emily Vyse, Brooke Smith Planning on behalf of Ancient Order of Forester's Peter Willan, Chair for The Friends of Richmond Green Friendly Society Ltd Marie Claire Marsh, NLP Planning on behalf of RFU Christian Leigh on behalf of Jane Miller Paul Velluet Jamie Wallace, CgMs on behalf of Notting Hill Home Ownership Tor Barrett, NLP Planning on behalf of the West London Mental Health Caroline Wilberforce, Indigo Planning on behalf of on behalf of Sharpe NHS Trust Refinery Service Joanne Merritt Teresa Gonet, Highways Agency David Deaton Paul Luton Mark Jopling, The Teddington Society and the Friends of Udney Park Eliza Shaw Playing Fields Anthony Paish Lesley Forster Table 1: All respondents to the consultation John Finnerty All responses received on the Local Plan Pre-Publication Consultation 2 2. Summary of main issues raised during the Pre-Publication consultation MAIN ISSUES RAISED Introduction, Strategic Context, Vision and Objectives, Spatial Strategy • Need to take account of the important role of the voluntary and community sector • Refer to Village Plans in introductory section • Need for up to date evidence and for research such as SHMA findings to inform policies • Strategic Vision places insufficient weight on the importance of promoting previously developed brownfield sites for housing • Borough-wide MOL boundary review needed • No blanket approach to protecting industrial land and business parks • Disagree with protecting employment land, especially industrial estates and business parks in existing residential areas • Object to ‘restrictive’ approach towards transfer of industrial land to other uses • More emphasis on cycling, cycling infrastructure, safe routes and improving public transport • Car parking is not essential to vitality of town centres • Use of term ‘villages’ throughout the Plan • Need for emergency and disaster planning • More emphasis on social infrastructure needs for the elderly • Need to address shortfall for conventional sheltered housing • Explore opportunities to deliver homes along transport corridors and transport nodes • Need to address Habitats Regulations Assessment • Value of green infrastructure for wildlife and public amenity, lack of reference to ‘dark corridors’ • Strengthen historic environment, setting of heritage assets and heritage value Local Character and Design • Historic England recommendations to improve wording and clarity, such as adding ‘heritage assets’, and stronger emphasis on heritage sites and conservation areas with appropriate buffer zones around each • Remove any references to ‘enabling development’, which inherently is a contradiction in a Plan • Need for clarification on densities and application of London Plan Density Matrix • Need for positive response to developments that may be taller than their surroundings where they are in locations of good PTAL • ‘Resisting’ buildings that are taller than surrounding areas is too strong; require urban design analysis and application of other criteria in policy • Need to acknowledge that there are areas in the borough where tall or 'taller' buildings may be appropriate; need for more flexibility for locations of taller and tall buildings • Need to strengthen policy to say that areas such as Strawberry Hill are ‘not appropriate’ for taller buildings, rather than identifying them as ‘generally inappropriate’ • Strengthen reference to deliberate neglect or damage of heritage assets • Need to acknowledge that some selective/partial demolition of BTMs may in some cases by beneficial • Policies to focus on ‘conservation’ rather than ‘protection’ and need to weigh up scale of harm or loss and significance of non-designated heritage asset. • Views and vistas policy should only relate to those identified on the Proposals Map • Include references to Crown Estate's The Old Deer Park Richmond - Landscape Strategy, 1999 • Reconsider minimum distance between windows within the Amenity and Living Conditions policy – mixed views on whether this should be more flexible or strengthened • Separate policy for balconies All responses received on the Local Plan Pre-Publication Consultation 3 MAIN ISSUES RAISED • Need to recognise that not all land requires remediation work • Need to address construction impacts and air, noise and light pollution constraints • Need to strengthen basement policy: require structural impact assessments for adjacent buildings, take account of ground conditions and underground watercourses/future water flows, require insurance policies to cover any damages, require evidence of engagement with neighbouring properties • Presumption against any retrofitted basements (Barnes) • Basement policy should only apply to existing buildings where basements are being added • Clarify that restricted uses include self-contained units and bedrooms Green Infrastructure • Application for designation of Udney Park Playing fields as ‘Local Green Space’; would also require new policy wording that applies to ‘Local Green Space’ • Need to take account of recreation pressure on existing green infrastructure, such as SSSI (Richmond Park; Bushy and Home Park), and that new residential development is likely to exacerbate this pressures • Need to refer to historic dimension of Richmond’s exceptional landscape heritage • Need better links with cycling and cycling infrastructure • Differing views on strength of MOL policy, from a request that the policy should state the Council will not seek to develop land in MOL for schools; to include reference to educational uses for supporting the redistribution of open