Consultation Draft Consultation Statement NPPF Revision to Westminster’s Core Strategy Local Development Framework July 2012 Consultation Statement: NPPF Revision 1.0 Introduction 1.1 This Consultation Statement has been prepared to meet the requirements of Regulation 22 of the Town and Country Planning (Local Development) (England) Regulations 2012 (“The Regulations”), and forms part of the proposed submission documents for the purposes of Regulation 19 of The Regulations. It will be updated once the Regulation 19 consultation has taken place to form a final Consultation Statement. 1.2 The Statement details the consultation undertaken by Westminster City Council (‘the council’) during the Regulation 18 consultation on the revisions to the Core Strategy arising from the publication of the National Planning Policy Framework, referred to as the “NPPF Revision”. 1.3 It details who was consulted at Regulation 18 stage, for how long, and how they were invited to make representations. A summary of the main issues raised by the responses is provided, and details as to how these representations have been taken into account in the Consultation Draft NPPF Revision subject to the Regulation 19 consultation. 1.4 Consultation was carried out in compliance with the council’s Statement of Community Involvement (SCI, adopted January 2007), thus meeting Section 19 of the Planning and Compulsory Purchase Act 2004 (as amended). 1.5 All contacts on the council’s LDF database were consulted, together with all statutory consultees in Regulation 4 of The Regulations, all ward councillors, and all neighbouring boroughs. The council’s LDF database was created in April 2007 and was initially populated with contact information from the Unitary Development Plan (UDP) database. Since the creation of the database, consultee contact information has been updated on a continual basis, with contacts being added, removed or amended on request. The database currently has 2,254 consultees. 2.0 Formal Notification under Regulation 18 of The Regulations 2.1 Formal notification of the NPPF Revisions was carried out between 1st May 2012 to 15th June 2012, for a period of just over six weeks. Notification was made by email to the vast majority of the 2,254 consultees (see Appendix 4), with a small number of letters sent to those who were not able to be contacted by email. Statutory consultees and local/regional authorities contacted were: 1. The Environment Agency 2. English Heritage 3. Natural England 4. Homes and Communities Agency 5. Westminster PCT 6. NHS 7. The Highways Agency 8. Office of Rail Regulation 1 9. Civil Aviation Authority 10. Transport for London 11. Greater London Authority and Mayor of London 12. London Borough of Camden 13. London Borough of Southwark 14. London Borough of Lambeth 15. City of London 16. London Borough of Wandsworth 17. London Borough of Brent 18. Royal Borough of Kensington & Chelsea 2.2 A copy of the consultation letter is attached as Appendix 1. Consultees were advised that the City Council was intending to make two revisions to the Core Strategy: the NPPF Revision and the CMP Revision. Consultees were advised that notice was being made in accordance with Regulation 18, that once both revisions had been made this would replace the Unitary Development Plan, and that although the revisions were notified together, they would be progressed separately. Consultees were invited to let the council know what they would like to see in these two revisions, and asked what they thought the revisions should contain. They were also advised of the consultation timescale, provided with a telephone contact for further information, and relevant weblinks for further information. 2.3 The City Council’s website also advertised this stage of consultation on pages relating to the Core Strategy, City Management Plan and National Planning Policy Framework (attached as Appendix 2). This also included a link to the consultation letter. 2.4 Seventeen responses were received (attached as Appendix 5), with 11 of those responses having relevance for the NPPF Revision (with the others relating to the CMP Revision). The following is a summary of the main issues raised and details how the council took the main issues into account: 1. Take account of the London Plan 2011 (Mayor of London). 2. Strategies to support the London Plan and the Mayor’s Transport Strategy including safeguarding land for transport where necessary (Transport for London). 3. Climate change particularly flood risk (Environment Agency). 4. Thames Tunnel (Thames Water). 5. Need high quality infrastructure e.g. high speed broadband (St James’s Conservation Trust). 6. Over-sized housing that only meets investment needs rather than housing people (Knightsbridge Association). 7. Knightsbridge Barracks site (Knightsbridge Association). 8. Commercialisation of the Royal Parks (Knightsbridge Association). 9. Take account of different character of areas e.g. Covent Garden (Covent Garden Community Association). 10. Conserve heritage assets as appropriate to significance (Covent Garden Community Association). 11. Deliver homes and affordable housing (Covent Garden Community Association). 12. Positive support for sustainable economic growth (Barclays Bank, WPA). 2 13. Give more clarity and emphasis to all three aspects of sustainability as referred to in the NPPF (Verina Glaessner –individual). 14. Identify office development, where affordable housing must be provided alongside commercial development (Archdeacon of Charing Cross). 15. Locally people identify additional housing sites in return for some of the gains as permitted by the Localism Act 2011(Archdeacon of Charing Cross). 16. Change Policy CS15 so specialist housing is ‘prioritised’ rather than ‘allowed’ where need is identified (Archdeacon of Charing Cross). 17. Change Policy CS16 to state that the council and its partners will act to ensure the current unacceptable shortfall in affordable housing is urgently addressed and bring housing into use (Archdeacon of Charing Cross). 18. Places of worship also provide social and community services (Archdeacon of Charing Cross). 19. Reference to establishing the infrastructure requirements as part of infrastructure planning should be linked to CIL (Archdeacon of Charing Cross). 2.5 Revisions to the Core Strategy have been included to address most of the 19 key issues raised by consultees that relate to the NPPF Revision and these are referenced on the Schedule of Changes appended to the revision document. However, the following issues are considered to be already adequately covered by the adopted document or alternative mechanisms, and in some cases additional detailed policies being developed through the City Management policies will address these matters: 6. Over-sized housing that only meets investment needs rather than housing people (Knightsbridge Association). This is addressed by the requirement to optimise housing delivery in Policy CS14. Further detailed policies will also address (refer draft policies CMP 4.1 and CMP 4.4 which will be developed further). 8. Commercialisation of the Royal Parks (Knightsbridge Association). This is addressed by the Royal Parks Policy CS11. Further detailed policies will control events and noise in the Royal Parks (refer draft policies CMP 3.18 and CMP 6.4). 9. Take account of different character of areas e.g. Covent Garden (Covent Garden Community Association). Some changes have been made in relation to references to Covent Garden. However, at a broader level, the Core Strategy provides policies for all of the areas identified across Westminster, taking account of their different characteristics, needs and future. 11. Deliver homes and affordable housing (Covent Garden Community Association). Addressed through Policies CS 16 to CS16 and in the emerging City Management detailed housing policies. 14. Identify office development, where affordable housing must be provided alongside commercial development (Archdeacon of Charing Cross). This is already provided for in Policies CS1requiring housing from commercial development in the Central Activities Zone, where most commercial development is and CS16 which requires affordable housing as a proportion of housing above certain thresholds. 3 15. Locally people identify additional housing sites in return for some of the gains as permitted by the Localism Act 2011(Archdeacon of Charing Cross). The mechanisms for this do not lie with the Core Strategy although amendments have been made to refer to changes including neighbourhood planning. 16. Change Policy CS15 so specialist housing is ‘prioritised’ rather than ‘allowed’ where need is identified (Archdeacon of Charing Cross). The City Council would not necessarily prioritise specialist housing above, say affordable housing, even where there is an identified need. This wording is also about ensuring there is a need for the accommodation, and it is not used as a means to avoid other planning obligations such as affordable housing. 17. Change Policy CS16 to state that the council and its partners will act to ensure the current unacceptable shortfall in affordable housing is urgently addressed and bring housing into use (Archdeacon of Charing Cross). This is already considered to be adequately covered by the housing policies CS14 - CS16, taking into account competing land pressures, site constraints, viability etc as set out in the Spatial Strategy in Part II and Policy CS32 which deals with the level at which planning obligations and CIL are sought. 18. Places of worship