2018 London Plan

The FPPG response to the draft London Plan contains many of the points raised in the response to the OPDC (reg 19) Local Plan consultation.

The new London Plan is unsound, failing to conform to the National Planning Policy Framework about the role and importance of neighbourhood plans. Stronger, better and earlier design input is critical to the delivery of the London Plan and neighbourhood planning can provide this along with character assessments at the very local level. Increasing housing numbers and developing more small sites needs effective community engagement.

The new London Plan is the first to be produced where local neighbourhood plans are required to be in general conformity with its strategic policies but misses a major opportunity to demonstrate how land use planning, initiated by local communities, could contribute to the London Plan’s policy aims and objectives. The failure to consider planning architecture to reduce crime is conspicuous.

Neither the OPDC Draft Local Plan nor the Draft London Plan includes proposals to improve London roads like the north south road network in North Kensington and North Hammersmith. We repeat the case for an additional Overground station at ‘Westway Circus’, as made in the StQW Neighbourhood Plan and the RBKC Local Plan Partial Review. This would be a much cheaper than the Hythe Road station costing £198m proposed by the OPDC. A new Westway Circus station should be a priority for raising low PTAL levels in North Kensington and relieving present and future traffic congestion in the area. It is good the London Plan (unlike the OPD Draft Plan) refers to Hythe Road as a ‘potential’ station.  No funding is yet identified, and optimistic future PTAL improvements should not have been used as a basis for granting planning permissions.

Policy D4             Housing quality and standards:     The Plan says new homes are to be fit for purpose and meet the changing needs of Londoners over their lifetimes but these standards are too low, falling short of the Parker Morris standards and insufficient to meet the needs of individuals and families.

The London Plan is encroaching on non-strategic matters that should be for Boroughs not the Mayor as with Policy D8 that requires Boroughs to identify locations for tall buildings in their Plans. Policy D8 on Tall Buildings asserts that Tall buildings have a role to play in helping London accommodate its expected growth as well as supporting legibility across the city to enable people to navigate to key destinations. Studies from the 1960s show that a high density does not require tall buildings. More important the effects of Brexit and the Government’s Northern Powerhouse agenda have been ignored and people now consult the GPS maps on their phone rather than view their surroundings.

Policy GG1          The London Plan appears to be turning its back on engaging with communities to build  strong and inclusive communities. There is nothing about the proper vetting of Local Neighbourhood Forums by local authorities to ensure only those living in the Ward are eligible to reflect the ethnic composition of the Ward and to stop domination by developers, religious and political groups.

Policy H1             We object to this as it applies to the London Borough of Ealing. It imposes a disproportionate burden on the Borough in providing the new homes London undoubtedly needs. Many of the Borough’s cherished neighbourhoods have already been seriously damaged by badly planned and increasingly insensitive re-developments.  Ealing is expected to deliver 28,000 new homes over the next 10 years or 2,800 per annum, the largest increase over the targets set by the 2011 London Plan not including the Old Oak opportunity area. The nearest thing Ealing has is a core strategy is from 2012 and provides for 14,000 new homes to be built over a 15 year period – or 890 homes per annum. The London Plan’s targets would transform the Borough and drastically reduce the quality of life both for new and existing residents.

Policy HC5          Supporting London’s culture and creative industries should have something about help to local community groups. Far too many policies sound impressive but are merely aspirational and easily dismissed by a determined developer.

Policy HC7          Protecting Public Houses as community assets is important

Policy S1             Developing London’s social infrastructure                This policy is crucial but has not been and will not be observed. Almost every site that becomes available is given over to new housing. Social infrastructure in all its forms is not keeping pace and requires more than just free WiFi. There needs to be a needs assessment of social infrastructure to meet the needs of London’s diverse communities, the co-location of different forms of social infrastructure and the rationalisation or sharing of facilities.