The Planning Inspectorate Temple Quay House Report to the 2 The Square Temple Quay Bristol BS1 6PN London Borough of ( 0117 372 8000 Wandsworth by Linda Wride Dip TP MRTPI an Inspector appointed by the Secretary of State 14 June 2010 for Communities and Local Government PLANNING AND COMPULSORY PURCHASE ACT 2004 SECTION 20 REPORT ON THE EXAMINATION INTO THE LONDON BOROUGH OF WANDSWORTH CORE STRATEGY DEVELOPMENT PLAN DOCUMENT Document submitted for examination on 20 March 2009 Examination hearings held between 2 and 16 February 2010 File Ref No: LDF 000804 ABBREVIATIONS AAP Area Action Plan AHEVA Affordable Housing Economic Viability Assessment CIL Community Infrastructure Levy CS Core Strategy DPD Development Plan Document DMPD Development Management Policy Document GLA Greater London Authority GOL Government Office for London IC Inspector’s Changes LDF Local Development Framework LDS Local Development Scheme LSIA Locally Significant Industrial Area LSP Local Strategic Partnership MC Minor Changes MUFIA Mixed Use Former Industrial Area OA Opportunity Area PF Planning Framework PPG Planning Policy Guidance PPS Planning Policy Statement RSL Registered Social Landlord s Section SA Sustainability Appraisal SCI Statement of Community Involvement SCS Sustainable Community Strategy SHLAA Strategic Housing Land Availability Assessment SIL Strategic Industrial Land SFRA Strategic Flood Risk Assessment SMAA Strategic Housing Market Assessment SPD Supplementary Planning Document SSAD Site Specific Allocations Document UDP Unitary Development Plan VNEBOAPF Vauxhall Nine Elms Battersea Opportunity Area Planning Framework 2 1 Introduction and Summary of Overall Conclusion 1.1 Under the terms of Section 20(5) of the Planning & Compulsory Purchase Act 2004, the purpose of the independent examination of a development plan document (DPD) is to determine: (a) whether it satisfies the requirements of s19 and s24(1) of the 2004 Act, the regulations under s17(7), and any regulations under s36 relating to the preparation of the document (b) whether it is sound. 1.2 This report contains my assessment of the London Borough of Wandsworth Core Strategy (CS) DPD in terms of the above matters, along with my recommendations and the reasons for them, as required by s20(7) of the 2004 Act. 1.3 I am satisfied that the DPD meets the requirements of the Act and Regulations. My role is also to consider the soundness of the submitted CS against the advice set out in paragraphs 4.51 – 4.52 of Planning Policy Statement 12 (PPS 12). In line with national policy, the starting point for the examination is the assumption that the local authority has submitted what it considers to be a sound plan. 1.4 The changes I have specified in this report are made only where there is a clear need to amend the document in the light of the legal requirements and/or to make the document sound in accordance with PPS 12. Annexes A and B contain schedules of changes. I have used the Council’s suggested wording, unless stated otherwise. 1.5 The changes set out in Annex A (prefix IC) are those required to make the DPD sound. For the most part, these changes arose out of further work undertaken by the Council in response to concerns I raised at an Exploratory Meeting held in June 2009. They were subject to public consultation between September and November 2009, and post-submission sustainability appraisal (SA) in September 2009. A further change which came forward during the hearing sessions was subject to targeted public consultation in February 2010, after the hearing sessions finished. 1.6 Annex B (prefix MC) are Proposed Minor Changes. Some of these changes were put forward in the statements prepared by the Council for the hearing sessions, some in response to matters arising at the hearings themselves and the remainder were identified as part of a proof reading exercise. They add clarity to the DPD by sign-posting how and where strategic policies are being carried forward in subsequent DPDs; update the DPD where necessary; deal with minor typographical errors and improve grammar without changing the thrust of the strategy. As these minor changes are not required to address soundness issues, I have not dealt with them in detail in my report. However, I believe their inclusion is required to ensure that the CS is clear, up-to-date, coherent and easily understood. 1.7 My overall conclusion is that the London Borough of Wandsworth Core Strategy DPD is sound, provided it is changed in the ways specified in Annex A. The principal changes required are, in summary: 3 a) To amend Policies PL 5 (provision of new homes) and IS 5 (achieving a mix of housing), together with the supporting text, to require housing targets, including affordable housing targets and the tenure split between affordable rented and intermediate affordable housing, to be reviewed when the replacement London Plan is adopted. b) To amend Policy IS 5 c (affordable housing) so that the definition accords with national guidance; to ensure the trigger for affordable housing provision is consistent with the London Plan; to specify the proportion of affordable housing required based on the findings of the Affordable Housing Economic Viability Assessment, and to clarify the circumstances in which a site specific economic viability assessment will be required; to signpost that other housing policies will be included in the Development Management Policies Document. c) To amend Policy IS 5 g (gypsy and traveller accommodation) and the supporting text to refer to the estimated requirement for additional pitches in the plan period 2017/18 - 2021/22; clarify the role of the Site Specific Allocations Document in meeting future needs; indicate how demand for, and provision of, additional pitches will be monitored and reviewed. d) To amend policies relating to the locations where tall buildings may be acceptable (Policies IS 3, PL 11, PL 12, PL 13, PL 14) to reflect the Council’s Stage 1 Urban Design Statement and to acknowledge the ongoing work in the Stage 2 Urban Design Statement and lower level DPDs. e) To replace Policy IS 7 b (planning obligations) with a new section which refers to the Council’s intention to develop a Supplementary Planning Document on Planning Obligations and an associated Community Infrastructure Levy (CIL) charging schedules to support the provision of infrastructure projects. f) To amend Policy PL 7 (waste management) and supporting text to confirm the Council’s role as waste planning authority; set out the DPDs which provide the spatial delivery tool to implement the Municipal Waste Management Strategy; refer to the movement of waste up the waste hierarchy; correct the estimate of land required to meet the London Plan waste apportionment figures; ensure this requirement is reviewed when the replacement London Plan is published. g) To amend Policy PL 11 (Nine Elms and adjoining areas in north east Battersea) the supporting text so that targets for homes and jobs and the quantum/mix of development permissible in the Vauxhall Nine Elms Battersea Opportunity Area (VNEBOA) are reviewed when work on the VNEBOA Planning Framework is complete, and that the outcomes are fed into the Spatial Strategy for the Queenstown Road to Nine Elms area coming forward in the Site Specific Allocations Document DPD. h) To substitute the revised Infrastructure Delivery Table. 1.8 My report firstly considers the legal requirements, and then deals with the relevant matters and issues considered during the 4 examination in terms of justification, effectiveness and consistency with national policy. 2 Legal Requirements 2.1 The London Borough of Wandsworth Core Strategy is contained in the Council’s Local Development Scheme (LDS), the most recent LDS having been approved in January 2010. The CS was submitted to the Secretary of State for examination in the timescale specified. In response to issues of significant concern identified at an Exploratory Meeting in June 2009, further work was undertaken by the Council over the summer of 2009, whilst the examination was suspended for 11 weeks. This caused some slippage in the anticipated timing of the Pre-Hearing Meeting (PHM) and the hearing sessions. However, it should be possible to adopt the DPD by September 2010, as envisaged in the LDS. 2.2 The Council’s Statement of Community Involvement (SCI) was adopted in January 2007. It is evident from the documents submitted by the Council, including the Regulation 25, 26 and 30 (e) Statements and its Legal Compliance Self-Assessment Statement that the Council has met the requirements as set out in the Regulations. 2.3 Alongside the preparation of the DPD, it is evident that the Council has carried out a parallel process of sustainability appraisal. 2.4 The screening assessment of the CS identifies two Special Areas of Conservation (SAC): Wimbledon Common (part of which lies within the borough) and Richmond Park, which lies on the borough boundary. In accordance with the Regulations contained in Articles 6(3) and (4) of the Habitats Directive, the Council carried out a Habitats Regulations Assessment. The report concludes that the policies contained in the CS are not likely to have a significant effect on either the Wimbledon Common or Richmond Park Special Areas of Conservation, and therefore an “Appropriate Assessment” is not required. Natural England agreed with the Council’s general conclusion. Accordingly I am satisfied that the Appropriate Assessment stage of the DPD is not required. 2.5 Subject to the changes in Annex A, I am satisfied that the DPD has regard to national policy. 2.6 By letter dated 22 October 2008 the Mayor of London indicated that the CS was not in general conformity with the London Plan in respect of three main matters. Firstly, the reference to “net” rather than “gross” units in Policy IS 5 relating to the trigger for affordable housing contributions.