lbhf comments opdc draft local plan march 2016

LBHF COMMENTS March 22, 2016

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OPDC DRAFT LOCAL PLAN CONSULTATION LBHF RESPONSE – MARCH 2016 London Borough of Hammersmith and Fulham’s comments in response to the OPDC’s Draft Local Plan consultation are set out as follows:

CHAPTER 1 : INTRODUCTION

Policy/paragraph Consultation Question

Council’s response Suggested change to text

CHAPTER 2: SPATIAL VISION & OBJECTIVES



Spatial Vision & Objectives Our Mission

QVO2: Do you agree with the mission statement? If not, what might you change?

The 4th bullet states that the mission is to “Engage with, and support the participation of, local communities during the plan making and development management processes” This council considers that as well as “engage with and support”, the develop management processes should actively ensure that benefits flow to the surrounding local communities, such as College Park, and the host boroughs. These benefits could include both homes and jobs.

Amend Mission to better reflect provision of benefits to surrounding areas.


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CHAPTER 3: OVERARCHING SPATIAL POLICIES



OSP1: Optimising Growth

Figure 12 Whilst maximising connectivity is a key priority the link to Wormwood Scrubs would have to consider the sensitive edge along the northern bank of the Scrubs and any impact on the ecology of the site as a result. This would need to be reflected in amendment through the Local Plan where the link is proposed.

OSP2: Land Use The Preferred Policy Option states that the OPDC will support proposals that contribute to the creation of a new part of London by: a) Delivering a new thriving centre at Old Oak that seeks to accommodate 24,000 homes and 55,000 jobs; b) Protecting and regenerating the Park Royal industrial estate as a powerhouse of the London economy accommodating 10,000 new jobs and 1,500 new homes. However, the supporting text refers to a minimum of 25000 homes.

The two statements require harmonization. The London Plan refers to minimum figures.

OSP3: Connections and open spaces

Pg.39, Figure 16 Pg.39, Figure 16 – misleading to show St Marys cemetery as ‘existing green space’. It may have some amenity value for some members of the

Remove green shading for St Marys Cemetery.


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community.

OSP4: Densities and building heights

Questions: QOSP4a: Do you agree with the areas identified as sensitive edges/locations in Figure 18? QOSP4b: Are there any sensitive edges that could accommodate higher densities?

recommended air quality policy for the operational phase no 12 master planning detailed in the local air quality study states that developments should not create a new street canyon or a building configuration that inhibits effective pollutant dispersion. OSP4 makes no linkages with air quality, the key issues refer to need to” ensure the creation of a liveable place and avoid poor quality environments” but the potential for creating further air quality issues needs to be incorporated into the policy wording.

a) OPDC will support proposals that deliver predominantly: i. the highest density development around Old Oak Common Station; ii. high density development around other rail stations and at key destinations responding to the surrounding context; iii. medium densities at residential led areas; and iv. lower densities at sensitive edges. b) OPDC will support proposals that focus taller buildings at stations, key destinations and where they contribute to place making. c) OPDC will support proposals that allow effective pollutant dispersal and do not create a new street canyon or building configuration that inhibits effective pollutant dispersal.

OSP4: Densities and building heights

Questions: QOSP4a: Do you agree with the areas identified as sensitive edges/locations in Figure 18? QOSP4b: Are there any sensitive edges that could

North and south and along the length of the Grand Union Canal should be a sensitive edge. The edges of Wormwood Scrubs are also sensitive. The Local Plan sets out the Hs2 station as location for tall buildings and this will need to be reconciled with its proximity to the Scrubs and any impact that any proposals would have on Wormwood Scrubs.

a) OPDC will support proposals that deliver predominantly: i. the highest density development around Old Oak Common Station; ii. high density development around other rail stations and at key destinations responding to the surrounding context; iii. medium densities at residential led


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accommodate higher densities?

areas; and iv. lower densities at sensitive edges. b) OPDC will support proposals that focus taller buildings at stations, key destinations and where they contribute to place making. c) OPDC will support proposals that allow effective pollutant dispersal and do not create a new street canyon or building configuration that inhibits effective pollutant dispersal.

Page 31 Table 1

The Integrated Water Management Strategy (IWMS) is not referenced in the list but perhaps should be. The need to manage surface water through use of above ground measures could impact the spatial policies and therefore needs to be considered.

Include the IWMS in Table 1.

Page 45 OSP4: Densities and Building Heights

Page 45: photographic examples - would be clearer if they could be labelled according to the degree of density they are representing.

Label photographs according to the degree of density they are representing.

OSP4: Densities and Building Heights General Comment

It appears that the policies on high residential densities might conflict with the policies on design, heritage, sensitive edges and views. This needs further testing and evidence.

OSP4: Densities and Building Heights

Key Issues Key Issues, No 3 – amend to say ‘ To be successful, such buildings should be exemplar and ensure the creation of a liveable, healthy place in a high quality environment.’

Key Issues, No 3 – amend to say ‘ To be successful, such buildings should be exemplar and ensure the creation of a liveable, healthy place in a high quality environment.’


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Preferred Policy option, b

Preferred Policy option, b – Strengthen policy to ensure that tall buildings are appropriately located as part of comprehensive development of the OA. Therefore avoid random tall buildings across the site developing over life time of project.

b) after ‘….where they contribute to placemaking’ add ‘and in the context of the overall comprehensive development of the area.’

CHAPTER 4: THE PLACES




page 42, key issues, 3 A well designed high quality environment should seek to be healthy in line with the OPDC’s ambition to be a ‘ Healthy Town’.

Amend text in 3. So that last sentence reads ‘…should be exemplar and ensure the creation of a healthy, liveable place in a high quality environment.’


Page 43, Figure 18 Page 43, Figure 18, Densities And Building Heights – both sides of the Grand Union Canal are considered to be sensitive edges. This is consistent with the statement on page 56, K which states that ‘provides a sensitive edge onto the Scrubs and the Grand Union canal.’

Change plan to show both sides of the GUC as sensitive


Page 44, para 3.29 Page 44, para 3.29 – expand on why High density development is considered appropriate around stations.

Page 44, para 3.29 – ‘High density development is appropriate around stations because…..’


Page 44, para 3.30 Page 44, para 3.30 – delete ‘are likely’ and replace with ‘will’ - The high and highest densities will exceed the London Plan Density Matrix.

Page 44, para 3.30 – ‘The high and highest densities will exceed the London Plan Density Matrix.’

OSP4: Densities and Page 44, para 3.22 Page 44, para 3.22 (but should be 3.32) – last change last sentence


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Building Heights

(but should be 3.32) sentence which ends ‘where they contribute to co-ordinated placemaking and create a moment of interest.’ – what does ‘coordinated placemaking’ mean as not very clear? and a ‘moment of interest’ maybe negative as well as positive.


QOSP4a No. Need to show both north and south of grand union canal as sensitive edges.

need to show both north and south of grand union canal as sensitive edges.

OSP5: Places

Page, 47 Figure 23, The Places

Review the boundaries of P1 Old Oak South and P8 Scrubs Lane as the character of P8 extends to the south of GUC along the length of Scrubs Lane and it be logical to include this in P8 rather than P1.

Include of all of Scrubs lane in P8.

OSP5: Places

Page, 48 Justification Include reference to working with the boroughs and their knowledge and understanding of the area and keys issues. Refer to the need to build upon other boroughs Visions for their areas in the immediate vicinity to help inform place making for Old Oak.

add new text to reflect this point before or after Para 3.28

OSP5: Places

QOSP5A, B, C Review the boundaries of P1 Old Oak South and P8 Scrubs Lane as the character of P8 extends to the south of GUC along the length of Scrubs Lane and it be logical to include this in P8 rather than P1.

Include of all of Scrubs lane in P8.

P1 Old Oak South Preferred Policy Option

QP1a: Do you agree with the approach set out for this

The policy approach is supported, but the wording of the preferred policy option should be tightened in a number of areas. The policy

This comment is relevant to a number of other policies set out in the Places section. An example of how the Old Oak South open


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preferred policy option? If not, what might you change?

requires, for example, new development to “Celebrate the unique character of Wormwood Scrubs and the Grand Union Canal and associated nature reserve and support these in becoming accessible focal points for the area”. This provides little real guidance and is open to wide interpretation. A further example is that new development will be required to “Be mindful of existing residential communities at Wells House Road, Midland Terrace/Shaftsbury Gardens,….” . Again, this I wording is too general as to make it relatively useless in assessing development proposals.

spaces policy could be improved would be to replace “celebrate” with “respect and enhance”. The policy would then read “Respect and enhance the unique character of Wormwood Scrubs and the Grand Union Canal and associated nature reserve and support these in becoming accessible focal points for the area”.

page 56-58 P1 Old Oak South Preferred Policy Option

Character, appearance and setting of Grand Union Canal Conservation Area and proposed Cumberland Park Factory Conservation Area should be preserved or enhanced.

Settings of listed buildings within St Mary’s Cemetery and Kensal Green Cemetery should also be ‘preserved or enhanced’.

Setting of Historic Park and Garden at Kensal Green Cemetery should also be ‘preserved or enhanced’.

Page 56-58 - Add Heritage policy option:




page 60 P1 Old Oak South Preferred Policy

Para 4.19 - A comprehensive green infrastructure strategy would help to assess whether this is a suitable nature reserve and

add after … relocated in an alternative manner. Add ‘A comprehensive green infrastructure strategy would help to assess

PAGE 58- Social Infrastructure is P prescriptive.


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Option whether it should be relocated. whether this is a suitable nature reserve and whether it should be relocated.’

Page 62 P2 Old Oak North

QP2a: Do you agree with the approach set out for this preferred policy option? If not, what might you change?

The preferred policy option includes the policy below. Delivery l) Support the early redevelopment of the area; m) Safeguard the Powerday waste site (see policy EU4). The safeguarding of the Powerday site for waste is supported, but it would be better placed in the Land uses section of the policy.

Include a new para in the Land uses part of the policy to read: “Safeguard the Powerday site for waste management purposes”

Page 64-66 P2 Old Oak North









Page 66 Old Oak North Preferred Policy Option – Open Spaces

Preferred Policy Option – Open Spaces and QP2f – should the new park be provided as one large

A minimum space for a park/ open Space in Old Oak North should be set out to ensure that its sufficient for the population to the north of the canal and does not place over reliance on the use of Worm wood Scrubs especially as there is little possibility for a good connection from the new community in the

set out a criteria in open spaces section to require a minimum size large open space/park and reflect this in the justification.


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space or as a series of linked new spaces across Old Oak North?

north to Wormwood Scrubs in the south. One large open spaces lends itself to more flexibility for the types of leisure and recreation it could provide

Page 74 P3: Old Oak High Street


Unlike for Old Oak South, there is no Environment section to the PPO for Old Oak North.

Include an Environment section and refer to relevant environment issues, particularly management of surface water. This area includes the Grand Canal which could form part of the area’s SuDS Strategy.

P3: Old Oak High Street

The term “Old Oak High Street” and the vision for this area should be reconsidered. It appears to be unsuitable for vehicular transport due to its topography – and there needs to be clarity in relation to the vehicular route between Willesden Junction and Old Oak South through Old Oak and its character and quality.

The term “Old Oak High Street” and the vision for this area should be reconsidered.

page 72 P3: Old Oak High Street

page 72, ‘Density’ and ‘Streets’

Criteria should be added to either sections to cover the following – ensure the street has a suitable sense of

enclosure, the height

density of buildings should respond to the change in the width of the High Street and associated public amenity spaces with consideration for daylight and overshadowing to provide quality open spaces.

Page 78 P4: Grand Union Canal

Page 78 Preferred Policy Option – Heritage:

This should refer to ‘preserve or enhance’ rather than ‘conserve and/or enhance’.

Character, appearance and setting of


Character, appearance and setting of


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proposed Cumberland Park Factory Conservation Area should be preserved or enhanced.



proposed Cumberland Park Factory Conservation Area should be preserved or enhanced.




Page 77, figure 35 the length of the Grand union canal on both the north and south of the canal should be identified as a sensitive edge

change plan to should show the length of the Grand Union Canal on both the north and south of the canal should be identified as a sensitive edge


Density Point f) recognises that GUC is a sensitive location and therefore in line with the guidance set out Development capacity section of the draft Local Plan suggest that’s lowest heights are more appropriate here.

Delete reference to taller elements in point f.

Page 96 P7: North Acton


No Environment section included. Include an Environment section and refer to relevant environment issues, particularly management of surface water. This area includes the Grand Canal which could form part of the area’s SuDS Strategy.

Page 104 P8: Scrubs Lane

Preferred Policy Option – Heritage:






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4.137 – Large scale advertisements hoardings line the frontages of many sites on Scrubs Lane detracting from the appearance of the street scene.

The removal of advertisement hoardings causing substantial injury to visual amenity should be an objective.


4.137 – Large scale advertisements hoardings line the frontages of many sites on Scrubs Lane detracting from the appearance of the street scene.

The removal of advertisement hoardings causing substantial injury to visual amenity should be an objective.

Page 104 P8: Scrubs Lane

General the entire length of this corridor needs to be considered when looking at policies for streets, heritage, densities so that there is no obvious delineation between what is the OPDC boundary and what is LBHF boundary. It should be seamless.

Page 114 P10: Wormwood Scrubs

Welcome a site specific policy within the draft Local Plan which sets out the need to work with the Borough and Wormwood Scrubs Charitable Trust and agree any strategy or proposals. Need to recognise the various designations of ecological protection – Site of Borough Grade 1 importance for Nature Conservation and the Local Nature Reserve . The edges of Wormwood Scrubs are also sensitive. The Local Plan sets out the Hs2


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station as location for tall buildings and this will need to be reconciled with its proximity to the Scrubs and any impact that any proposals would have on Wormwood Scrubs. Whilst maximising connectivity is a key priority the link to Wormwood Scrubs would have to consider the sensitive edge along the northern bank of the Scrubs and any impact on the ecology of the site as a result. This would need to be reflected in amendment through the Local Plan where the link is proposed.

CHAPTER 5: SUSTAINABLE DEVELOPMENT



SD1: Sustainable development

QSDb: Do you agree with the chapter’s preferred policy option? If not, what might you change?

Existing Local Authority Local Plans especially with regard to land contamination and similar issues should be incorporated. In issues regarding the assessment and management of land contamination, the local authority is the regulatory body and existing local policies should take precedence in these matters.

Amend preferred policy option to read b) Planning applications that accord with the policies in this Local Plan, the London Plan, the West London Waste Plan and, where relevant, with policies in existing neighbourhood plans will be approved without delay, unless material considerations indicate otherwise;

Page 120 SD 1: Sustainable Development

QSDa: Are there any other sustainable development policy themes you think

Yes. This chapter deals very briefly with sustainability issues in a broad sense and lacks any of the detail that is present in the other ‘Thematic Policies’ chapters.

More detail should be provided on the evidence base that backs up the policy (which is certainly wider than just the Integrated Impact Assessment referenced in the Table 3)


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OPDC’s Local Plan should be addressing?

and on the key sustainability issues for the OPDC Area. Signposting to other policies could be included to avoid repeating some of the issues dealt elsewhere in the other Thematic Policy chapters. Stronger justification text could also be included.

QSDb: Do you agree with the chapter’s preferred policy option? If not, what might you change?

Not entirely. Section (a) of the PPO is fine as it is actually related to sustainable development. The remainder – (b) and (c) – seem to be quite generic policy commitments that are not specific to sustainable development issues.

I suggest removing sections (b) and (c) from the PPO as they are unnecessary.

QSDc: Are there any other policy alternatives that could replace the chapter’s preferred policy?

No. As stated in the OPDC Local Plan, achieving sustainable development is a requirement of national and regional policy, so in order to be consistent with the NPPF and London Plan, the OPDC Plan must promote sustainability. Therefore, it is not appropriate to have an alternative approach in this policy area.

CHAPTER 6: DESIGN



Page 126 D1: Strategic Policy for Design

QDa: Are there any other design policy themes that you think OPDC’s Local Plan should be addressing?

No.

QDb: Do you agree No. It should be recognised in the PPO that Suggest that an additional bullet point is


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with the chapter’s preferred policy options? If not, what might you change?

there are a number of issues, including critical infrastructure that the design and landscaping need to provide in addition to enhancing character, providing a sense of place etc

added to the PPO that relates to the provision of critical infrastructure. The justification for this is that there are key issues like provision of potable water supply and drainage that will be directly influenced by design of the OPDC Area that need to be taken into account at the earliest stage of development design at a strategic level.

QDc: Are there any other policy alternatives that could replace the chapter’s preferred policies?

No.

Page 130 D2: Streets and Public Realm

PPO Preferred Policy Option in relation to advertisements should be expanded to include: ‘The OPDC will seek to secure the removal of advertisements which are the cause of substantial injury to amenity or public safety through the use of discontinuance notices.’

Preferred Policy Option in relation to advertisements c) - should be expanded to include: ‘The OPDC will seek to secure the removal of advertisements which are the cause of substantial injury to amenity or public safety through the use of discontinuance notices.’

Page 130 D2: Streets and Public Realm

QDb: Do you agree with the chapter’s preferred policy options? If not, what might you change?

Not entirely. The issues covered in bullet point (b) are good, but there is scope to make a reference to the role that streets and public realm will need to play in providing a resilient environment in terms of management of surface water.

Suggest adding a bullet point to part (b) of the PPO that covers something like a requirement to deliver multifunctional uses, including provision of climate change adaptation benefits such as sustainable drainage.

Page 134 D3: Open Space

QDb: Do you agree with the chapter’s

See comments for D2 as the same could be said for this PPO.

As above.


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preferred policy options? If not, what might you change?

Page138 D4: New Buildings

QD4a: Are there any additional criteria and/or elements to the proposed policy option for tall buildings and London Plan policies which should be considered?

Yes. Sustainability requirements could be highlighted more than they are in the current PPO.

Suggest that “Sustainable Design” could be given its own heading in the PPO with some brief supporting text.

D4: New Buildings QD4 a,b and c

Given that the Local Plan covers large areas of new industrial, mixed use and variations of residential developments, more detailed, locally specific policy guidance would very useful. Policy D4 should be divided, such as

Industrial buildings

Mixed use buildings

Residential buildings (lower density)

Tall buildings

There will be great differences between the building types in relation to the specifics of the area (orientation to canal, railway infrastructure, sensitive edges, town centres etc.) such as with regard to scale, grain, frontages, local impact on visual amenity and microclimate, relationship with private open spaces, roofscape, materials, wider visual

Provide more detailed, locally specific policy guidance which would be very useful. Policy D4 should be divided, such as

Industrial buildings

Mixed use buildings

Residential buildings (lower density)

Tall buildings


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impact, silhouette, permeability etc. It appears that the policies on high residential densities might conflict with the policies on design, heritage, sensitive edges and views. This needs further testing and evidence.

Page 142 D5: Alterations and Extensions

PPO aii) Preferred Policy Option aii). should be expanded to include reference to materials as well as scale, form, height and mass.

Preferred Policy Option aii). should be expanded to include reference to materials as well as scale, form, height and mass.

Page 142 D5: Alterations and Extensions

QDb: Do you agree with the chapter’s preferred policy options? If not, what might you change?

Not entirely. The issues covered in bullet point (a) are good, but there is scope to make a reference to the opportunity for environmental improvements that extensions/alterations can provide e.g. in terms of integrating climate change adaptation measures where possible.

Suggest adding a bullet point to part (a) of the PPO that covers something like a requirement to deliver environmental improvements that extensions/alterations can provide e.g. in terms of integrating climate change adaptation measures where possible.

Page144 D6: Heritage

PPO a) and b) Preferred Policy Option aiii

Preferred Policy Option a). and b). should be amended to refer to ‘preserve or enhance’ rather than ‘conserve, enhance’. Preferred Policy Option aiii). in relation to Heritage at Risk is too vague and should be amended to read ‘promote the restoration of and secure the reuse and long term future of heritage assets on the Heritage at Risk Register’.

Preferred Policy Option a). and b). should be amended to refer to ‘preserve or enhance’ rather than ‘conserve, enhance’. Preferred Policy Option aiii). amend to read ‘promote the restoration of and secure the reuse and long term future of heritage assets on the Heritage at Risk Register’.


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Page144 D6: Heritage

PPO This should not just relate to heritage assets which is a clearly defined term but also to the historic environment in general.

For example:

in policy D6 a ii: “ensure historic buildings and structures, in particular heritage assets, contribute to improving and creating a sense of place;”

in policy D6 b: “Proposals will be required to conserve and / or enhance the historic environment and the significance of heritage assets to contribute to successful placemaking.”

D6: Heritage General Comment

General Comment Concern that the preferred policy options take a narrow view of designated heritage assets – generally referring only to Conservation Areas and omitting any mention of listed buildings and their setting or the Registered Historic Park and Garden at Kensal Green Cemetery and its setting. The NPPF requires the impact of development proposals on the significance of all designated heritage assets to be considered in the decision making process and recognises that harm to significance can arise from development within the setting of heritage assets. The wording of the preferred policy options should also be amended to reflect the statutory duties within the Planning (Listed Buildings and Conservation Areas) Act 1990 relating to listed buildings, which are to

Policy Options need to be reviewed/ redrafted to take into account heritage assets. The wording of the preferred policy options should also be amended to reflect the statutory duties within the Planning (Listed Buildings and Conservation Areas) Act 1990 relating to listed buildings, which are to ‘preserve or enhance’ rather than ‘conserve and / or enhance’ as mentioned in multiple locations within the Local Plan Draft document.


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‘preserve or enhance’ rather than ‘conserve and / or enhance’ as mentioned in multiple locations within the Local Plan Draft document.

D7: ? General Comment

new Preferred Policy Option required

If not included anywhere in the Local Plan then the Draft document needs a Preferred Policy Option requiring the:

provision of well-designed hard and soft landscaping,

protection of trees of significant amenity and

making of Tree Preservation Orders where justified in the interests of amenity.

new Preferred Policy Option requiring the:

provision of well-designed hard and soft landscaping,

protection of trees of significant amenity and

making of Tree Preservation Orders where justified in the interests of amenity.

CHAPTER 7: HOUSING



Page 156 H1: Strategic Policy for Housing

QHb: Do you agree with the chapter’s preferred policy options? If not, what might you change?

Not entirely. As this is the strategic policy, I would expect a positive reference for the requirement of housing in the OPDC Area to be designed and constructed to meet the highest levels of sustainability performance

Suggest adding a bullet point that refers to the requirement for housing proposals to be designed and constructed to high levels of sustainability performance.

Page 168 H4 Affordable Housing

QH4b: Which of the four proposed options do you think would secure the best

It is noted that the OPDC has not established a preferred policy approach, but has identified 4 options. The council would support an approach that is most likely to meet local housing needs. Option 3, based on a viability

Prefer option 3


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outcome for meeting affordable housing need? Please explain why.

tested percentage, is the preferred approach.

Page 180 H9 Gypsy and Traveller Accommodation

The council notes the policy that “Where OPDC’s Gypsy and Traveller Accommodation Needs Assessment study determines a need for provision of pitches on an additional site OPDC will work with the London Boroughs of Brent, Ealing and Hammersmith& Fulham to identify a suitable site”. In this respect, the council will also expect the OPDC to work with LBHF and the Royal Borough of Kensington & Chelsea to help identify suitable sites to meet identified need in the two boroughs.

No change

CHAPTER 8: EMPLOYMENT



CHAPTER 9: TOWN CENTRES USES



TC1/TLC2/ Figure 93

It is not clear whether the OPDC will be designating town centres through the Local Plan. Town centre boundaries need to be much clearer if a designation is being suggested.

Provide detailed mapping to show the extent of the designations.


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TLC1 Point C – It is not clear whether there is going to be more than one ‘town centre’ The wording in point c suggests multiple town centres.

Remove the plural

TC1 Whilst we support the intentions, points d,e,f are very vague for policy criteria.

Add more definitive wording or explanation about what is expected in order to accord with these bullet points.

9.8 This paragraph could do with some further explanation about how the spatial distribution and uses can help promote healthy lifestyles – e.g. Walking or restricting hot food takeaways.

Add further explanation

9.10 The lack of alternative options for policy TC1 seems odd. Alternative options which still involve a mix of uses could be included.

Consider appropriate alternative options.

Figure 92 Neighbourhood Town Centre? Is it a town centre or a neighbourhood centre? The Neighbourhood centre classification needs to be clearly defined.

Delete ‘town’ from the Neighbourhood centre classification in Figure 92 and elsewhere in the document.

TC2 – Key issue 3 “…to meet needs..” Can you clarify what you mean by need. Is it to meet the projected need for the development or local need or day to day shopping needs?

Suggest amending it to say: “to meet local need generated by the development”

9.13 Object to the word ‘fantastic’ which is too objective.

9.19 Second sentence. Should say..”NPPF sequential test”

Add NPPF to the second sentence.

TC 2 Alternative option 1

Agree that the alternative option of Old Oak as a Metropolitan centre should be dismissed.

TC2 Alternative Option 2

Disagree, with the justification for dismissing alternative option 2. Designating a lower order

Better reasoning need in the justification.


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centre would not preclude larger quantum of retail floor space coming forward. A tightly drawn boundary would be more restrictive to the growth of a centre. The categorisation of centres could be reviewed as the centre establishes itself.

TC2 We acknowledge the need projected in the RLNS for the area, but there is concern about designating high level centres before they exist. A higher level of designation could put pressure on a centre to live up to its categorisation and potentially lead to overprovision and vacancy. This is particularly important given the changing nature of high streets. In our view the categorisation of these centres should be reviewed as the centre evolves and, if categorisation is necessary, then this should begin at a level more akin to the initial phasing of the development e.g. 5-10 years. 5-10 years is considered to be the most reliable period for projecting retail need. Anything beyond that can only be considered indicative.

Consider a lower categorisation of centre.

TC2 We support the approach used to sequential and impact testing and the proposed thresholds. This approach is considered to be in accordance with the NPPF.

TC2/TC3 The policies appear to be drafted to assess what is appropriate in town centres and there is nothing specific for the neighbourhood

Suggest adding separate policy or bullet points to manage local centres.


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centres. There is an opportunity to have policies which address the specific needs of the lower order centres. Would a different mix be appropriate in these centres for example.

TC3 Point a) 1. Tables and chairs on the public highway (footpath) may need to be separately considered from a highways perspective.

Review this from a transport perspective. Signposting or cross referencing with relevant transport policy would be useful.

TC3 c) and para 9.33 This may contradict the policies to provide a certain mix of uses and a certain proportion of independent traders. For example, an applicant could immediately apply for permission to expand his/her 80 sqm ‘independent’ unit having previously adhered to the 10% rule in point d)

Remove point c) as it undermines other policies in the plan and doesn’t add anything that cannot already be achieved through permitted development.

TC3 f) Clarification on precisely where betting shops etc are being restricted would be useful. Otherwise it sounds like a zero tolerance policy on such uses.

Clarify where betting shops etc are being restricted.

TC3 – para 9.32 Can you define ‘meanwhile uses’ How are they different to permanent uses. Will they have a lifespan?

Define ‘meanwhile uses’

TC4 a) Point 3. Complementing other centres should not be triggered by quantum, it should be done regardless of whether the proposal exceeds need. 9.43 says larger proposals. Can you clarify what you mean by larger?

Remove text from ‘where’ onwards in point 3.

TC4 The RLNS projections are useful to identify need, but TC4 reads as if they are targets to be met for the area and for the specific centres. Such prescription is inevitably going to

Put projected needs table in supporting text and make it clear that the figures are indicative. Perhaps use the phrase “up to” rather than approximately in point B. It should


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encourage a developer to align with the high figure rather than making their own judgement on an appropriate level of retail for their development.

also mention that this is subject to assessment.

CHAPTER 10: SOCIAL INFRASTRUCTURE



S12 Education Refer to LBHF School Organisation and Investment Strategy LB Hammersmith & Fulham School Organisation & Investment Strategy 2015

S12 Education Key Issues: 1 - The need for school places is based on a calculation of the child yield from the development.

S12 Education Key Issues: 2 - Funding for school development is derived from a combination of Government grants, planning negotiations and land deals with developers.

http://democracy.lbhf.gov.uk/documents/s59991/School%20Organisation%20and%20Investment%20Strategy%20-%20Main%20Report.pdf

http://democracy.lbhf.gov.uk/documents/s59991/School%20Organisation%20and%20Investment%20Strategy%20-%20Main%20Report.pdf


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S12 Education Preferred Policy Option: C

The council will consider whether an all-through school will be appropriate.

Allocate sites for the provision of new schools (ages 3-18).

S12 Education P40 The need for wider use of the schools portfolio for Early Years’ services, childcare and other services for children and young people should be acknowledged.

S12 Education P241 Remove picture of Westminster City School.

S12 Education 1. Page 238. Key issues. The Local Plan should state who is the Local Education Authority within the OPDC area.

2. Page 240 , para 10.14. Justification. There needs to be recognition that there is more than one authority around the OPDC area and clarify how funding from individual approved developments towards expansion of existing educational facilities ‘in the surrounding hinterland’ will be allocated to the various authorities. Or recognise that further work needs to be done in order to work out a process for doing this. E.g. If each local authority makes observations on a proposed development


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identifying likely child yields from a development, and a sum is negotiated, how will this funding be divided up between adjoining authorities, or will the closest adjoining authority be allocated the resources?

Page 240, para 10.15 - Justification. The OPDC needs to engage at the earliest possible stage with LBHF if it wishes to discuss the potential for expansion of existing schools to accommodate the additional educational facilities resulting from development in the OPDC area as this could impact on LBHF’s School Capital work programme.

Amend 3rd sentence of para 10.15 to read: ‘The OPDC will undertake early discussions with education providers to understand the potential for the expansion of existing facilities.’

CHAPTER 11: TRANSPORT



T1 Strategic Policy for transport

Strategic objective 18. Ensure there us a high quality transport infrastructure, including a Crossrail station and a HS2 rail hub to support development in the north of the borough and improve transport accessibility and reduce traffic congestion and the need to travel.

T2: Walking crossing facilities were not mentioned

T3: Cycling no comment

T4 Rail General

General Potential for platforms on West Coast Main Line at Willesden Junction in order to improve access to the Opportunity Area and allow


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interchange from primarily outer suburban services to London Overground and Bakerloo Line, even if Crossrail connection to West Coast Main Line is delivered.

page 267 QT4a

Do you have any suggestions of additional rail connections to the OPDC area that should be provided?

Yes, to Hounslow via the North London Line and Kew west curve, to Brent Cross and Luton via the Dudding Hill line, and Chiltern Line service to High Wycombe.

Page 270 QT5b:

Should OPDC seek to encourage low and zero emission buses?

Yes it should.

T5: Buses Need to consider the following :

when designing new roads to allow space to facilitate bus operations.

proposals should consider the latest bus design guidance and aim to improve bus movements and connectivity to the existing bus network.

Page 272 T6: Roads and Streets

PPO Preferred policy option must include all road users, (note part d) does not mention disabled users Justification 11.49 could be re-arranged and to start with: ‘All new and improved roads must be built to adoptable standards and any decision to adopt


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streets would need to be made in collaboration with the relevant local councils. reason: when reading this part it could be interpreted that is for consideration for Park Royal side, only. •Road design principles- the following documents to be considered: MfS 1 and 2; TfL’s Streetscape Guidance; London Cycling Design Standards Guidance; Kerbside Loading Guidance; Accessible Bus Stop Design Guidance; • The Approach to road adoption- to be decided at the outset of the proposal and in consideration with the LHA processes and latest guidance as well as in line with the latest, for example DfT’s Draft Advice Note on Private Streets & Road Adoption


QTb: Do you agree with the chapter’s preferred policy options? If not, what might you change?

Not entirely. Roads and streets have the capacity to help mitigate the effects of climate change and can facilitate resilience of the OPDC Area to impacts such as over – heating and flooding. This issue should be covered briefly in the PPO.

Suggest adding a bullet point (or amending bullet point (e) to refer to role that streets and roads can play in helping provide resilience against climate change impacts.


Preferred policy option must include all road users, (note part d) does not mention disabled users Justification 11.49 could be re-arranged and to start with: ‘All new and improved roads must be built to adoptable standards and any decision

Preferred policy option must include all road users, (note part d) does not mention disabled users Justification 11.49 could be re-arranged and to start with: ‘All new and improved roads must be built to adoptable standards and any


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to adopt streets would need to be made in collaboration with the relevant local councils. reason: when reading this part it could be interpreted that is for consideration for Park Royal side, only. •Road design principles- the following documents to be considered: MfS 1 and 2; TfL’s Streetscape Guidance; London Cycling Design Stnadards Guidance; Kerbside Loading Guidance; Accessible Bus Stop Design Guidance; • The Approach to road adoption- to be decided at the outset of the proposal and in consideration with the LHA processes and latest guidance as well as in line with the latest, for example DfT’s Draft Advice Note on Private Streets & Road Adoption

decision to adopt streets would need to be made in collaboration with the relevant local councils. reason: when reading this part it could be interpreted that is for consideration for Park Royal side, only. •Road design principles- the following documents to be considered: MfS 1 and 2; TfL’s Streetscape Guidance; London Cycling Design Stnadards Guidance; Kerbside Loading Guidance; Accessible Bus Stop Design Guidance; • The Approach to road adoption- to be decided at the outset of the proposal and in consideration with the LHA processes and latest guidance as well as in line with the latest, for example DfT’s Draft Advice Note on Private Streets & Road Adoption

Page276 T7: Car Parking

QTb: Do you agree with the chapter’s preferred policy options? If not, what might you change?

Not entirely. At least some car parks will presumably be outside and be locations where surface water run-off will need to be managed. The role that car parking can play in providing environmental management benefits should be highlighted.

Suggest adding a bullet point that states that all external car parking will integrate measures such as SuDS and will not direct run-off into the combined sewer network.

T8: Freight Servicing and Deliveries

Page 284 T9: Construction

QTb: Do you agree with the chapter’s

This PPO only deals with the transport aspects of construction when presumably it should deal

Suggest including reference in the PPO to other aspects of construction, including the


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preferred policy options? If not, what might you change?

with other aspects as well? need to employ sustainable construction techniques, materials etc.

T10: Transport Assessments and Travel Plans

change text from the ‘Justification 11.81 The Travel Plan should be secured by a planning obligation and include ongoing management.’ To ‘Justification 11.81 The Travel Plan should be secured by a S106 and include ongoing management.’

11.81 The Travel Plan should be secured by a S106 and include ongoing management.’

T10: Transport Assessments and Travel Plans

change the ‘Justification 11.81 The Travel Plan should be secured by a planning obligation and include ongoing management.’ To ‘Justification 11.81 The Travel Plan should be secured by a S106 and include ongoing management.’

CHAPTER 12: ENVIRONMENT AND UTILITIES



EU1: Strategic policy for the environment and utilities

QEUa: Are there any other environment and utilities policy themes that you think OPDC’s Local Plan should be

Missing details of policy context. Key Issues 1. Include; Local authorities hold the specific responsibility for the management of land contamination within their boundary under Part 2A of the EPA 1990 and will have to agree in writing any proposed submissions or


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addressing? actions with regard to the assessment or remediation of land contamination

EU1: Strategic policy for the environment and utilities

The comments under EU6 apply here as well. Further, the synergy between measures to reduce greenhouse gas emissions and air pollutant emissions should be established here. In addition, the need to ensure that good indoor air quality is maintained where insulation is proposed for CO2 emission reduction.

EU4: Waste Management

QEUa: Are there any other environment and utilities policy themes that you think OPDC’s Local Plan should be addressing?

This policy does not deal with construction or contaminated waste. As part of the proposals for sustainable development, facilities for the treatment of potentially contaminated soils should be made available early in the overall development process and should be included as a factor in phasing plans.

An additional point should be added to ensure that adequate soil treatment and similar facilities are incorporated to Waste Policies now in order to satisfy the proposals contained within the Decontamination Strategy.

Page 304 EU4 Waste management

The council supports the preferred policy option to “safeguard the Powerday (Old Oak Sidings) waste site in Old Oak”.

No change

EU5: Circular economy and resource efficiency

QEUb: Do you agree with the chapter’s preferred policy options? If not, what might you change?

The policy should specifically include contaminated arising from development

Amend preferred policy option a) ii. to read; Maximising the use of secondary materials and the opportunities for reuse, remanufacture or recycling of soils and other materials

Page 312 EU6: Decentralised Energy

QEUb: Do you agree with the chapter’s preferred policy

Not entirely. Whilst the positive approach to inclusion of decentralised is welcomed as a way of minimising CO2 emissions etc, there may

Amend the PPO to reflect the need for achieving high levels of CO2 emissions reduction in pursuit of zero carbon through


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options? If not, what might you change?

also need to be firmer commitments to zero carbon development which encompasses not just decentralised energy but also energy efficiency and renewable energy generation..

implementation of a range of energy efficiency and low/zero carbon technologies.

EU6: Decentralised energy

Preferred Policy Option

This opportunity area sits within an a Local Air Quality Management Area declared across the borough due to exceedances of nitrogen dioxide and fine particulate matter. The European Commission has issued the UK with a ‘Letter of Formal Notice’ for breaching NO2 limit values. Defra and the GLA have written to the Council calling for cooperation in tackling the problem, but also reminding us of Government powers that could require local authorities to pay the associated EU fines.

The relationship between local energy generation and air pollution should be clearly defined here and it should be made clear that such energy generation shall not have a negative impact on local air quality.

OPDC will support and facilitate: a) provision of energy supply infrastructure that enables development (electricity and gas); b) the provision of infrastructure to deliver a decentralised energy network; c) proposals which contribute to the delivery of a decentralised energy network subject to: i. providing evidence that appropriate management mechanisms will be put in place to ensure that end customers are protected in respect of the price of energy provided; and ii. ensuring that heat losses from the network are minimised. iii) Proposals will be expected to demonstrate they shall not have a negative impact on local air quality. Development proposals will be required to: d) demonstrate a collaborative


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approach to working with OPDC and its development partners to contribute to the supply and capacity of the decentralised energy network unless it can be demonstrated that this is not technically feasible or economically viable; e) be designed to enable connection to the decentralised energy network, where there is no connection to a decentralised energy network yet available, and/or where CCHP or CHP would not be technically feasible or financially viable; f) demonstrate that provision is included to accommodate routes and land for energy centres and utilities networks; and g) submit an Energy Statement.

EU8: Green infrastructure & biodiversity

QEU8a: Where could new green infrastructure be incorporated into the layout of new development in the OPDC area?

Although poor air quality is identified as a key issue, the preferred policy option does not identify that greening should be used to improve air quality and/or minimise the exposure of people to poor air quality. This should be added.

Development will be required to: a) protect and/or enhance and create multi-functional green and water spaces and ensure they are connected by street greening and other green links; b) demonstrate how green infrastructure has been: i. integrated with utilities infrastructure; and


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ii. planned, designed and managed to contribute to and be integrated with, the wider green infrastructure network; iii. used to improve air quality and/or minimise the exposure of people to poor air quality c) take account of the proximity of SINCs, and the habitat and species targets in relevant Biodiversity Action Plans (BAPs); d) be accompanied by an Ecological Statement for major applications; e) have particular regard to the measures for the protection and enhancement of ecology and biodiversity in Wormwood Scrubs and for the Grand Union Canal.

Page 316 EU 8: Green Infrastructure & Biodiversity


Not entirely. Green infrastructure is likely to play an important role in helping to manage surface water flooding, so this could be referenced in the PPO.

Suggest amending bullet point (b) (i) or (ii) to include this reference.

Page 320 EU 9: Extraction of Minerals

QEUc: Are there any other policy alternatives that could replace the chapter’s preferred policies?

This policy is inappropriate for this location and the policy should set out why this is not an option. One alternative would be to not have a specific PPO covering this issue. Need to consider what would the implications of this be. The implications of having the policy and allowing licensing for such works would be

Consider deleting the PPO


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contrary to the vision, placemaking and regeneration objectives.

EU9: Extraction of minerals


The local geology is extremely unlikely to provide any opportunity for the discovery of economically useful reserves of unconventional oil and gas resources. However, there is a minor possibility of ballast and other materials being discovered during investigation or construction works which could become a useful resource over the duration of the project.

Amend preferred policy option to start; Applications for mineral extraction, including the exploration, appraisal and operation of unconventional oil and gas resources, will be considered against the following criteria:

EU9: Extraction of minerals

If Oil and Gas Development is considered at this site, it must be demonstrated that it will not contribute to the poor air quality in the borough which is already a Local Air Quality Management Area. Pollution to local land and perched waterways would also need to be considered as it would create an offence under the Environmental Damage Regulations 2009.

Applications for mineral extraction, including the exploration, appraisal and operation of unconventional oil and gas resources, will be considered against the following criteria: a) Protection of nearby residents and businesses from the effects of the operations, particularly in regard to air quality and noise; b) The operation’s design, including its sensitivity to the character of the urban landscape and to features of national, London, and local importance; c) Site access, traffic generation and the routing of heavy vehicles; d) Safeguarding of water supplies and the water environment, the safe and sustainable disposal of waste water


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and flood risk management including surface water; e) The effects on public rights of way, open spaces or outdoor recreation; f) The control and mitigation of greenhouse gas emissions and dust during construction and operation; g) The efficient use of resources (such as construction materials or water); h) The contribution of the operation to the development of heat and energy recovery or low carbon technologies; i) Site restoration, and effective after use following development; and j) the safeguarding of biodiversity, and sites of interest for nature conservation.

EU10: Air Quality The European Commission has issued the UK with a ‘Letter of Formal Notice’ for breaching NO2 limit values. Defra and the GLA have written to the Council calling for cooperation in tackling the problem, but also reminding us of Government powers that could require local authorities to pay the associated EU fines. As the borough is an Air Quality Management Area (identified in the ‘key issues’) and due to the potential of these fines being levied on the Council, it is essential that the impacts of any development is agreed with the Council. This should be established in this policy. Point 4 of

Development will be required to demonstrate through an air quality assessment how it: a) implements the recommendations of the Old Oak and Park Royal Air Quality Study (summarised in Table 15 below); b) has regard to the relevant borough’s Air Quality Management Plans and the mitigation measures identified therein; c) considers air quality impacts during construction and operation with the


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the options does identify that assessments would be necessary, but it should be specified that these are in agreement with the individual local authorities.

aim of being air quality neutral, with mechanisms for how this will be monitored over time; and d) seeks to minimise air quality impacts from surrounding uses.

EU12: Land Contamination

QEUa: Are there any other environment and utilities policy themes that you think OPDC’s Local Plan should be addressing?

Missing details of policy context. The regulator for land contamination is the Local Authority, not the Local Planning Authority.

12.104 Amend to include; After remediation under planning, as a minimum, land should not be capable of being determined as contaminated land as defined by Part 2A of the Environmental Protection Act 1990 by the relevant local authority.



In order to satisfy part iii of policy option b), five of the seven steps outlined in section 12.109 will need to have been satisfied. For this to happen, the final design will need to be fixed before planning permission can be granted and site investigation work has to have been completed and assessed, i.e. as a pre-application process prior to granting planning permission. The relevant local authorities will require additional resources to deal with this level of involvement.

No proposed text changes. This issue requires a re-organisation of priorities and assumptions with regard to the management of land contamination and the local authorities who have to agree any submissions or proposals relevant to land contamination which a mere textual change will not address.


The focus here is wrong, the Local Authority is the regulator for land contamination and the Environment Agency provides additional support where relevant.

12.107 Amend to: Land contamination and remediation is the subject of planning and other regulatory regimes. A key to the successful redevelopment of brownfield land is therefore


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early and continual engagement between developers, planners and regulators. OPDC will expect dDevelopers will be expected to to work with OPDC, the relevant London Boroughs, and the Environment Agency and the OPDC in assessing the risks and the management of contamination, in assessing the suitability of the proposed use for the conditions on that site, and in agreeing any necessary steps for remediation. All steps must be agreed with the local authority as the regulator for contaminated land issues.


The focus here is wrong, the Local Authority is the regulator for land contamination and the Environment Agency provides additional support where relevant. The full titles of CLR11 and the Guiding Principles should be included. A reference to Part 2A of the EPA1990 should also be included as the primary definition of ‘contaminated land’, and the regulatory regime

12.108 Amend to: Regulatory advice and guidance is available to identify the principal matters which both the Environmental Regulator will Planning Authority and environmental regulator look to be undertaken when approaching redevelopment and land contamination. The Environment Agency documents ‘Model Procedures’ and ‘The Guiding Principles’ are particularly useful as they highlight the main stages in the process, best practice and refer to further guidance.


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Insufficient understanding of the processes of land contamination assessment and management. All assessment and remedial work has to be undertaken by a competent person

12.109 Amend to: Where land is known or found to be contaminated, or where a sensitive use is proposed or exists, this decision to be made solely by the relevant local authority, developers will be expected to assess their proposals using the seven stage process below: 1. Preliminary Risk Assessment. Comprising a desktop study including details of past and present uses at the site and the surrounding area to identify any potential sources of contamination, potential risks and sensitive receptors. A conceptual site model should be produced to demonstrate where any pathway connects any of these sources to the sensitive receptors. Information collected by the relevant local authority as part of their preliminary review of historical land uses must be incorporated into the Preliminary Risk Assessment and any risk assessment without this information will not be accepted as complete under CLR11. 2. Site Investigation Scheme. Based upon stage one, setting out how the site investigation will be carried out, how the sources of pollution identified in the conceptual site model will be targeted and to determine the existence of the pathway to the identified receptors. 3. Site Investigation. To be undertaken using current guidance and methods. 4. Risk Assessment. Based upon site investigations, to determine the degree and nature of any contamination on the site and the risks posed by any contamination to


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Consistency across policies to be maintained If the opportunities for local soil treatment are to be taken seriously, a policy requiring a proper assessment of the possibility for such a facility should be incorporated in EU4

Amendments required to 12.111 to match revised commitments in EU4

Infrastructure provision

QDIc: Are there any additional pieces of infrastructure not in Table 16 that you think OPDC should be identifying?

Missing infrastructure 13.26. Include a commitment to provide facilities for soil treatment and remediation as part of the overall development project rather than on a site only or ad-hoc basis.

Managing and promoting development

Resource provision? 13.34. The provision of pre-application advice to developers with regard to land contamination issues will have to be by arrangement with the relevant local authority. The OPDC is not qualified to address these issues as they are not the regulator.


Cannot access the list of information required for planning applications

13.35. Include the current list of documents within the document, not via a broken web link


Decisions regarding the assessment and management of land contamination must be made by the relevant local authority and based on the correct guidance and current best practice.

Amend 13.38. Once a planning application has been submitted to, and validated by OPDC, it is considered by the relevant regulating authority against relevant planning policy and any other material considerations. This Local Plan, alongside NPPF, London Plan, the Old Oak and Park Royal Opportunity Area Planning


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Framework (OAPF), any neighbourhood plans, and Supplementary Planning Documents and other relevant guidance will form the basis for assessing and determining planning applications.

Monitoring Local Plan effectiveness

13.44 A regular summary of the area of brownfield land brought back into beneficial use should be included.

Some general points that do not fit into specific boxes: The requirement that; after remediation under planning, as a minimum, land should not be capable of being determined as contaminated land as defined by Part 2A of the Environmental Protection Act 1990 and that this decision can only be made by the relevant local authority does not seem to have been considered as a key factor in the assessment and management of land contamination through the planning process. The OPDC will not inherit this right as a Planning Authority. There is no policy proposed to ensure that consistency of approach to the assessment and management of land contamination across the three local authorities will be assessed and maintained. If the OPDC becomes a land owner and developer, it will assume the full responsibility for ensuring that land contamination issues are dealt with adequately, but the Local Authority will still remain the regulator for these issues.


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Decontamination Strategy Why is this not called a Land Contamination Strategy? Global Remediation Strategies A Global Remediation Strategy in line with the Olympic Park Strategy is a potentially excellent start to the assessment and management of land contamination in the ODPC area, but the following key points should be accepted;

There is a major difference between the Olympic and ODPC sites. The Olympic park had a single completion date, the ODPC is seen as a long term development process to be undertaken over twenty years.

There was little or no change in the requirements for remediation during the Olympic Park development, but there is the possibility of major revisions to the assessment of risk over twenty years

Therefore, the following questions need to be answered:

Who will take ultimate responsibility for setting out the global strategy?

Who will be responsible for the review and revision of the Global Remediation Strategy during the life of the ODPC following changes to risk assessment, legislation, known site conditions etc.

How with the strategy interact with the existing local authority contaminated land assessment and management policies or strategies?

Who will be responsible for ensuring that decisions regarding land contamination will be consistent across the separate boroughs?

Where more than one developer is involved in an area potentially covered by a single Site Specific Remediation Strategy, who will be responsible for the design and execution of the Strategy?

Ideally, any plan to ensure that waste soils are treated and re-used within the development area requires all relevant policies to be designed to interact positively.

Sustainable Remediation and Waste Setting out a common policy for the entire regeneration programme is another excellent step, but one that needs to be in place, together with any infrastructure, before any major redevelopment takes place to get the maximum advantage of such a policy. The Olympic Park was redeveloped over a much shorter period than the ODPC area regeneration is expected to take. As above, there will be a requirement to review and revise policies as required over the life of the project. Key points:

The Main Olympic site was in common ownership for most of this time which provided opportunities that may not be available in the ODPC regeneration area unless this too comes under single ownership.


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There was a single boundary to the Olympic site, avoiding the need to move potentially contaminated material over public roads and simplifying waste movement procedures.

Part of the Olympic site was given over to soil treatment works which were present during most of the construction phase, although they were moved during the process as land was required for specific parts of the development. This was incorporated into the phasing of works.

To make the maximum benefit of these proposals, an estimate of the volumes and types of material to be treated or disposed of must be made at the earliest opportunity, this information will be required to design any on-site treatment facilities and for these to be ready before any major remedial works are undertaken.

Much of the information about possible contamination is already available with the relevant local authority and this information should be sought out at the earliest stage as part of the initial Global Remediation Strategy work.

Therefore, if the strategy is to work properly the following questions will need addressing;

If treatment works, such as a soil hospital are to be included in the overall waste management scheme for the ODPC site; o When will it be available? o Who will operate it? o Will a single site be set aside for the duration of the projects? o Will there be sufficient space for stockpiles of material to even out demand for treated soils or volumes of soils to be treated? o Will the facility be open to other developers outside the OPDC area to maximise the overall efficiency over the OPDC project lifetime

by filling unused capacity during slack periods in the OPDC development programme?

As part of the overall regulatory programme for the Olympic Site, a suite of guidance documents was generated to ensure the right people were engaged and the correct licenses, regulatory agreements etc. were in place when necessary. Is this model also t be followed for the OPDC project?

CHAPTER 13: DELIVERY & IMPLEMENTATION



Page 331 Delivery and

general comment around funding and

There is reference to working with the boroughs in para 13.5 to identify infrastructure


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Implementation

delivering infrastructure including legal agreements.

needs. It is also essential for the Pod to work closely with the boroughs to set out governance to agree the further prioritisation of the infrastructure list over the life of the project as the boroughs will have the local working knowledge in terms of capacity, need and demand . And also to agree any ongoing management and maintenance of any items delivered as there maybe major implications for services that the borough provides and therefore implications for ongoing revenue budgets. As such is it critical that boroughs are involved in any negotiations and agreements to secure infrastructure which may have a direct bearing on the councils services and budgets.

Table 16: Infrastructure Requirements

What are items UT3 and UT4? Presumably one of these relates to water supply. Think the issue should still be identified in the table even if further work is to be undertaken.

Refer to infrastructure issue in the table for items UT3 and UT4.

Managing and Promoting Development

Neither of the web-links in Paras 13.35 and 13.37 work.

Check hyperlinks and fix.

It may be worth referencing that each borough is the Lead Local Flood Authority for the relevant parts of the OPDC and must be consulted on all major applications which must provide surface water management strategies.

Suggest adding some text in Para. 13.38 to cover this issue.

Page 346- General this section needs to consider how the


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Managing and Promoting Development

boroughs are involved in the assessment of planning applications.

CHAPTER 14: GLOSSARY

Drainage Hierarchy Definition not included Include definition as outlined in London Plan Policy 5.13.

Lead Local Flood Authority

Definition not included Include definition

Air Quality Comments on Air Quality Strategy

Air Quality Comments on Air Quality Strategy The Executive summary states “modelling confirms that NO2 concentrations currently exceed the AQOs, but indicates that they will reduce in the future as older vehicles are replaced by newer ones, with tighter emission standards” This does not make reference to the issues such as VW emissions scandal and that Euro 6 diesel cars currently emit 6 times more than the official limit for NOx. New real world driving tests from next year are proposed to test emissions from diesel cars but there will be a conformity factor of double that and then 50% from 2020. So there continues to be uncertainty as to what reductions will be achieved by replacement of older vehicles which is not detailed here. The executive summary details “ the monitoring and modelling results suggest a pressing need for mitigation measures to be implemented in order to meet the AQOs for NO2. It is important that, where possible, developments should not add extra emissions to the area” However this is not supported by the wording of the recommended policies for the operational phase, which do not go far enough to support this. “Policy 7 Freight: To minimise the impact of emissions from vehicles delivering and collecting freight, the OPDC will investigate the possibility of establishing a freight consolidation centre that will facilitate undertaking the final stage of delivery by zero emission vehicles.” Also identified in the executive summary, “As there are existing particulate issues in the area and a huge amount of construction activity will be required , it is vital that construction activities are planned in detail and dust emissions are avoided as far as possible to avoid continued exceedance of the AQO”. Recommended policy for the construction phase includes “5 Monitoring: The OPDC will investigate the possibility of establishing a construction monitoring website, in which real time monitoring data from all active sites will be provided and tracked…this will enable a coordinated response when high particulate levels are recorded across a wide area.” Again the wording of the statement does not provide adequate assurance that this vital measure will be implemented.


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Review of policy context and legislation does not detail that because the opportunity area sits within an a Local Air Quality Management Area declared across the borough of Hammersmith and Fulham due to exceedances of nitrogen dioxide and fine particulate matter, Defra and the GLA have written to the Council calling for cooperation in tackling the problem, but also reminding us of Government powers that could require local authorities to pay the associated EU fines. This appears to conflict with the statement in section 2.2 “ While district councils have a statutory duty to carry out LAQM, it is important to note that councils are not obliged to achieve the AQOs as they do not have sufficient control over all the sources that could potentially give rise to the breach”

Section 2.4 details “It is stated that longer-term improvements to air quality (and other benefits such as urban cooling) can also be delivered through a strategic approach to the provision of trees in the public realm which considers the form and structure of the canopy and how groups or avenues of trees interact with the open space network to create ‘breeze pathways’ that optimise air flow. The green infrastructure strategy is still to be developed, so this is unavailable for review at this time. The relationship between breeze pathways and improved air quality remains to be expanded upon in the final planning framework, further to comments on the draft planning framework.

Section 2.4 details Hammersmith and Fulham’s AQAP, in addition this section would benefit from detailing that the Council has established a resident led Air Quality Commission that will recommend actions for the Council to include in a new AQAP.

The suggestion in section 3.2 for “further monitoring in certain areas in order to increase knowledge of air quality across the area and to enable applicants to verify their dispersion modelling when they are preparing air quality assessments in support of planning applications” is welcomed. The proposed location of the monitors should confirm which borough these will be located in and detail how this data will be made available to members of the public and local authorities.

Section 3.6 details the dispersion modelling completed, specifying exposure to traffic pollution modelled. It is not clear whether any point sources were considered for inclusion in the modelling. More information should be provided as to how these were considered/discounted. Concentrations were not modelled at varying heights when one of the key recommendations of the study is “Where possible, not locating residential units on the ground floor near to the A4000” Because varying heights have not been modelled this statement is not well supported, avoiding residential units on the ground floor may not go far enough. Appendix C details model verification, the statement “under-predicted at a greater number of sites (26 as opposed to 17)” should be checked as the tables do not support this. Section 3.7 states “ proposed individual developments should meet the tightest emission standards detailed in the Mayor of London’s SPG on Sustainable design and construction” this is taken to mean Band B emission standards will be applied across the opportunity area and this is welcomed.


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Operational phase recommended policy 3 parking is welcomed “ 1 car parking space per 5 residential units with one active electrical point per space” as existing policies would not provide significant encouragement to the uptake of electric vehicles. Appendix B states that ADMS –roads version used models the effect of street canyons on concentrations within the canyon…usually only important when the aspect ratio …Is greater than 0.5” Appendix B goes on to state that in the study “street canyons, noise barriers, buildings and complex terrain were not modelled” The air quality study should detail why these aspects were not modelled. The results for the 163 receptors modelled have been presented visually but not tabled, which should be provided as an appendix to assist with review of the document. Operational phase recommended policy 12 master planning details that “developments should not create a new “street canyon” or a building configuration that inhibits effective pollution dispersion” This should be expanded to detail that dispersion modelling should utilise models that offer advanced treatment of street canyon. CERC newsletter winter 2015/16 details when this is appropriate ADMS-Urban 4 and ADMS-Roads 4 include an advanced street canyon modelling option, which is most appropriate:

When modelling tall street canyons (height/width > 1);

When modelling asymmetric canyons, with different building heights, densities or distances from the road on either side of it;

When modelling a road with substantial pavements within a canyon; or

When looking at the variation of concentration with height within a road canyon. The advanced street canyon option affects pollutant concentrations inside and outside canyons, which allows for a smooth transition between modelling with and within a street canyon. Using this option requires more input data than the basic street canyon option. This data can be generated either by hand or automatically from digitised road and building datasets using the supplied ArcGIS Street Canyon Tool. Policy for operational phase 15 assessment for planning purposes should provide more detailed guidance as to how dispersion modelling should be completed and confirm when advanced modelling tools should be utilised such as ADMS advanced street canyon modelling, to ensure a consistent approach to air quality assessment.