M7&8 notes 18 January 2019

Matters 7 and 8: Format, Scope and Content of the Plan; conformity with national policy.

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Friday January 18 2019

Note: Comments have been paraphrased. Some comments have been removed based on repetition or lack of clarity.

M7. Does the Plan set out a spatial development strategy in accordance with relevant legislation and national policy? In particular:

a) Does the Plan deal only with matters which are of strategic importance to Greater London?

MHCLG:   London Plan does not provide a definition of ‘strategic’.

Home Builders Federation:  There is a policy vacuum regarding what is appropriate for the London Plan to address. It should focus on strategic matters.

Retirement Housing Consortium:

  • What is strategic is a matter for the Mayor to decide.
  • London Plan is regional and does not cut across borough plans.

London Forum:

  • Current London Plan is more prescriptive than the New London Plan.
  • London Plan has been a great help: been up-to-date. It is an essential decision-making tool. London Plan is part one of spatial development plan. It is the basis of many Local Plans.

Just Space:

  • On sustainable development: no one size fits all. There must be variations.

London Neighbourhood Planners:

  • What makes a policy strategic?
  • Many practical implications for neighbourhood planners.

London Forum:

  • Mayor is creating a framework through London Plan.

Sustainable Development Commission:

  • NPPF and definition of sustainable development. Macro carbon budget.

Greater London Authority:

  • What is of strategic importance? Variation in interpretation over time.

Just Space:

  • Gap between policy and practice.
  • London Plan does not deal with matters of strategic importance.
  • Not consistent with national policy.

Aitch Group:

  • What constitutes a strategic matter?
  • London Plan goes into too much detail.

London Borough of Hammersmith and Fulham:

  • Contaminated land and sustainable design not in the New London Plan.

London Forum:

  • Priorities shift over time.

Neighbourhood Planners London:

  • Role of strategic spaces.

MHCLG:

  • What should be of strategic importance?

London Borough of Bexley:

  • There is a lack of a Plan B. What if prescriptive policies don’t work?

Greater London Authority:

  • Aim not to reject strategies and not too much cross-referencing.
  • Sustainable design and construction and contaminated land are covered in other legislation and Opportunity Areas
  • No one size fits all in London Plan.
  • Policies continually reviewed and Greater London Authority consults with boroughs about local policy and national policy.

[Break]

b) Would the policies in the Plan provide an effective strategic framework for the preparation of local plans and neighbourhood plans in London?

Greater London Authority:

  • Some policies in which London Plan has a wider remit.

London Forum:

  • Supports London Plan.

London Assembly Planning Committee:

  • Support plan teams and representatives.
  • London Plan deals with matters of strategic importance.
  • Unless plan has a clearer objective and strategic direction then it won’t have a sufficient framework.

London Borough of Hammersmith and Fulham:

  • If sustainable design and construction and contaminated land were in the plan then it would have a better strategic vision. If no policies then no supplementary planning guidance.

London Borough of Bexley:

  • Plan does not provide a strategic framework.
  • How do you reflect the aspirations of local people?

Aitch Group:

  • Focus on time frame and matters in terms of strategic direction.

Home Builders Federation:

  • London Plan might become ineffective as it contains too many policies.
  • Requires a lot of contextual work by London boroughs.

London Forum:

  • Concern about local resources and skills.
  • There should be area-based frameworks.

London First:

  • Best practice design guidance should be provided.

Neighbourhood Planners London:

  • Neighbourhood forums accustomed to working with Local Plans.

MHCLG:

  • A consistent set of terms for boroughs would be helpful.
  • There should be aspects for broad strategic plans.
  • Are the good growth sections policies or objectives?

Greater London Authority:

  • London Plan saves boroughs some work to a degree.
  • Detail should be at local level.
  • New London Plan is not that bloated.
  • London review panel can review design.

(c) Does the Plan address detailed issues that would be more appropriately addressed in local plans and neighbourhood plans?

Aitch Group:

  • Detail is more appropriate in Local Plans.

Retirement Housing Consortium:

  • Not necessary to have strategic objective only provided in London Plan.
  • Boroughs may implement differently.

London Forum:

  • Fast approval rather than long debates can help build more affordable homes.

London Neighbourhood Planners:

  • Current version of London Plan is not great at exploring how strategic priorities can be balanced.

[Unknown]:

  • Plans should be simplified and more strategic to be more effective.

London Borough of Bexley:

  • Not always possible to provide level of detail.

Home Builders Federation:

  • Merit of London Plan is it is a way to do heavy lifting.
  • Issue with idea that increasing detail will make it more deliverable.

Greater London Authority:

  • Challenge in terms of level of growth.
  • Detailed space standards and no comments about level of prescription.
  • SPG: feedback on over-egging.

[Break]

d) Is the approach to planning in London described in paragraphs 0.0.21 and 0.0.22, particularly with regard to the relationship between the spatial development strategy and local plans, neighbourhood plans and the Borough’s development management responsibilities, justified and consistent with national policy and legislation?

MHCLG:

  • Local Plan coverage can be limited in terms of how up-to-date and comprehensive it is.
  • London Plan has been through its iterations in a timely manner.

London Forum:

  • Requirement for detail at Local Plan level.

Home Builders Federation:

  • Requirement of Local Plans to reflect NPPF.

Aitch Group:

  • SPG is a good place.
  • What if policies are examples of how an objective can be achieved?

London Neighbourhood Planners:

  • ‘Neighbourhood plan’ and ‘neighbourhood forum’ should be included as part of glossary.

Just Space:

  • There should be more emphasis on ‘neighbourhood’ in London Plan.

Greater London Authority:

  • Neighbourhood plans and forums will be in the New London Plan.

[Unknown]:

  • How is plan in accordance with policies and role in planning applications?
  • Local authorities could create policies to achieve aims of London Plan.
  • Can we remove over-prescriptive aspects of the strategic plan?

Greater London Authority:

  • Policy is established by local authority.

Home Builders Federation:

  • What is role of national policy?

M8. Given the legal requirement for the Mayor to have regard to the need to ensure that the Plan is consistent with national policies, is it justified for certain policies to deviate from national policy and guidance?

Greater London Authority:

  • Aspects are not consistent with national policies and aspects are not consistent with an element of national policy.

Home Builders Federation:

  • Some policies more effective at borough-level.

MHCLG:

  • Is there evidence of justifications for policies not being consistent with national policies?

London Forum:

  • London Plan and NPPF.

Home Builders Federation:

  • Impact of London Plan on other parts of the country.

Greater London Authority:

  • London Plan can be inconsistent with national policy.

London Assembly Planning Committee:

  • More resources required.

END

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