response primary local consultation summary respondent .../media... · objection to thames water...

Response

Entry

Number

Primary Local

Plan reference

Consultation Summary Respondent

Reference

Number

Respondent Name and

Organisation

1 Sub Area 4 Physical, psychological and cultural barrier of A12. District and school not enough to address the issue. REP.LP.001 James Butler

2 Sub Area 4 Questions critical mass of population to make plan effective. REP.LP.001 James Butler5 T.4 Important relationship between physical activity, travel choises, health and sustainability. REP.LP.002 Fred Smith3 T.9 Support for additions to Plan regarding cycling, although additions are general. REP.LP.002 Fred Smith

4 SP5 Suprised that cycling does not figure more strongly in the context of Policy SP5. Considers that physical activity, including cycling, is a great way to improve health, control weight and help people feel better about themselves.

REP.LP.002 Fred Smith

6 Infrastructure Suggestion that the Capital Ring walking route is diverted through Queen Elizabeth Olympic Park. This would be more attractive than the existing route and bring additional visitors, awareness of and revenue for the parks facilities.

REP.LP.003 Colin Saunders, Capital Ring

7 Infrastructure Change to the route should be accepted in principle by LLDC and incorprated into the Local Plan. The only cost would be in signage and could be inexpensive. REP.LP.003 Colin Saunders, Capital Ring

8 Infrastructure Electricity Transmission: National Grid’s high voltage electricity overhead transmission lines / underground cables within London Legacy Development Corporation’s administrative area form an essential part of

the electricity transmission network in England and Wales REP.LP.004 Julian Austin, Amec on

behalf of National Grid

9 Infrastructure Gas Transmission. National Grid has no gas transmission assets within the administrative area of London Legacy Development Corporation REP.LP.004 Julian Austin, Amec on behalf of National Grid

10 Infrastructure Overview of National Grid provided. REP.LP.004 Julian Austin, Amec on behalf of National Grid

24 BN.7

As the Corporation have chosen not to include a separate Park related policy as suggested in the Authority’s previous comments the following amendments are required to supporting text to Policy BN7 to fully

represent the Authority’s strategy for what is in effect a substantial area of the Olympic Park. Policy application text:

6.25 The Map at Fig 16 shows the extent of the Lee Valley Regional Park area within the Legacy Corporation boundary. Many areas of Local Open Space fall within this boundary, together with the legacy sports facilities at the Lee Valley Hockey and Tennis Centre and the Lee Valley VeloPark. The historic Three Mills Island also forms part of the Regional Park as do the Greenway, and towpaths alongside the River Lee Navigation, Hertford Union Canal, City Mill River, Three Mills Wall River and Prescott Chanel. Many of these Local Open Spaces areas are within the ownership of the Lee Valley Regional Park Authority whose Park Development Framework (2011) sets out the strategy for their future development and management. of the Park including these spaces, providing information about their function, quality and character. of Local Open Space. The strategy in this Local Plan is designed to align with the Park Development Framework. Development proposals within the Lee Valley Regional Park area will take account of this Framework in addition to relevant BAPs.

REP.LP.005 Stephen Wilkinson, Lee Valley Regional Park Authority

25 BN.7It is appreciated that the timescale for completion of the PDF Area Proposals may fall outside the relevant deadline for completing and examining the Local Plan. It would therefore be appropriate to include a summary of the proposals as part of paragraph 6.25 with a link to the Authority’s website for further detail.


28 1.5Request to include additional comments regarding the LVRPA. REP.LP.005 Stephen Wilkinson, Lee

Valley Regional Park Authority

27 SA1.7Minor revisions to text within Sub Area 1 suggested. REP.LP.005 Stephen Wilkinson, Lee


26 Sub Area 1 Minor revisions to text within Sub Area 1 suggested. REP.LP.005 Stephen Wilkinson, Lee


30 2.3Minor revisions to text within Sub Area 2 suggested regarding connections. REP.LP.005 Stephen Wilkinson, Lee


29 Sub Area 2

Considers that the vision for North Stratford and Eton Manor requires change and correction to recognise the role of the Eton Manor area in containing the Lee Valley Hockey and Tennis Centre. The following changes are requested: "North Stratford and Eton Manor will become an area of new high-quality housing with generous new Local Open Space set along the Parklands of Queen Elizabeth Olympic Park and the world class sporting venues at Lee Valley VeloPark and the Lee Valley Hockey and Tennis Centre at Eton Manor."


31 3.2

Revisions to text suggested within the area profile and policy 3.2. These include the LVRP area and the maintenance and enhancement for the entire greenway. REP.LP.005 Stephen Wilkinson, Lee Valley Regional Park Authority

34 4.2Revisions to text suggested within sub area 4 regarding connections. The improvements to existing and new connections considered necessary for the delivery of development anticipated in Sub Area 4 are Improving the pedestrian underpass adjacent to Bromley by Bow Station and linking pedestrian and cycle routes to allow access to the new District Centre and the Lee Valley Regional Park beyond.


33 4.4Minor revisions sought to text suggested within sub area 4 regarding adherence to LVRPA proposals. REP.LP.005 Stephen Wilkinson, Lee


32 Sub Area 4 Minor revisions to text suggested within the area profile of sub area 4 regarding the ecological and heritage based assets of Three Mills Island. REP.LP.005 Stephen Wilkinson, Lee


35 Sub Area 4 Minor revisions to text suggested within the area profile of sub area 4 regarding the Lea Way. REP.LP.005 Stephen Wilkinson, Lee Valley Regional Park Authority

21 General Sections

Part of the Introduction to the The Lee Valley Regional Park Authority (LVRPA) response. This includes details regarding LVRPA statutory responsibilities, area boundaries and political membership. REP.LP.005 Stephen Wilkinson, Lee Valley Regional Park Authority

22 General Sections

Part of the Introduction to the The Lee Valley Regional Park Authority (LVRPA) response. The Authority welcomes the changes made to the layout, ordering and content of the revised Local Plan. REP.LP.005 Stephen Wilkinson, Lee Valley Regional Park Authority

42 BN.7

Given the strategic importance of the site, the scale of infrastructure development at Abbey Mills PS and the potential for future infrastructure investment at the site it is important that the site is not is not constrained by unnecessary planning policy restrictions, such as Local Open Space designation and Policy BN.7, which could prevent future upgrades to essential infrastructure. Request to delete the Local Open Space designation from the Abbey Mills PS site. Objection to Thames Water Abby Mills Pumping Station designation as a Local Open Space. If for any reason this is not accepted, the Policy should be amended so as to recognize the need for future operational development at the Abbey Mills PS site.

REP.LP.006 Thames Water

1

38 SP4

More detail required to allow Thames Water to make a detailed assessment of the impact of proposed housing provision on local infrastructure. Need additional information on the aspirations for sites to enable more specific comments on the site proposals, for example, the anticipated timing/phasing of development. Developers should contact Thames Waters’ Developer Services department early to discuss

proposals. Developers may be required to fund studies to determine network capacity, and fund upgrades to the network. It is important not to under estimate the time required to deliver necessary infrastructure, for example: local network upgrades take around 18 months and Sewage Treatment & Water Treatment Works upgrades can take 3-5 years.


37 S.5Welcomes and supports the inclusion of the policy, in particualr the support expressed for the Lee Tunnel and Thames Tideway Tunnel. However, it considers that the policy should be improved in relation to non-strategic water supply and sewerage and waste water infrastucture by expanding the policy to refer to all new development rather than just Major new development, in order to align with London Plan Policy 5.14 and the National Planning Policy Guidance.


40 S.8

Considers that any flood risk policy should therefore include reference to sewer flooding and an acceptance that flooding could occur away from the flood plain as a result of development where off site infrastructure is not in place ahead of development. It is vital that sewerage/waste water treatment infrastructure is in place ahead of development if sewer flooding issues are to be avoided. This therefore increases the importance of Thames Water’s representations regarding a specific water supply and sewerage infrastructure policy. Proposes the addition of the following text to Policy S.5 "The development or

expansion of water supply or waste water facilities will normally be permitted, either where needed to serve existing or proposed development in accordance with the provisions of the Development Plan, or in the interests of long term water supply and waste water management, provided that the need for such facilities outweighs any adverse land use or environmental impact that any such adverse impact is minimised.”


41 Sub Area 4

This section makes reference to the Thames Water Abbey Mills Pumping Station (PS) site. The Abbey Mills PS site is in operational use as it transfers wastewater to Beckton for treatment. Given the scale of wastewater/sewage it deals with, it is of strategic importance to London’s infrastructure. Thames Water welcome the operational status of Abbey Mills PS in paragraph 13.1. Paragraph 13.1 also states that:

“Land around the Thames Water pumping station at Mill Meads is designated as Local Open Space: Policies BN6, BN7 and S5 of the Local Plan are applicable to this land”. Policy BN6 of the Local Plan

relates to Protecting Metropolitan Open Land (MOL). There is no MOL covering the Abbey Mills PS site and therefore reference to Policy BN6 should be deleted.


39 Sustainability

Addressed water efficiency in the Plan as a whole and considers the approach to be sound. Thames Water wholly support the efficient use of water and therefore support the text in this respect in principle. However, managing demand alone will not be sufficient meet increasing demand and Thames Water adopt the Government’s twin-track approach of managing demand for water and, where necessary,

developing new sources, as reflected in their latest draft Water Resource Management Plan. Therefore, it is important that the Local Plan facilitates any necessary new water supply infrastructure.


44 B.1

Site is identifies as B.1b6 Other Industrial Location as a redevelopment opportunity with significant employment and some residential opportunity, providing transition to lower mix of employment uses. Site forms part SA4.3 allocation which is medium density, mixed use area including significant diverse business floorspace and new homes, including family housing. Industrial uses to west of Cooks Road which includes site described as a buffer between residential and A12 traffic noise. Para 4.8 states research and development opportunities at Pudding Mill will complete economic profile of area. Transformation depends on opportunities and promotion of area as east London economic hub while maintaining economic base.

REP.LP.007 Peter Brady, Planning Law Practice on behalf of Gilcris Property LLP

45 B.1

2014 Business Survey referred to in Para 4.9. 2014 ELR identified a small surplus in B2/B8 land. Local Plan concludes that further release may be appropriate provided suitable employment space is re-provided within mixed use development. Para 4.10 however says further loss of B2/B8 will not be supported unless in very particular circumstances.


46 B.1

B.1 protects employment function within each cluster. Bullet 5a of B.1 states should maintain or re-provide B2/B8 uses and maintain or re-provide B1 uses or increase job density within B Classes. This appears to be worded so B2 floorspace could be replaced with B1 floorspace with increased density. However Para 4.15 contradicts this flexibility by stating that where permanent or most recent use is B2/B8 equivalent floorspace should be maintained or reproved with the exception being where the use is in conflict with the immediate surroundings or incompatible with the mixed use proposed within the Local Plan. Bullet 5b says will apply to current B1 uses. This prevents the redevelopment of Vulcan Wharf.


47 B.1Table 2 describes the Cooks Road area which includes the Vulcan Wharf site as providing redevelopment opportunity with significant employment within B1 to B8 uses alongside other uses, with element of residential providing transition to lower employment mix in remainder of Pudding Mill. This regards significant residential as desirable within Cooks Road.


51 B.1

On first reading policy B.1 appears to allow mixed use development of Vulcan Wharf with residential and employment floorspace. However paragraphs 4.15 and 4.16 contradict this flexibility rather than add explanation. Para 4.15 would not allow a scheme which does not replace industrial or warehousing floorspace on a like-for-like basis but nevertheless increases or provides equivalent job density. Paragraph 4.16 makes clear Bullet 5b only applies to land in current B1 use. These paragraphs prevent the redevelopment of site in B2 use for a mixed use schemes which would provide B1 job opportunities.


52 B.1

Policy B1’s aim of seeking to maintain sufficient land for employment uses is laudable but too restrictive. Paragraphs 4.15 and 4.16 severely limit the ability of the Cooks Road area to be redeveloped for mixed

use residential, B1 (office/research and development), retail, leisure or other employment generating scheme so should have flexibility within it. Existing B2 uses provide limited employment and are environmentally incompatible with the regeneration of the surrounding area. Retention of equivalent B2 floorspace does not provide additional job opportunities. This policy prevents the redevelopment of Vulcan Wharf and the replacement of limited B2 employment with significantly greater jobs within a mixed-use development incorporating Class B1 and other employment generating uses. B.1 restricts the redevelopment of the site to scheme maintaining existing levels of B2 floorspace which contradicts the findings of the 2014 Business Survey and Employment Land Review which concluded that a surplus of B2/B8 industrial land exists and that further release may be appropriate. However this is immediately contradicted by the requirement that a suitable quantity of employment space is re-provided within mixed-use developments. This is however, directly contradicted by paragraph 4.10 which seeks to prevent the loss of existing B2 and B8 floorspace other than in particular circumstances. If B.1 is retained in its current form, the Local Plan will not secure the regeneration of the area and environmental and employment improvement. This will prevent redevelopment at Vulcan Wharf for mixed-use residential and employment scheme not necessarily within Classes B2 or B8.


56 B.1

Local Plan should be amended to pass the test of soundness as it would not allow Cooks Road area to be redeveloped in a manner which secures the regeneration of the area while maximising employment and other opportunities. Should reword bullet 5a and 5b of Policy B.1 to read: Proposals on employment land outside the clusters and where new uses are proposed within the OILs shall include appropriate levels of office, research and development, retail or leisure development in order to maintain or where possible enhance existing levels of employment on the site. Should delete "Further loss of B2/B8 industrial floorspace within the Legacy Corporation will not be supported, except in the very particular circumstances set out below. This principle will be applied to the protection of B Use Classes in accordance with Table 2 within designated clusters, and according to a criteria-based approach outside the clusters." within 4.10 and delete paragraph 4.15. Should amend 1st sentence in paragraph 4.16 to "Policy B1 will allow the redevelopment of existing industrial sites by way of mixed use residential and employment schemes."


43 SA4.3

Representations submitted on behalf of Gilcris, freeholders of Vulcan Wharf. They support mixed use development of the Vulcan wharf site and object to wording of B.1 and supporting text. Site is currently used for cooking oil production with office, storage and workshop. Buildings do nothing to character of area or advance regeneration aims. Crossrail is temporarily using adjoining land in connection with station. Across the river, developments of residential and commerical at 34 and 14 storeys are taking place.


48 SA4.3

Site forms part of SA4.3 described on p218 as medium density, mixed use area with significant proportion of family housing. Description refers to 25% non-residential floorspace which suggests major part of allocation should be residential. Allocation refers to predominantly industrial floorspace use mix to the west of Cooks Road and around Crossrail portal without explanation of why Cooks Road area should be reserved for industrial rather than residential, office and research and development or other employment generating employment.


2

49 SA4.3Site allocation should explain why heights are limited to 21m above ground. REP.LP.007 Peter Brady, Planning Law

Practice on behalf of Gilcris Property LLP

50 SA4.3Aspiration to secure the redevelopment of Cooks Road and aspiration for maintaining and providing jobs in the area is supported. REP.LP.007 Peter Brady, Planning Law


53 SA4.3

SA4.3’s restriction of the redevelopment of the area to the west of Cooks Road and around the Crossrail portal to predominantly industrial floorspace is not justified and reference to the maintenance of the

industrial as a buffer to the A12 is not explained. If the remainder of the Site Allocation requires protection from A12 traffic noise this can be secured through design and noise mitigation measures. Impacts of A12 traffic was not a concern when permission (06/90011/FUMODA) was granted on the other side of the river from Vulcan Wharf for 202 flats offices, café/bar, offices and leisure. The report described the scheme as a high density, well-designed, mixed use development in a sustainable location replacing a derelict, unsightly area and contributing to regeneration of the area. The potential impact of noise from external sources was dealt with by condition which secured a sound insulation scheme. The description of the proposal replacing existing unsightly development and contributing significantly to the regeneration of the area could equally be applied to the redevelopment of the Vulcan Wharf site.


54 SA4.3Galliard Homes development is significantly higher than the 21m height restriction within the Local Plan for the Cooks Road area. Height along High Street was not a factor when this permission was granted, There is no justification for this height restriction.


55 SA4.3Providing aim of maintaining and enhancing job opportunities is secured there uis no reason Cooks Road area should not be mixed use but predominantly residential as other parts of allocation. REP.LP.007 Peter Brady, Planning Law


57 SA4.3Should amend SA4.3 to make it sound by deleting "Heights of up to 21m above ground level are appropriate on this site, except for some taller elements in the Local Centre (see Policies B.2 and BN.10)" and "Other Industrial Location allocation maintained along the western to form a buffer to A12 (see Policy B.1)".


59 B.1Policies within the Business chapter promote economic development including through employment clusters and town centres. Proposed clusters in Newham include Bow Goods Yard, Cooks Road, Sugar House Lane, and Rick Roberts Way. Stratford is the largest centre, with a Metropolitan designation, with local centres at East Village and Pudding Mill. They also support the principle of facilities for Higher Education in or adjacent to Stratford Centre.

REP.LP.008 Hannah Clifton, London Borough of Newham

60 B.2

Paragraphs 4 and 5 of B.2 are unclear. Paragraph 4 should be amended as necessary. Paragraph 5 in support of town centre uses in edge of centre locations is inconsistent with the NPPF sequential test. Welcome acknowledgement of problems caused by the over-concentration of hot food takeaways and betting shops but should be strengthened to be consistent with the LBN Local Plan with stricter controls on betting outlets and a tight definition of what comprises a ‘concentration’. Newham currently has 86 betting outlets and this concentration of non-retail uses does little for an area’s vitality or attractiveness and

there is significant crime and anti-social behaviour associated with betting shops. The clusters of betting shops are blighting high streets, particularly in deprived areas, preventing strategic town centres improvements. The Local Plan should not accommodate an over-concentration of such outlets.


61 H.1 Policies in this section identify new neighbourhoods and types of housing within them. The Local Plan does not specify a family housing target despite stating there is a particularly high requirement. The 39% within Newham policies is appropriate.


62 H.4Policy is not strong enough to resist student accommodation to what would be proportionate to London as a whole. Paragraph 2 is concerning as should meet strategic needs which is too open-ended with no figure applied to this. There should be recognition that student need may decline in the future and should be designed to enable conversion to mainstream housing. Should amend to include a justifiable quantity of student accommodation and cover design issues.


63 H.6

The HMO policy is not strong enough to discourage conversion of family housing so is inconsistent with the Newham Local Plan and Policy H.1. Should amend to: "The (LLDC) will specifically seek to protect family housing and will resist the loss of all family dwelling houses through subdivision of or conversions to flats or HMOs unless exceptional circumstances prevail". Continued support for commitment to investigate an Article 4 direction requiring planning permission for small HMOs. Newham's evidence suggests that this is a borough-wide issue so should be initiated within the LBN part of the area. LLDC should commit to doing so.


65Built and Natural Environment

The Local Plan should push for exemplary design as required by the London Plan in the LLDC area. Support for the review of all design standards through a Supplementary Planning Documnet. REP.LP.008 Hannah Clifton, London Borough of Newham

66 Infrastructure Lea River Park/Leaway should be given more prominence. REP.LP.008 Hannah Clifton, London Borough of Newham

72 T.10 Part 1: Newham asks ‘…and potential conflicts between user groups’ is added to the end of first sentence to avoid conflict between traffic streams. REP.LP.008 Hannah Clifton, London Borough of Newham

68 T.4

Policy T4: Sustainable Transport - Newham requests that additional wording should be added to this section and corrections made, as outlined below: Part 4: to be reworded to correct errors as follows: ‘Expect new development to be designed to include measures that will have a manageable minimise its impact on public transport and minimise the impact on the highway network, and to have no or minimum levels of car parking which do not exceed London Plan parking standards.’ Part 6: to be reworded to support car clubs as follows: ‘Require new developments to include locations for car clubs , facilities for electric vehicle charging and stands for cycle hire, as appropriate.’ Part 8: to be reworded to make it stronger: ‘Require new developments to use target-based Travel Plans to encourage smarter travel, incentivised through S106 Agreements.’ Part 9: to be reworded to avoid conflict between traffic streams: ‘Encourage the use of the waterways in the area for transport and leisure and as routes for pedestrians

and cyclists, as appropriate, managing any potential conflict through design’. Table 7: Street Network: Angel Lane is not part of the Strategic Road Network.


67 T.6 Figure 24: Key Connections - There are two connections missing from this map that are currently under discussion: a footpath on the south side of Bow Back River; and a Warton Road link. Newham therefore asks that Figure 24 is amended.


69 T.6Policy T6: Local Connectivity Part 1: Newham notes that correction of an error required as pedestrian and cycle activity cannot be prioritised on major roads such as Stratford High Street. Part 3: Newham believes a reference to Section 278 Agreements is required and the last sentence should be reworded as follows: ‘Section 106 Agreements and Section 278 Agreements will be used…’


70 T.8Policy T8: Parking. Part 1: Newham is unclear as to what this section means and asks that it is clarified or removed. Part 5: A correction should be made to this line: ‘….a sustainable approach to parking car

use .’ Part 6: Newham believes this should specify what standards are to apply to the provision of electric charging points. Part 7: This should specify what standards are to apply to the provision of parking for

Blue Badge holders.


71 T.9Policy T9: Pedestrians and Cyclists. Part 2: Newham believes this should be reworded to make it stronger: ‘…minimising conflict with other modes wherever possible through design and/or management.’ Part 3: This should be reworded to specify what parking standards should apply for cyclists; and second sentence should be reworded for clarification: ‘Public provision should be in a safe and secure and overlooked location, preferably under shelter. Private provision should be secure within the curtilage of the dwelling house.’


73 Sustainability Outline of what is included within the sustainability chapter of the Local Plan. REP.LP.008 Hannah Clifton, London Borough of Newham

74 Sub Area 2 Identfies the approach taken to Leyton Road within Sub Area 2 as being generally consistent with the adopted LB Newham Local Plan Strategic Site S04 and supports this. REP.LP.008 Hannah Clifton, London Borough of Newham

76 SA3.4Wording of allocation agreed at officer level in July. However paragraph 5.5 should be amended to include a caveat to be consistent to SA3.4. REP.LP.008 Hannah Clifton, London

Borough of Newham

3

77 SA3.6

Site is mixed use proposal with option for a new secondary school and/or primary school. Sites close to Stadium Island and Sweetwater are more appropriate. REP.LP.008 Hannah Clifton, London Borough of Newham

58 Sub Area 3 The main issues are: Carpenters Estate; Site allocation at Rick Roberts Way; Omission of site allocation for secondary school close to the Stadium; Houses in Multiple Occupation; Small Houses in Multiple Occupation; Hot Food Takeaways and Betting Shops; Design standards; and Family Housing.


75 Sub Area 3 Area covers the southern part of the Olympic Park, Stratford City, Stratford International and Regional stations and areas on either side of Stratford High Street. Greater Carpenters District and Rick Roberts Way are most significant.


80 Sub Area 3 Figure 34 needs amending to be correct. REP.LP.008 Hannah Clifton, London Borough of Newham

78 Sub Area 4

Sub Area 4: Bromley-by-Bow, Pudding Mill, Sugar House Lane and Mill Meads - This covers the areas described above, all of which are in Newham except for Bromley-by-Bow. Of the areas proposed for redevelopment without extant planning consent, Pudding Mill is the most significant. Newham’s Local Plan designates this site as Strategic Site S09, mixed use with a transition from employment land. The

LLDC proposal is generally consistent with the LBN Local Plan. The LLDC also propose to prepare a Supplementary Planning Document for this area which Newham supports.


79 Sub Area 4

Should include a site allocation to the south of the stadium for a secondary school. REP.LP.008 Hannah Clifton, London Borough of Newham

81 BN.2Need for definition of commercial activity in line with paragraphs 7.24 of the London Plan, which states that use of the waterspace and land alongside should be prioritised for water related purposes, in particular for passenger and freight transport. Welcome details regarding on what ground would moorings be considered suitable and how the LLDC will seek to prevent disruption to the movement of passengers and freight. Consideration has not been given to navigation or river regime.

REP.LP.009 Catherine Whyte, Port of London Authority

83 T.10

Consider policy T10 to be unsound as it is not wholly compliant with the London Plan or further clarification is needed on several points, as detailed below. The policy states that “the Legacy Corporation will

encourage and support the use of the waterways for passenger and freight transport and leisure uses, taking into account any impact on biodiversity and drainage functions”. No reference is made to impact on

navigation and river regime and this part of the policy should be re-written to include this, so that it is in line with policy 7.24 of the London Plan which prioritises uses of the waterspace and land alongside it for water related purposes, particularly passenger and freight. Policy T10 goes on to say that “where appropriate, the Legacy Corporation will require development proposals to provide new or improved access to

the waterways, and improvements to towpaths and footpaths, and facilitate the introduction of moorings and other waterway-related infrastructure where these do not compromise the other functions of those waterways”. It is unclear what is meant by “access to the waterways” and whether this means access into the water or solely to the towpaths and footpaths. There would be environmental and health and

safety implications associated with access directly into the river that would need to be addressed. Clarification should be provided on this point. The policy refers to the introduction of moorings and the PLA would welcome some clarification on the types of moorings that the Legacy Corporation would like to see facilitated.


82 T.4

PLA supports the Plan in principle, however finds policy T4 to be unsound as it is not wholly compliant with the London Plan or further clarification is needed on several points. Part 9 of the policy states that the Legacy Corporation will “encourage the use of the waterways in the area for transport and leisure and as routes for pedestrians and cyclists, as appropriate”. The PLA considers that the wording is unclear and

as such, should be re-worded to read “encourage the use of the waterways in the area for transport and leisure and the towpaths as routes for pedestrians and cyclists, as appropriate” (our proposed

amendment in bold).


85 4.1

Our client has considered the latest draft policy for the Bromley-by-Bow area as set out in the section on Sub Area 4 of the draft plan. Whilst we note that some of the draft wording of this section of the plan has been amended somewhat to provide some additional flexibility regarding the form of development achievable, in our view the effect of such changes are likely to be modest and will not go far enough to provide the level of flexibility required to enable a viable development to come forward. For example, we note that whilst Policy 4.1 (district centre) accepts that partly comprehensive development could be accepted, Site Allocation SA4.1 (relating to the land uses within the whole of Bromley-by-Bow) makes it clear that “…there should be certainty over delivery of the complete comprehensive scheme.” This is an

unambiguous statement which would be difficult for prospective developers to adhere to given the different ownership and operational constraints affecting the area. We can therefore only reiterate once more our client’s view that the various policies within this section should be reworded further to reduce the degree of prescription and that this can be done in ways which don’t allow the piece meal development of

individual sites.

REP.LP.010 Iestyn John, Bell Cornwell LLP on behalf of TRAD

84 SA4.1

Over recent years, our client has submitted numerous representations on draft policy contained within a range of documents concerning the area within which their site is located, including those produced by the London Borough of Tower Hamlets (LBTH), the Mayor of London and most recently (please see our representations dated 3rd February 2014) those by the London Legacy Development Corporation (LLDC). Please note a number of recurring observations. We consider that these are largely still relevant that you note our client’s continuing objections on this basis. Our previous comments can be

summarised as: Our client’s support for the regeneration of the Bromley by Bow area and their willingness for the TRAD site to be included in any such development; Their concerns about the degree of

prescription which the documents sought to establish in respect of the extent and form of development acceptable within the area i.e. that policy required that only a single large scheme covering the whole of the southern part of Bromley-by-Bow would be acceptable. In this regard, our client had particular concerns regarding the reliance being placed on the Tesco site being redeveloped and the complexities associated with development of that land; The need to formally allow greater flexibility regarding the nature of development in order to facilitate rather than dis-incentivise possible development opportunities. Our client’s view is that the various policies within this section should be reworded further to reduce the degree of prescription and that this can be done in ways which don’t allow the piece meal development of

individual sites. Recent changes in land ownership have taken place on land in the southern part of the Bromley-by-Bow area (i.e. that closest to the TRAD land), with the Crowley and Clockhouse sites now owned by Danescroft - developers who are keen to progress regeneration within the area. There is now a greater prospect than ever before that development of a substantial area of land within Bromley-by-Bow, potentially including the TRAD land, could be brought forward in the near future. This would finally allow regeneration of the area to begin. Importantly, a development of this size, though not encompassing the whole area, is very likely to be able to deliver many of the objectives which the Corporation is keen to see met. It is therefore vital that this potential opportunity be exploited to the full and recognised in the draft local plan with its wording amended in the manner suggested above in order that any scheme can be progressed in a timely manner whilst economic conditions remain favourable and whilst the momentum for change, created through the change in land ownerships, remains strong. Relevant parts of the Local Plan should be amended to facilitate this.


86 SA4.1

The Corporation will be aware of the recent changes in land ownership which have taken place on land in the southern part of the Bromley-by-Bow area (i.e. that closest to the TRAD land), with the Crowley and Clockhouse sites now owned by Danescroft - developers who have shown themselves to be keen progress regeneration within the area. There is now a greater prospect than ever before that development of a substantial area of land within Bromley-by-Bow, potentially including the TRAD land, could be brought forward in the near future. This would finally allow regeneration of the area to begin. Importantly, a development of this size, though not encompassing the whole area, is very likely to be able to deliver many of the objectives which the Corporation is keen to see met. It is therefore vital that this potential opportunity be exploited to the full and recognised in the draft local plan with its wording amended in the manner suggested above in order that any scheme can be progressed in a timely manner whilst economic conditions remain favourable and whilst the momentum for change, created through the change in land ownerships, remains strong. Having given full and proper consideration to our client’s

comments, we trust that you will amend the relevant parts of the Local Plan in the manner suggested.


4

89 BN.10

Minor revisions to text within Policy BN.10 suggested. Request minor amendments (outlined in bold italics) to the policy which will to redress this as follows:12. Amenity and natural environment: impacts to the surrounding area (including open spaces, waterways and other buildings) that relate to:• Overlooking

• Daylight

• Overshadowing

• Light spill / reflection

The ‘Cross-reference to policies’ section at the bottom should include BN2 (Creating distinctive waterway environments).

In addition, under the ‘Policy application’ as supportive text suggesst the following to be included:

Tall buildings can have a potential adverse impact on the ecology of the waterways from shading or lighting. Advice should be sought from the Environment Agency as to appropriate setbacks

and lighting designs to ensure any adverse impacts are avoided or minimised.

REP.LP.011 Keira Murphy, Environment Agency

90 BN.11 Support for air quality policies. Support for developement proposas appropriate regard to Borough Policies. REP.LP.011 Keira Murphy, Environment Agency

91 BN.13 Support for BN.13 and supporting paragraph. REP.LP.011 Keira Murphy, Environment Agency

87 BN.2 Support for policy BN2. REP.LP.011 Keira Murphy, Environment Agency

88 BN.2 Support for policy BN2. REP.LP.011 Keira Murphy, Environment Agency

92 SP5 Supports the Strategic Policy and considers that it complies with the NPPF and Policies 5.3 and 5.5 of the London Plan (2011). REP.LP.011 Keira Murphy, Environment Agency

93 S.4Supports the policy and its specific requirements for developments to demonstrate they achieve the highest standards of sustainable design and construction. In particular supports requirements in the policy to demonstrate living roofs and sustainable drainage systems. Makes general comment that would have preferred to see the policy refer to a water efficiency standard of BREEAM Excellent, noting that the South East including London is classified as an area suffering serious water stress.


94 S.5Strongly supports the policy, in particular reduction potable water demand, grey water recycling and rainwater harvesting measures, along with the References in supporting paragraphs to the EU Water Framework Directive (2000/60/EC) and opportunities to improve water quality in the River Lea. See the requirement to achieve a residential water use standard of 105 lppd as justifable by the evidence within this EA catchment.


95 S.6 Supports policy S.6 Waste Reduction’ with its requirement that new developments demonstrate how they adopt the Waste Hierarchy in their design, maximised reuse and recycling with construction materials

and make provision for future residents to maximise reuse and recycling. REP.LP.011 Keira Murphy, Environment

Agency

96 S.8

Strongly supports Policy S8. Requests minor amendment to Paragraph 8.20: "The sequential test and exceptions test has been applied to the site allocations in accordance with paragraph 100 of the NPPF (see Appendix 6 of Sites Report, 2014)." It is also requested that the '‘Flood Risk and Sequential and Exceptions Test for the Site Allocations’ (Appendix 6 of Sites Report, 2014) should be listed on the

Evidence Base References on page 141 as this is an important background, evidence document.


98 SA1.1 Seeks additional text within the 'Development Principle's of the site allocation:" Include flood risk mitigation measures in line with current Strategic Flood Risk Assessment." REP.LP.011 Keira Murphy, Environment Agency




102 SA1.7Seeks additional text within the 'Development Principle's of the site allocation:" Include flood risk mitigation measures in line with current Strategic Flood Risk Assessment." REP.LP.011 Keira Murphy, Environment

Agency


97 Sub Area 1 Seeks additional text within the chapter, i.e. regarding flood risk mitigation measures in line with current Strategic Flood Risk Assessment. REP.LP.011 Keira Murphy, Environment Agency



106 SA2.3Seeks additional text within the 'Development Principle's of the site allocation:" Include flood risk mitigation measures in line with current Strategic Flood Risk Assessment." REP.LP.011 Keira Murphy, Environment

Agency

107 SA3.1

Site in flood zone 2 and 3. Site design principles are unsound without further reference to design criteria. Level 2 SFRA outlines mitigation measures have have not been taken forward into design criteria so inconsistent with paragraph 100 of NPPF and requirements of NPPG to address the level of flood risk at site level instilling design guidance for site allocations. Should add a bullet to development principles "Include flood risk mitigation measures in line with current Strategic Flood Risk Assessment"


108 SA3.2

Note sequential test passed. Site in flood zone 3 but site allocation's design principles not sound without further recognition of flood risk as design criteria and improvements to Lea Navigation. Level 2 SFRA outline flood mitigation measures that have not been taken into design criteria which is not consistent with NPPF Para 100, namely directing away from areas of highest risk where development is necessary and making it safe without increasing flood risk elsewhere. Also where states using opportunities offered by new development to reduce causes and impacts of flooding. National policy diagram shows that where site allocations are put forward in areas of flood risk, following sequential test a Level 2 SFRA should assess the level of flood risk at site level as a result of appropriate policies and design guidance for allocations. Recommend minor amendment under Development Principles on p198 to: Ensure flood risk is reduced through design, layout and appropriate mitigation.


109 SA3.4

Note sequential test passed. Site in flood zone 3 but site allocation's design principles not sound without further recognition of flood risk as design criteria and improvements to Lea Navigation. Level 2 SFRA outline flood mitigation measures that have not been taken into design criteria which is not consistent with NPPF Para 100, namely directing away from areas of highest risk where development is necessary and making it safe without increasing flood risk elsewhere. Also where states using opportunities offered by new development to reduce causes and impacts of flooding. National policy diagram shows that where site allocations are put forward in areas of flood risk, following sequential test a Level 2 SFRA should assess the level of flood risk at site level as a result of appropriate policies and design guidance for allocations. Recommend minor amendment under Development Principles on p200 to: Include flood risk mitigation measures in line with current Strategic Flood Risk Assessment.


110 SA3.5 Site mostly in Zone 1. Support for waterways improvements under design principles as bounded by river so can improve ecology and access. REP.LP.011 Keira Murphy, Environment Agency

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111 SA3.6

Note sequential test passed. Site in flood zone 3 but site allocation's design principles not sound without further recognition of flood risk as design criteria. Level 2 SFRA outline flood mitigation measures that have not been taken into design criteria which is not consistent with NPPF Para 100, namely directing away from areas of highest risk where development is necessary and making it safe without increasing flood risk elsewhere. Also where states using opportunities offered by new development to reduce causes and impacts of flooding. National policy diagram shows that where site allocations are put forward in areas of flood risk, following sequential test a Level 2 SFRA should assess the level of flood risk at site level as a result of appropriate policies and design guidance for allocations. Recommend minor amendment under Development Principles on p202 to: Include flood risk mitigation measures in line with current Strategic Flood Risk Assessment


112 SA4.1

We don’t believe the site allocation design principles are sound (justified and consistent with national policy) without a firmer reference to flood risk as design criteria. The Level 2 Strategic Flood Risk

Assessment outlines flood risk mitigation measures that have not been taken forward into design criteria for the site allocation. In our view this is not consistent with paragraph 100 of the National Planning Policy Framework. To overcome our concerns we therefore recommend 1 minor amendment under ‘Development Principles’ on page 215 as follows: Include flood risk mitigation measures in line with current

Strategic Flood Risk Assessment.


113 SA4.2 Recommend 1 minor amendment under ‘Development Principles’ on page 217 as follows: Include flood risk mitigation measures in line with current Strategic Flood Risk Assessment REP.LP.011 Keira Murphy, Environment Agency

114 SA4.2 Recommend 2 minor amendments under ‘Development Principles’ on page 218 as follows: 1) Include flood risk mitigation measures in line with current Strategic Flood Risk Assessment 2) Improve the

waterside environment of the River Lea, Waterworks River and Bow Back River. REP.LP.011 Keira Murphy, Environment

Agency

118 B.1B.1 directs SMEs to Cooks Road OIL. REP.LP.012 Caroline Harper, Jones

Lang LaSalle on behalf of Badat/Thornton

124 B.6B.6 encourages higher education, research and development, naming Pudding Mill as a potential location. Text acknowledges this would be within the area's employment offer. Education uses have not featured in discussions with LLDC. While not objecting in principle but policy should be flexible to allow such provision to come forward offset against higher value uses and development parameters such as height and density to remain viable and deliverable.

REP.LP.012 Caroline Harper, Jones Lang LaSalle on behalf of Badat/Thornton

120 SP2

Regeneration policies in east London emphasise housing. The draft FALP and draft Housing Strategy (April 2014) prioritise housing delivery. The London Plan makes clear that housing targets are average minimum housing supply targets to be exceeded where possible (LP Policy 3.3) and the FALP calls on local authorities to augment these targets with additional housing capacity to reduce the gap between local and housing need and supply. We do not therefore consider it appropriate to limit the potential remaining capacity of Sub Area 4 to 1,206 units (Appendix 2), or to limit scale and massing to medium density within Pudding Mill (SA4.3). SA4.3 seeks to limit the quantum of development through height restrictions. The Framework goes one step further and specifies density guidelines, in addition to a 6 storey readable datum, albeit that this could vary by 1 – 2 storeys. The overall approach should not be constrained. The Local Plan should encourage high quality development allowing design to maximise site and

housing potential (in accordance with LP Policies 3.4 and 7.6). Policies should be flexible to change and growth opportunities (Para 17 of the NPPF). Question the timetable for housing delivery within Appendix 2 for remaining housing capacity within Sub Area 4. Discrepancy between delivery within this table and the site allocation where the 2015 date is more appropriate.


125 SP2Support aspiration to ensure developments maximise opportunities for high-quality, accessible and sustainable homes within SP.2. Support for intention to exceed housing target. REP.LP.012 Caroline Harper, Jones


126 H.1Support for the flexible approach to housing mix within H.1 with proposals meeting local and strategic requirements subject to site circumstances. Should be reflected in approach to housing mix at Pudding Mill. REP.LP.012 Caroline Harper, Jones


127 H.2Support approach to affordable housing within H.2 seeking to maximise provision subject to criteria and viability. Welcome opportunity for off-site or financial contributions in exceptional circumstances. REP.LP.012 Caroline Harper, Jones


122 Infrastructure Clarity it sought as to how the site wide infrastructure enhancements will be funded. There should be scope to offset delivery of infrastrucure to the benefit of the wider Pudding Mill area against other requirements, such as affordable housing, to ensure that devleopment remains viable and therefore deliverable.


115 SA4.3

Representing landowners, Badat Bros Ltd (Badat ) and Paul Thornton (Thornton ), who own sites fronting Cook’s Road and Barbers Road in Stratford. The LLDC will be aware that Badat and Thornton are

working together to bring forward their sites (hereafter referred to as Badat / Thornton ) for residential-led redevelopment. The sites form part of London Borough of Newham’s Strategic Site S09 (‘Pudding Mill

Lane’) and are now also part of the LLDC’s proposed Pudding Mill Site Allocation in its emerging Local Plan. Newham de-designated the site and wider area from its previous Strategic Industrial Location (SIL)

in order to realise its regeneration potential, and to reflect changes in the surrounding area. The draft Local Plan similarly seeks to regenerate the area, to deliver a mix of uses including residential and employment. To this end there have been several meetings with the LLDC, mostly recently on 16 June 2014, to discuss proposals for the combined site and also how these can be accommodated within the Land Use and Design Framework (Framework ) produced by Rick Mather Architects to guide development within Pudding Mill. We address the Framework in our responses to the draft Local Plan below.


116 SA4.3Site Allocation SA4.3: Pudding Mill . 5. As the LLDC will be aware, Badat / Thornton welcomes planning policy which supports and encourages the regeneration of Pudding Mill. We agree that there is considerable developer activity and interest in the area, reflecting its proximity to the City, Canary Wharf, Stratford and Queen Elizabeth Olympic Park. This interest should be capitalised on.


117 SA4.3

6. Concerned as to the justification for the quantum of non-residential floorspace sought within Site Allocation SA4.3 – Pudding Mill. The figures sought across Pudding Mill (25% - draft Local Plan Site

Allocation SA4.3) and on the Badat / Thornton site (25% - Framework) are not supported by the findings set out in the LLDC Area Land Review Final Report (URS for the LLDC, May 2014). 7. This Review highlights the following: a. All of the Review’s growth targets are to varying degrees optimistic. b. Pudding Mill is not a location considered appropriate for capturing the central London office market. Appropriate

sites are instead identified as Stratford City, Here East, central and south Stratford and Queen Elizabeth Park South. c. Demand for industrial floorspace will continue to fall. While this will be offset by increases in local demand for office space, this growth will be modest, even under a high growth scenario. d. Growth scenarios suggest it would be appropriate for provision of between 17,100 sq m and 59,500 sq m of office / workshop type employment space, either in mixed use areas and / or as part of mixed use developments. It caveats that this scale of demand is a step change from historic trends and should be monitored carefully. e. 21,888 sq m of office floorspace is already anticipated within Pudding Mill as a result of pipeline developments in the LLDC area that currently hold planning permission. f. The local office market should be located as close as possible to the centre of activity.


119 SA4.3

9. Given the evidence and the direction of other proposed policies, we query the appropriateness of specifying a blanket target of 25% for non-residential uses, both within Pudding Mill and on the Badat / Thornton site. Such an approach does not account for the optimism of the Review’s growth targets, the extent of the range of office / workshop type employment space provision recommended in the Review,

provision elsewhere within the area covered by the LLDC, or market fluctuations. We would suggest that a more flexible approach to the quantum of non-residential use would be appropriate. 10. While Badat / Thornton understands that the intention to create a successful new neighbourhood at Pudding Mill, Local Plans are required to be based on adequate, up-to-date and relevant evidence taking full account of relevant market and economic signals (para 158 NPPF, 2012). The London Plan similarly states that employment use requirements should be justified according to evidence of demand (LP Policies 4.2, 4.4). We find the LLDC’s preference for standalone commercial buildings within Pudding Mill (page 42 of the Framework) an inadequate approach to dealing with vacant employment floorspace; the effect will simply

be vacant buildings rather than the vacant ground floor units which the LLDC is seeking to avoid. Moreover this suggests some reticence at the LLDC that there is the demand for the proposed quantum of employment floorspace in this location. This adds further weight to our argument that the Local Plan should be flexible as to the quantum of employment floorspace it seeks, having regard to demand, supply and need. We would also suggest that there are more appropriate locations for a concentration of employment uses in Pudding Mill, closer to the new local centre.


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121 SA4.3Re-alignment of Barbers Road . 16. We do not agree that it is appropriate to re-align Barbers Road. As discussed with the LLDC, so doing puts added risk on deliverability by having to rely on third party land ownerships or the relocation of adopted roads. Retaining the existing alignment avoids this, and could still accommodate a new cycle and pedestrian bridge and incorporate appropriate screening for the Crossrail substation.


123 SA4.3See map for land ownership. REP.LP.012 Caroline Harper, Jones


131 SP1

Consultation report states SP.1 amended to reflect Economy Study and role of businesses. Policy does not reflect this change. REP.LP.013 Alan Gunne-Jones, Planning & Development Associates Ltd on behalf of Gowlain Building Group Ltd

130 B.1

Comments within the consultation report to B.1 state will provide clarity on protection of employment in line with Economy Study. This study recommended protecting remaining industrial land within area. Changes to B.1 are insufficient to address concerns and ensure protection of employment. Same response in Report to comments on Para 5.4 in previous Plan.

REP.LP.013 Alan Gunne-Jones, Planning & Development Associates Ltd on behalf of Gowlain Building Group Ltd

128 SP1Plan is not sound as not positively prepared, not justified and not consistent with national policy. At previous stage support for Objective 1, Objective 2 and Strategic Policy SP.1 but objections to Paragraphs 5.4 and 5.11; Draft Policy BEE.4; SA2.6 Sub-Proposals and 13.23 Site Allocations. This highlighted a contradiction between encouraging employment and permitting proposals which displaced long established employment uses.


133 2.4

The response provided in the Consultation Report (August 2014) to the comments made during previous consultation are not considered to adequately respond to the fundamental concern raised that there is no adequate provision for existing employment uses to be retained and sustained and no explanation of what other alternatives have been considered.


129 SA2.1

Considers that the response the previous consukltation response within the Regulation 19 consultation report does not adequtely deal with the issues previouly raised by 'hiding behind' the approach in the extant planning permission for the wider area within which the site is included. Considers that no adequate provision is made for existing employment uses to be retained and sustained and no explanation of what alternatives have been considered and so consideres the Plan to be unsound.


132 Sub Area 2 See 129 above REP.LP.013 Alan Gunne-Jones,

Planning & Development Associates Ltd on behalf of

134 Sub Area 2 See 129 above REP.LP.013 Alan Gunne-Jones,

Planning & Development Associates Ltd on behalf of

135 Sub Area 1 Objecting to the proposed bridges across Old Ford Locks (at the southern end of the Hackney Cut) and across the Bottom Lock on the Hertford Union Canal. REP.LP.014 Vivian Bellamy

136 Vision

Considers the Vision to be unsound as it does not give expression to the key priorities of the London 2012 Games Legacy and does not make clear how the needs of the existing population in 2015 will be met. Considers that for the vision to be sound it must include-• Mention of the Olympic Host Boroughs and the closing of the deprivation gap for East London, how the benefits of the Olympic Legacy will reach all

residents in these Boroughs and the Boroughs key role in the delivery of the Local Plan • The high importance of creating job opportunities for local people and ensuring the diversity of the economic offer

• The successful integration of existing communities, like the Carpenters estate and at Bromley by Bow, through measures such as lifetime neighbourhoods.

• Commitments to positively improve the social and environmental conditions in the area

REP.LP.015 Manoranjitham Saravanamuthu

137 SP1

Several businesses included within the Economy Study 2014 were not contacted to be informed of publication Local Plan so consultation insufficient. SP1 not sound as does not build local supply chains to connect development of existing businesses. This would mean new investment will not remain in the area. Few businesses have reported benefits from the 2012 Games through procurement processes, more regularly reporting disruption and loss of business. Brief mention in Para 4.4 of social enterprise but not within SP1 itself. There is insufficient focus on existing economic assets- should summarise Economy Study, mention of valued centres providing skills and training for local people such as Building Crafts College and wording on how convergence will be achieved included. SP1 should set measurable targets to achieve convergence and economic development.


138 B.1

Should have more discussion of conclusions of Economy Study. Recent industrial land releases have been three times higher than London Plan targets. Due to residential land values there is pressure to convert employment sites. Development should not stifle the thriving and resilient local economy documented in the Economy Study. The option of significantly increasing job densities within B2/B8 use B.1 5 (b) will increase pressure to redevelop existing employment spaces, reducing likelihood of re-provision of industrial typologies and that existing businesses can be accommodated in new developments. Cultural, artistic, manufacturing and making, and food businesses celebrated in Economy Study require space to work and cannot be accommodated within higher-density office spaces. Should define Locally Significant Industrial Sites and Other Industrial Locations. Policy should highlight the importance of local employment which has failed to consider this in terms of NPPF requirements of economic, social and environmental sustainable development. To ensure B.1 is sound: a. Should recognise the employment cluster in the Greater Carpenters District in Table 2. Existing workspace should remain in employment use to provide local employment including in light industrial uses. Current business occupiers are growing, providing local jobs and training and are valued by local residents. Need these forms of employment as well as retail jobs at Stratford Metropolitan Town Centre to achieve convergence. b. Should strengthen Industrial land designations in Table 2 and supporting text should reflect this. c. Delete ‘or significantly

increase job densities within B use classes’ from Policy B.1 5(b) to ensure effectiveness d. Add definitions for Locally Significant Industrial Sites and Other Industrial Locations to be effective. e. B.1 and

supporting text should strength retention of local employment sites in terms of delivering lifetime neighbourhoods and reducing the need to travel. Should make a link between homes and jobs in order to convergence and sustainable development.


139 B.2

Policy B2 is not sound and should set out need for town centre uses. Little investment from new town centre developments, such as Westfield, re-circulates in the local area and office workers could leave without spending in the local economy. Growth of Stratford Metropolitan Town Centre could be at the expense of other town centres. It is not clear that the duty to cooperate has been fulfilled on this matter, nor London Plan and NPPF requirements for positive planning to support town centres. Adverse impacts of the Town Centre extension on the existing Stratford Shopping Centre, which provides affordable goods and services, spaces for young people to socialise and skateboard had not been addressed. Table 3 does not show how key existing assets in Hackney Wick will be integrated with new development, and there has been a lack of engagement with community and business groups in Hackney Wick and Fish Island in plans neither for new neighbourhood Centre nor at new district town centre at Bromley by Bow. To be sound should amend to encourage town centre uses that contribute to the local economy through local multiplier effects and local supply chains. Should address the LLDC’s duty to co-operate in terms of

adverse impacts on other town centres and expand description of Stratford Town Centre Extension in Table 3 to acknowledge and retain existing Stratford Shopping Centre. Table 3 for Hackney Wick Neighbourhood Centre should list key existing assets and how to be integrated.


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140 B.3

B3 is not sound as does not address how interim uses will connect with and meet needs of local residents, business and community groups. Hackney Wick Fish Island experience suggests interim uses can be disconnected from non-temporary residents, businesses and community groups. Skatepark attracts from outside local area, so concern that serves as a marketing and promotional device for development. B.3 fails to highlight importance of cultural and creative industries. Such industries are linked to the local economy through the supply chain and can develop to viable industries. Should amend to make sound by requiring community engagement in design and implementation of proposals and add wording on value of cultural and creative industries to local economy in the long term.


141 B.4

Should amend policy to remove viability considerations as far more affordable workspace is lost in Hackney than is delivered through S106. What is delivered is not comparable in terms of affordability of other characteristics. Also necessary in terms of aims of supporting a diverse economy. Up to 75% of market rents is too high, and should clarify that low cost provision should maintained for the long term. Low rents attract talent who are then forced out by higher rents a short time later as happening within Hackney Wick and Fish Island. Committing to providing long term, low cost accommodation would retain talent in the area. Should add bullet stating low cost provision supported where provides space for existing industries to grow, such as reported within the Carpenters District. Should amend wording to remove 'where viable and where it complements plans for the wider area. The 75% figure should be lowered and should expand to clarify low-cost provision should remain low cost for the long term with long-term tenancies. Should add further bullet to clarify that provision of new low-cost should be supported where allows businesses to grow. Should acknowledge role in creating lifetime neighbourhoods.


142 B.5

Policy unsound as no target to monitor effectiveness. Without targets in a weaker position to secure jobs and training for local people, so should set targets to demonstrate direct benefit to disadvantaged residents. Should define term local residents, it is also reported that few residents from existing communities were able to access jobs and apprenticeships within the Games. Policy does not set out how achieved in practice, not in conformity with 2.4 of the London Plan which is clear that will promote local economic investment driven by community engagement and how this will be achieved. Experience at Bromley by Bow Centre and community links shows importance of detail. No mention of lifelong learning despite being aim of section. To be sound should set construction and end-user job targets for participation in skills and employment training, define local residents, must promote local economic investment by community engagement and how to be achieved including links with schools. Should add new paragraph setting out aims in relation to lifelong leaning through jobs and training. Should discuss evidence base explaining rational for LLDC policies.


143 B.6

Policy does not offer clarity that local people will benefit from new higher education, research and development institutions. Text should require proposals to set out clear pathways to how local people can access, including bursaries. Experience from New York suggests local communities are often displaced rather than benefit. Should do things differently requiring potential institutions to work in collaboration with communities to define needs and aspirations. Should make strategic links between institutions and schools and families. No mention of lifelong learning despite being aim of section, so should add paragraph to state how aim can be secured through development proposals in relation to higher education, research and development. Should be amended to require proposals to set clear pathways for local access to education, training and other opportunities including bursaries, make strategic links with B.6 connecting higher education, research and development to schools and families. Should add new paragraph to set out aims for lifelong learning secured in relation to higher education, research and development. Should discuss evidence base and explain policy rationale.


147 BN.10 All new and developing centres are specified as appropriate for tall buildings. This assumes that tall buildings are an essential part of regeneration. Locations need to be specific and justified. REP.LP.015 Manoranjitham Saravanamuthu

148 BN.11

Regarded as unsound as not enough being done in the plan to address air quality and EU limits or to reduce and control noise. Greater clarity on issues needed and development proposals should be at least air quality neutral. To make the policy sound the following changes are required: • Development proposals should be at least air quality neutral and not lead to further deterioration of existing poor air quality. •

There needs to be clarity about the noise problems the policy is trying to reduce. For example, aircraft noise from City Airport and noise from the night time economy are unwanted noise with severe impacts.


145 BN.2

The policy is considered unsound beacuse uses are not clearly defined and the uses are not controlled to prevent disruption to other uses. The policy is not good enough to protect public assess to all parts of the waterways and there is no mention of safeguarded wharves and freight transport. Four changes are suggested to make the policy sound. To make the policy sound the following changes are required: • So

as to give a clear direction to development proposals affecting the waterways the wording must be “required to” rather than the weaker “expecting”. • Positive support for public access; “prevent disruption” and

“improve access as appropriate” are not sufficient. • There should be a target for freight transport by the waterways in connection with major developments. • There should be reference to maintaining and

enhancing the biodiversity of the waterways; “improving ecological potential “ is not sufficient.


146 BN.6

The policy is unsound because Local Open Space is not well defined and needs clarification. It would be more helpful if urban greening and food growing were in the same section of the plan. Community empowerment should be included within the Plan. Improvement to Figure 15 needed and although the dots are colour coded green, there is no information about whether these will be green or hard surfaces. Local distinclivess, charcater and the linking of open spaces are left out. Changes to text suggested can be summarised as needing to make greater requirements for open space and all new developments should provide green open space; the Plan should have quantitative targets and qualitative standards; green space should be embedded throughout the area and small sites utilised for food growing and all new development should provide green open space, including habitat for wildlife with native vegetation, to provide for a more sustainable area.


149 SP4SP4 is not sound. Does not specify its duty to cooperate with surrounding boroughs in addressing waste issues;which is more than requiring retention of existing waste management facilities. SP4 should highlight duty to cooperate and require innovative waste self-sufficiency measures in all new developments and refurbishment schemes.


152 SP4

Transport and connectivity . Paragraphs 7.10 and 7.11 are not sound. There is a disconnect in the ‘transport and connectivity’ section between the aims of delivering sustainable, possibly ‘walkable’ and

lifetime local neighbourhoods and the delivery of national and international connections. There is a lack of clarity about the relationship between them (particularly with a total of 10 transport policies). There are also possible tensions between them particularly in term of the aims of convergence – (specifically addressing deprivation in a meaningful way).

To ensure paragraphs 7.10 and 7.11 are sound, the LLDC should provide greater clarity. If there is an aim to prioritise walking and cycling in order to deliver ‘walkable’, lifetime neighbourhoods and thus to

reduce the need for other type of transport connections, this should be set out clearly in the introduction and in the policies. If this is the key aim then there should also be a reduction in focus on wider transport connectivity including national and international.


150 IN.1

Considers that Policy IN.1 is unsound as it does not address all environmental and publicly perceived health issues. Considers that to be sound Policy IN.1 should also require that new telecommunications equipment is where possible shared (to avoid clustering and over proliferation), is not located on residential buildings, where possible, and that monitoring be carried out to ensure that any detrimental health impacts are identified.


151 IN.2Policy IN.2: Planning for waste. Policy IN.2 is not sound. In planning terms the LLDC has a responsibility to address how it will deal with waste within its boundaries and should specifically set out how it will co-operate with the surrounding boroughs on waste. There is clearly a link between policy IN.2 and policies in Section 8. There are possibilities of delivering innovative waste self-sufficiency measures that could / should be referred in this policy.


8

156 T.10

Policy T10 is not sound. It does not say how it using the waterways for passenger and freight transport and leisure uses will be encourage and supported by the LLDC. Sections of the waterways that have been closed off by barriers since 2010 and there is no clarity on whether roaming rights will be restored to the sections of the River Lee that are currently closed off. To be sound, policy T10 should say that the LLDC more clearly how it will deliver the policy. It could for example:• carry out analyses with surrounding boroughs, local businesses and canal user groups on what kind of freight and leisure transport might be possible or viable

• work to achieve a timetable for section of the waterways that have been closed off to be opened

• co-ordinate experimental uses of the waterways and

• promote the use of existing tour bus stops for more regular transport usage.


153 T.4

Policy T4 is not sound. While the focus on pedestrian and cycle routes are important, for older and disabled people and those with young children having access to public transport is of equal priority. There are ongoing difficulties for many because bus routes have not been created or re-instated (post-Olympic Park developments) and resulting in those who have difficulties having to cross extremely busy and / or dangerous roads. To ensure that T4 is sound, there is a need to increase priority for local public transport accessibility across the area and acknowledge particular transport accessibility problems / difficulties for older and disabled people and those with young children.


154 T.5

Policy T5: Street network. Policy T5 is not sound. It does not provide a clear relationship to health and safety issues. To ensure that policy T5 is sound, the street network should provide another level of reading to identify not just immediate issues of connection but also of health and safety. This should include where there are dangerous road crossings and areas high in particular matter and nitrogen dioxide –

which would be important to address in developments.


155 T.6

Policy T6: Facilitating local connectivity. Policy T6 is not sound – it does not address with equality the transport needs of older and / or disabled people and those with young children. To be sound policy T6

should give equal priority (along with pedestrians and cyclists) to locally connecting public transport – specifically for older and / or disabled people and those with young children. 2. Policy T6 is not sound – it

fails to set out measurable targets for achievement. To be sound policy T6 should reference a clear (and publicly accessible) timetable for improved connectivity across the LLDC area.


157 SP5

Considers that the policy fails to set out the relationship between places to live and work in and that the creation of lifetime neighbourhoods and supporting local economy policies could support redressing a balance – particularly for low income households; does not set out how the LLDC will achieve convergence; is focused on new development and does not fully consider policy relating to existing homes and

infrastructure. To ensure SP.5 is sound, add ‘Ensuring that development supports the creation of lifetime neighbourhoods, a strong local economy and local jobs to - reduce the need to travel, transport costs

and levels of air pollution’; identify that it will monitor a targeted number of existing residents of different ages over a time frame consistent with the lifetime of the LLDC covering a wide range of health and well-

being issues to assess the impact of the Legacy on their life changes and that of their families; included reference to "including refurbishment" to be clear that the the area is not just seen as a clean sheet and that the policy refers to existing and new neighbourhoods.


158 S.2

Considers the policy to be unsound as it does not mention the need to reduce embodied carbon emissions. The Policy should refer to embodied carbon emissions and require measurement of this in new development (including the demolition of existing buildings) and set a target for reducing these. Considers the Policy unsound as it does not address the variance between estimated and actual energy performance in new development. The policy should require an analysis of actual emissions one and three yeas post construction as well as an estimate of unrelgulated emissions. Does not consider paragraph 8.7 to be sound. It should must clarify what the London Plan policy 5.2 means within the LLDC context. For example, (1) Be lean: use less energy. Clarity is needed on less energy than what? How will this be measured? (2) Be clean: supply energy efficiently. Clarity is needed on what this might be compared to. Also it needs to say how ‘maximisation of energy efficiency’ might be quantified and

measured?


159 S.3

Policy S.3 is not sound as it does not refer to London Plan policy 7.14 which requires that air quality assessments are carried out in any new proposals or extensions of existing heat networks that include biomass boilers. Policy S.3 is not sound as it does not appear to give equal focus on existing homes in terms of connection with existing combined heat and power energy networks.


160 S.4

Policy S.4 (2) is not sound – it is not measurable. To be sound S.4 (2) should specify a comparable and measurable reduction in CO2 emissions – specifying reductions in embodied as well as operational

emissions. 2. Policy S4 is not sound as it fails to promote retrofitting as required by London Plan policy 5.4. To be sound policy S4 should promote refurbishment and retrofitting. To emphasise the importance of this in terms of environmental and social sustainability, policy S.4 should require that: “in instances where new housing developments are proposed to replace existing homes, an assessment of

environmental performance (including of operational and embodied carbon in demolition and new build), and social and costs and benefits should be provided compared to alternative refurbishment options." To support social sustainability the policy should also state that where any development proposals include demolition of social-rented homes, full support of residents will be required prior to commencement of plans. To be sound, Policy S.4 should mention that development should ensure no further deterioration in existing poor air quality through achieving air quality neutral as required by London Plan policy 7.14


144 Sub Area 4

These policies and site allocations do not consider the impact on exsiting retail centres outside the LLDC area. E.g. On existing Bromley by Bow High Street. They do not provide connectivity with the existing communities and businesses. It is unclear how linkages will be delivered. To make the policies and allocations sound, the following changes are needed: • Building heights should be sensitively designed along

the canal/ river areas. • The site allocations should recognise the need for traffic calming along the Blackwall Tunnel Approach Road; a key issue for improving connections • New development should integrate

with the local community by providing workspace for different uses.


161 Delivery and Implementation

Section 14 Delivery and Implementation. This section is unsound because:- • No targets are identified in most of the monitoring criteria. • Open Space/ Biodiversity improvements aren’t measured. The target

is to maintain what it is like at the moment. • There is no monitoring of impacts outside of the LLDC area e.g. on the existing Bromley by Bow neighbourhood


162 H.5

Support for the allocation of Bartrip Street South as there are not enough sites within Hackney. Hackney have written in past stating looking for land but not found any. H5 does not identify enough sites to meet needs so is unsound and this does not even include needs from the other boroughs. Should reconsider the White Post Lane and Chapman Road sites in terms of flooding and relocation of storage.

REP.LP.016 Jennifer Maughan

163 H.5

Local Plan is not in accordance with the SCI which states special arrangements to ensure that hard to reach groups including Gypsies and Travellers are involved. We are not aware of any efforts made by the LLDC to approach members of the Gypsy and Traveller community. Response to the SCI in 2012 suggested tapping into the resources and local knowledge of the Gypsy and Traveller communities in the 4 Boroughs and actively engage with them through meetings and site visits as well as the criteria for assessing sites discussed with the community, together with any potential site options. Despite requests for meetings a meeting was held in July 2014, after these studies completed with no opportunity to influence methodology or practice.

REP.LP.017 Ilinca Diaconescu, LGTU

164 H.5

Have not met the duty to cooperate in producing evidence for H.5. Appreciate work taken place with Hackney to assess needs of those living within the Hackney managed site but have not effectively engaged with the other boroughs, particularly Newham. Need to understand the needs of those living within the Parkway Crescent site which borders the LLDC area following relocation from Clays Lane within the Park. These residents lived on the Clays Lane site for 40 years and were promised to be moved back within the Park following the Games, this was dropped once LLDC failed to identify a suitable site. It is unsound not to include needs within the assessment given they are a longstanding part of the community. Tower Hamlets and Waltham Forest have unmet needs and this Local Plan was an opportunity to seeks to meet these. Paragraph 5.25 of the Plan states the whole of the identified needs would not be met through the allocation and that the LLDC will work with neighbouring boroughs to meet them. Request a detailed plan of the work carried out. Given lack of engagement within the GTAA unsure how Duty can be met without this Plan.


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165 H.5

Plan is not positively prepared to meet needs of gypsies and travellers and unmet needs of neighbouring authorities, in particular at Parkway Crescent. The 2014 GTAA includes a scenario which looks at need from this site in case commitment to relocate to within area kept. Should reflect this in final form of H.5 to acknowledge full extent of needs. Unsound in only meeting needs of gypsies and travellers in Hackney.


166 H.5

Plan not justified and effective in approach Gypsy and Traveller needs. The GTAA which informed the pitch target is unsound as very little engagement took place within it. So does not meet the Duty to Cooperate and Planning Policy for Traveller Sites paragraph 6. Community interview work only carried out in Hackney, with telephone interviews for the other boroughs. These responses showed little knowledge and confused sites between Parkway Crescent and previous unauthorised encampments. During the study requested were made to meet the consultants and LLDC with no response received. Concerned that cannot meet the identified need for 19 new pitches but fully support allocation SA 1.9 of Bartrip Street South but other sites listed in the appraisal could also be allocated so should be reviewed again. These sites are: 31-41 White Post Lane and 90 White Post Lane which should not have been discounted on flood zone 3 grounds; Land at Bartrip Street/Wick Road (Bartrip Street North) should review the employment allocation; Chapman Road Depot Site should be explored through relocation of employment uses elsewhere. In relation to the policy the criteria would make it very difficult for new sites to be considered deliverable, in particular criterion number 4 which sets a wide range of constraints to new sites becoming available so should be replaced with ‘Policy constraints will seek to be mitigated in order to

increase provision for Gypsy and Traveller sites’. Consideration of viability of sites would make it almost impossible to come forward as Gypsy and Traveller sites are not seen by landowners or developers to be

viable and competitive forms of housing provision. Proximity to other Traveller sites is important, but in the context of the LLDC will limit potential sites to the Hackney Wick area alone.


167 H.5

Plan is not consistent with national policy i.e. paragraphs 6 and 9 of Planning Policy for Traveller Sites. Plan and evidence have not been produced with sufficient ‘early and effective community engagement’

and does not identify suitable locations for sites to meet the needs for years 6-10 and 11-15 of the plan period. Does not demonstrate sufficient collaborative work with to meet identified need, in particular that arising within the Parkway Crescent site. Should review additional sites and potential locations with neighbouring boroughs. A detailed work plan setting out the strategy for joint working should be provided in order to satisfy the Duty to Cooperate and requirements of the PPTS.


168 H.5

Monitoring form uses old census categories, which should be updated to include gypsy and traveller. Has not been asked opinions on consultation even though state make special efforts to engage hard to reach communities. H5 is unsound as does not meet identified needs and evidence is incorrect. Unfair that area made up of four boroughs but needs of only one taken into account, especially since land been taken from boroughs so cannot meet their needs within the area. Tower Hamlets know their needs but haven’t provided any in 30 years. Haven't asked what needs are but there is also evidence from the 2008

assessment. Duty to cooperate not met and there are pitch needs for each borough. To be sound should engage with Tower Hamlets and the traveller community and look for new sites. LLDC meets normal housing needs of the four boroughs which should be the case for gypsy and travellers.

REP.LP.018 Marian Mahoney

169 H.5

Plan should be in accordance with SCI which states will make special arrangements to ensure hard to reach groups are involve which has not occurred. Have not engaged with residents of the Parkway Crescent site which is subject to a commitment for relocation to within the Park following the Games. The GTAA only interviewed site residents within the planning area despite this promise. Telephone interviews with Newham council officers gave incorrect information.

REP.LP.019 Tracie Giles

170 H.5

The Plan is not positively prepared so should meet all of the needs identified in the GTANA, including those from other boroughs than Hackney. Support for Bartrip Street South allocation more sites are required. Evidence base is not robust as travellers were not aware study was taking place with only a Newham officer being interviewed. Information provided was inaccurate confusing Parkway Crescent site with previous unauthorised encampment, incorrect pitch numbers, stating sufficient supply. The 2008 GTAA identified need for 19 new pitches in Newham by 2017 and this has not been met and the waiting list isn’t properly managed. Statement that was unauthorised camp adjacent to the Parkway site is not true and is confused with Hackney site. Study did not establish information on gypsies and travellers in bricks

and mortar and assumptions based on Census are ambiguous. The study does not display understanding of history of site and Games move, officer from Newham stating happy with current site which isn’t

true, labelling under in-migration is also offensive as residents of area for 40 years. Parkway Crescent site is unsatisfactory built in a hurry. Residents living under stress with hope for a good site. Policy not effective as allocation doesn’t meet the identified need so should engage with other authorities and gypsy and traveller community to identify more sites within the Plan itself not in the future as no certainty that

this will happen. Gypsy and traveller accommodation should be given equal priority to other forms of housing.

REP.LP.019 Tracie Giles

178 Sub Area 1

Revocation of the Hazardous Substances Consent for the land at Eastway, Hackney should be considered. REP.LP.020 John Moran, Health and Safety Executive


Consultation with HSE can be an effective way of allievating problems due to incompatible developmetn at later stages fo the planning process. HSE have provided specific commetns on site allocations and policy areas which may be affected by the consultation zones of major hazard installation and major accident hazard pipelines. Refer to other specifc comments.

REP.LP.020 John Moran, Health and Safety Executive

172 General Sections

The response provides details regarding consultation zones associated with major hazardous installations within the LLDC area; compatibility issues raised by developing housing within the inner, middle and outer zones; refers to PADHI+ to determine HSE’s advice regarding mixed-use developments.



The response provides a summary of the compatibility issues raised by developing housing within the inner, middle and outer zones; a summary of the compatibility issues raised by developing workplaces within the inner, middle and outer consultation zones; Where there are major hazard installations and MAHPs within the area,considers that the LLDC should mark the associated consultation zones on a map. HSE reccomends contacting the pipeline operator for up-to-date information on pipeline location development within any consultation zone in the area. HSE recommends that LLDC include in your plan an analysis of compatible development type within the consultation zones of major hazard installations and MAHPs based on the general advice contained in the PADHI guidance


179 SP2

HBF is principal representative body of the house-building industry and comments reflect views of members. Welcome plan commencing in 2015 to align with FALP but extends to 2031 which could cause confusion over housing delivery expectations. Should clarify what is to be provided, e.g. 1,471 dpa or 14,710 over the next ten years. This may change post 2025. The 14710 is the minimum, complicated by London Plan requirement that housing target is ‘augmented’ with extra housing capacity to close gap between need and supply. The soundness of the London Plan depends on LPAs carrying out their own

SHMAs to identify their needs and additional supply to provide 7000 additional homes per year to meet the London 49000 objectively assessed need. The Local Plan is silent on this.

REP.LP.021 James Stevens, HBF

180 SP2

Plan fails the duty to cooperate. The London Plan is not a development plan document so the London Plan requires the 34 planning authorities to individually discharge the duty to cooperate as demonstrated by new paragraph inserted into the FALP. Need to demonstrate that plans have been prepared in a sufficiently positive way, taking account of cross boundary matters including assisting with meeting the unmet needs of neighbours which the Plan is silent on. Until LLDC conducted its own SHMA and conducted a discussion with its neighbours and/or the other authorities of its housing market area, then cannot conclude that the 1,471 dpa represent the objective needs. LLDC will need to consider its migration and commuting flows and other links with the wider south east authorities to ensure that any methodological assumptions regarding housing are supported, or are consistent, with those other London Boroughs and authorities of the south east.


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181 SP2

The What Homes Where shows net in and out flows from Tower Hamlets based on GP registration data should also consider flows for Newham, Hackney and Waltham Forest. It shows a high level of in-migration from northern England, Midlands and elsewhere in London. Mayor’s demographic forecasts assume a 3% decrease in inward migration. Through the duty to cooperate should forewarn these

authorities that their own assessments of housing need should increase to acknowledge the assumption that London will experience a 3% decline in in-migration over the next decade. In terms of out-migration the Mayor assumes 5% increase over the decade. Most moves are contained within London however there are moves into Essex and the Thames estuary. These authorities are not planning on the basis of this assumption so the LLDC should alert them to this in line with NPPG to be agreed under the duty to cooperate. Recognise difficulties of these discussions but is a consequence of Mayor’s reluctance to

discharge on behalf of boroughs.


182 SP2

SP.2 is unsound because it is unjustified and does not meet the requirements of legislation and national planning policy. The 24,000 dwellings is not a product of local level assessment of need required by the London Plan and doesn’t consider cross-boundary housing issues through the duty to cooperate. The plan period is 2015 to 2031 and SP.2 specifies that the plan will provide for 1,471 dwellings per annum

(dpa) which over 16 years is 23,536 dwellings which broadly corresponds to 24,000 figure. However, footnote 21 states the target is considered to be 22,065 dwellings which includes two years prior to the plan period. Struggling to reconcile this with 23,536 which conforms to the minimum housing supply target set out in table 3.1 of the FALP. It is unclear why 2013/14 and 2014/15 are factored into the calculation. If the start of the Plan period were brought forward to 2013/14 this be an 18 year plan period and need to plan for 26,478 dwellings over the life of the Local Plan. Footnote 21 states the requirement for the 18 year period to be 25,007 which fail to understand. Despite this, is still only the minimum benchmark position of the FALP which requires planning authorities to exceed these benchmarks. Part Da of Policy 3.3 of the FALP states should treat the targets as benchmarks to be augmented with extra housing capacity to close gap between need and supply.


183 SP2

Change to FALP clarifies that the targets in table 3.1 should LPAs should address the gap between housing supply and need, and seek to exceed their relevant targets through identifying additional sources of housing capacity and the Duty to Cooperate. Unclear how LLDC plans to contribute to additional 7000 dwellings a year so should demonstrate how intends to increase supply above 24000. Plan specifies will seek to exceed the FALP target but replies on London Plan evidence unsupported by additional studies exploring how 1,471 dpa could be exceeded. Worrying as Mayor stating measures to close the gap will be effective. If unable to identify additional capacity should be stated within Plan and to the Mayor of London. HBF keen to monitor housing supply within London and Mayor doesn’t lose sight to problem of

planning for 70,000 additional homes over the decade. Plan should acknowledge whether is feasible to deliver more than 24000 to meet need which would be clear message to the boroughs.


184 SP2

Part Dd of London Plan policy 3.3 and 3.8 part B require local assessment of need in the form of a SHMA and relying on London SHMA 2013 may not be sufficient. Recognition of lack of demographic information relating to the LLDC area but is a national and regional requirement. Then 24,000 is capacity derived and is not an objective assessment of need so LLDC should collaborate with the four other London boroughs to produce a SHMA for the HMA, assuming this constitutes a reasonable housing market area (HMA). If this exercise identifies a need above bench marketing targets then should find way of accommodating elsewhere through duty to cooperate. This may not result in a different housing target as FALP targets based on comprehensive capacity-based assessment which does not bear relation to needs. Meeting needs requires at least 49,000 dpa 60,000 dpa to address the backlog, so likelihood SHMA for HMA would result in needs exceeding FALP benchmarks. This would require authorities within sub-region to engage through duty to cooperate and if no capacity, explore ways of meeting unmet needs elsewhere. Assume 1471 target is separate to that of the 4 boroughs so should clarify for LLDC area only as potential for double-counting and boroughs making claim on units within the LLDC area for own targets. FALP targets are based upon LLDC’s supply being accounted for separately from borough

benchmarks.


185 SP2

Note comment that may not be possible to maintain a 5% buffer beyond 5 years and FALP acknowledges this difficulty. This was not discussed at the FALP hearings so LLDC cannot exempt itself from national policy requirements for a 5% buffer. It is questionable whether the Mayor can exempt London planning authorities from national policy requirements. A 5% buffer should not be difficult as it does not require additional land but bringing forward identified sites from later in the plan period and potentially granting permission earlier. Fail to see why this would present difficulties as is aim of assisting LPAs in maintaining housing delivery.


187 B.2

Support principles of Policy B.2, but shouldn’t apply Table 3 rigidly in relation to the scale proposed, nor focus development towards Stratford Centre. This states Stratford Town Extension will provide

approximately 55,000sqm (NIA) of additional comparison floorspace across the whole of the town centre to 2030, focused to the centre-east. Evidence for this within the Retail and Leisure Requirements Review is concerning as used dated household shopper survey information and how the impact of Westfield Stratford City (WSC) has been assessed. This shows how used baseline data from a household telephone survey of shopping patterns undertaken for the Canning Town Retail Study (2007) applied an adjustment informed by Lakeside Sub-Regional Retail Study to factor in the opening of Westfield Stratford City. This suggests the WSC will attract only 30% of its trade from the 12 study area zones, with 70% coming from inflow from unspecified areas which is too small as study areas to assess need at Stratford. This approach is not robust or sound as survey out of date and rely on judgements. Should have commissioned a new survey covering a primary catchment area of Stratford. Study also states figures beyond s In paragraph 6.8.6, PBA go onto state that: "The figures shown in Table 6.8 are based on the current identified levels of population and expenditure growth, but are susceptible to changes. It is therefore recommended that 2021 are considered indicative and subject to regular review especially since population growth expected in area. Recommendations are contrary to Table 3 so not sound. Paragraph 21 of NPPF shows how policies should support existing businesses, taking account of whether they are expanding or contracting plan for location in the area. Policies should be flexible enough to accommodate unanticipated needs not As WSL are a major contributor to the Stratford economy should not have any restrictions placed upon them. Should amend policy and retail hierarchy to allow for greater flexibility with ranges of retail floorspace and not a cap.

REP.LP.022 Tony Tapley, RPS Planning on behalf of Westfield Shoppingtowns Limited

186 H.2

Represent Westfield Shoppingtowns Limited. Responded also earlier in year to previous version which explained own and manage Westfield Stratford City and are key stakeholders. Should amend wording to H.2 to state maximising affordable housing should be based upon viability. Should add flexibility to housing tenure split to enable consideration of site specific considerations.


188 SA3.1

Support principle of allocation to ensure comprehensive development takes place but should make clear Stratford is now Metropolitan Centre. Safeguarding of land for platforms at Stratford is not justified. Reference to the number of units at Cherry Park relates to a specific scheme, so as detailed designs get drawn up may change so should be seen as a guide. Site is highly accessible so presents opportunity to deliver significant number of homes.


198 SD.1

Considers through para. 9 of the NPPF that sustainable development needs to be pursued through the Plan, a key element of which is ‘replacing poor design with better design.’ This is the principal aim of the

proposed redevelopment of Hamlet Industrial Estate, which currently comprises poor quality employment accommodation. A redevelopment scheme is sought on the site, replacing the low-grade employment accommodation with high quality SME employment and residential floorspace. This is a sound approach in that poorly designed accommodation should be replaced with high quality developments that better meet the needs of future residents and commercial occupiers of the LLDC area.

REP.LP.023 Michael Holloway, Daniel Watney on behalf of Roypark (1988) Ltd and Newstates Ltd

197 Vision

Considers that the Vision does not recognise that clusters of "spaces for creative and productive" uses are only present due to low accommodation costs. Many of these occupiers reside in largely pre-development post-war factory buildings which have typically suffered from a lack of investment. Should not confuse these examples as the ‘Vision’ for future regeneration as it is unrealistic and lacks aspiration.

This vision is not sound in terms of being positively prepared and justified, in that it does not consider that in order for regeneration to occur, land values must be permitted to rise without the artificial constraint. LLDC must accept that as a result the current occupiers may not be realistic tenants in the future. LLDC must accept that as a result the current occupiers may not be realistic tenants in the future. If the aim of the Plan is to artificially control commercial rents in redevelopment schemes in order to encourage such uses and attract SME / creative type uses, this must be explained and reasoned as a planning gain, which would need to be offset elsewhere to ensure viability.


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192 SP1

Great emphasis on creative present which considered making unique so protects such uses. This does not consider why these uses are common in the area which is due to availability of low quality accommodation with associated rents. When regeneration occurs land values will rise and occupier unlikely to be realistic occupiers in future. Seeking protection of existing uses attempts to artificially influence market forces which could impact on viability of schemes. Although uses can be encouraged through provision of space for SMEs and other creative uses, onerous restrictions on loss of space may discourage redevelopment schemes from coming forward. NPPF Para 17 set out the principles, one of which is driving and supporting sustainable development for homes and businesses needed and opportunities maximised. By discouraging development by influencing market forces, Plan will not assist important schemes from coming forward which could potentially hider LLDC area reaching potential.


191 B.1

Unsound approach to loss of employment floorspace disproportionately focusing on floorspace maintenance without regard to the qualitative benefits of job creation, quality and market demand. Should have flexibility for proposals replacing under-used, low density employment accommodation with higher quality, higher density proposals but reduced employment floorspace but create jobs. Using the HCAs Employment Densities Guide a B2 property generates a FTE job for every 36sqm (GIA) compared to B8 every 70 sqm and B1 every 12sqm NIA. This shows office use can generate the same amount of employment as a larger scale B2 or B8 use. At Hamlet Industrial Estate, a B2 use would generate approximately 60 FTE jobs compared to 152 FTE B1 office jobs. This shows that different employment uses provide greater numbers of jobs than others, which should be taken into account. Should be some flexibility afforded to job creation where existing employment floorspace is low-grade, inefficient and low employment. Should have flexible approach to SMEs and creative industries.


194 B.1

Too much protection to B8 uses outside of clusters which does not assess the benefits of replacing under-used B8 accommodation with higher quality, flexible employment floorspace promoting creative industries and greater employment densities. London Plan policy 4.4 requires LPAs to take account of the potential of surplus industrial land to meet strategic and local requirements assessing the suitability of such sites for continued use. Paragraph 21 of the NPPF requires LPAs to plan proactively to meet the development needs of businesses. By placing restrictions on the loss of low-grade industrial floorspace, the Plan restricts the potential of sites potentially bringing forward modern flexible employment accommodation. NPPF Para. 22 seeks to avoid the long term protection of employment sites and applications for alternative should be treated on their own merits.


200 B.1

Floorspace focus with no regard to quality and unit specification is unsound. Hamlet industrial estate comprises of a large amount of floorspace but poor quality and low density. Should holistically assess qualitative benefits. Flexible, higher quality employment floorspace would generate a greater number of jobs and improve accommodation. Local Plan's aim of creating flexible space for SMEs. By restricting policy in terms of floorspace does not have flexibility or assess qualitative impacts so is not positively prepared. No regard to the cost of creating higher quality accommodation against the existing basic industrial accommodation.


201 B.1

Clarity required on justification of job densities within B1 use as 5b specifies. This is not justified. Disproportionate focus on maintain existing floorspace without regard to qualitative benefits in regard to jobs, quality and market demand. No regard to the cost of creating higher quality accommodation against the existing basic industrial accommodation. Should have flexibility for proposals which replace low density employment with higher density but with reduction of floorspace.


202 B.1

It is not clear when 5 c to h would be relevant. This is unjustified so not sound. Disproportionate focus on maintain existing floorspace without regard to qualitative benefits in regard to jobs, quality and market demand. No regard to the cost of creating higher quality accommodation against the existing basic industrial accommodation. Should have flexibility for proposals which replace low density employment with higher density but with reduction of floorspace.


203 B.1

Text seeks to maintain economic character of sub area with no regard to economic changes occurring with regeneration. As land values increase preference for alternative uses may arise so inappropriate to protect current employment uses. No policy justification of interfering with market forces to protect specific jobs and industries. No justification of unique economic character of area. Not positively prepared and justified. If aim is to artificially control commercial rents in schemes this would be planning gain so would be offset against viability.


204 B.1

Reference to re-providing employment floorspace but no regard to better quality with reduced floorspace. Policy not sound as does not have flexibility to respond to site specifics and characteristics. Disproportionate focus on maintain existing floorspace without regard to qualitative benefits in regard to jobs, quality and market demand. No regard to the cost of creating higher quality accommodation against the existing basic industrial accommodation. Should have flexibility for proposals which replace low density employment with higher density but with reduction of floorspace.


205 B.1

Not clear when 5 a or 5 b would apply so unsound. REP.LP.023 Michael Holloway, Daniel Watney on behalf of Roypark (1988) Ltd and Newstates Ltd

206 B.1

Reference to re-providing employment floorspace but no regard to high quality with reduced floorspace. Paragraph not clear as states should significantly increase job densities. Should encourage replacement of low quality, low density employment with high quality employment with high job density. Does not have flexibility to respond to site specifics and characteristics. Disproportionate focus on maintain existing floorspace without regard to qualitative benefits in regard to jobs, quality and market demand. No regard to the cost of creating higher quality accommodation against the existing basic industrial accommodation. Should have flexibility for proposals which replace low density employment with higher density but with reduction of floorspace.


207 B.1

Approach there can be no loss of floorspace under 5a unless case under 5 c to h, but not clear when these apply. Flexibility is positive but starting point of no loss is too simplistic not taking redevelopment principles into account. Requirements for justification including relocation strategies, marketing evidence and viability is too onerous. Should support sectors on emerging sectors and job creation requiring marketing and relocation strategies for underuse B8 floorspace outside clusters. This is not positively prepared as places too onerous a requirement. Disproportionate focus on maintain existing floorspace without regard to qualitative benefits in regard to jobs, quality and market demand. No regard to the cost of creating higher quality accommodation against the existing basic industrial accommodation. Should have flexibility for proposals which replace low density employment with higher density but with reduction of floorspace.


208 B.1

Designation of Fish Island South as SIL requiring range of B2 and B8 floorspace is supported but should allow for greater flexibility outside clusters in particular at Fish Island North to convert B2/B8 space into other creative, SME units. This is sound approach as allocated designated uses to suitable locations. Should be more flexible outside the clusters.


193 B.4

Promoting concept of affordable workspace is unsound without clear explanation of intention. Workspace is either market rate, constrained market rate (i.e. use restricted for only one type of tenant) or subsidised. What is affordable to one provider is not to another. To encourage low-cost workspace should be assessment of the prevailing market rate in the area. In Hackney Wick many users are occupying low quality industrial or warehouse buildings not for their lawful use so should only be based upon lawfully used, reasonable quality accommodation. The term affordable links it to affordable housing, which is means tested. Any requirement for low cost workspace must be considered in terms of viability. And should be considered as a planning gain and offset against affordable housing.


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209 B.4

Part 3 allows managed workspace to be acceptable where no loss of employment. This is suitable wording as does not require floorspace to be maintained. Is unsound and unenforceable as does not consider viability nor define affordability or prevailing market rents. Need to have regard to subsidised workspace being paid for through S106. Assumed low cost workspace based on prevailing market rent which is unrealistic. Bullet 4 stipulates S106 would restrict rents to 75% of historic market rent which is unsound without detailed methodology on how calculated and applied. Rents derived from size, use, condition, specification, location, lease term, rent free, repair obligations, ability to undertake alterations. Would not undertake a rent review each time one of the units becomes available.


210 B.4

Acknowledges the re-provision of floorspace or density which is positive as long as clear case for supporting either which is sound. REP.LP.023 Michael Holloway, Daniel Watney on behalf of Roypark (1988) Ltd and Newstates Ltd

211 B.4

Policy should recognise that low cost workspace is a subsidy/planning gain and should be considered in viability terms. Provision of low cost and managed workspace would enable SMEs to maintain a presence when land values increase. Provision of such workspace affects scheme viability so should have regard to affordable housing reductions. Local Plan aims are to provide low cost workspace for SMEs and creative industries but needs to be benefits in doing so otherwise will not be brought forward.


199 Business Growth

Sound approach to employment clusters where Fish Island South is more appropriate for designation than Fish Island north. Should then allow a flexible approach outside clusters which complies with NPPF. REP.LP.023 Michael Holloway, Daniel Watney on behalf of Roypark (1988) Ltd and Newstates Ltd

212 Business Growth

Should not include an incomplete development as a case study. A case study should demonstrate a track record of what being compared against. No evidence of market rate to justify a 75% of market rate figure.

REP.LP.023 Michael Holloway, Daniel Watney on behalf of Roypark (1988) Ltd and

213 SP2

Seeking to deliver in excess of the FALP target is sound. REP.LP.023 Michael Holloway, Daniel Watney on behalf of Roypark (1988) Ltd and Newstates Ltd

215 H.1

Policy states should include a mix of 1, 2 and 3 bedroom units and larger with units of 2 bedrooms or more constituting more than half the total. This is sound in accordance with London Plan policy 3.8 and Local Plan objectives.


216 H.1

Para 5.9 is contradictory as it encourages a mix of 1, 2 and 3 bedroom units and will consider site circumstances including location, viability and maintenance of mixed and balanced communities but then states that family housing should be maximised. This would not take into account the site circumstances previously listed and not provide a broad mix. Family units should form part of the balanced mix and this does not comply with London Plan policy 3.8 which encourages a choice of homes taking account of identified housing requirements.


195 H.2

Support affordable housing percentages being influenced by scheme viability but this is contradicted in supporting text which notes that 35% will be starting point for assessment. REP.LP.023 Michael Holloway, Daniel Watney on behalf of Roypark (1988) Ltd and Newstates Ltd

217 H.2

Policy seeks affordable housing to be maximised whilst having regard to needs and tenure requirements, affordable housing targets and delivery rates, need to facilitate development and viability, including phased reappraisal. This provides a sensible approach to affordable housing provision having regard to viability which is sound.


218 H.2

Para 5.13 contradicts the main policy by setting a minimum target of 35% affordable homes which should be used as a minimum to commence discussions on individual schemes. This contradicts H.2 which allows viability to be assessed to facilitate development. Minimum target of 35% cannot be applied as specifies subject to viability. If not viable at 35% then need to accept a lower percentage. Also need to recognise that affordable workspace can be provided as per B.4 which should be offset against the affordable housing requirement. Presumes all schemes to be viable at 35% which is not justified.


219 H.2

Reference to maximising larger family housing contradicts Para 5.8 which suggests high requirement for one bedroom properties within affordable. This is not justified. REP.LP.023 Michael Holloway, Daniel Watney on behalf of Roypark (1988) Ltd and Newstates Ltd

214Housing and Neighbourhoods

Support designation of key neighbourhoods where Hamlet Industrial Estate falls within Hackney Wick. This is sound and supports NPPF aims of directing development to key neighbourhoods. REP.LP.023 Michael Holloway, Daniel Watney on behalf of Roypark (1988) Ltd and Newstates Ltd

220 CI.1

This policy requires the provision of new community infrastructure as part of new large-scale development. There is however no definition of what constitutes large scale development and therefore which schemes should provide new community infrastructure on-site. This is not justified as it does not define those developments which should provide community infrastructure.


196 BN.10

Contradictory in its approach by requiring that tall buildings respect the scale and character of surrounding properties. REP.LP.023 Michael Holloway, Daniel Watney on behalf of Roypark (1988) Ltd and Newstates Ltd

223 BN.10

Support REP.LP.023 Michael Holloway, Daniel Watney on behalf of Roypark (1988) Ltd and Newstates Ltd

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224 BN.10

The inclusion of a policy for developing tall buildings is encouraged but is contradictory in its approach by requiring that tall buildings respect the scale and character of surrounding properties. REP.LP.023 Michael Holloway, Daniel Watney on behalf of Roypark (1988) Ltd and Newstates Ltd

225 BN.10

We consider the general policy to be sound but the wording needs to be amended to include the protection of key identified views only. REP.LP.023 Michael Holloway, Daniel Watney on behalf of Roypark (1988) Ltd and Newstates Ltd

226 BN.10

If a proposal meets all of these criteria, then it should be considered as a suitable location for a tall building regardless. This policy needs to acknowledge the benefit of locating taller buildings on the edge of centres and outside of centres where they occupy ‘strategic’ positions in legibility terms.


227 BN.10

The policy should be about making key routes through the LLDC area and increasing legibility to and around centres. Land and proposed developments around the town and local centres are as important as those within the centres in terms of increasing legibility.


228 BN.13

Remediation costs should be taken into account when assessing the viability of schemes. REP.LP.023 Michael Holloway, Daniel Watney on behalf of Roypark (1988) Ltd and Newstates Ltd

221 BN.2

Support for policy BN2. REP.LP.023 Michael Holloway, Daniel Watney on behalf of Roypark (1988) Ltd and Newstates Ltd

222 BN.9


229 S.5

Policy S.5 Water supply and waste water disposal. We consider this to be positively prepared by allowing a flexible approach to the proposals. REP.LP.023 Michael Holloway, Daniel Watney on behalf of Roypark (1988) Ltd and Newstates Ltd

230 S.8

Policy S.8 Flood risk and sustainable drainage measures. This policy states that no basement development will be permitted within Flood Zones 2 or 3. This should be amended to say ‘no habitable basement

development will be permitted within Flood Zones 2 and 3’ due to basement levels still providing a suitable location for uses such as ancillary commercial and car parking. We do not consider this to be justified

as it should be reworded to allow less vulnerable uses to be located to the basement and ground floor, with more vulnerable uses such as residential to the upper floors.


236 1.1

Object strongly to the focus on quantum of employment floorspace as opposed to the quality and type of floorspace. We also contend that the protection of low-cost and managed workspace is seeking to artificially interfere with the market in order to protect such uses. This policy is not sound in terms of being positively prepared in that it does not allow for any flexibility depending on site specifics and characteristics.


237 1.3

Re-word Policy 1.3 (Part 5). REP.LP.023 Michael Holloway, Daniel Watney on behalf of Roypark (1988) Ltd and Newstates Ltd

238 1.4

Reference to the boundary wall of Hamlet Industrial Estate should be removed from the figure as it is not justifiable that this has any heritage value. REP.LP.023 Michael Holloway, Daniel Watney on behalf of Roypark (1988) Ltd and Newstates Ltd

189 SA1.2

Representations sent on behalf of Roypark (1988) Ltd, owners of Hamlet Industrial Estate and Newstates Ltd who own 20-22 Rothbury Road. Respond to whole Locla Plan but relate principally to Fish Island North. Detail of the Hamlet Industrial Estate and Rothbury Road sites are provided. Existing units are mixed industrial, with low employment, not reflecting SME vision of Hacknwy Wick and Fish Island. Sites present opportunity to achieve aims of LLDC with high quality employment units suited to SMEs.


239 SA1.2


240 SA1.2


241 SA1.2

This approach is not sound in terms of being positively prepared as it places onerous requirements on justifying the loss of certain employment floorspace. REP.LP.023 Michael Holloway, Daniel Watney on behalf of Roypark (1988) Ltd and Newstates Ltd

231 Sub Area 1

The diagram suggests an area of green space fronting a fairly large area along the two canal paths abutting Hamlet Industrial Estate. This does not correspond with Site Allocation SA1.2. REP.LP.023 Michael Holloway, Daniel Watney on behalf of Roypark (1988) Ltd and Newstates Ltd

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232 Sub Area 1


233 Sub Area 1

Still feel that there is a blanket assumption across Hackney Wick and Fish Island that only heritage-led regeneration is appropriate, which does not acknowledge that there is an abundance of low quality, non-heritage assets, including Hamlet Industrial Estate.


234 Sub Area 1

We would suggest that instead of ‘protecting’ these creative and cultural uses, the wording is amended to ‘promote and support’ such uses, to acknowledge the importance of designing higher quality affordable

ccommodation for these users.REP.LP.023 Michael Holloway, Daniel

Watney on behalf of Roypark (1988) Ltd and Newstates Ltd

235 Sub Area 1

considers that there is an opportunity to extend the boundaries of the Neighbourhood Centre to include land to the south of White Post Lane. REP.LP.023 Michael Holloway, Daniel Watney on behalf of Roypark (1988) Ltd and Newstates Ltd


Considers that the Local Plan places inequitable imbalance between positive approach to delivery on Park and negative development management approach on fringe. Roypark submitted representions to last consultation period, now soundness being consulted upon. Para 182 of NPPF explains rke of inspector in assessing whether Plan sound in terms of postively prepared, justified effective and consistent with national policy. Representations focus on soundness with comments on policies and supporting text. Table addresses on individual basis with principal concerns listed. Plan lacks recognition of viability. Encouragement of low cost workspace and affordable housing which is a significant planning gain impacting on viability which should be offset elsewhere eg through affordable housing provision.


242 Vision See REP.LP.015 (Section Response Entry 136) REP.LP.024 Warren Lubin

243 SP1

SP1 not sound as does not ensure growth of local business which did not benefit from the Games, instead reporting disruption and loss of business. Not enough focus on existing economic assets including Building Crafts College in Carpenters District. There are no measurable targets around local jobs provided so will be difficult to monitor the effectiveness of policy. To ensure SP.1 is sound should add bullet on local supply chains, give existing economic assets more attention and direct net local jobs should be added to Table 1. Should also provide estimate of employment growth arising from business growth already within existing workspace.

REP.LP.024 Warren Lubin

244 B.1

B.1 is unsound as it does not provide enough support to retain employment and industrial land. The importance of retaining industrial land should be strengthened. Technological and maker growth take place in workshops and yards as well as offices. Should have more discussion of conclusions of Economy Study particularly important for businesses within Carpenters District which are long-standing and keen to expand. Fails to recognise importance of local employment in terms of lifetime neighbourhoods. To be sound should include employment cluster within Carpenter District and should remain in industrial use. Can provide employment within Sub Area 3 in addition to the retail jobs. N.1 should acknowledge importance of retaining employment sires in terms of lifetime neighbourhoods and reducing need to travel.


245 B.2

Policy B2 is not sound and should set out need for town centre uses. Little investment from new town centre developments, such as Westfield, re-circulates in the local area and office workers could leave without spending in the local economy. Growth of Stratford Metropolitan Town Centre could be at the expense of other town centres. It is not clear that the duty to cooperate has been fulfilled on this matter, nor London Plan and NPPF requirements for positive planning to support town centres. Adverse impacts of the Town Centre extension on the existing Stratford Shopping Centre, which provides affordable goods and services, spaces for young people to socialise and skateboard had not been addressed. Should amend to encourage town centre uses that contribute to the local economy through local multiplier effects and local supply chains. Should address the LLDC’s duty to co-operate in terms of adverse impacts on other town centres and conformity with the London Plan and NPPF. Should expand description of

Stratford Town Centre Extension in Table 3 to acknowledge and retain existing Stratford Shopping Centre.


246 B.4

B.4 does not sufficiently protect workspaces and does not recognise need for new low cost workspace to facilitate existing businesses growing. Business in Carpenters Estate report lack of space to grow into. Does not recognise the importance in terms of lifetime neighbourhoods. To be sound needs amending to support retention and remove ‘where viable and where it complements plans for the wider area’.

Should add additional bullet stating will be supported where allows existing businesses to grow and acknowledge role in lifetime neighbourhoods.


247 B.5No target to monitor effectiveness of B.5 which places LLDC in weaker position to secure jobs and training for local residents. Need to set targets to demonstrate direct benefit to excluded and disadvantages residents. Target should be set for proportion of construction and end user hobs for local residents for participation in skills and employment training initiatives.


248 SP2

Policy is unsound as proportion of affordable homes does not reflect FALP London-wide targets which is important given housing delivery within area, needs backlog within London SHMA and high need for affordable housing in growth boroughs. Meeting needs is crucial to convergence. Is not sound as doesn't address need to maintain range of tenures to meet identified needs within area. Without specifically safeguarding social rented accommodation will not be a net gain. Affordable rent and intermediate homes go beyond income ranges of households in need of affordable housing in this part of London and failing to protect social rented will impact on convergence. This highlighted in large numbers within previous consultation. Should have annual affordable housing target of at least 595 as a proportion of the FALP target and safeguard social rented.


249 H.2

Policy H2 does not have up to date evidence base, having adverse impact on low income households and convergence. Policy depends on households eligible for social rented to access affordable rent homes covered by housing benefit. No evidence to support this, particularly for large bedroom sized homes. No breakdown of households that might be able to afford capped or discounted rents without access to benefits compared to social rented. No assessment of potential adverse impact of affordable rents compared to social rents particularly for those not dependent on benefits, or potential increase in levels of in-work poverty. No evidence of households previously private renting but now had to move out of borough [Newham] to facilitate their rent covered by housing allowance. To be sound affordable rent affordability should be updated including assessment of affordability of affordable rented homes.


250 CI.1

CI1 not sound. Fails to provide policy relating to the need and delivery of locally based healthcare facilities. Health care issues as required by London Plan policy 3.17 have not been addressed. Note health inequality issues in this part of London and the duty to cooperate. fails to address life-long educational needs - important in addressing pover and convergence. To be sound, the Community Infrastrucure including schools section should a) provide a policy with clear and measurable targets for healthcare facilities, in cooperation with surrounding planning authrorities. Table should show existing and planned healthcare facilites. b) should provide a policy section on life-long educational requirements - or amend policy CI2. to more widely cover lifelong education in the area. To be sound CI.1 should make reference to Lifetime Neighbourhoods – specifying that ‘developments should be designed so that the layout, tenure and uses interface with surrounding land, and improve people’s access to social and community

infrastructure’. The policy should promote development of local shops and services which also provide local community based places where diverse communities engaging with one another. It should also

more proactively promote delivery of multi-purpose community venues that would bring together a range of new and existing communities for educational, health, social and decision-making purposes. The policy should refer to provision of youth facilities .


251 CI.2Policy CI.2 is unsound as it fails to protect exising schools. Suggests some criteria for when loss of schools would be permitted. REP.LP.024 Warren Lubin

253 BN.11Regarded as unsound as not enough being done in the plan to address air quality and EU limits or to reduce and control noise. Greater clarity on issues needed and development proposals should be at least air quality neutral. To make the policy sound proposals should be at least air quality neutral and not lead to further deterioration of existing poor air quality.


252 BN.6 See REP.LP.015 (Response entry 146) REP.LP.024 Warren Lubin

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254 T.6 See REP.LP.015 (Response 155) REP.LP.024 Warren Lubin255 SP5 See REP.LP.015 (Response 157) REP.LP.024 Warren Lubin256 S.2 See REP.LP.015 (Response entry 158) REP.LP.024 Warren Lubin

257 S.3 See REP.LP.015 (Response entry 159) REP.LP.024 Warren Lubin

258 3.1

Sub Area 3 not sound as risk that retail and leisure may not be accessible to lower income households currently served by High Street, market stalls and older shopping centre. Very little retail investment circulates within the area and risk that workers could arrive at station and not spend within the local economy. Would create polarisation and divisions, not convergence. Should require accessible to low income households, support for existing businesses in terms of affordable workspace, ensure that development facilitates money entering the local economy, should support better connections between high street and communities adjacent and should set out how benefits and adverse impacts on local economy are measured. Does not set out how address and minimise exposure to poor air quality, developments should be air quality 'neutral'.


259 3.2

Policy is unsound because does not recognise possibility of enhancement and refurbishment of built environment and does not specify need to work with local communities as well as partners. To be sound should support refurbishment and retrofitting of built environment and set a timeframe for when improvements are to occur, prioritising needs of young families, elderly and disabled and that LLDC will work with local communities as well as partners.


260 SA3.4

SA3.4 is unsound as is already a mixed use area comprising of Carpenters Estate, new homes of mixed tenure active businesses and social and community infrastructure. In 2013 a majority of residents produced a Community Plan which highlighted the strengths of the existing community, access to transport, green play spaces and community infrastructure. It presented a vision for community-led and sustainable improvement that would build on solidarity of community and benefit health and well-being. Its vision is of refurbishment, retention of businesses and services improvements to community transport, shops and other facilities. This also said investigate Neighbourhood Planning for area where progress has been made towards development of a neighbourhood forum and defining boundaries. Discussions with LLDC have taken place with support from Locality. Community Plan identifies needs for new entrance to Stratford Regional station however development proposed in allocation is not required or desirable. LLDC made clear Carpenters Estate not necessary to meet housing targets. Policy 2.4 of London Plan highlights sustaining communities and promoting opportunities for economic development and jobs for young through community engagement. Greater Carpenters should be a model of this. Should remove allocation from plan. Policies are required for the area but most appropriate would be sensitive refurbishment, building on homes, businesses and community infrastructure already present. Can be achieved through a Neighbourhood Plan.


261 Sub Area 1 Objects to proposals for new canal bridges at Fish Island. REP.LP.025 Ian Shacklock

262 SP1Representations on behalf of Innovation City which is key stakeholder in area with permission for Here East comprising former IBC/MPC. Support policy aim of working with partners to develop a strong local economy driving east London transformation. Here East will provide 5,500 jobs in higher education, start-ups, corporates, investors and social enterprises.

REP.LP.026 Jeremy Castle, Deloitte on behalf of iCity.

263 B.1 Support for B.1 and designation of Here East as employment hub and description within the Table. REP.LP.026 Jeremy Castle, Deloitte on behalf of iCity.

264 B.6Support for B.6 in terms of educational facilities being located on edge of employment hubs which supports Here East proposals for mixed use in former IBC/MPC including pre-let tenants. REP.LP.026 Jeremy Castle, Deloitte on

behalf of iCity.

265 T.4

iCITY generally supports the intention of the policy to support the use of public transport and the reduction in car usage. However, the first sentence of the first paragraph could be read as confusing as sometimes minimising the reliance on the private car will not necessarily optimise the development within a particular area. Therefore iCITY seeks to ensure that the policy enables an appropriate level of car parking proportionate to the circumstances of each development in order to optimise development.

REP.LP.026 Jeremy Castle, Deloitte on behalf of iCity.

267 SA1.7The new east-west route between the Canal Park and Waterden Road should be recognised in the site allocation plan for Here East and Sweetwater. REP.LP.026 Jeremy Castle, Deloitte on

behalf of iCity.

266 Sub Area 1 In the plan's connectivity figure for the Hackney Wick and Fish Island sub area, it does not recognise an off-road connection between the Canal Park and Waterden Road REP.LP.026 Jeremy Castle, Deloitte on behalf of iCity.

269 Objective 3Further integrate historic buildings into Objective 3. REP.LP.027 Lucy Rogers/Tom Ridge,

East End Waterway Group

270 BN.2The title of the policy implies that a new character or distinctiveness is intended for the area. The policy needs to explain what makes the waterways a ‘defining feature of the area’ through reference to the

industrial history of the East End. The special historic character of the waterways has been neglected. The policy should be renamed and 5 new points should be added to the policy. REP.LP.027 Lucy Rogers/Tom Ridge,

East End Waterway Group

271 Sub Area 1

Objects to proposals for new canal bridges at Fish Island. REP.LP.027 Lucy Rogers/Tom Ridge, East End Waterway Group


The LLDC Plan should support the protection and beneficial use of the waterways.To be sound the Plan should contain a far more effective account, emphasising the period of industrial history that we can still see today and that is of London-wide importance.

REP.LP.027 Lucy Rogers/Tom Ridge, East End Waterway Group

275 SP1

Several businesses included within the Economy Study 2014 were not contacted to be informed of publication Local Plan so consultation insufficient. SP1 not sound as does not build local supply chains to connect development of existing businesses. New economics foundation work on local multipliers show how inward investment remains in area generates value through multiplier effects. There is insufficient focus on existing economic assets- should summarise Economy Study. Sector not fully recognised within Table 1, including small workshops, shops and affordable premises that can operate alongside other business and contribute to area attractiveness. Should be recognised as part of whole and direct specialist industries such as media to specific locations. Does not set measurable targets relating to achieving convergence. Should add new bullet on supply chains, recognise existing economic assets, net direct and local jobs should be added to table 1 and estimate for employment growth arising from existing businesses be provided. Not possible to monitor the aim of convergence and economic development unless this is transparent.

REP.LP.028 Lucy Rogers East End Trades Guild

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276 B.1

B.1 does not go far enough to retain industrial land. The GLA’s evidence report Accommodating Growth in Town Centres 2014 states that the market has pushed out commercial activities starting with low

value uses, contributing to decline in manufacturing activities. The report also states that take-up of lowest value space is high and vacancies low. This indicates high demand for Low Threshold Enterprise Space. Report also confirms importance to have a diverse business base and economy with low to high value activities providing employment and income opportunities. LTES likely to contribute towards this with low value jobs within industrial, manufacturing and warehousing for those at high risk of unemployment or worklessness. Availability of LTES particularly important for regeneration as for people less likely to commute to work. The Demand for Premises of London’s SMES report 2006 stated a case for intervention in areas where employment being pushed out in favour of high value uses such as housing. This

displacement an example of market failure appropriate response is to protect employment land from uses which threaten to make commercial space unviable. The study also demonstrated that small businesses willing to sacrifice space for accessibility. As stock of LTES reduces businesses are either forced out of occupy space which is not fit for purpose. Should recognise the importance of maintaining industrial land as growth in technological and maker industries will take place in workshops and yards, not offices. Should bring out more detail of Economy Study and unsound at present. Rates of industrial release are three times London Plan targets, and given high residential prices pressure to convert employment land is high and release targets exceeded. Should strengthen employment land protection so do not put the diverse economy highlighted in the Business Survey at risk. The option of increasing job densities within B2/B8 will increase pressure to redevelop, reduce likelihood of re-providing industrial uses and less likely that existing businesses will be re-accommodated. The sectors celebrated within the Business Survey need space to work and cannot be accommodated within office developments. Policy doesn’t define Locally Significant Industrial Sites and Other Industrial Locations. To be sound policy must not allow housing to threaten economic development, ensuring sectors can work alongside each other;

industrial designations should be strengthened and updates to Table 2 made; delete words ‘significantly increase job densities within B use classes’ from 5b. Should define LSIS and OIL and should

acknowledge role of employment protection for lifetime neighbourhoods and reducing the need to travel. Plan should make link between homes and jobs in delivering the convergence aim.


277 B.2

B.2 is unsound as does not show how existing assets in Hackney Wick are to be integrated with new development. There has been a lack of engagement with businesses and communities on the Neighbourhood Centre and wording should be amended to encourage town centre uses that contribute towards the local economy through local multiplier effects and supply chains. Very little investment from shopping centres filters into the local economy and there is risk that office workers leave without spending in the local economy. Planning growth of Stratford should not be in expense of other centres in surrounding boroughs, in particular the growth proposed within Tower Hamlets centres. Not clear fulfilled duty to cooperate on this matter, nor positive planning requirements of London Plan and NPPF.


278 B.3

B.3 fails to highlight importance of cultural and creative industries which should be seen as long term health not interim. Such industries are linked to the local economy through the supply chain and can develop to viable industries. Should amend to make sound by requiring community engagement in design and implementation of proposals. Motivated by experience in Hackney Wick Fish Island where interim uses are disconnected from non-temporary residents, business and community groups who do not benefit from or engage with interim uses which instead attract from outside the area, for example the skatepark.


279 B.4

Suggested re-wording is provided for the supporting text of the policy to allow for appropriate flexibility, in line with Test of soundness 3 as set out in paragraph 182 to the NPPF, which requires plans to be deliverable over their period, based on effective joint working. This re-iterates our comments on the previous Plan’s Draft Policy BEE.6. Appropriate flexibility would also allow for better compliancy with the

London Plan Further Alterations (2014) (Test of Soundness 4). Suggest amended wording to meet all of the Tests of Soundness.



The response outlines what the EETG is. The importance of small businesses to the new development areas should be emphasised. Argument that order to create thriving, vibrant local communities and to promote their economic, social and environmental sustainability there must be a level playing field for negotiating a commercial lease between Commercial landlords and tenants.


280 SD.1Policy SD.1 – Sustainable Development. Support the assertion that London Legacy Development Corporation (LLDC) will ‘take a positive approach that reflects the presumption in favour of sustainable

development’.

REP.LP.029 GL Hearn on behalf of Danescroft Land Limited

281 B.1Support for employment clusters REP.LP.029 GL Hearn on behalf of

Danescroft Land Limited

282 B.2Welcome allowance of residential within town centres. REP.LP.029 GL Hearn on behalf of


283 B.2 Support potential district centre at Bromley-by-Bow and note the stipulation of comprehensive development within policy 4.1. See comments to SA4.1. Support residential across the site. REP.LP.029 GL Hearn on behalf of Danescroft Land Limited

284 SP2Support maximising housing provision in exceedence of FALP target. REP.LP.029 GL Hearn on behalf of


285 H.1Support for requirement of more than 50% residential units to have 2 bedrooms or more. This promotes choice linked to emerging private rented sector market. Should have flexibility within policy so insertion of wording 'where practicable' before more than half.


286 H.2Support for need to facilitate development as consideration of delivery of affordable housing. Flexibility is integral to development coming forward. REP.LP.029 GL Hearn on behalf of


287 H.7Welcome reference to private rented sector as tenure choice. REP.LP.029 GL Hearn on behalf of


288 CI.1

Policy CI.1 – Providing New and Retaining Existing Community Infrastructure. Unsound - Policy CI.1 states that ‘new community facilities should be available for use by other sections of the community for

alternative uses when not being used by the main user e.g. schools’. Whilst we support the principle of shared community facilities, to ensure effectiveness it should be considered on a site by site basis to

ensure the layout and/or design of the facility is suited to shared use. Accordingly we recommend the following revised wording: Where appropriate and/or practicable new community facilities should be available for use by other sections of the community for alternative uses when not being used by the main user, e.g. schools; the Legacy Corporation will secure this through Section 106 Agreement.


289 CI.2Recognise the aspiration to provide a primary shchool at Bromley by Bow. Size should properly relate to the development area and be supported by a robust evidence base. Without sufficient evidence the policy would be unsound.


290 BN.10The Local Plan should not be prescriptive about height (Site Allocation SA4.1) as this should be informed by design, layout, relationships with other buildings and overall viability. REP.LP.029 GL Hearn on behalf of


291 T.6

Figure 24 and T.6 – Facilitating Local Connectivity

The ‘key connections’ shown on Figure 24 are supported in principle however it is considered that connections should be sufficiently flexible to be informed by emerging development proposals rather than

unnecessarily influence the layout and form of development this should be reflected in the reasoned justification to this policy.


17

295 4.1

Policy 4.1 – Potential District Centre. 1.13 The landowner welcomes a comprehensive approach and seek to achieve the policy requirement to ‘achieve or be part of’ a comprehensive development of the

Bromley-by-Bow Site Allocation area, subject to operational considerations and points outlined below at para 1.21 below. 1.14 Similarly the landowner recognises and supports the need to accommodate on-site infrastructure as far as is possible and viable, including an ‘all-movement’ junction, the mechanism for the delivery of which requires further consideration including financial support from public sources.

1.15 The landowner considers the list of uses, believed to be necessary to create ‘an appropriate mix and balance’, too prescriptive and instead these uses should be considered as guidance only, with the

exact nature and scale informed by the emerging Masterplan, note comments above at para 1.8 .


296 4.2Welcome policy commitment to new all-movement junction on the A12 and improved accessibility. However, new connections should be informed by the emerging Masterplan and not seek to stifle future development proposals. Update reasoned justification.


297 4.2 Support the key connections in figure 36. However, connections should be sufficiently flexible to be informed by emerging development proposals rather than unnecessarily restrict the layout and form of future development.


298 4.3 Support policy 4.3 REP.LP.029 GL Hearn on behalf of Danescroft Land Limited

299 4.4 Policy 4.4 should say preserve or enhance the character of the conservation area not preserve and enhance. REP.LP.029 GL Hearn on behalf of Danescroft Land Limited

293 SA4.1

Alongside the other Bromley-by-Bow South landowners, PLOT (Bromley-by-Bow) LLP is aligned in their aspiration to bring forward the development of the Bromley-by-Bow South site. 1Sub Area 4 – Bromley-

by-Bow, Pudding Mill, Sugar House Lane and Mill Meads. LLDC’s vision for Sub-Area 4, as an area of ‘new business and residential communities that find a focus at a new District Centre at Bromley-by-Bow

and a new Local Centre at Pudding Mill, with a secondary hub of employment and leisure uses in the north part of Sugar House Lane’ is welcomed and supported by the landowner. However the landowner

has significant concerns that whilst the extent of the Bromley-by-Bow site allocation relates to both Bromley-by-Bow North and Bromley-by-Bow South, an area comprising some 8ha across which there are significant social infrastructure requirements, the Bromley-by-Bow North site already has an existing planning permission (PA/11/02423) and is likely to come forward outwith the policy drafted in the Local Plan for, inter alia, 741 residential units, 4,432sqm use class A and B floorspace, 6,299sqm sui generis floorspace and public open space. 1.6 A number of financial contributions were secured totalling some £5.5m to mitigate wider impacts. Only contributions for Bromley-by-Bow Station and Bow Interchange were ‘ring fenced’ meaning contributions towards infrastructure in the wider site allocation are unclear. Therefore

Bromley-by-Bow North is unlikely to make any further contribution to the social infrastructure costs for the wider site Bromley by Bow South has a number of complex challenges, different to those at Bromley-by-Bow North, and it is unreasonable to consider that the south site can account for the majority of social infrastructure requirements, including a primary school and community facilities, in its own right. As such the landowner has fundamental concerns about viability and considers the policy aspirations, which can now only be met by Bromley-by-Bow South, need to be recalibrated. In recognition of the above, our client considers that it would be appropriate to divide the wider Bromley-by-Bow site into separate ‘North’ and ‘South’ areas for the purpose of the Local Plan and recalibrate the Site Allocation in order to

differentiate the proposals and expectations for each site, giving due consideration to the existing planning permission for Bromley-by-Bow North. 1.9 The landowner therefore considers this policy to be unsound by virtue of its lack of effectiveness and believe that it should be recalibrated to reflect specific requirements in both the North and South of the wider Bromley-by-Bow area. The subsequent representations in this letter seek to achieve this aim.


294 SA4.1

Suggest additional challenges: - different landowerships across the site area,- operational uses which need to be considered as part of redevelopment proposals, - viability to balance development requirements agains the need for social infrastructure. Should remove comment 'presure from development and rising.....payments' as it is considered to be a matter for hte subsequent masteprlan and superfluous at this point of plan-making, not linked to the challenges facing future development proposals.


300 SA4.1

Site allocations relates to BBB north and BBB south. BBB north has an extant planning permission. Policy aspiration and expectations for Bromley by Bow therefore need to be recalibrated before our client can support this approach. Indicative blue chatching identifiying the District Centre should be extended further north in order to ensure flexiblity for retail. Site allocation includes a new 1.2 ha park, lapsed pp and adopted masterplan (2012) included a lesser amount of open space. Need for increased open space near Three Mills Park is not justfied and likely to not be feasible. Question specific reference to a library. Suggest reference removed and state ‘community facilities if possible/practical’. ‘Employment generating business’ should be at an appropriate scale to be determined by the masterplan to complement other

retail and community uses. Prescriptive policy is inappropriate in this instance and likely to restrict and unduly delay future development proposals. 1.24 The importance of viability is enshrined in para.173 of the NPPF which states: ‘Plans should be deliverable. Therefore the sites and scale of development identified in the plan should not be subject to such a scale of obligations and policy burdens that their ability

to be developed viably is threatened’.


301 SA4.1

One of the key Development Principles is the need for future development to demonstrate that it will contribute to ‘comprehensive development’ (of the Bromley-by-Bow Site Allocation area) by virtue of a

‘Masterplan Approach’ and ‘phasing of development across the overall site’. The landowner supports a ‘comprehensive approach’ to the site but not comprehensive development per se. The comprehensive

approach should be supported by flexible policy, masterplan-led to create a framework to enable phased development to come forward subject to viability. This will allow aspirations to be tested and a masterplan framework to come forward that is adaptable in order to incentivise delivery. The landowner therefore seeks a recalibrated policy with changes to the associated Development Principles to reflect this. It is pertinent to note that comprehensive development, in the form of comprehensive delivery, has previously failed. That fact is acknowledged in the adopted Bromley-by-Bow Masterplan (2012). which refers to complex land ownership resulting in comprehensive delivery being unlikely (para 3.2.2). Comprehensive development of Bromley by Bow South is most likely to come forward through a more flexible process based around a comprehensive Masterplan with a robust delivery strategy. The Development Principles also require future development to provide ‘certainty over delivery of the complete

comprehensive scheme’. This is considered to be unsound and unrealistic. Therefore the requirement is unjustified. This is particularly relevant because the extant planning permission at Bromley-by-Bow North

means that development across Bromley-by-Bow cannot and will not be delivered comprehensively by virtue of the fact that the northern part of the site will come forward ahead of the southern part in all likelihood. We therefore suggest that the Development Principles are revised to state, inter alia: - that a Masterplan approach for the Bromley-by-Bow South Site Allocation as a whole is followed - The masterplan seeks to incorporate the uses identified within the re-calibrated policy; - The masterplan creates a framework for development that tests the uses in terms of layout, design, viability, deliverability and identify a ‘comprehensive approach’ to delivery; - This should include options and phasing to reflect the challenges of the site. The Development Principles also specify that the ‘predominant height of new

buildings across the area should be 18m’. The landowner considers that this policy to be too prescriptive, and therefore likely to stifle the viability of future development proposals. The wider Bromley-by-Bow

area is identified as a (potential) District Centre, therefore a suitable site for taller buildings (draft Policy BN. 10). Furthermore the previously approved (lapsed) planning permission included buildings up to 20 storeys, so the policy risks encouraging a homogeneous and (ultimately) unviable development. Height is a matter for design and layout for the masterplan to define. As a consequence the section relating to predominant building height is considered to be unsound and likely to impact on future development. Accordingly the landowner proposes the following revised wording: - The height of new buildings should be informed by local characteristics and considered on a site by site basis through the masterplan process, subject to meeting other policies in this Local Plan.


302 SA4.1

Conclusions. The Landowner supports the aspirations behind the proposals for Sub-Area 4, specifically in relation to Bromley-by-Bow South; however there is concern that delivery of the site could be compromised by policy in its current prescriptive form. A rigid application of this type of policy would prevent development, and not correspond with the positive objectives of the NPPF in respect of the presumption in favour of sustainable development. 1.36 The landowner believes that the submission of a planning application(s) linked to a site-wide Masterplan is likely to provide the most flexible and therefore appropriate mechanism for the delivery of the wider site and this should be reflected in the draft Local Plan. 1.37 I trust the above is clear, we would be grateful if you could provide us with confirmation of these representations. We would like an opportunity to discuss with LLDC at an early date in order to address/resolve the genuine concerns of our clients.


292 Sub Area 4 Consider the delivery of Sub-Area 4 to be pivotal to the success of the Local Plan and have set out further comments on Sub-Area 4. REP.LP.029 GL Hearn on behalf of


18


The response states that the Highways Agency does not have anything to add to the Local Plan. REP.LP.030 Laxman Ghimire, Highways Agency

305 Vision

Considers that the vision is not sound as it does not adequately signal commitment to realise some priorities of the London Games 2012 Legacy, namely community participation and the promotion of social inclusion in housing, jobs and cultural life..Its treatment of continuing “sustainable development” misses some of the key concerns of stakeholders, such as the need to deal with poor air quality by shifting

passengers and freight loads onto less polluting transport providers and the need to demand better than industry norms for lifetime buildings and neighbourhoods. For the Vision to be sound considers that it should include: (a) A firm commitment by LLDC to work to positively improve the overall social and environmental conditions in the area; (b) Mention of active collaboration with the four Olympic host boroughs in work in implementing this plan to close deprivation gaps across the boroughs so benefits of Olympic Legacy will reach all residents; (c ) Explanation of how new jobs will be provided to the benefit of existing residents in the older established parts of the plan area as well as offering minimum-distance commuting opportunities for new residents.

REP.LP.031 Steve Butters, CPRE

306 SP1

SP.1 not sound as to achieve convergence need to build local supply chains which is not mentioned. Only brief reference to promoting social enterprise but no policies to support it. Insufficient focus on existing economic assets and should summarise information within the Economy Study. Should add wording on how achieve convergence through growth of existing assets and set out measureable targets relating to achieving convergence and economic development. Should add new bullet on local supply chains and mention social enterprise, more attention to existing economic assets and net direct and local jobs added to table 1 as well as estimate of employment arising from indigenous businesses in existing workspaces or options for occupying new workspaces.


307 Sub Area 2

Wants to encourage LLDC to make improvements to the draft plan, which is regarded as unsound in key aspects, in order to secure a more comprehensive strategy for a greener, safer and healthier Olympic legacy district. The following sections indicate our principal concerns and suggestions for alterations to the draft plan. With specific suggestions for alterations to the Plan made against those parts. Considers Policies 2.1 – 2.4 (together with the site allocations) unsound as they do not: Provide the diversity of housing options promised in pre-Olympic Games forecasts of the legacy effects. Provide explicit guidance

on limits to tall building and design guides for both high and bulky developments, and include mandatory limits and good practice for heights and massing of all large buildings. Specify amount and type of community facilities which must be provided in the Chobham Manor and Chobham Farm developments. Nor does it say enough about the need for diversity and balance in the provision of retail shops and services in the East Village “local centre”. Considers that for the section on Sub-Area 2 to be sound it should include: (a) a clear plan for securing variety of form and diversity of function in residential and retail

development; (b) stronger guidance and mandatory limits on height and massing of all substantial buildings, broadly in accord with what has already been required at East Village; (c) more detail and stronger commitment to provision of community facilities across the sub-area.


314 B.1

One of the priorities for, Hackney Wick and Fish Island is safeguarding Bow Midland West Rail Site for rail use and promoting access to the surrounding road network. The Strategic Industrial Location (SIL) designation incorporating Bow Midland West Rail site is welcomed. Table 2 which makes clear what balance of uses and form of development will be suitable with each location confuses the two railhead sites. The BOW MIDLAND WEST site is currently operated by Aggregate Industries and London Concrete as a rail served aggregates depot and concrete batching plant, with extant planning permission for an asphalt plant and capacity to increase production on site. It forms the southern tip of SIL area referenced. BOW GOODS YARD EAST was operated as a freight terminal but used for as warm up track Olympics, the former use is to be reinstated as an operational rail facility. It comprises the full extent of SIL area referenced: B1a3. The cluster function for Bow Midland West should make specific reference to the existing operations on site (aggregates distribution and concrete batching), consented proposals (asphalt plant) and potential for future expansion of these or other rail related uses. Need to make following modifications for soundness: B.1a2 Fish Island South Including Bow Midland West Rail Site Strategic Industrial Location (Preferred Industrial Location). A range of significant B2 and B8 Use Classes of industrial, warehousing, transport, waste management and distribution a .A safeguarded rail head and associated bulk freight distribution use. Uses should make effective use of the railhead, including potential for aggregate distribution and for concrete batching, the manufacture of coated materials, other concrete products and handling, processing and distribution of or aggregate material . Only small-scale supporting ancillary uses will be supported. B.1a3Bow Goods Yard East and West Strategic Industrial Location (Preferred Industrial Location) A safeguarded rail head and associated bulk freight distribution use. B2, B8 and waste management uses are appropriate. Only development supporting the rail-related (and at Bow West aggregates distribution uses) and small-scale ancillary uses will be supported.

REP.LP.032 Vilna Walsh, Firstplan Ltd on behalf of Aggregate Industries (UK) Ltd and London Concrete Ltd

312 B.1

Has two key areas of concern: 1.The extent of the Bow Midland West Rail site has not been defined on any plan within the Local Plan. Without the site being outlined in plan form the Publication Local Plan cannot be considered to be “sound” as it has failed to accord with national policy, the omission is not justified and renders the plan in-effective in this respect.Table 2 has confused Bow Midland West Rail site

with Bow Goods Yard East and in so doing does not appropriately identify the safeguarded Bow Midland West Rail site nor the uses that are considered appropriate on this site. This confusion renders this part of the Plan unsound. A very straight forward modification which can be made to make the Plan sound in respect of the above. Table 2, Employment Clusters (Page 27 LLDC LP Publication Version), sets out confused references to Bow Goods Yard East and West and does not clearly define the function of each site (separate representations have been made in this respect). Furthermore, the extent of the safeguarded Bow Midland West Rail site is not defined either on the Proposals Map or on Figure 28, Sub Area 1 Key Diagram. Failure to properly define the safeguarded site on the Proposals Map and related Key Diagrams is considered to render the Plan unsound. Whilst the Plan does identify this as one of its priorities, the omission of an specific plan outlining the extent of the site is considered to be unsound on the basis that it is not justified with the LLDC having failed to adopt the most appropriate strategy when considered against the reasonable alternatives. For the Local Plan to be effective and deliverable the policy approach must clearly be to identify the range of uses which can realistically be located in specified areas. By not properly identifying the extent of the safeguarded site, the Plan is considered to also be unsound on the basis that it is not consistent with National Policy and because it has not been positively prepared. All of these issues have been previously considered at the the Fish Island Area Action Plan EIP and there has been no change has which would justify any different approach being taken to the safeguarding of the this site than that recommended by the Inspector at the AAP EIP. The Proposals Map, should specifically identify the full extent of the Bow Midland West Rail Site located within the SIL shaded area. A site location plan showing the extent of the site is attached to the covering letter for ease of reference. The site should be referenced on the Legend as: “Safeguarded Rail Site – Bow Midland West.”


310 Sub Area 1

Paragraph 10.3 to be amended as follows (additional text shown in italics, underlined and shaded for ease of reference). “Strategic Links: Safeguarding the Bow Midland West Rail site for rail use and

promoting access to the surrounding road network. Further south in Fish Island, there is a Strategic Industrial Location (SIL) designation that incorporates the Bow Midland West Rail site as identified on the Proposals Map and Figure 28. New development should not adversely affect existing business and should be designed to take account of their existence and their existing and future operational requirements, particularly where those businesses are located within the designated employment clusters.”


311 Sub Area 1

MODIFICATIONS REQUIRED TO MAKE THE LOCAL PLAN SOUND Figure 28, Sub Area 1, Key Diagram, should specifically identify the full extent of the Bow Midland West Rail Site located within the SIL shaded area. A site location plan showing the extent of the site is attached to the covering letter for ease of reference. The site should be referenced on Figure 28 as: “Safeguarded Rail Site – Bow Midland

West.”


313 SA4.3

There is no in principle objection to the Site Allocation SA4.3: Pudding Mill Lane. However, it does lie in close proximity to the southern end of the Safeguarded Bow Midland West Rail site (located within Sub Area 1: Hackney Wick and Fish Island). Given the priority given to the safeguarding of the Rail site (Paragraph 10.3, eighth bullet point) and the requirement that new development should not adversely affect the rail site and that new development should be designed to take account of its operational requirements then it is considered that the site allocation should make reference to the proximity of the allocated site to the safeguarded rail site. The inclusion of reference to that fact that regard will need to be had to not prejudicing the operation of the safeguarded rail freight site (for example by ensuring that noise sensitive uses are located away from the site) will further ensure the Plan is sound. It would also complement welcome text within the allocation which already indicates a predominantly industrial floorspace use mix in the area to the west of Crooks Road and around the Crossrail portal. MODIFICATIONS REQUIRED TO MAKE THE LOCAL PLAN SOUND The following amended text for the Site Allocation S14.3: Pudding Mill lane is suggested (New text shown in italics, underlined and shaded for ease of reference)


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316 H.2

Need for flexibility to changing circumstances is key. Supporting text states a minimum of 35% affordable homes across the area. Recognise needs for a range of housing type, mix and tenure but affordable housing on development sites will be determined by viability. Particularly within East Village where majority of affordable has been in advance of market and now occupied. Further affordable units benefit from detailed reserved matters and are obliged through S106 to be delivered before certain quantum of market. Should recognise the role of viability in shaping development proposals.

REP.LP.033 Steffan Rees, Quod on behalf of QDD Athletes Village UK Limited

317 H.4Question the suitability of image adjacent to student housing policy as does not include student accommodation. REP.LP.033 Steffan Rees, Quod on

behalf of QDD Athletes Village UK Limited

318 H.7East Village comprises new PRS product and is concerned about bullet 4 of policy which indicates that will seek to secure mechanism to secure as private rented for the long term. This is new concept so challenge of whether success should be recognised. Should ensure that do not present a barrier to switch to future private sale in changed circumstances. No planning controls to do so.


319 BN.10It is important however that emerging Policy does not diminish or dilute principles which have already been established within existing planning permissions. REP.LP.033 Steffan Rees, Quod on


320 T.6

“…Cumulatively across the Pudding Mill Site Allocation 25 per cent non-residential floorspace should be achieved , with a predominantly industrial floorspace use mix in the area to the west of Crooks Road

and around the Crossrail Portal. Regard will need to be had in the site layout and design of any proposals to the nearby Safeguarded Bow Midland West Rail site and ensuring that the existing and future operation of the rail site is not prejudiced. In particular proposals should be designed to minimise the potential for conflicts of use and disturbance. Landowners will need to……”


321 SA2.2Whilst QDD AV welcome the general approach contained within the Sub-Area and Site Allocation, we note a number of inaccuracies which could set the context for the application of some policies within the Local Plan which are set out below:


323 SA2.2Note that East Village benefits from a Public Transport Accessibility Level (PTAL) of S-Ga opposed to the la-3 stipulated in Site Allocation SA2.2. REP.LP.033 Steffan Rees, Quod on


324 SA2.2

The Local Centre boundary should extend along the entire Stratford City Plots N01 to N05 frontage to rflect the extent of permitted non-rsidential floorspace. REP.LP.033 Steffan Rees, Quod on behalf of QDD Athletes Village UK Limited

315 Sub Area 2

General Comments QDD AV consider the Publication Version to be generally sound subject to stressing the need for maximum flexibility and that changing circumstances may mean that a review of proposals could take place on sites which already benefit from planning permission but have not yet been delivered. It is also critical that information on the existing state contained within the draft Plan is entirely accurate on the basis that a number of policies (e.g. Policy BN.10 relating to building heights) will be informed and applied, in part, by individual sites' surrounding context.


322 Sub Area 2

Table 8 'Prevailing Heights in Sub Area 2' incorrectly indicates that prevailing heights in East Village extend to 20 metres with higher elements on the southern and northern edge. The prevailing heights of built Plots within East Village range from circa 40m AOD to 58m AOD and it is critical that the Site Allocation accurately reflects the actual building heights across East Village, the principle of which have been established within the Stratford City Outline Planning Permission;


335 BN.10It is our client’s submission that Stratford High Street should be identified as a location for tall buildings. REP.LP.034 Victoria Bullock, Barton

Wilmore on behalf of Bashir

325 SA4.2

1.0 OVERVIEW. 1.1 These representations are submitted on behalf of Mr Bashir. Mr Bashir is the freehold owner of land at shown at Appendix 1. The site benefits from a grant of planning permission secured by a third party, namely Landprop. The hybrid planning permission (from the London Thames Gateway Development Corporation) was granted on 27th September 2012 (Ref: LTDC-12-012-FUL) and provides for circa 1200 new homes and 69,000 non-residential land uses. Mr Bashir was not party to the S106 Agreement. 1.2 The site falls within the outline (parameters based) element of the permission. From the approved plans it falls within a larger plot identified as Plot MU2 (Drawing PP-1-110) and is identified for non-residential use, primarily Class B1 (Drawings PP- 1-104 to 106). 1.3 Our client is broadly supportive of the Sugar House Lane area being identified for growth. Our concern relates to the effectiveness of Policy SA4.2 in relation to paragraph 182 of the National Planning Policy Framework (NPPF). In short as drafted the Allocation: • Lacks clarity and does not provide a clear basis from which a decision maker should react to a development proposal or therefore for a developer(s)

preparing a scheme(s); and • Is overly prescriptive, has the effect of enshrining the planning permission into planning policy and as a result does not provide sufficient flexibility to guide future planning

applications, respond to rapid change or achieve the objectives of the policy.

REP.LP.034 Victoria Bullock, Barton Wilmore on behalf of Bashir

327 SA4.2

3.0 SITE ALLOCATION SA4.2 SUGAR HOUSE LANE. 3.1 Our client supports the identification of land at Sugar House Lane as a location for growth. However it is our submission that as drafted the policy is not effective as per para 182 of the NPPF and is therefore unsound. Specifically as drafted the Policy: • Lacks clarity and does not provide a clear basis from which a decision maker should react to a

development proposal or therefore for a developer(s) preparing a scheme(s); and • Is overly prescriptive, has the effect of enshrining the planning permission into planning policy and as a result does not

provide sufficient flexibility to guide future planning.


328 SA4.2

The Template 3.2 It is noted that the same template is used for each Site Allocation. Unlike the topic based policies there is no clear distinction between the policy, reasoned justification and the policy application. It is unclear from the Site Allocation template what is policy wording and what is the justification/explanatory text. This is an important distinction as it goes to the core of how a decision maker should react to a future development proposal (see Para 154 of the NPPF). 3.3 The use of standard headings also leads to an unnecessary level of detail, repetition and prescription within the allocation. It serves to reduce flexibility and burdens the Local Plan with matters that would be more appropriately addressed through an SPD, a design brief or indeed application(s). The level of detail of policy should be sufficient to ensure that the policy is effective. The approach taken is counter to this. 3.4 We consider the various sections of the policy below having regard to paragraph 3.1 above. In short we would suggest that only the text currently shown in bold, together with a plan identifying the location of site, should comprise the policy (both subject to revisions considered below). With the remaining text deleted or, where appropriate, clearly identified as justification/explanation.


20

329 SA4.2

As drafted the policy states: "A new medium-density, mixed-use area including business (cultural and creative) and local retail space focused in the northern and southern part of the site; up to 1,200 new homes with a significant number of family homes, Local Open Space and public realm. A new all-movements junction to enable access to the area and new bridges to link the area to surrounding communities will be required alongside development.” Whilst we support the principle of the allocation and the reference to mixed use development, we have concerns regarding the effectiveness of the policy wording. The

reference to delivery of ‘up to 1,200 new homes’ is overly prescriptive and limits the development potential of the allocation. It is assumed that the 1200 unit figure is derived from the extant permission which

provides for 1192 new homes (12/00336/LTGOUT/LBNM). The outline element of the permission approved a set of parameter plans that reflect just one of many possible responses to the site in terms of building heights, residential density and therefore quantum of accommodation. To limit the overall number of units to reflect just one scheme lacks flexibility.


330 SA4.2

Strategic Policy SP.2 Maximising Housing and Infrastructure Provision within New Neighbourhoods states that the Legacy Corporation will work with its partners to maximise opportunities for delivering high quality homes delivering in excess of the London Plan target of 1,471 housing units per annum. In this context, and that of the London Plan which identifies housing targets as minima, there should be greater flexibility and aspiration within the Site Allocation. To ensure the policy is effective, we would suggest that the wording be changed to ‘a minimum of’ of 1200 dwellings. 3.9 The reference to medium density also

lacks flexibility. The allocation as a whole could accommodate a range of different densities to reflect the different constraints and opportunities that operate across the area, for example high density development to Stratford High Street to assist placemaking, legibility and maximising the opportunities of public transport accessibility, with lower density family housing to the south of the allocation. As drafted the policy implies a prescriptive standardised approach. 3.10 We would suggest the following: “A new medium-density, mixed-use area including business (cultural and creative) and local retail space focused in

the northern and southern part of the site; up to a minimum of 1,200 new homes as a range of densities with a significant number of family homes, Local Open Space and public realm. A new all-movements junction to enable access to the area and new bridges to link the area to surrounding communities will be required alongside development.” It is unclear whether the remaining text forms part of the allocation.

This should be clarified. In any event it is noted that it makes reference to ‘retaining a strong employment focus’. This is at odds with the need to review employment land in the context of meeting housing

needs. Again, we would suggest that the reference to employment focus is a function of the existing planning permission and approved disposition of land uses, the effectiveness of which is considered further below.3.12 We would therefore suggest the following: “The area should adopt a genuinely mixed-use character retaining a strong with employment focus that includes a base for creative industries and introduces a

new residential community served by a range of local amenities and highquality public transport, pedestrian and cycle connections. The area will be defined by its unique natural environment and historic industrial legacy that includes extensive canal and river frontage, robust yet adaptable buildings and intricate yards and passages. The historic character of the 23810/A5/VB Page 6 October 2014 Publication Version Local Plan 2015 – 2031 Site Allocation SA4.2 Sugar House Lane area should be created by weaving high-quality new buildings into the historic fabric”


331 SA4.2

The Plan. 3.13 The plan that accompanies the allocation effectively enshrines the planning permission into policy. Specifically the proposed employment designation is a replication of the approved Parameter Plan Uses at Ground Floor PP-1-104. 3.14 Anyone can secure planning permission on third party land. We would suggest that the approved scheme was not prepared inclusively and does not have the full support of landowners, evidenced by the fact that our client was not party to the S106 Agreement. In short the permission directs employment uses to land not in LandProps control. In our view little weight should be attached to the approved disposition of land uses as they were not based on landowners agreement or commercial reality and may not be effective or deliverable (as per para 173 NPPF). A Local Plan that then enshrines the approved scheme into policy in turn raises questions of its effectiveness and deliverability. 3.15 The plan implies that there is only one scheme for the site, whereas it is possible that the allocation headlines could be achieved by numerous iterations/schemes. The Allocation should not tie policy to a scheme only capable of implementation through CPO. A developer/landowner may chose not to build out the planning permission and seek an alternative scheme on all or part of the site with different configurations / disposition of land uses to better reflect market demand and commercial reality at that point in time. The Plan lacks flexibility and could frustrate that approach and thus aspirations of the allocation. Again, a Local Plan that enshrines the approved scheme into policy in turn raises questions of its effectiveness and deliverability. 3.16 The plan also lacks clarity, for example one interpretation could be that only employment uses are to come forward in the designated area to the north of the allocation, this being the general approach of the permitted scheme. As noted above, this lacks flexibility and could limit the ability of developers to bring forward effective and deliverable schemes. In our view the policy aspirations of the allocation could be achieved through a mixed use development in this location with commercial/active uses to the ground floor with residential above. This would reflect the higher public transport accessibility in this location, together with the benefit of providing both frontage and activity to Stratford High Street. Notwithstanding the above it is not the role of the allocation to masterplan the site.Rather the allocation should be independent of the planning permission, and any other masterplan, and instead set the policy basis for the assessment of future applications on all or part of the allocation. 3.17 As drafted the Plan and approach is not effective and fails the soundness test as per para 182 of the NPPF. Our concerns in respect of the plan could be addressed by a revised plan that simply identifies the extent of the land the subject of the allocation (see appendix 2). This should be accompanied by a corresponding change to the Vision at page 205. This together with policy wording that then enables the sites within the allocation to come forward separately subject to demonstrating compliance with the overall vision for the allocation and providing their fair balance of land uses in accordance with the policy objectives.


333 SA4.2

three bedroom plus homes. This fails to acknowledge the different possible character areas within the allocated site and the role of different sites in terms of housing provision and need as they come forward. 3.20 We would suggest that in the context of the bold text of the policy stating a preference for ‘a significant number of family homes’ that this development principle can be deleted. 3.21 In terms of the

reference to designated heritage assets and the need for high quality public open space, these are policy matters that are covered by the provisions Local Plan or NPPF and we would query the need to repeat them.


334 SA4.2

Relevant Planning Policy. 3.24 As noted above, this provision should not form part of the policy as it represents a matter of fact and context rather than a provision against which any future applications should be determined. Moreover it is a point in time comment that is likely to date quickly in the context of the plan period. Summary 3.25 As drafted the Site Allocation is not effective and is therefore unsound. Our concerns could be addressed by: • Clarity regarding what constitutes policy, reasoned justification and policy application; • Amendment of what is understood to constitute policy as per paragraphs 3.10 and

3.12 above; • Replacement of the current Site Allocation plan with a redline plan (see enclosed at Appendix 2); and • Deletion of the Development Principles, Phasing and Implementation and Relevant

Planning History sections of the allocation or if retained amended as per the above.


332 SA4.3

Development Principles. 3.18 In our view the development principles do not add to the policy and should be deleted. Should the LLDC wish to retain the text it should be clarified as whether it is policy, reasoned justification or policy application. We would also make comment on the detailed provisions below. 3.19 We object to the reference to ‘a high proportion of family housing – at least 40% (three

bedroom and larger) – will need to be provided’. Taken on its face, as drafted the policy reads as though all schemes that come forward, regardless of their location, housing need or scheme viability will be

required to achieve 40%


347 BN.10It is our client’s submission that Stratford High Street should be identified as a location for tall buildings. REP.LP.035 Victoria Bullock, Barton

Wilmore on behalf of Gallagher

337 SA4.2

Gallagher are broadly supportive of the Sugar House Lane area being identified for growth. Our concern relates to the effectiveness of Policy SA4.2 in relation to paragraph 182 of the National Planning Policy Framework (NPPF). In short as drafted the Allocation: • Lacks clarity and does not provide a clear basis from which a decision maker should react to a development proposal or therefore for a developer(s)

preparing a scheme(s); and • Is overly prescriptive, has the effect of enshrining the planning permission into planning policy and as a result does not provide sufficient flexibility to guide future planning

applications, respond to rapid change or achieve the objectives of the policy.

REP.LP.035 Victoria Bullock, Barton Wilmore on behalf of Gallagher

21

339 SA4.2

3.0 SITE ALLOCATION SA4.2 SUGAR HOUSE LANE. 3.1 Our client supports the identification of land at Sugar House Lane as a location for growth. However it is our submission that as drafted the policy is not effective as per para 182 of the NPPF and is therefore unsound. Specifically as drafted the Policy: • Lacks clarity and does not provide a clear basis from which a decision maker should react to a

development proposal or therefore for a developer(s) preparing a scheme(s); and • Is overly prescriptive, has the effect of enshrining the planning permission into planning policy and as a result does not

provide sufficient flexibility toguide future planning


340 SA4.2

It is noted that the same template is used for each Site Allocation. Unlike the topic based policies there is no clear distinction between the policy, reasoned justification and the policy application. It is unclear from the Site Allocation template what is policy wording and what is the justification/explanatory text. This is an important distinction as it goes to the core of how a decision maker should react to a future development proposal (see Para 154 of the NPPF). The use of standard headings also leads to an unnecessary level of detail, repetition and prescription within the allocation. It serves to reduce flexibility and burdens the Local Plan with matters that would be more appropriately addressed through an SPD, a design brief or indeed application(s). The level of detail of policy should be sufficient to ensure that the policy is effective. The approach taken is counter to this. We consider the various sections of the policy below having regard to the paragraph above. In short we would suggest that only the text currently shown in bold, together with a plan identifying the location of site, should comprise the policy (both subject to revisions considered below). With the remaining text deleted or, where appropriate, clearly identified as justification/explanation.


341 SA4.2Support the principle of the allocation and the reference to mixed use development. Concerns regarding the effectiveness of the policy wording. 3.7 The reference to delivery of ‘up to 1,200 new homes’ is

overly prescriptive and limits the development potential of the allocation. To limit the overall number of units to reflect just one scheme lacks flexibility.REP.LP.035 Victoria Bullock, Barton


342 SA4.2

In the context of policy SP.2 and the London Plan housing targets there should be greater flexibility and aspiration within the Site Allocation SA4.2. To ensure the policy is effective, we suggest that the wording be changed to ‘a minimum of’ of 1200 dwellings. 3.9 The reference to medium density also lacks flexibility and as drafted the policy implies a prescriptive standardised approach. 3.10 We would suggest the

following: “A new medium-density, mixed-use area including business (cultural and creative) and local retail space focused in the northern and southern part of the site; up to a minimum of 1,200 new homes as

a range of densities with a significant number of family homes, Local Open Space and public realm. A new all-movements junction to enable access to the area and new bridges to link the area to surrounding communities will be required alongside development.” It is unclear whether the remaining text forms part of the allocation and this should be clarified. Reference to ‘retaining a strong employment focus’ is at

odds with the need to review employment land in the context of meeting housing needs. Suggestion that the reference to employment focus is a function of the existing planning permission and approved disposition of land uses. Suggestion of the following text: “The area should adopt a genuinely mixed-use character retaining a strong with employment focus that includes a base for creative industries and

introduces a new residential community served by a range of local amenities and high quality public transport, pedestrian and cycle connections. The area will be defined by its unique natural environment and historic industrial legacy that includes extensive canal and river frontage, robust yet adaptable buildings and intricate yards and passages. The historic character of the 23810/A5/VB Page 6 October 2014 Publication Version Local Plan 2015 – 2031 Site Allocation SA4.2 Sugar House Lane area should be created by weaving high-quality new buildings into the historic fabric”


343 SA4.2

The Plan. 3.13 The plan that accompanies the allocation effectively enshrines the planning permission into policy. Specifically the proposed employment designation is a replication of the approved Parameter Plan Uses at Ground Floor PP-1-104. 3.14 Anyone can secure planning permission on third party land. We would suggest that the approved scheme was not prepared inclusively and does not have the full support of landowners, evidenced by the fact that our client was not party to the S106 Agreement. In short the permission directs employment uses to land not in LandProps control. In our view little weight should be attached to the approved disposition of land uses as they were not based on landowners agreement or commercial reality and may not be effective or deliverable (as per para 173 NPPF). A Local Plan that then enshrines the approved scheme into policy in turn raises questions of its effectiveness and deliverability. 3.15 The plan implies that there is only one scheme for the site, whereas it is possible that the allocation headlines could be achieved by numerous iterations/schemes. The Allocation should not tie policy to a scheme only capable of implementation through CPO. A developer/landowner may chose not to build out the planning permission and seek an alternative scheme on all or part of the site with different configurations / disposition of land uses to better reflect market demand and commercial reality at that point in time. The Plan lacks flexibility and could frustrate that approach and thus aspirations of the allocation. Again, a Local Plan that enshrines the approved scheme into policy in turn raises questions of its effectiveness and deliverability. 3.16 The plan also lacks clarity, for example one interpretation could be that only employment uses are to come forward in the designated area to the north of the allocation, this being the general approach of the permitted scheme. As noted above, this lacks flexibility and could limit the ability of developers to bring forward effective and deliverable schemes. In our view the policy aspirations of the allocation could be achieved through a mixed use development in this location with commercial/active uses to the ground floor with residential above. This would reflect the higher public transport accessibility in this location, together with the benefit of providing both frontage and activity to Stratford High Street. Notwithstanding the above it is not the role of the allocation to masterplan the site.Rather the allocation should be independent of the planning permission, and any other masterplan, and instead set the policy basis for the assessment of future applications on all or part of the allocation. 3.17 As drafted the Plan and approach is not effective and fails the soundness test as per para 182 of the NPPF. Our concerns in respect of the plan could be addressed by a revised plan that simply identifies the extent of the land the subject of the allocation (see appendix 2). This should be accompanied by a corresponding change to the Vision at page 205. This together with policy wording that then enables the sites within the allocation to come forward separately subject to demonstrating compliance with the overall vision for the allocation and providing their fair balance of land uses in accordance with the policy objectives.


344 SA4.2

Development Principles. 3.18 In our view the development principles do not add to the policy and should be deleted. Should the LLDC wish to retain the text it should be clarified as whether it is policy, reasoned justification or policy application. We would also make comment on the detailed provisions below. 3.19 We object to the reference to ‘a high proportion of family housing – at least 40% (three

bedroom and larger) – will need to be provided’. Taken on its face, as drafted the policy reads as though all schemes that come forward, regardless of their location, housing need or scheme viability will be

required to achieve 40%three bedroom plus homes. This fails to acknowledge the different possible character areas within the allocated site and the role of different sites in terms of housing provision and need as they come forward. 3.20 We would suggest that in the context of the bold text of the policy stating a preference for ‘a significant number of family homes’ that this development principle can be deleted. 3.21 In terms of the

reference to designated heritage assets and the need for high quality public open space, these are policy matters that are covered by the provisions Local Plan or NPPF and we would query the need to repeat them.


345 SA4.2

Phasing and Implementation. 3.22 The emerging allocation refers to the extant planning permission providing/enhancing bridges linking the peninsula to Bromley-by-Bow and to Three Mills highlighting that equivalent provision would need to be made if any new application comes forward or if the permitted scheme is amended. 3.23 Again, the above approach is inflexible. Policy needs to stand alone and separate of the permission and set the policy basis for the consideration of future schemes. This does not necessarily mean the reprovision of the same solutions permitted in the context of a different scheme. We would query the need for this section as even redrafted, it is likely to burden the Local Plan with matters that would be more appropriately addressed through the SPD, a design brief or indeed application(s).


346 SA4.2

Relevant Planning Policy. 3.24 As noted above, this provision should not form part of the policy as it represents a matter of fact and context rather than a provision against which any future applications should be determined. Moreover it is a point in time comment that is likely to date quickly in the context of the plan period. Summary 3.25 As drafted the Site Allocation is not effective and is therefore unsound. Our concerns could be addressed by: • Clarity regarding what constitutes policy, reasoned justification and policy application; • Amendment of what is understood to constitute policy as per paragraphs 3.10 and

3.12 above; • Replacement of the current Site Allocation plan with a redline plan (see enclosed at Appendix 2); and • Deletion of the Development Principles, Phasing and Implementation and Relevant

Planning History sections of the allocation or if retained amended as per the above.


348 SA4.2Appendices submitted showing land ownership boundary and allocation boundary. REP.LP.035 Victoria Bullock, Barton


359 SD.1Support for policy SD.1 REP.LP.036 Owen Whalley, LB Tower

Hamlets

22

353 Vision

Welcomes the LLDC's commitment to bringing forward a new Local Plan that supports the achievement of the convergence principle set out in the Host Borough Strategic Regeneration Framework (SRF) produced in 2009. The council broadly supports the Introduction (section 1),Our Area (Section 2) and Our Vision (Section 3) in the LLDC publication draft local Plan. However it is considered that a map showing administrative boundaries (such as Figure 1.4 in the draft Local Plan) should be included with the document alongside a profile of the sub areas. While it is recognised that information is provided in Section 9, The Local Plan Sub Areas it is felt that this section could be strengthened through providing detail on the existing condition and character rather than concentrating on the potential. It is similarly felt that a profile of Tower Hamlets and the other Growth Boroughs should be provided. In drawing a picture of the pervading influences on the area especially in the context that the LLDC area only has a small existing population, it would be beneficial to provide a strong context in relation to the four boroughs. An understanding of the profile of the four boroughs will enable a more sophisticated integration of future development with the surrounding social, economic and environmental landscape. Regarding the vision for the legacy Corporation in 2031(page 14), it is considered that the projected outcomes of the convergence principle should be identified. Consequently, further commentary on employment, education and health indicators in a manner similar to the final paragraph of 'A vision for the legacy Corporation Area Creating Jobs and Communities' (page 36 of the LLDC draft Local Plan) should be provided.

REP.LP.036 Owen Whalley, LB Tower Hamlets

360 SP1

Generally support but should reflect generation of opportunities for local businesses. Change to insert local before national and international in bullet one. Policy makes no reference to supporting office floorspace for SMEs at 250sqm and 100sqm to align with LBTH planning policies. As emphasising flexible and interim uses policy should be entitled with the word flexible in addition. Policy should affirm stronger connections between economy and employment levels as delivery of new jobs has not been discussed. Should include a map on the clusters.


361 B.1

Generally support but part 5 could be rationalised with focus of maintaining and re-providing job density. Part 5f should be strengthened to state that viability appraisal considers marketing for 12 months, has considered alternative employment uses and its location, accessibility, size and condition make it unsuitable for continued employment. Should amend description of Wick Lane and Crown Close to Local Industrial Location, making clear it is a transition area from SIL to residential at FI Mid with emphasis on function being modern light industrial providing smaller flexible space. Should alter text for Bow Goods Yard East and West to make effective use of the railhead including the existing, planned or potential use of the railhead for aggregate distribution’. Should include map of clusters.


362 B.2

Generally support but should include management of the night economy to protect amenity. Bullet 1 seeks to resist harm from concentration of A2 and A5 but A5 could be further detailed in line with LBTH planning policies which states A5 should not be more than 5% of total units in centre. Should outline understanding of the centres to improve integration with surrounding environment. Should include map showing detailed centre boundaries.


363 B.3Support but should consider community growing projects on interim sites. REP.LP.036 Owen Whalley, LB Tower

Hamlets

364 B.4Support but should amend text to 'New managed workspace and/or low cost workspace will be encouraged where it:' REP.LP.036 Owen Whalley, LB Tower

Hamlets

365 B.5

Generally support but not sufficiently robust. Should include jobs and training targets both as percentage to be targeted at local residents and for financial contributions to support training provision. A minimum target of 20% is appropriate and would assist in deriving benefits for the local community. Policy does not refer to procurement of the local supply chain. LBTH would expect use of local suppliers to account for 20% of the value of contracts let for the construction phase. This was secured at Neptune Wharf. Should make explicit that developers will be expected to work with the growth boroughs nominated organisations to maximise opportunities for local firms to win contracts through procurement procedures.


366 B.6Support. REP.LP.036 Owen Whalley, LB Tower

Hamlets

354 Business Growth

Welcome commitment to retaining and promoting employment uses to enable growth of east London. Regrettable there is no target for opportunities for local businesses to benefit from the construction phase, potential occupation of the employment space or supply chains. Should identify an appropriate target in line with LBTH policies which is set at 25%. Sections do not reference serviced apartments and hotels are only discussed in site allocations and a policy on this would be beneficial given the number of tourist attractions and business destinations. Also absence of discussion on the night time economy.


350 SP2SP.2 and H.1 not sufficiently robust to maximise delivery. Specifically absence of a % based affordable housing target and family homes across all tenures. Family housing targets should draw on LBTH requirements outlined within their current policies. Not enough safeguards to ensure housing is sufficiently affordable.


367 SP2

Object to SP.2 and question soundness on grounds of total sum figure for affordable housing rather than %, and should state 35% within SP.2. Expression minimum target is not helpful and 445 should be clarified as 445 units. Minimum sum figure does not present robust mechanism to deliver in excess of this and does not align with the 35% within adopted LBTH planning policies. Tenure and mix policies are based upon the 2009 TH SHMA and recent trends show delivery falling so need to provide more. LBTH expect affordable provision within its area to be available to TH residents for nominations but also where land given to employment use rather than housing expect to be able to nominate tenants for housing within other parts of the LLDC area.


368 H.1

Object to policy and soundness questioned for reasons of lack of family housing target, does not safeguard loss of family housing and more detail and clarity required. LBTH seek 20% of market housing as 3+ beds, 25% of intermediate housing as 3 bed, and 45% of social/affordable rented housing, and without this not robust enough to deliver housing needed for Tower Hamlets residents. Paragraph 5.9 should state all proposals should provide 'an appropriate balanced mix of one, two-and three+ bedroom units and family housing secured aligned with LBTH planning policies. Should also qualify how expect applicants to show how provision of family housing has been maximised. Should state target of 10% of habitable rooms to be wheelchair accessible within the policy. LBTH officers concern about undeveloped character of area and existing provision should not prejudice more affordable housing provision. Question the use of the phrase design considerations within bullet 4, should replace with design standards. Table within GLA SHMA shows that the number of families is projected to grow but proportion remain unaltered. Figures outlined do no deal with full assessment of backlog need for affordable housing so should have further detail on targets for family housing. An overly conservative approach has been undertaken to viability in the Combined Policy Viability Study and there more scope for enabling more family sized housing.


23

369 H.2

Object to policy and question soundness for reasons of the 60/40 Split in affordable housing, lack of percentage target for affordable housing, need for greater clarity with regard to off-site affordable housing provision and capping of rents. The 60/40 split does not comply with LBTH policies which specify a 70/30 split. A percentage based target for affordable housing will maximise delivery and allow for affordable housing uplift units goes beyond the London Plan targets. LBTH policies sets a target of minimum 50% target for Affordable Housing overall. This policy suggests that the off-site location should be required to meet its own Affordable Housing requirement of the proposed 35%. Should reword to: 'Offsite provision will only be considered where it provides a greater number of affordable units than that of, and in addition to the on-site provision'. Plan should clarify and define 'identified needs and tenure requirements', the affordable housing targets and delivery rates, and application of part 5. Should break down paragraph 5.14 to reveal the complex content. The commitment for half of the affordable rented product to include rental rates capped and the remainder with typical rents of less than 80% of market value including service charge is not based on evidence and is not a London Plan policy and is not an appropriate measure to adopt. 80% of market rent is not affordable to the LBTH average incomes for those in housing need and LBTH officers have concerns about establishing local market rents given the absence of stock in the area. The LBTH and GLA agreement for Affordable Rented encourages providers of AH to adopt blended rents in between the 'discounted' and 'capped' levels and LBTH also issues annual guidance on appropriate rent levels. Statement 'In practice, the Legacy Corporation is not setting specific local rental caps, but will expect developers and registered providers to agree the proposed rental levels, maintained as low as possible, based on meeting local Borough needs, benefit caps and maximising output' does not provide any clear mechanism on how rental levels which should be based upon local Borough guidance on Affordable Rents which meet local needs. Should amend sentence 'subject to the availability of appropriate funding, delivery of social rented accommodation within the area will be supported' to delivery of social rented accommodation within the area will be supported and encouraged for the largest family units when viability permits it to be provided as part of a larger mix of tenures.'


370 H.3 Support but should be changed to The Legacy Corporation will encourage provision of....' REP.LP.036 Owen Whalley, LB Tower Hamlets

371 H.4 Support but should include reference to overconcentration and pressure on infrastructure. REP.LP.036 Owen Whalley, LB Tower Hamlets

372 H.5 Support REP.LP.036 Owen Whalley, LB Tower Hamlets




Concern that the Plan will not deliver sufficient primary and secondary school places or safeguard the provision of a secondary school at Fish Island East I Sweetwater is provided for within the Fish Island Area Action Plan (FlAAP). Further clarification as to why the site allocation is not reflected in the LLDC Plan given the allocation has been subject to lengthy discussion and was ultimately found sound. The LLDC should identify how they intend to meet needs identified.



Policy not sufficiently robust in ensuring affordable housing delivery beyond the 455 units, so ability to meet need. Should incorporate the 35% figure into SP.2 which would assist in maximising delivery on each site and vision for mixed and balanced communities. Similar approach should be taken to family housing with a % figure across all tenures. These issues exacerbate low estimated provision for affordable and family housing within site allocations, where support for target within these allocations supported.



Provision of health facilities is also considered to be significantly underrepresented in this plan. Only one Health Centre has been provided in the site allocations yet the LLDC's Infrastructure Delivery Plan (lOP) predicts that development will result in approximately 48,000 new residents by 2031 and considering national standards other sites should be allocated to deliver health facilities.


375 CI.1

Question soundness becasue of insufficient provision of health centres, and being largely silent on provision of new community facilities. Note that only one health centre has been provided in site allocations, yet IDP predicts that development will result in 48,000 new residents by 2031. The LLDC should set out the following to justify the site allocation of only one health faciilty: • The extent of engagement with the

NHS to establish that the provision of only one facility is appropriate. • Identify facilities within the four relevant local Authorities that have capacity to accommodate need arising from development in the LLDC

area and set out the extent of the capacity of the facilities.LBTH officers propose that at least two other sites are allocated to deliver health facilities. It is considered that this policy should take a positive approach to the delivery of new social I community facilities and identify priorities. It is noted that the sole allocation is a library at the Sweetwater site allocation.


376 CI.2Object to policy and question soundness. Considers that there is aloss of potential provision of a secondary school at Sweetwater . Further clarity is required to demonstrate sufficient provision of school places based on need given the population generated from development as well as existing and planned supply across the LLDC and growth boroughs . This policy does not align with the Fl AAP Policy Fl.46 whereby, Fish Island East (known as Sweetwater in the LLDC Local Plan) established a site allocation for a primary school or


377 SP3 Supprt for SP3 REP.LP.036 Owen Whalley, LB Tower Hamlets

378 BN.1 It is suggested that this policy could be strengthened through detailing what is meant by 'place' and 'local distinctiveness'.This is considered to be particularly important as the sub area profiles do not give sufficient information on the existing identity,character and local distinctiveness of places.


387 BN.10It is considered that the structure of this policy should be altered and that greater clarity should be given to 1) the details of the centre boundaries as these have not been fully identified or explained and 2) the order of the hierarchy for example is Stratford Town Centre the first preference for tall buildings, with Bromley-by-Bow being the second preference. It is also considered that the second part of this policy,referencing the hierarchy,should be at the start of the policy.


388 BN.11Generally support BN.11. Potential inclusion of site based interventions within site allocations. Policy should reflect the need to minimise the effects of adverse noise pollution on the local population. REP.LP.036 Owen Whalley, LB Tower

Hamlets

389 BN.12 Support REP.LP.036 Owen Whalley, LB Tower Hamlets

390 BN.13Gernerally support BN.13. Outline of Tower Hamlets policy and suggested incorperation of elements regarding the process of remediation and the storage of hazardous substances. REP.LP.036 Owen Whalley, LB Tower

Hamlets

391 BN.14Part 3 of this policy is strengthened to also state that extensions should be subsidiary to the host building and is a positive addition to the host building. REP.LP.036 Owen Whalley, LB Tower

Hamlets

392 BN.15Support REP.LP.036 Owen Whalley, LB Tower

Hamlets

393 BN.16 Support REP.LP.036 Owen Whalley, LB Tower Hamlets

379 BN.2 Support for BN.2 REP.LP.036 Owen Whalley, LB Tower Hamlets

380 BN.3

Support for Biodiversity policy. Amendments to SINC mappping nessesary. Duty to consider QEOP as a SINC. REP.LP.036 Owen Whalley, LB Tower Hamlets

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381 BN.4

No mention of the provision of private amenity spaces. There should be a clear strategy about not accepting schemes that result in overlooking or privacy issues throughidentifying degrees of tolerance. Planning decisions are made on balance and there is no need for further dilution of good place making principles through using phrases such as 'unacceptable loss of privacy' and 'unreasonable degree of overlooking'.


382 BN.5 BN.5 Requiring inclusive design SUPPORT LBTH officers would like to see the insertion of a minimum target for delivery of 10% wheelchair accessible units within this policy. REP.LP.036 Owen Whalley, LB Tower Hamlets

383 BN.6General support for BN.6. Include reference to amenity value. REP.LP.036 Owen Whalley, LB Tower

Hamlets

384 BN.7Support for Local Open Space. Include public rights of way. REP.LP.036 Owen Whalley, LB Tower

Hamlets

385 BN.8 Support fot BN.8 REP.LP.036 Owen Whalley, LB Tower Hamlets

386 BN.9Support REP.LP.036 Owen Whalley, LB Tower

Hamlets

394 SP4

Further clarity is required to demonstrate sufficient provision of school places based on need given the population generated from development as well as existing and planned supply across the LLDC and growth boroughs . This policy does not align with the Fl AAP Policy Fl.46 whereby, Fish Island East (known as Sweetwater in the LLDC Local Plan) established a site allocation for a primary school or secondary school. The policy also conflicts with Policy DM18 of the Managing Development Document which seeks to 'safeguard the potential for schools in accordance with site allocations'.


395 IN.1Generally Support IN.I. It is suggested that there should be reference to clutter and movement on the street where telecommunications infrastructure is proposed as this will assist maintain ease of movement. REP.LP.036 Owen Whalley, LB Tower

Hamlets

396 IN.2

Considers that this policy is not consistent with site allocation SA1.3 Hepscott Road 2.and that part 7 may not be feasible and therefore the loss of a site should only be permitted where part 4, and 6 apply and that the proposed arrangements are to the satisfaction of the borough and the GLA (as established in SA1.3) It is suggested that this policy is not in agreement with SA1.3 Hepscott Road. Policy JN.2 states that the loss of an existing waste management facility would only be permitted where it can be demonstrated that an additional waste management facility has been secured andis deliverable,and meets other conditions one of which is that the new site is in the same waste authority area or waste authority groups as the origina• site.

LBTH's officers support the resolution within SA1.3 Hepscott Road in which the loss of a safeguarded site can be acceptable where the 'capacity of the site can be resisted unless it can be demonstrated this capacity can be more efficiently re-provided elsewhere within London.Any such proposal must ensure that such an approach counts towards the Borough's overall waste apportionment target (to the satisfaction of the Borough and the GLA).'It is suggested that alternative locations For waste management sites in LBTH are not readily available.This has been demonstrated through the Local Plan process.


357 Infrastructure

Although section 205 of Localism Act 2011 provides an MDC with a mandate to deliver infrastructure, the legislation does not clearly provide an MDC with powers to manage or operate public services. LLDC should clarify its intention in respect of these powers. All parties should be clear of their responsiblities regarding infrastructure delivery, operation and maintenance.


397 T.1 T. Strategic Transport improvements SUPPORT It is considered that LLDC make a greater commitment to making the case for a Crossrail 2 station at Hackney Wick. REP.LP.036 Owen Whalley, LB Tower Hamlets

406 T.10 Support REP.LP.036 Owen Whalley, LB Tower Hamlets

398 T.2 T.2 Transport improvements SUPPORT REP.LP.036 Owen Whalley, LB Tower Hamlets

399 T.3

T.3 Supporting transport schemes GENERALLY SUPPORT The intention of this policy is unclear.Do all the six criteria have to be met or will they each be judged on a case by case basis? LBTH officers are concerned that highway schemes that improve vehicle capacity would be supported if it can be demonstrated they support growth.Encouraging these types of schemes would be contrary to transport policy and infrastructure delivery in LBTH - which seeks to ensure growth in movement takes place using sustainable modes- and indeed Objective 4 of the Plan. Policy should be re-worded to be clear that highways capacity for cars will not be supported.


400 T.4

T.4 Managing development and its transport impacts GENERALLY SUPPORT Part 4 of the policy should read 'minimal' instead of 'minimum'. It is not necessary for all development to have a travelplan as the policy implies. The need should be based on a case by case assessment of the potential level of car trips generated by the site and as such it is suggested part 8 of this policy is amended.


401 T.5

GENERALLY SUPPORT Although Highways share the aspiration in Table 7 that Carpenters Road should serve as mainly an access road to the Olympic Park, nonetheless it will form part of a through route offering attractive time savings for driver between the A12 and Stratford. It would be useful if the Plan stated that designations under Table 7 would be under review and LLDC consider or support traffic management measures to mitigate excessive through traffic should this arise.


402 T.6T.6 Facilitating local connectivity SUPPORT It is considered that part 3 of this policy is quite confusing. If new connections are to be designed as adoptable highway then the legislation used to adopt them is not s106 TCPA. If routes through are not to be adopted as highway then why would they be adoptable standard?


403 T.7

T.7 Transport Assessment and Travel Plans SUPPORT It may be useful for the policy to mention that Transport Statements may be required instead of a TA -again judged on a case by case basis. REP.LP.036 Owen Whalley, LB Tower Hamlets

404 T.8

T.8 Parking and parking standards in new development OBJECT, soundness questioned Reason for objection: 1. Car parking permit free agreements should be supported in areas of good PTAL rating The parking standards do not offer additional safeguarding in addition to those in the London Plan. Increased car trips on local networks (including the notorious A12) need a more robust car parking policy and this should be pursued in the Plan. As a minimum,it is expected that the relevant borough standards apply where they are more restrictive than the London Plan.This is particularly the case in the LBTH scenario which has been recently adopted (2013) and has been tested against the NPPF and London Plan. There should also be a specific reference to requiring car parking permit free agreements in areas of good PTAL,high parking stress and/or for major development. Part 1 of this policy should read 'minimal' instead of 'minimum'.


405 T.9 Support REP.LP.036 Owen Whalley, LB Tower Hamlets

407 SP5 SP5:Delivering a sustainable and healthy place to live and work SUPPORT REP.LP.036 Owen Whalley, LB Tower Hamlets

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408 S.1S.1 Health and Wellbeing SUPPORT It is considered that all major developments should carry out a Health Impact Assessment and the results of this should be submitted as part of any detailed planning application in line with the london Plan provisions.This would be more of an effective way to address all the factors mentioned this policy.


409 S.2

S.2 Energy in new development GENERAL SUPPORT The C02 emission reductions proposed do not align with Tower Hamlets Policy DM29 of the Managing Development Document. They are 10% lower than the Tower Hamlets Local Plan. It is also noted that that the emission reductions are assessed against a building regulations 2010 baseline. Given that Building regulations 2013 are already in force, and applications must be registered against this, it suggested that this is updated to represent a C02 saving against a building regulation 2013 baseline. The non-domestic element of the policy is based on the assumption that 2016 building regulations will offer a betterment to the 35% reduction currently being requested. However, it is unlikely that a >35% improvement on the current buildings regulations will materialise, which will result in worse performing buildings (in terms of C0 2 emissions) being consented through this period, than currently required. It is recommended that a % reduction in C0 2 emissions on building regulations is applied to developments through the period 2016 - 2019.


410 S.3S.3 Energy infrastructure and heat networks SUPPORT REP.LP.036 Owen Whalley, LB Tower

Hamlets

411 S.4S.4 Sustainable design and construction SUPPORT REP.LP.036 Owen Whalley, LB Tower

Hamlets

412 S.5

S.5 Water supply and waste water disposal SUPPORT. Clarity should be provided on why the Thames Tideway Tunnel was built.It was not built to deal with water storage (even though this is betng undertaken),but its main purpose is to improve water quality of the River Lea and Thames in line with the River Basement Management Plan (RBMP),by holding foulwater that would normally be drained into the rivers,during large storm events.


413 S.6

S.6 Waste reduction GENERALLY SUPPORT LBTH officers strongly request that this policy deal with the management of waste collection arrangement so as to ensure that 'future collection options' are consistent with the four growth , borough's waste collection arrangements.


414 S.7S.7 Overheating and urban greening SUPPORT REP.LP.036 Owen Whalley, LB Tower

Hamlets

415 S.8

Supports the policy. Suggests that a hierarchy table of SUDS is inserted. It is also suggested that a reference is made to state that source control SUDS are also preferred. At paragraph 8.22 it is suggested that reference is made to DEFRA consultation on Section 9 of the Flood and Water Management Act. It is proposed that SAB is replaced and any sustainable drainage approval will go through lhe normal planning channels


352 Sub Area 1 Concerned that the site allocation in Sub Area 1does not accord with the Fish Island AAP specifically with regard to not providing an option of a secondary schoolon Fish Island East REP.LP.036 Owen Whalley, LB Tower Hamlets


In general, the Council supports the overarching principles set out in the LLDC Publication Local Plan document. One key concern for the Council however,is that a number of policies are not in line with Tower Hamlets' Adopted localPlan,which has been subject to extensive consultation and engagement,including with the LLDC, and has been found sound as part of an independent examination in public. Key areas of inconsistency are highlighted below.



There are a number of assumptions made within the Combined Policy Viability Study which indicate that an overly conservative approach has been undertaken. The assumptions/variables which could be considered as overly conservative or having potential for further testing/investigation are site typologies, build costs, gross to net ratios, marketing costs, CIL payments, CIL discounts.


417 Our Area

Description of area is incomplete or inaccurate. Mention of redevelopment for housing does not mention demolition of former estates. Mayor’s foreword confuses Stratford City and the Park. Description refers

to under-utilisation of land but not removal of the businesses which were using land before Games. Reference to 100ha of local open space but not local MOL at Eastway which included a nature reserve, land on park or that LOS includes pathways, concreted areas and playing field. Park claimed to be ‘largest new urban park in Europe for 150 years’ but is larger park in West London which is less than 20 years old.

Open space at 100ha shrunk from 129ha projected, alterations to the south and may shrink again. Fails to reveal value of land for housing development as contains rivers and canals. Businesses would have benefitted if they has not been forced to sell at industrial prices. References to deprivation, poor qualifications and unemployment as reasons for development fail to show how Games have made this worse. Land described negatively in past shows how pressure for intervention. Message that Park formally contained only gardens is incorrect as housing estates, industrial, parks, churches and cycle track were previous uses. Area has potential and value for housing development.

REP.LP.037 Julian Cheyne

418 Our Area

Convergence goal irrelevant if statistics describe arrival of more prosperous population which will be the result of policies. Carpenters Estate as a case against sustaining stable communities, there is no indication this can be achieved and arguable that is no stable. Plan gives no guidance on how comunity is to be sustained and suggestion of increased density implied demolition rather than refurbishment. Previous occupiers have lost their place and secure tenancies. Supposed to have right to return but no statements are made in this section about such rights. No understanding that LLDC understands deprivation and how manipulated to jutify change. Use of convergence is prejudicial implying movement on both sides to meeting point.


419 Our Area Jobs within Park were industrial and done by local people. Alteration of area to include new job types not discussed. How will new jobs for local people meet needs of present population. REP.LP.037 Julian Cheyne420 Our Area Refer to areas of potentially contaminated land and remediation is a case study later in the Plan where states engagement took place as part of decontamination. REP.LP.037 Julian Cheyne

421 Our Area Park was a functioning industrial area before Games, survivors being at Hackney Wick Fish Island. One option was to place Athlete's village at Fish Island which would have been lost but now recognise the heritage value and designated a Conservation area.


422 Our Area Area had thriving communities, but were areas of derelictio in industrial areas. Opinion against these areas has been prejudiced. Lower Lee Valley has a future without the Games. REP.LP.037 Julian Cheyne423 Our Area New environment less hospitable to wildlife. REP.LP.037 Julian Cheyne

424 Our Area

Summary doesn’t acknowledge presence of radioactive material. Claim that rigorous engagement has taken place not correct as did not heed warnings from residents about radioactive material. Dismissed

warnings from HSE and DEFRA and contractors were having to issue unexpected find notices one material emerged, failing to inform Planning Decisions Team. Site covered with plastic sheet warning of need for further remediation. Clays Lane residents lived on a contaminated site for 25 years without remediation. Land didn’t need to be dug up and remediated as parkland, by carrying out this remediation made

more hazardous. LLDC doesn’t appear aware of radioactive store on Sweetwater site. No response to complaint about works at Stadium.


433 VisionImpossible to tell from maps what will happen in the area. Parts of Carpenters Estate do not appear on the key diagram and Sub Area 3 map only shows Rick Roberts Way designation. REP.LP.037 Julian Cheyne

437 B.1

B.1 referred to within SA3.4 allocation. Lack of detail in this policy in relation to the Carpenters Estate as is not listed in Table 2 as cluster. Cannot determine how opportunities for local people will be sought. Language relating to release from designation at Leyton Road north suggests designation is a burden rather than loss of job opportunities. Comparing designation of Rick Roberts Way and lack of at Carpenters suggests one has protection and other does not.


438 B.1 Designations have been changed at Leyton Road, Rick Roberts Way and Eton Manor so how much reliance can be placed on designations within the Plan? REP.LP.037 Julian Cheyne

26

427 Business Growth

Almost 5000 jobs have been moved out of Park which would still have been available for local people. REP.LP.037 Julian Cheyne

436 H.1No discussion about affordable and social housing which relevant to Carpenters. Policy H.2 not cross-referenced. REP.LP.037 Julian Cheyne

429 H.5Clays Lane Traveller community moved to Leyton Road. Removal of communities to enable Olympic project benefits. REP.LP.037 Julian Cheyne


Games led to destruction of estate at Clays Lane which provided student housing and housing up to 1000 people. Housing loss not referred to in Plan and not taken into account. REP.LP.037 Julian Cheyne


Lack of job opportunities and meeting needs of present also false assertions about affordable housing where different targets claimed in past. From 50% to 35%, 33% and 28%, depending on whom you listen to. Claiming delivery of 33% across the Park yet the target for Cobham Manor is only 28% so other sites would need well over this to achieve this. Targets do not take viability into account where statement about 20% made recently. East Village does not provide the 50% claimed and the affordability questioned. LLDC starting from a clean slate not taking account of housing lost. Residents of Clays Lane were re-housed which not necessarily the case and this was a loss of very affordable housing. Do not include loss local opportunities in calculations, if it did so % affordable housing would be much lower. The amount of housing provided is falling, which will be more of case now UCL to go onto Park. Further loss with transfer of school from Rick Roberts Way to housing site next to stadium, making it harder to achieve affordable housing targets. Housing also reduced at Stratford City from 500 to 2800 costing public purse £275million. This is a loss of opportunities for local people as a loss of affordable housing.



Should designate other areas such as Wise Road and Kerrison Road as residential neighbourhoods. Been there longer than East Village. REP.LP.037 Julian Cheyne


Hackney Wick and Fish Island for the most part does not have any particular designations, only conclusion is open to demolition. REP.LP.037 Julian Cheyne

428 Sub Area 2

Considers the lack of reference to allotments at Eton Manor and the recent planning permissions granted by LLDC and London Borough of Waltham Forest repsectively to retain the relocated allotments from the Olympic Park in location to which they were moved rather than reproving a proportion of these at Eton Manor as previously planned to be a broken promise that considers did not involve consultation with those affected. Considers that the protection provided to the cluster of businesses to the north of the Chobham Farm has been removed by the plan and presumes that this is becuase further residential development is planned here.


435 SA3.4Carpenters Estate contains housing and industry and no discussion in this section on this. Status of residents is relevant given sustainability and no discussion of opportunities for local people and needs of the present.


434 SA3.5 Few designations within Sub area 3 is SA3.5 where allotments are proposed but this originally applied also to allotments at Eton Manor which now removed. REP.LP.037 Julian Cheyne

432 SA3.6 Inclusion of a school in SA3.6 is inaccurate and being changed without consultation. REP.LP.037 Julian Cheyne


Difficulties in understanding documents. Hard for objections to be made in the required way and cannot be described as public consultation. Plan is flawed and unsound. Definition of sustainable developemtnand aim of new heart for east London for local people are key, specifcally 'present' and 'local' which are undefined and not within the Sustainability Appraisal. Does not indicate it will meet local needs, more likely displaced and marginalised. in the SA there was No Plan option which was rejected. Plan has not examined impacts of removal of residents and businesses for the Games.



No mention of Community Land Trust planned at Chobham Manor. Disgarded rush to banish deprivation. Failure of participation identified in proposal on Rick Roberts Way, illustating fragility. Newham and LLDC reached agreement to place school planned for this site adjacent to stadium through private discussions.



Questions principles of engagement within Newham planning documents and Local Plan. REP.LP.037 Julian Cheyne


No mention of efforts of Carpenters residents to develop community plan or moved towards neighbourhood plan and forum. If concerned about supporting local people should include reference within the Plan. This work carried out by unpaid members of the community.



Lack of definition of 'present' and failure to represent the recent past, alteration of designations without consultation and breaking of promises, so cannot be relied upon to create opportunities for local people. Problem with Plan as a whole and way LLDC operates.


443 Objective 2Support for Objective 2 to establish and maintain locally distinctive neighbourhood which meet housing needs while providing excellent and easily accessible social infrastructure. This means delivering approximately 24,000 new homes and ensuring homes are accessible to and affordable for a broad spectrum of community as well as meeting specialist accommodation needs.

REP.LP.038 Frances Young, NLP on behalf of East Thames Group

444 H.1

Important to provide a range of dwelling sizes and types, so support aims of policy but should have some flexibility in terms of unit sizes and changing needs over time. Should review housing needs on regular basis, so should amend to: 1. meet identified local and strategic requirements, containing which is currently for a mix of one-two- and three-bedroom units and larger, with units of two bedrooms and more constituting more than half the total. Account should be taken of subsequent housing needs assessments carried out during the plan period to determine the appropriate mix. This should also be reflected in paragraph 5.9 by adding “and specific needs identified in the most recent Housing Need Assessment for the local area”. This will ensure policy is justified.


445 H.2

Policy H2 seeks to maximise affordable housing on sites capable of providing ten units or more, as 60% affordable rent/social rent and 40% intermediate. This should be written as an aim to be reviewed on a scheme by scheme basis in liaison with registered providers. Policy states that will consider the needs and tenure requirements, affordable housing targets and delivery rates, need to facilitate development and viability which is supported. Paragraph 5.13 then notes that the minimum target for affordable housing is for 35% across the area, again there is need for flexibility on a site by site basis. Paragraph 5.14 recognises flexibility in setting local rental caps, whilst paragraph 5.15 recognises that viability may vary across the development acknowledging scope to re-appraise viability prior to each subsequent phase .Support for this flexibility. Use of Chobham Farm as a housing mix case study - acknowledges that the proposed mix of the first phase is well balanced. This also refers to the re-assessment mechanism to ensure that the maximum viable proportion of affordable units is provided in subsequent phases. The proposed amendment to Policy H2 to allow flexibility in breakdown of affordable housing would make policy “justified”.


446 SA2.1Considers that the Chobham Farm Site Allocation SA2.1 should be extended to include the strip of land to the north of the site allocation (north of Henrietta Street) that is part of the Chobham Farm Scheme that has planning permission for employment uses in this location and considers that this could be appropriate for housing in the longer term.


450 BN.10SCBD considers that it would be inappropriate to permit buildings any taller than those already approved under the LCS at Stratford Waterfront. REP.LP.039 Steffan Rees, Quod on

behalf of SCBD Limited

27

448 SA3.1

Plan generally sound subject to need for flexibility, which could involve a review of proposals on sites benefitting from planning permission, particularly for TIQ. SCBD are working at delivering pre-lets in challenging office market, so challenge of ‘attracting’ international investment and businesses identified in Para 2.6 should not be underestimated, so need flexibility of Plan to allow for other compatible uses to

be considered. SCBD interest relates to Sub Area 3 which presents opportunity for drawing investment, new cultural and education uses, office expansion and housing. Para 12.3 confirms changing circumstances may mean review of existing permissions and that final development will become apparent over time, and more significant changes where economic and other circumstances suggest it is desirable. This flexibility should manifest itself within the SA3.1 allocation.

REP.LP.039 Steffan Rees, Quod on behalf of SCBD Limited

449 SA3.1

SA3.1 allocation’s development principles describe uses in outline permission but should set out further clarity on need for flexibility to change. Further guidance required including reference to other Plan

policies such as the Metropolitan Centre, similar to that identified within SA3.2. Noted that SA3.2 includes a key connection to TIQ south from SA3.2 but the S106 only requires a safeguarded area from new buildings or structures in that location. So should amend the principle to reflect this. SCBD resist any requests for funding for that connection as part of any future development proposal because the outline permission already establishes the principle of the safeguard, and would be inappropriate for any additional commitments to be made for this provision.

REP.LP.039 Steffan Rees, Quod on behalf of SCBD Limited

451 1.1The emphasis on retaining the precise quantum of B class floorspace within Hackney Wick and Fish Island is considered flawed. The policy emphasis should promote qualitative enhancement of floorspace, job creation and increasing employment densities. The policy support for B2 (general industrial) and B8 (storage and distribution) uses use within Fish Island is opposed.

REP.LP.040 Ben Kelway, NLP on behalf of Aitch Group

452 1.6Specific height guidance for Fish Island, beyond the guidance in Policy BN10, is unnecessary. REP.LP.040 Ben Kelway, NLP on behalf

of Aitch Group

453 SA1.6

It is clearly inappropriate for the LLDC’s Local Plan to restrict building heights within this allocated land to a level below the heights of the recently approved development which covers the majority of that land.

For these reaaons, we would suggest that Policy SA1.6 should be redrafted to omit bullet point 6 and building heights in this area should be guided by Policy BN.10 and the London Plan Policy 7.7.REP.LP.040 Ben Kelway, NLP on behalf

of Aitch Group

454 SP1

Should add new bullet to SP1 on building local supply chains in order to connect major development to organic growth of existing businesses. If not done new investment will not remain in the area, e.g. few businesses report they benefitted from the Games through procurement processes, more commonly reporting disruption and loss of business. New economics foundation work on local multipliers show how inward investment remains in area generates value through multiplier effects.

REP.LP.041 Gill Wildman, Plot London

455 B.1Support employment retention but does not go far enough, in particular for land for dirty industries. New technology and maker growth will occur in workshops and yards of industrial estates not offices. Should include more detail from Economy study on this.


456 B.3

Should amend to make sound by requiring community engagement in design and implementation of proposals. Motivated by experience in Hackney Wick Fish Island where interim uses are disconnected from non-temporary residents, business and community groups who do not benefit from or engage with interim uses which instead attract from outside the area, for example the skatepark. Need to address issue of contributing to convergence aims rather than as a marketing tool. Should be amended to require proposals to be part of a long term strategy for the area. Amend wording to make clear LLDC does not see cultural and creative industries as an interim use but part of economy in the long term. These businesses are linked to others through the supply chain. Should remove policy unless affordable and suitable space for cultural and creative uses are not secured elsewhere.


457 B.4

Should amend policy to remove viability considerations as far more affordable workspace is lost in Hackney than is delivered through S106. What is delivered is not comparable in terms of affordability of other characteristics. Also necessary in terms of aims of supporting a diverse economy. Up to 75% of market rents is too high, and should clarify that low cost provision should maintained for the long term. Low rents attract talent who are then forced out by higher rents a short time later as happening within Hackney Wick and Fish Island. Committing to providing long term, low cost accommodation would retain talent in the area. Should add bullet stating low cost provision supported where provides space for existing industries to grow, such as reported within the Carpenters District. Should acknowledge importance of affordable workspace in lifetime neighbourhoods. Should add additional bullet to clarify that low cost workspace needs to span a range of growth stages of businesses from start-up to larger forms to enable businesses to stay in area. Businesses in HWFI need small, start-up spaces and larger spaces to grow into, see link to B.3 interim uses.


458 B.5

Should set targets for construction and end-user jobs for local residents and numbers participating in skills and employment training initiatives. Not setting a target because they can be exceeded is not sound, as without a target in a weaker position. Need to set these to be effective at achieving convergence. Should define what is meant by local residents, and few communities had access to jobs associated with Games.


459 B.6See REP.LP.015 (Response entry 143) REP.LP.041 Gill Wildman, Plot London

460 BN.10All new and developing centres are specified as appropriate for tall buildings. This assumes that tall buildings are an essential part of regeneration. Locations need to be specific and justified. REP.LP.041 Gill Wildman, Plot London

461 IN.2

Policy IN.2 is not sound. In planning terms the LLDC has a responsibility to address how it will deal with waste within its boundaries and should specifically set out how it will co-operate with the surrounding boroughs on waste. There are possibilities of delivering innovative waste self-sufficiency measures that could / should be referred in this policy. The Plan demonstrates a lack of a vision about waste in the area, which is an ongoing issues and also ignoring any recycling potential, reuse and refurbish, which is a regular practice of local artists and business people in the area, such as the Frontside Skate Park, Yard Theatre and RUrban Wick.


463 SA2.1Considers that the Chobham Farm Site Allocation SA2.1 should be extended to include the strip of land to the north of the site allocation (north of Henrietta Street) that is part of the Chobham Farm Scheme that has planning permission for employment uses in this location and considers that this could be appropriate for housing in the longer term.

REP.LP.042 Frances Young, NLP on behalf of London and Continental Railways

462 Sub Area 2 Supports the vision for North Stratford and Eton Manor and the Area Priorities at paragraph 11.5. Considers that the Key diagram should be adjusted to show the Chobham Farm development parcel extending north of Henrietta Street and that the Park/Open Space in this development parcel should be moved to the east of the current position shown.


464 SA3.1Consider that bullet relating to delivery of Chobham Farm South site shall depend on access via town centre link bridge from 2020 would enhance the site but would not be seen as a prerequisite to development. Bullet should be rewritten to exclude reference to the link bridge.


465 1.1

References to protecting and promoting general industrial uses within the Hackney Wick Station Area should be removed. REP.LP.043 Ben Kelway, NLP on behalf of Pearl & Coutts

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466 1.4The Local Plan should be recalibrated to equally recognise the deficiencies in the area’s townscape. No. 14 Queen's Yard and the Clarnico Building should not be identified as heritage assets on Figure 30. REP.LP.043 Ben Kelway, NLP on behalf

of Pearl & Coutts

467 1.6Specific height guidance for Fish Island, beyond the guidance in Policy BN10, is unnecessary. REP.LP.043 Ben Kelway, NLP on behalf

of Pearl & Coutts

468 SA1.1The emphasis should be on retention/enhancement of employment capacity, alongside a significant number of new homes. The Local Plan must be clear that employment capacity can be retained/enhanced as part of more efficient and intensive mixed use development including a sizeable residential component. However, it is inappropriate in an area identified for mixed use regeneration and intensification for the scale and mass of development to be guided by the low rise and low grade existing buildings that would mostly be replaced.

REP.LP.043 Ben Kelway, NLP on behalf of Pearl & Coutts

469 Sub Area 1 Objects to proposals for new canal bridges at Fish Island. REP.LP.044 Malcolm Tucker, GLIAS

470 B.1

Rick Roberts Way cluster should be renamed to Rick Roberts Way North to remove confusion with allocation REP.LP.045 Alister Henderson, Planning Perspectives on behalf of National Grid Property

472 B.1

Rick Roberts Way cluster should be renamed to Rick Roberts Way North to remove confusion with allocation REP.LP.045 Alister Henderson, Planning Perspectives on behalf of National Grid Property

471 SA3.6

Should remove reference to school within SA3.6 as will be re-located elsewhere to ensure plan is justified. REP.LP.045 Alister Henderson, Planning Perspectives on behalf of National Grid Property

473 SA3.6

Comments made in context of National Grid landholding in south east corner of SA3.6 site. Understanding that the secondary school is to be relocated elsewhere so should remove reference to secondary school within the allocation. Welcome acknowledgement that residential capacity could be increased but should not pursue business space on south east corner of site within National Grid ownership because only viable use would be residential on this site requiring remediation. Failure to do so would mean site remaining vacant and not effective. Reserve position of primary school is not supported by evidence and again would not be viable on the National Grid site. So any school provision should be not on land within National Grid ownership. Welcome reference to remediation within allocation. Building heights reference within the policy are unduly prescriptive and future applications should respect character scale and massing and be considered on its own merit. Grading of heights also pre-empts ant detailed designs for the site so should be removed. Overall emphasis on redevelopment is supported.

REP.LP.045 Alister Henderson, Planning Perspectives on behalf of National Grid Property

474 VisionSee REP.LP.015 (Section Response Entry 136) REP.LP.046 Osita Madu

475 SP1SP1 does not ensure the business growth. Few locals have benefitted from the games, indeed many around Carpenters reporting disruption and loss of business. Not enough focus on existing assets including Building Crafts College. There are no measurable targets for local jobs so difficulty to monitor effectiveness of policy. Should add bullet on local supply chains, more attention to existing economic assets, and newt direct jobs and local jobs figures should be added to Table 1. Should provide estimate of employment froth of existing businesses.

REP.LP.046 Osita Madu

476 B.1

B.1 is unsound as it does not provide enough support to retain employment and industrial land. The importance of retaining industrial land should be strengthened. Technological and maker growth take place in workshops and yards as well as offices. Should have more discussion of conclusions of Economy Study particularly important for businesses within Carpenters District which are long-standing and keen to expand. Fails to recognise importance of local employment in terms of lifetime neighbourhoods. To be sound should include employment cluster within Carpenter District and should remain in industrial use. Can provide employment within Sub Area 3 in addition to the retail jobs. B.1 should acknowledge importance of retaining employment sires in terms of lifetime neighbourhoods and reducing need to travel.


477 B.2

Policy B2 is not sound and should set out need for town centre uses. Little investment from new town centre developments, such as Westfield, re-circulates in the local area and office workers could leave without spending in the local economy. Growth of Stratford Metropolitan Town Centre could be at the expense of other town centres. It is not clear that the duty to cooperate has been fulfilled on this matter, nor London Plan and NPPF requirements for positive planning to support town centres. Adverse impacts of the Town Centre extension on the existing Stratford Shopping Centre, which provides affordable goods and services, spaces for young people to socialise and skateboard had not been addressed. Should amend to encourage town centre uses that contribute to the local economy through local multiplier effects and local supply chains. Should address the LLDC’s duty to co-operate in terms of adverse impacts on other town centres and conformity with the London Plan and NPPF. Should expand description of

Stratford Town Centre Extension in Table 3 to acknowledge and retain existing Stratford Shopping Centre.


478 B.4

B.4 does not sufficiently protect workspaces and does not recognise need for new low cost workspace to facilitate existing businesses growing. Business in Carpenters Estate report lack of space to grow into. Does not recognise the importance in terms of lifetime neighbourhoods. To be sound needs amending to support retention and remove ‘where viable and where it complements plans for the wider area’.

Should add additional bullet stating will be supported where allows existing businesses to grow and acknowledge role in lifetime neighbourhoods.


479 B.5No target to monitor effectiveness of B.5 which places LLDC in weaker position to secure jobs and training for local residents. Need to set targets to demonstrate direct benefit to excluded and disadvantages residents. Target should be set for proportion of construction and end user hobs for local residents for participation in skills and employment training initiatives.


480 SP2 See REP.LP.024 (Response entry 248) REP.LP.046 Osita Madu481 H.2 See REP.LP.024 (Response entry 249) REP.LP.046 Osita Madu482 CI.1 See REP.LP.024 (Response entry 250) REP.LP.046 Osita Madu483 CI.2 Policy CI.2 is unsound as it fails to protect exising schools. Suggests some criteria for when loss of schools would be permitted. REP.LP.046 Osita Madu485 BN.11 See REP.LP.015. (Response entry 148) REP.LP.046 Osita Madu484 BN.6 See REP.LP.015 (Response entry 146) REP.LP.046 Osita Madu

486 T.6 See REP.LP.015 (Response 155) REP.LP.046 Osita Madu

487 SP5 See REP.LP.015 (Response 157) REP.LP.046 Osita Madu488 S.2 See REP.LP.015 (Response entry 158) REP.LP.046 Osita Madu489 S.3 See REP.LP.015 (Response entry 159) REP.LP.046 Osita Madu

490 3.1 See REP.LP.024 (Response entry 258) REP.LP.046 Osita Madu491 3.2 See REP.LP.024 (Response entry 259) REP.LP.046 Osita Madu492 SA3.4 See REP.LP.024 (Response entry 260) REP.LP.046 Osita Madu


Section 14 on Implementation and delivery does not comply with the duty to cooperate with communities that will be impacted by any proposed development schemes stemming from the Local Plan. This section outlines the statutory powers available to the LLDC to ensure that it achieves the objectives that it has set out in the Local Plan. how will the LLDC consider the needs of existing residents expressed through its Community Plan, Neighbourhood Plan, consultation feedback which expresses their needs to retain existing homes? To ensure that the implementation and delivery is effective it is important that LLDC strikes a good balance between existing community needs and any redevelopment that may threaten to displace them. Therefore it is important that a viability study is carried out to demonstrate to all stakeholders the benefit of any proposed re-development of the sub areas


29

496 B.5

Policy seeks S106 for major development, implying that minor development will be acceptable in all cases. There may be circumstances when a minor scheme fails to meet employment policies or site allocations, for example a conversion resulting in a loss of employment floorspace under B.1 and it is felt that this policy should apply in this case. Planning Contributions SPD should define the appropriate qualifying development thresholds for contributions. Hackney’s draft Planning Contributions SPD specifies that development generating 10 or more end use employees is ‘qualifying development’ for purposes

of employment training. Understood that LLDC Planning Contributions SPD will be expanded to include more detail following the CIL examination.

REP.LP.047 Katie Glasgow, London Borough of Hackney

497 B.5Welcome inclusion but should be more assertive, setting out circumstances when low cost/managed workspace should be provided. This is critical in support for SME and cultural and creative sectors in particular at Hackney Wick Fish Island. Should amend policy to reflect this. Hackney has list of approved workspace providers which developers are required to work with in affordable housing provision.


498 H.1 Concern about wording including units of 2 or more bedrooms to be more than half. LLDC and Hackney SHMA identify a need for family accommodation, particularly family affordable, and absence of % requirement may be ineffective at meeting needs. Should amend to reflect a % target.


500 H.2Previous comments on 35% affordable housing benchmark and inconsistency with Hackney planning policies of 50% still stands. Share Mayor's objective to maximise affordable housing but consider 50% is still valid for Hackney part of LLDC area. Concerned that proposed policy will not meet full range of need particularly those in greatest need. Concerns that Plan does not commit to figure within H.2 but references target within reasoned justification. Should consider whether this target should be within Policy H.2


501 IN.2 Supports the requested minor amendments to the supporting text of Policy IN.2 proposed by the North London Waste Plan Boroughs Group to the Reasoned Justification text at Paragraphs 7.6 and 7.7, in their response to the consultation.


502 Infrastructure The Local Plan adopting London Plan parking standards is not considered aspirational enough in terms of minimising car use / car parking. Local Plan transport policy should be reviewed and brought into line with the policies and guidance in Hackney's new Sustainable Transport SPD.


503 Sustainability Highlights DEFRA and DCLG’s current consultation titled ‘Delivering Sustainable Drainage Systems’. This consultation is seeking views for an alternative to the implementation of SuDS Approval Bodies (SABs)

as set out in Schedule 3 of the Flood Water Management Act 2010. The outcome of this consultation may have implications on the wording in paragraph 8.22. Minor amendments may be required in future to align with the outcomes of the Government’s consultation.


504 SA1.1 Seeks clarification of terms. REP.LP.047 Katie Glasgow, London Borough of Hackney

505 SA1.7 Similar comments as raised above in relation to terminology for Non Residential Frontage and Other Open Space. REP.LP.047 Katie Glasgow, London Borough of Hackney


Suggestion to have more information such as accomodation schedule and phasing strategy, to demonstrate how growth in area can be supported by infrastructure identified in IDP. REP.LP.047 Katie Glasgow, London Borough of Hackney


The strategy and the detailed policies are for the most part welcome and are considered to take forward the key aims and objectives of the Hackney Wick Area Action Plan. However, there remain some outstanding areas of concern, in particular in relation to policies regarding affordable housing and housing mix which are inconsistent with policy requirements as set out in the Council’s Core Strategy and

emerging Development Management Local Plan. Further clarification or modifications would be useful in order to improve the effectiveness of the Plan’s policies. Further comments and recommendations have

been made in Appendix 1 (outlined in other cells) for consideration. It would be helpful when cross referencing polices at the bottom of certain policies, to include their respective page number. Welcome the inclusion of a paragraph explaining that there will be flexibility in future to respond to changing housing requirements.


507 1.1The emphasis on retaining the precise quantum of B class floorspace within Hackney Wick and Fish Island is considered flawed. The policy emphasis should promote qualitative enhancement of floorspace, job creation and increasing employment densities. The policy support for B2 (general industrial) and B8 (storage and distribution) uses use within Fish Island is opposed.

REP.LP.048 Ben Kelway, NLP

508 1.4Figure 30 currently identifies the frontage of No. 80-84 and the majority of No. No. 88 Wallis Road under the umbrella term ‘heritage assets.’ We disagree with the identification of any of the buildings at the site

as being of heritage significance other than the corner building at No. 88 Wallis Road.REP.LP.048 Ben Kelway, NLP

509 1.6Specific height guidance for Fish Island, beyond the guidance in Policy BN10, is unnecessary. REP.LP.048 Ben Kelway, NLP

510 SA1.1 The guidance regarding roof forms is considered overly prescriptive and inappropriate. REP.LP.048 Ben Kelway, NLP

511 Vision


residents in these Boroughs and the Boroughs key role in the delivery of the Local Plan • The high importance of creating job opportunities for local people and ensuring the diversity of the economic offer • The

successful integration of existing communities, like the Carpenters estate and at Bromley by Bow, through measures such as lifetime neighbourhoods. • Commitments to positively improve the social and

environmental conditions in the area.

REP.LP.049 Ulrike Steven, What if:projects Ltd

512 SP1 See REP.LP.046 (Response entry 475) REP.LP.049 Ulrike Steven, What if:projects Ltd

513 B.1

B.1 is unsound as it does not provide enough support to retain employment and industrial land. The importance of retaining industrial land should be strengthened. Technological and maker growth take place in workshops and yards as well as offices. . Should have more discussion of conclusions of Economy Study particularly important for businesses within Carpenters District which are long-standing and keen to expand. Fails to recognise importance of local employment in terms of lifetime neighbourhoods. To be sound should include employment cluster within Carpenter District and should remain in industrial use. Can provide employment within Sub Area 3 in addition to the retail jobs. N.1 should acknowledge importance of retaining employment sires in terms of lifetime neighbourhoods and reducing need to travel.


514 B.2 See REP.LP.046 (Response entry 477) REP.LP.049 Ulrike Steven, What if:projects Ltd

515 B.4 See REP.LP.024 (Response entry 246) REP.LP.049 Ulrike Steven, What if:projects Ltd

516 B.5Policy has no target to demonstrate effectiveness. Without this in a weaker position to secure jobs and training for local residents. Need targets to evidence direct benefits to excluded and disadvantaged residents as part of convergence aims. Targets should be set for proportion of construction and end-user jobs for local residents and for numbers of residents participating in skills and employment training initiatives.


517 SP2 See REP.LP.024 (Response entry 248) REP.LP.049 Ulrike Steven, What if:projects Ltd

518 H.2 See REP.LP.024 (Response entry 249) REP.LP.049 Ulrike Steven, What if:projects Ltd

520 CI.1

CI.1 unsound as fails to set strategic policy for the delivery of the full range of social and community infrastructure. CI.1 should make reference to Lifetime Neighbourhoods - specificying that 'developments should be designed so that the layout, tenure and uses interface with surrounding land, and improve people's access to social and community infrastructure. Policy should promote development of local shops and services which also provide communtiy based places where diverse communities engage with one another. Should more proactively promote delivery of multi-purpose community venues. Policy should refer to youth facilities.


521 CI.2 See REP.LP.046 (Response entry 483) REP.LP.049 Ulrike Steven, What if:projects Ltd

30

523 BN.11 See REP.LP.015. (Response entry 148) REP.LP.049 Ulrike Steven, What if:projects Ltd

522 BN.7 See REP.LP.015 (Response entry 146) Comment made to both BN.6 and BN.7 REP.LP.049 Ulrike Steven, What if:projects Ltd

519 Infrastructure

Policies CI1 and CI2 is not sound. A) Fails to provide policy for locally based healthcare facilities. Signficant health care issues required by London Plan policy 3.17 not been addressed. B) fails to address life long edcuational needs. To address A) A policy with clear and measureable targets relating to healtcare facilities in cooperation with the surrounding planning authoirties should be provided. It should set out a table of existing and planned healthcare facilities. To address B) should provide a policy on lifelong educational requirements - or amend CI2 to cover.


524 T.6 See REP.LP.015 (Response 155) REP.LP.049 Ulrike Steven, What if:projects Ltd

525 SP5 See REP.LP.015 (Response 157) REP.LP.049 Ulrike Steven, What if:projects Ltd

526 S.2 See REP.LP.015 (Response entry 158) REP.LP.049 Ulrike Steven, What if:projects Ltd

527 S.3 See REP.LP.015 (Response entry 159) REP.LP.049 Ulrike Steven, What if:projects Ltd

528 3.1 See REP.LP.024 (Response entry 258) REP.LP.049 Ulrike Steven, What if:projects Ltd

529 3.2 See REP.LP.024 (Response entry 259) REP.LP.049 Ulrike Steven, What if:projects Ltd

530 SA3.4

SA3.4 is unsound as is already a mixed use area comprising of Carpenters Estate, new homes of mixed tenure active businesses and social and community infrastructure. In 2013 a majority of residents produced a Community Plan which highlighted the strengths of the existing community, access to transport, green play spaces and community infrastructure. It presented a vision for community-led and sustainable improvement that would build on solidarity of community and benefit health and well-being. Its vision is of refurbishment, retention of businesses and services improvements to community transport, shops and other facilities. This also said investigate Neighbourhood Planning for area where progress has been made towards development of a neighbourhood forum and defining boundaries. Discussions with LLDC have taken place with support from Locality. Community Plan identifies needs for new entrance to Stratford Regional station however development proposed in allocation is not required or desirable. LLDC made clear Carpenters Estate not necessary to meet housing targets. Policy 2.4 of London Plan highlights sustaining communities and promoting opportunities for economic development and jobs for young through community engagement. Greater Carpenters should be a model of this. Should remove allocation from plan. Policies are required for the area but most appropriate would be sensitive refurbishment, building on homes, businesses and community infrastructure already present. Can be achieved through a Neighbourhood Plan. Plan states remaining capacity within Sub Area 3 us 629 to 2030 so is inclusion as a site allocation necessary?


531 Sub Area 3

Plan should protect disenfranchised communities who depend upon local authority support. Objectives are contradicted by LB Newham decisions in relation to Carpenters Estate. How will Plan secure promoting convergence and community participation are implemented considering LB Newham stance of blocking resident efforts to improve Estate? Under Localism Act LB Newham has duty to cooperate however actions undermine Local Plan objectives. LB Newham declines Landlord’s Consents and residents would like to improve their neighbourhood and be involved in planning and regeneration process.

Carpenters TMO and residents have successfully attracted Pocket Park funding Carpenters Park more useable and playful but LB Newham refused Landlord’s Consent for this with the argument of

comprehensive redevelopment plans. This shows disrespect for community. Carpenters Estate has not benefited from the Olympic Legacy in any way and small investment of £6K to improve a central green space is deemed inappropriate. The statement assumes LB Newham makes the decisions irrespective of local opinion. Proposals for temporary information points with the Carpenters TMO and local residents have also been developed, and granted planning permission but LB Newham refused Landlord’s consent with no reason. What if: projects appointed by the TMO have worked with local residents and prepared

improvement proposals that can be implemented by the local community and involve local construction businesses. Attempts to discuss these small scale projects with LB Newham representatives and officers have been unsuccessful. People who have lived on the estate for more than 40 years are left in a state of uncertainty. The Carpenters TMO is currently in a legal dispute with the LB of Newham who are withholding TMO allowances resulting in TMO having to make most staff redundant. The TMO is currently continuing to maintain the Carpenters Estate on behalf of the LB Newham and are funding this work from their savings. LB Newham’s actions with regards to the TMO are understood by many as an attempt to remove the TMO. Without the TMO’s maintenance regime the estate could fall into a state of

disrepair which would support the Council’s ambition for demolition. LB Newham refused access to Denison Point for Open House for ‘health and safety’ reasons. Carpenters Estate residents have started the

process of forming a Neighbourhood Forum and supported by What if: projects have secured support from Locality.


532 See REP.LP.024 REP.LP.050 Ramila Patel

534 Vision See REP.LP.015 (Section Response Entry 136) REP.LP.051 Victor Adegbuyi, Newham Union of Tenants

535 SP2

Policy title does not reflect London plan's aims to optimise rather than maximise housing delivery. Title doesn't reflect need for sustainable development and lifetime neighbourhoods. Should be amended to "Optimising housing and infrastructure provision to create lifetime neighbourhoods". Affordable homes target does not reflect a proportion of FALP target which is important given number of homes to be delivered, the 2013 London SHMAs identification of backlog need and need for affordable particularly within the Growth Boroughs. Affordable homes are crucial to convergence. To be sound annual target should be 595 a proportion of 106598 FALP target. Does not address need to maintain range of tenures needed within area. Without social rented much of gross affordable will not emerge without protection of existing. Cost of affordable rent and intermediate are beyond means of households in need and failure to protect existing social rented adversely impacting on convergence. This was highlighted in large numbers to previous consultation. To be sound should safeguard existing residential units including social rented and land.

REP.LP.051 Victor Adegbuyi, Newham Union of Tenants

536 H.1

Policy doesn't adequately address need for larger 4 and 5 bedroom homes and could result in delivery of too many 2 bedroom homes. To be sound should set targets for 3, 4 and 5 bedroom homes. Evidence is weak and out of date. ORS study depends on information from 2008-10 before introduction of affordable rents. Fails to address diversity of need essential in east London with a diversity of communities. To be sound new needs assessment should be commissioned and should insert date of when carried out within the Plan. Policy is not effective and states housing developments should have no unacceptable adverse impacts on mix and balance of the proposed area but with no detail on how this is to be monitored. Should set measuring of this out in policy.


537 H.2

Policy H2 does not have up to date evidence base, having adverse impact on low income households and convergence. Policy depends on households eligible for social rented to access affordable rent homes covered by housing benefit. No evidence to support this, particularly for large bedroom sized homes. No breakdown of households that might be able to afford capped or discounted rents without access to benefits compared to social rented. No assessment of potential adverse impact of affordable rents compared to social rents particularly for those not dependent on benefits, or potential increase in levels of in-work poverty. No evidence of households previously private renting but now had to move out of borough [Newham] to facilitate their rent covered by housing allowance.


538 H.3Policy ineffective without measurable targets. London Plan does not set indicative target relating to older persons housing within the area but should cooperate with boroughs to meet their needs. REP.LP.051 Victor Adegbuyi, Newham

Union of Tenants

31

539 H.4Policy does not set measurable targets. Mentions facilitating a balance of tenure and income and no unacceptable amenity impacts. What level would overconcentration be defined? Should set out precisely what is meant be unacceptable amenity impacts and over-concentration to be sound.


540 H.5Policy is inadequate in equalities terms. Only one site has been allocated and appears to fail to consider sites alongside larger new development that might provide opportunities for links with communities in permanent housing. Should more clearly consider gypsy and traveller communities in terms of sustainable neighbourhoods.


541 H.6Policy refers to affordable housing but is unclear what is meant by this. HMOs generally within private rented, not conforming to planning definitions of affordable housing. To be sound further clarity on whether reference to affordable housing is that defined within London Plan policy 3.10.


542 H.7Policy is not sound as it is not clear if genuinely means homes confirming to planning definitions of affordable housing. To be sound need clarity on whether reference to affordable housing is defined in the London Plan. To be sound it should fulfil the 10% wheelchair accessible or easily adaptable for wheelchair users within London Plan policy 3.8d.


544 CI.1 See REP.LP.049 (Response entry 520) REP.LP.051 Victor Adegbuyi, Newham Union of Tenants

545 CI.2

See REP.LP.046 (Response entry 483) REP.LP.051 Victor Adegbuyi, Newham Union of Tenants

543 Infrastructure See REP.LP.049 (Response entry 519) REP.LP.051 Victor Adegbuyi, Newham Union of Tenants

546 See REP.LP.024 REP.LP.052 Narmada Patel

548 H.6

Policy requires proposals to meet relevant HMO standards and internal and residential amenity standards. Para 5.28 provides further clarification but no detail on what these normal standards are. Only known as the Mayor's Housing SPG which notes in Para 2.1.14 that apply to all housing in London including new build, conversions and changes of use where dwellings created. Do not apply to specialist housing including students, sheltered and HMOs. This is cross-referenced by H.6 and is included within the evidence base. It is explicit that these standards do not apply to HMOs therefore should be amended so references to internal and residential amenity standards are removed.

REP.LP.053 DP9


Representations on behalf of The Collective. Agrees with number of key aims and aspirations including need to ensure development meets local needs and London as a growing city. The Collective is working on an project in Stratford for around 400 units of shared living. This seeks to tackle real housing issues and broaden the choice of homes in east London. This will be attractive to young professionals, moving to area and those from east London. This is practical and affordable with proven track record, easing pressure on housing market. The extensive communal areas and options to scale up and down according to need, attract people to stay and an alternative to low quality HMO accommodation. Collective maximises density through shared living space using highest design. Creates internal communities more likely to remain in area, preventing skills loss from London. Provides to support businesses which are in line with Local Plan aims.

REP.LP.053 DP9

549 BN.10Policy BN.10 should be amended to include reference to the suitability of Stratford High Street to accommodate tall buildings. Given the above, supporting paragraph 12.9 should be amended to include reference to opportunities for tall buildings on Stratford High Street.

REP.LP.053 DP9

550 SA3.4Allocation excludes key connection between Stratford High Street and Park via Lett Road, Wilmer Lea Close, Gibbons Road and Hutchins Close. REP.LP.053 DP9

551 SP1

Brief mention in Para 4.4 of social enterprise but not within SP.1 itself. There is insufficient focus on existing economic assets. Should summarise Economy Study, mention of valued centres providing skills and training for local people such as Building Crafts College and wording on how convergence will be achieved included. SP1 should set measurable targets to achieve convergence and economic development. Should mention social enterprise and existing enterprises and assets should be given more attention and should summarise Local Economy evidence base value existing centres providing valuable skills and training should be mentioned and wording added to explain how convergence can be achieved through existing enterprises as well as development. New bullet should be added on building local supply chains and net jobs and local jobs added to Table 1. Estimate of employment growth from businesses within existing workspaces should be provided.

REP.LP.054 Geraldine Black, Community Links

552 B.1

Should have more discussion of conclusions of Economy Study. Recent industrial land releases have been three times higher than London Plan targets. Due to residential land values there is pressure to convert employment sites. Development should not stifle the thriving and resilient local economy documented in the Economy Study. The option of significantly increasing job densities within B2/B8 use B.1 5 (b) will increase pressure to redevelop existing employment spaces, reducing likelihood of re-provision of industrial typologies and that existing businesses can be accommodated in new developments. Cultural, artistic, manufacturing and making, and food businesses celebrated in Economy Study require space to work and cannot be accommodated within higher-density office spaces. Should define Locally Significant Industrial Sites and Other Industrial Locations. Policy should highlight the importance of local employment which has failed to consider this in terms of NPPF requirements of economic, social and environmental sustainable development. To ensure B.1 is sound: a. Should recognise the employment cluster in the Greater Carpenters District in Table 2. Existing workspace should remain in employment use to provide local employment including in light industrial uses. Current business occupiers are growing, providing local jobs and training and are valued by local residents. Need these forms of employment as well as retail jobs at Stratford Metropolitan Town Centre to achieve convergence. b. Should strengthen Industrial land designations in Table 2 and supporting text should reflect this. c. Delete ‘or significantly

increase job densities within B use classes’ from Policy B.1 5(b) to ensure effectiveness d. Add definitions for Locally Significant Industrial Sites and Other Industrial Locations to be effective. e. B.1 and

supporting text should strength retention of local employment sites in terms of delivering lifetime neighbourhoods and reducing the need to travel. Should make a link between homes and jobs in order to convergence and sustainable development.


553 B.2See REP.LP.046 (Response entry 477) REP.LP.054 Geraldine Black,

Community Links

554 B.3Policy is unsound as fails to highlight importance of cultural and creative industries that are part of the economy in long term not temporarily. Businesses are part of a diverse local economy linked to other businesses through supply chains and should not be demoted to temporary status. Not enough clarity in supporting text on how interim uses will be supported and enabled. To make sound wording should be added to make clear cultural and creative uses are a long term part of the economy and practical support measures referenced.


555 B.4

Policy does not sufficiently protect workspace. Far more affordable workspace is lost in Hackney than is delivered through S106. What is delivered is not comparable in terms of affordability of other characteristics. Also necessary in terms of aims of supporting a diverse economy. Up to 75% of market rents is too high, and should clarify that low cost provision should maintained for the long term. Low rents attract talent who are then forced out by higher rents a short time later as happening within Hackney Wick and Fish Island. Committing to providing long term, low cost accommodation would retain talent in the area. Should add bullet stating low cost provision supported where provides space for existing industries to grow, such as reported within the Carpenters District. Should amend wording to remove 'where viable and where it complements plans for the wider area. The 75% figure should be lowered and should expand to clarify low-cost provision should remain low cost for the long term with long-term tenancies. Should add commitment to at least 75% of subsidy for charitable uses. Should add further bullet to clarify that provision of new low-cost should be supported where allows businesses to grow. Should acknowledge role in creating lifetime neighbourhoods.


32

556 B.5

Policy unsound as no target to monitor effectiveness. Without targets in a weaker position to secure jobs and training for local people, so should set targets to demonstrate direct benefit to disadvantaged residents. Policy does not set out how achieved in practice, not in conformity with 2.4 of the London Plan which is clear that will promote local economic investment driven by community engagement and how this will be achieved. Experience at Community Links shows importance of detail. No mention of lifelong learning despite being aim of section. To be sound should set construction and end-user job targets for participation in skills and employment training, define local residents, must promote local economic investment by community engagement and how to be achieved including links with schools. Should add new paragraph setting out aims in relation to lifelong leading through jobs and training. Should discuss evidence base explaining rational for LLDC policies.


557 B.6See REP.LP.015 (Response entry 143) REP.LP.054 Geraldine Black,

Community Links

558 See REP.LP.024 REP.LP.055 Mabel Obili

576 SP1

Should add new bullet to SP1 on building local supply chains in order to connect major development to organic growth of existing businesses. If not done new investment will not remain in the area, e.g. few businesses report they benefitted from the Games through procurement processes, more commonly reporting disruption and loss of business. New economics foundation work on local multipliers show how inward investment remains in area generates value through multiplier effects. There is only brief mention of promoting social enterprise with no policies to support this and insufficient focus on existing economic assets in the policy. The Economy Study should be summarised; existing centres providing valued skills and training for local people should be mentioned (e.g. the Building Crafts College, Bromley by Bow Centre and Community Links); show how convergence aims will be achieved through growth of economic assets growth and development. Should set out measurable targets to meet aims of convergence and economic development and mention social enterprise in SP1. Should add net direct and local jobs within Table 1. Estimate for employment growth arising from existing businesses also required. Will not be possible to monitor convergence without this being transparent.

REP.LP.056 Richard Brown

559 B.1

Marketing strategies should be for 5 preceding years rather than 2 as will allow occupancy of industrial employment space. Economy study shows great demand for B2/B8 and B1 workspace alongside diminishing availability of industrial land as a result of release through Fish Island AAP. Is evidence to suggest Wick Lane Wharf have not marketed space sufficiently despite S106 agreements and clear demand. Needs to be more guidance within Para 4.15 for notional block typologies for how B2 uses can be provided within mixed use development as within Economy Study Part C and HWFI Design and Planning Guidance. New employment floorspace should be flexible to maximise potential and take-up including access and management. Mixed use developments should be designed to maximise forms and types of employment uses which can be incorporated into the development including how B1 and B2 use classes can be compatible with mixed use development through design including horizontal and vertical integration. Recommendations within Local Economy Study Part C and HWFI Design and Planning Guidance.


560 B.1Support potential for live/work within sub area 1 which needs to be supplemented with policy guidance which provides recommendations for appropriate management, tenure and design. REP.LP.056 Richard Brown

577 B.1Support efforts for retention of employment and industrial land but policies do not go far enough. Importance of retaining land for dirty industrial is under recognised. Growth of new technology and maker revolution will not occur in offices but in workshops and yards. More detail of Economy Study needs to be drawn out and reflected so unsound.


578 B.1Should include employment cluster at Carpenters Estate within Table 2. Existing workspace should remain in employment use to provide jobs for local people including light industrial. Land occupied by growing businesses, provide local jobs and training and are valued by local residents. Need this form of employment within the Sub Area in addition to retail jobs within the town centre to achieve convergence.


579 B.1Recent rates of industrial release are three time higher than London Plan targets. With high residential values is pressure to convert employment. Employment land protections should be strengthened to ensure future development doesn't stifle the resilient local economy identified within the evidence base. Industrial land designations should be strengthened for all industrial sites listed in Table 2.


580 B.1

Should delete words 'significant increase job densities within the B use classes from Bullet 5e. Providing developers with this option will increase pressure to redevelop existing employment space, reducing likelihood of re-provision of industrial typologies and that businesses can be accommodated within new developments. Cultural, artistic, manufacturing, making and food production celebrated within the evidence base require space to work and cannot be accommodated within offices


581 B.1Should add definitions of Locally Significant Industrial Sites and Other Industrial Locations. REP.LP.056 Richard Brown

582 B.1Should acknowledge the importance of retaining local employment site in terms of lifetime neighbourhoods, reducing need to travel and creation of successful neighbourhoods. Must make link between homes and jobs to deliver its convergence aims and meet NPPF requirements for economic, social and environmental sustainable development.


583 B.2

Should add wording to encourage town centre uses which contribute to local economy through supply chains including with existing businesses. Risk that office workers will leave without spending in local economy and concerned that growth will be at expense of vitality of other centres in surrounding boroughs. Various town centres in Tower Hamlets will have growth but not clear LLDC fulfilled duty to cooperate with local authorities on this matter, no London Plan and NPPF policies on this matter.


584 B.2Stratford Town Centre extension description should be expanded to include retaining Stratford Shopping Centre, acknowledging that space for residents to access affordable goods and services. This function should not be removed as it develops. Lack of engagement within Hackney Wick and Fish Island for neighbourhood centre plans. Table 3 should list key existing assets within the area and describe how will be integrated into development.


586 B.3

Should amend to make sound by requiring community engagement in design and implementation of proposals. Motivated by experience in Hackney Wick Fish Island where interim uses are disconnected from non-temporary residents, business and community groups who do not benefit from or engage with interim uses which instead attract from outside the area, for example the skatepark. Need to address issue of contributing to convergence aims rather than as a marketing tool. Should be amended to require proposals to be part of a long term strategy for the area. Amend wording to make clear LLDC does not see cultural and creative industries as an interim use but part of economy in the long term. These businesses are linked to others through the supply chain. Should remove policy unless affordable and suitable space for cultural and creative uses are not secured elsewhere.


561 B.4

Should propose form of managed dual use live work as a potential affordable workspace model. Evidence from LLDC Work Live study awaiting. Should explicitly name a studio provider as part of planning applications as well as written into S106 with detail to tenure, management and design. Should cross reference Policy 1.1 here as relevant to bullet 3 in terms of re-use of buildings. Also for H.7 as private rented sector is prevalent tenure in HWFI for artists and creative practitioners. Policy 1.4 bullet 3 suggest that worded to specify the re-use of heritage assets for affordable workspace in particular.


587 B.4

Should amend policy to remove viability considerations as far more affordable workspace is lost in Hackney than is delivered through S106. What is delivered is not comparable in terms of affordability of other characteristics. Also necessary in terms of aims of supporting a diverse economy. Up to 75% of market rents is too high, and should clarify that low cost provision should maintained for the long term. Low rents attract talent who are then forced out by higher rents a short time later as happening within Hackney Wick and Fish Island. Committing to providing long term, low cost accommodation would retain talent in the area. Should add bullet stating low cost provision supported where provides space for existing industries to grow, such as reported within the Carpenters District. Should acknowledge importance of affordable workspace in lifetime neighbourhoods.


33

588 B.5 See REP.LP.054 (Response entry 556) REP.LP.056 Richard Brown589 B.6 See REP.LP.015 (Response entry 143) REP.LP.056 Richard Brown

575 Business Growth

Businesses included within the Economy Study were not contacted that Local Plan published or receive copy of document. Consultation has been insufficient and inadequate in reference to requirement of NPPF to engage with businesses.


573 BN.10 All new and developing centres are specified as appropriate for tall buildings. This assumes that tall buildings are an essential part of regeneration. Locations need to be specific and justified. REP.LP.056 Richard Brown

574 BN.11 See REP.LP.015. (Response entry 148) REP.LP.056 Richard Brown571 BN.2 See REP.LP.015. (Response entry 145) REP.LP.056 Richard Brown572 BN.6 See REP.LP.015 (Response entry 146) REP.LP.056 Richard Brown

563 SP4 SP4 is not sound. Does not specify its duty to cooperate with surrounding boroughs in addressing waste issues;which is more than requiring retention of existing waste management facilities. SP4 should highlight duty to cooperate and require innovative waste self-sufficiency measures in all new developments and refurbishment schemes.


564 IN.1See REP.LP.015 (Response entry 150) REP.LP.056 Richard Brown

565 IN.2 See REP.LP.015 (Response entry 151) REP.LP.056 Richard Brown

566 Infrastructure

Paragrapahs 7.10 and 7.11 are not sound. There is s disconnect in the aims of delivering sustainable possibly walkable and lifetime local neighbourhoods and the delivery of national and international connections. Not clear on relationship between the 10 transport policies and there could be tensions between them. If the key aim is prioritsing cylcing and walking then there should also be a reduction in focus on wider transport connectivity including national and international.


570 T.10

Policy T10 does not say how using the waterways for passenger and freight transport will be encouraged and supported by LLDC. No clarity on whether roaming rights will be restored to the sections of the Lea River that are currently closed off. To be sound T10 should say more clearly how LLDC will deliver the policy. e.g. • carry out analyses with surrounding boroughs, local businesses and canal user groups on

what kind of freight and leisure transport might be possible or viable • work to achieve a timetable for section of the waterways that have been closed off to be opened • co-ordinate experimental uses of the

waterways and • promote the use of existing tour bus stops for more regular transport usage.


567 T.4 See REP.LP.015 (Response Entry 153) REP.LP.056 Richard Brown

568 T.5

Policy T5 is not sound. It does not provide a clear relationship to health and safety issues. • To ensure that policy T5 is sound, the street network should provide another level of reading to safety. This should

include where there are dangerous road crossings and areas high in particular matter and nitrogen dioxide – which would be important to address in developments. identify not just immediate issues of

connection but also of health.


569 T.6 See REP.LP.015 (Response 155) REP.LP.056 Richard Brown

585 Sub Area 4

The proposed new district town centre at Bromley by Bow is not a new idea, but there has been inadequate involvement of local groups (including the Bromley by Bow Centre) in the development of the most recent iteration of the proposal as described in the LLDC local plan. Again, it is not clear that the LLDC have fulfilled the duty to cooperate or requirements for stakeholder engagement on this matter.



Delivery and Implementation - this section is unsound because:-• No targets are identified in most of the monitoring criteria.

• Open Space/ Biodiversity improvements aren’t measured. The target is to maintain what it is like at the moment.

• There is no monitoring of impacts outside of the LLDC area e.g. on the existing Bromley by Bow neighbourhood.


600 Our Area No comment. REP.LP.057 Diana Thomson, Savills

602 SD.1Supports the principle of delivering sustainable development in accordance with the NPPF to bring about the LLDC’s vision for the area. REP.LP.057 Diana Thomson, Savills

601 VisionConsiders It unclear whether the prioritisation of the objectives for the LLDC area have been intentionally ranked.Would not expect the ordering of the objectives to preclude the focus on the delivery of new housing, and to exceeding housing targets across the area, as sought by the NPPF.

REP.LP.057 Diana Thomson, Savills

603 SP1Support principle of building strong and diverse economy for east London but objectives should remain deliverable in line with NPPF requirements. Promotion of employment opportunities should not prohibit delivery of buildings in sustainable locations.


604 B.1

Plans should be flexible to market needs and adapt to changing circumstances. To be flexible and deliverable policies should seek to stimulate development of employment floorspace whilst retaining sufficient flexibility to respond to market conditions. Note Cooks Road is identified as OIL employment cluster which we support as a buffer zone for the rest of Pudding Mill but more industrial uses here should not prejudice residential where more appropriate (i.e. to the north / north east of Cooks Road). Welcome stipulation that the cluster should deliver employment floorspace alongside other uses, including residential to aid the transition. Mix of uses within the OIL is welcomed however maintenance of existing balance of uses is restrictive and will not enable these areas to respond flexibly to market demand and changing requirements. Part 5 states that proposals for non-compliant uses within the OILs will not be permitted, unless criteria are met. The long term protection of clusters is likely to be restrictive and could ultimately preclude the promotion of sustainable development. Policy should recognise that each site should be treated on its own merits with regard to what is deliverable, given site development constraints. Diagram is not clear where the boundaries of diagram are no clear. Support for principle of employment provision within mixed use development, but the long term allocation of sites for employment uses where no reasonable prospect of a site being used is contrary to paragraph 22 of the NPPF. This states “applications for alternative uses of land should be treated on their own merits having regard to market signals and

the relative need for different land uses to support sustainable local communities”. It is questionable employment hubs is sound as it is not clear that the allocation of the Cooks Road OIL is based on objectively

assessed need. Long term allocation of these sites has the potential to curtail development potential not meeting the NPPF’s sustainable development objective. Policy should allow for appropriate managed

release of strategic employment sites and policy amended to enable the OIL to respond flexibly to changing market needs. The requirement to ‘maintain the existing balance of uses’ should be removed and

Figure 4 amended so boundaries are clearer


605 B.2 Policy should recognise opportunities for mixed use development outside designated centres where planning harm can be mitigated in context of infrastructure capacity and environmental and town centre impacts. Amend policy to indicate acceptability of town centre uses outside centres where no harm.


606 B.3 Welcome inclusion of points 4 and 5 and recommend that only the LPA can fully satisfy itself that uses would not prejudice ability of sites to come forward. REP.LP.057 Diana Thomson, Savills

607 B.4 Policy should recognise that the inclusion of low cost and managed workspace within schemes should be subject to viability and balanced with affordable housing and family housing provision. Policy should be amended to reflect delivery of affordable housing and family units within mixed use developments.


608 B.5Delivery of employment opportunities throughout construction should reference viability to ensure developments are not stifled. Should be updated within policy. REP.LP.057 Diana Thomson, Savills

609 SP2

Support maximisation of housing opportunities but target of 1471 is insufficient. Welcome London Plan and Para 47 of NPPF references to exceeding targets. NPPF requires a 5% buffer and where consistent history of under-delivery a 20% buffer. Plan sets out delivery past 5 years is uncertain but can meet buffer for first 5 years. Should assess borough part delivery rates where all four have failed to meet targets so LLDC should increase its target to meet requirements to mitigate against shortfalls. Should amend policy to reflect fact family housing is not required across all tenures.


34

610 H.1

Appreciate need for family housing but is not appropriate across all tenures so will not necessarily meet objectively assessed need. To be effective should be reworded to reflect need for smaller dwelling sizes identified within SHMA review.


611 H.2Appreciate need for range of housing tenures but tenure split does not take account of site specific circumstances and ability of sites to deliver affordable housing. Split should be subject to viability to ensure is deliverable. Object to phased viability re-appraisal in bullet 4. In spirit of HCA guidance review mechanism/deferred obligations should only be appropriate on large multi-phased schemes where development is to be built over extended period. Where developments to be commenced within agreed timescales, reviews should not be necessary and policy should be amended to reflect this. Should take account of


612 H.3 No comment. REP.LP.057 Diana Thomson, Savills613 H.4 No comment. REP.LP.057 Diana Thomson, Savills614 H.5 No comment. REP.LP.057 Diana Thomson, Savills615 H.6 No comment. REP.LP.057 Diana Thomson, Savills616 H.7 No comment. REP.LP.057 Diana Thomson, Savills


Note family housing requirement which is consistent with Newham's Core Strategy Site S09. Evidence for this derives from the Newham 2010 SHMA which is no longer robust especially given changes for Registered Providers and bedroom-tax. LLDC SHMA identifies need for high proportion of 1 and 2 beds which has been ignored within the policy. OLSPG identifies Pudding Mill as being new mixed use neighbourhood but does not identify it as a location for family housing. Given high accessibility of Pudding Mill area and site allocation requirements of 25% employment, new Local Centre and new local open space is appropriate to provide a range of dwelling types across the area. Should be viability led. So reference to significant proportion of family homes should be replaced with reference to broad range of unit types including one, two and family accommodation. Should not resist developers with sector and market knowledge seeking to deliver smaller dwellings.


617 CI.1

Requirement for additiional community infrastructure acknowledged. Policy should incorporate sufficient flexiblity to reflect the viability and dleivery of individual schme to ensure that requirements do not increase financial burder on schemes beyond which they can viably afford. Otherwise delivery of regeneration could be dealyed. The policy should incorporate greater flexiblity to ensure that the deliverability of sites is not compromised.


618 CI.2 No comments. REP.LP.057 Diana Thomson, Savills619 SP3 No comment. REP.LP.057 Diana Thomson, Savills620 BN.1 The policy should be positively prepared so as to achieve sustainable development. The policy should not, however, seek to overly restrict and control development proposals. REP.LP.057 Diana Thomson, Savills591 BN.10 We strongly object to the introduction of rigid height limits for buildings across the Pudding Mill area. The proposed 21 metre limit for the majority of the area appears arbitrary. REP.LP.057 Diana Thomson, Savills629 BN.10 N/A REP.LP.057 Diana Thomson, Savills630 BN.11 No comment. REP.LP.057 Diana Thomson, Savills631 BN.12 No comment. REP.LP.057 Diana Thomson, Savills632 BN.13 No comment. REP.LP.057 Diana Thomson, Savills633 BN.14 No comment. REP.LP.057 Diana Thomson, Savills634 BN.15 No comment. REP.LP.057 Diana Thomson, Savills635 BN.16 Excessively detailed or inflexible policies concerning the protection of individual buildings or groups of buildings should be avoided. REP.LP.057 Diana Thomson, Savills621 BN.2 No comment. REP.LP.057 Diana Thomson, Savills622 BN.3 No comment. REP.LP.057 Diana Thomson, Savills623 BN.4 No comments at this stage. REP.LP.057 Diana Thomson, Savills624 BN.5 No comments at this stage. REP.LP.057 Diana Thomson, Savills625 BN.6 No comment. REP.LP.057 Diana Thomson, Savills626 BN.7 No comment. REP.LP.057 Diana Thomson, Savills627 BN.8 No comment. REP.LP.057 Diana Thomson, Savills628 BN.9 N/A REP.LP.057 Diana Thomson, Savills636 SP4 We appreciate the importance of delivering a sustainable and healthy environments (built and natural), provided that policies are in accordance with the London Plan. REP.LP.057 Diana Thomson, Savills637 S.1 No comments at this stage. REP.LP.057 Diana Thomson, Savills

638 S.2Appreciates the importance of minimising carbon dioxide emissions in line with the Policy and the London Plan. Would note the importance of ensuring that the viability and subsequent deliverability of development is not compromised by unduly onerous energy requirements.


639 S.3Notse the importance of the provision of new energy infrastructure, however, considers that these requirements should not impede the deliverability of development and render proposals unviable. Seeks the addition of “where feasible and viable.” to the final sentence of the policy.


640 S.4 No comment. REP.LP.057 Diana Thomson, Savills641 S.5 No comment. REP.LP.057 Diana Thomson, Savills642 S.6 No comment. REP.LP.057 Diana Thomson, Savills643 S.7 No comment. REP.LP.057 Diana Thomson, Savills644 S.8 No comment. REP.LP.057 Diana Thomson, Savills646 Sub Area 1 No comment. REP.LP.057 Diana Thomson, Savills647 Sub Area 2 No comment. REP.LP.057 Diana Thomson, Savills648 Sub Area 3 No comment. REP.LP.057 Diana Thomson, Savills650 4.1 No comment. REP.LP.057 Diana Thomson, Savills

651 4.2 Welcome the delivery of new connections within the sub area to serve new development, however, these requirements should not impede the deliverability of development and render proposals unviable. REP.LP.057 Diana Thomson, Savills

652 4.3 No comment. REP.LP.057 Diana Thomson, Savills653 4.4 No comment. REP.LP.057 Diana Thomson, Savills655 SA4.2 No comment. REP.LP.057 Diana Thomson, Savills

35

592 SA4.3

Employment Provision: Quantum. Whilst we support the delivery of a mixed use area at Pudding Mill, we object to rigid designations which do not have the flexibility to respond to market demands and changing circumstances. By way of background, as the LLDC will be aware, the London Plan (2011) identifies the Lower Lea Valley (including Stratford) as an Opportunity Area and the GLA’s OLSPG, as

published in July 2012, sets out the Mayor’s planning priorities for the Queen Elizabeth Olympic Park and surrounding area. The Further Alterations to the London Plan (FALP) states at paragraph 2.62 that the

Mayor will continue to work with boroughs and other delivery partners to ensure that the development capacity estimates for Opportunity Areas are up-to-date, realistic and aligned with strategic as well as local priorities. Paragraph 2.62 of the FALP goes on to state that there is “concern that aspirational employment allocations should not fossilise housing potential” (our emphasis). It is further stated that “employment

capacities should, if necessary, be reviewed in the light of strategic and local employment projections” to ensure that housing output is optimised. We consider that the proposed approach in the suggested

policy wording for the Pudding Mill site allocation (p.218) conflicts with the approach identified in the FALP and needs to be reconsidered. Instead of requiring a rigid 25% provision of non-residential uses across the area, policy should be amended to promote developments which seek to maximise the potential of underused low employment generating areas. Developments which have the ability to provide better quality employment accommodation, enhanced townscape benefits and a better mix of uses to meet the LLDC’s wider needs in accordance with national and strategic planning policy directives should be

encouraged by policy. The provision of non-residential uses should be led by market demands and should be driven by viability. We would recommend that the LLDC reviews its prescriptive 25% target for non-residential floorspace across the Pudding Mill area in light of the FALP guidance, to ensure that these priorities are aligned. Where employment floorspace is to be provided within schemes, this provision should be market-led and not governed by prescriptive floorspace or job-generating requirements.


593 SA4.3Do not support direction of non-residential to central street across Pudding Mill which is unjustified, prejudicing vitality and viability of uses should be market-led. Ground floor non-residential should be encouraged along the waterways and at key nodes to encourage activity.


595 SA4.3

On the basis of high accessibility of Pudding Mill area and planning future improvement to enhance its connectivity think designation as medium density is too prescriptive and a missed opportunity to 'boost significant the supply of housing' as sought by national planning policy. See also London Plan policy 3.4 and draft FALP amended policy 3.7. Site allocation policy designation and Pudding Mill should be more flexible. This would allow for a design led approach to be adopted on individual sites which would inform the overall density of scheme proposals.


590 Sub Area 4

We are pleased to note that the LLDC considers Sub-Area 4 to be a place of extensive development opportunity, and that Pudding Mill is recognised as comprising an opportunity for change and development (Site Allocation SA4.3). Development Principles. The draft site allocation is accompanied by a number of key development principles. We comment on these as follows. As set out in our previous representations, we also continue to have serious concerns regarding the identified housing and employment provision numbers for the area and the evidence base required to support the proposed figures. We have a number of comments on the proposed allocation, which we set out below.


649 Sub Area 4

We are pleased to note that the LLDC considers Sub-Area 4 to be a place of extensive development opportunity, and that Pudding Mill is recognised as comprising an opportunity for mixed use development, to bring the delivery of “new business and residential communities”. We support development in the area and would like to see development which has the ability to come forward earlier than anticipated

encouraged as a catalyst for future development and investment. Development which is ready to come forward should not be prejudiced by prescriptive timescales set by planning policy but should be market-driven with appropriate phasing and delivery. The vision states that Pudding Mill Lane will “meet a wide range of housing needs, while the new homes, business and other premises will have been sensitively

and excellently designed, taking account of the historic waterside settings and the heritage assets within and around the Conservation Areas”. We consider that development sites should be treated on their

merits with regards to individual constraints and what is feasible, viable and deliverable. We would encourage a balanced approach to considering development proposals, with regard to be had to the individual benefits to be delivered by schemes.



Management of transition between new residential acocomodation and extant indusrial uses is acknowledged to be important. However developments which come forward early should not be unduly restricted (plan should be positively prepared in line with NPPF paragraph 182).



Planning contributions should meet the statutory tests set out in Regulation 122 of the CIL regulations and be in line with NPPF paragraph 173. REP.LP.057 Diana Thomson, Savills


No comment. REP.LP.057 Diana Thomson, Savills

674 Our AreaParagraph 2.6 Challenges and Opportuities. Challenges need to acknowledge and include the need for the plan to … ‘Address physically run down areas and sites’. Add remediation of land to the list of

challenges (it may be in the wrong column under ‘opportunities’)

REP.LP.058 Austin Mackie on behalf of British Telecom

677 SD.1 Supports, but with the request that the policy acknowledges the importance of delivery rather than simply the planning process. REP.LP.058 Austin Mackie on behalf of British Telecom

675 VisionSupport the vision and 5 objectives REP.LP.058 Austin Mackie on behalf of

British Telecom

678 SP1Support principle of economic development locations. REP.LP.058 Austin Mackie on behalf of

British Telecom

665 B.1Policy is unduly restrictive and inflexible which undermines regeneration and development targets at HWFI. See attached comments relating to B.1. REP.LP.058 Austin Mackie on behalf of

British Telecom

666 B.1 Counting yards as floorspace is unduly restrictive, undermining regeneration and targets at HWFI. REP.LP.058 Austin Mackie on behalf of British Telecom

680 B.1

Elements of policy are not consistent with the plan objectives. Evidence does not justify the protection afforded to existing employment uses outside defined clusters which is the same as within the clusters. Criterion 4 makes sense in retaining existing levels of employment / floorspace within defined employment areas, but criterion 5 applies the same protection outside. 5a protects B2 /B8 uses regardless of quality, character, location, and 5b has no regard to the opportunity / ability of a site to meet other Local Plan priorities. Evidence does not justify protecting all B2 and B8 sites within areas designated as Mixed Use Growth Areas and retaining this across areas of HWFI would adversely affect the ability of the plan to deliver its wider priorities. Outside clusters should not have to demonstrate 2 years marketing as this inhibits the regenerative opportunity of the area and delivery timeframes. Should delete criterion 5 as is retention of land outside of defined employment clusters and centres. Whilst Para 4.15 implies greater flexibility, this is not incorporated within Policy B1.5 as presently drafted. Should reword Criterion 5 as follows: “Proposals on land outside of defined employment clusters and which contain an element of

existing employment function will be considered against the following criterion: (a) the impact of the existing employment use on both existing and planned uses (b) the wider local plan aspirations for the site and its surroundings (c) relocation strategies showing, where necessary, that existing activity can be suitably accommodated in alternative locations (d) where sites are not suited to existing uses or there is no requirement to retain them, the ability to provide alternative employment floorspace, jobs and net economic benefits that address wider plan aspirations and which are capable of integration with a wider mix of uses”


682 B.2

While broadly support principle of unit size and location plan should not require formal impacts assessment for small units. 200sqm threshold is too low for non-A1 uses and does not appear to be justified within the evidence. Policy should recognise that some locations such as new routes, public realm and waterside can be appropriate for active uses but not within a centre. Make it clear that active non-A1 uses exceeding 350sqm but below 2500 is proposed outside centre then applicant would need to demonstrate that use complements Plan's aspirations for that location.


36

683 B.3

Support principle of interim uses but should not adversely impact on planned form of development of the site. For example, interim employment should not trigger B.1 issues. Should add text "The Legacy Corporation will encourage interim uses that meet with policy B.3 and generate new employment. Where such uses are introduced on sites not previously in active employment use or designated for employment use, the interim use will not be treated as an employment use under policy B.1.".


679 Business Growth

Support defined employment clusters. REP.LP.058 Austin Mackie on behalf of British Telecom

681 Business Growth

Existing employment floorspace should not apply to yards as is unnecessarily restrictive, rendering regeneration unviable. Requirement fails to consider character of many yards which have practical use and economic benefit. Should remove reference to yards.


685 Objective 2

Should make reference to exceeding housing targets rather than approximate number. Amend first bullet to "evidence suggests that we need to deliver a minimum of ##,000 new homes. We will endeavour to exceed these targets"


687 H.1 Not clear what criterion is referring to or seeks. Character and balance of residential communities will change in the area with new communities and balance of residential to non-residential changes. REP.LP.058 Austin Mackie on behalf of British Telecom


Support housing as a driver. REP.LP.058 Austin Mackie on behalf of British Telecom


Support key neighbourhoods definition. REP.LP.058 Austin Mackie on behalf of British Telecom

688 Objective 3 It will not be appropriate in all instances to ‘ maintain local distinctiveness’ or retain character. Amend Criterion 3 to start “Where appropriate…..” REP.LP.058 Austin Mackie on behalf of British Telecom

667 BN.1 See attached schedule, greater flexibility required in terms of character. [See other comments set out by Austin Mackie relating to the Built Environment]. REP.LP.058 Austin Mackie on behalf of British Telecom

689 BN.1 Fails to have regard to the potential opportunity to improve the character of an area. The policy assumes that all areas possess a positive existing character. REP.LP.058 Austin Mackie on behalf of British Telecom

668 BN.10 N/A REP.LP.058 Austin Mackie on behalf of British Telecom

691 BN.10

The policy fails to have regard to the fact that in many areas the existing context is poor and/or that the plan proposes to alter existing context (criterion 2 and 3). Delete Criterion 2 and 3 or amend to acknowledge that in many areas the existing context is not relevant or will change as part of the plan’s wider aspirations. The requirement for on-site communal space (5 and 6) may not always be relevant

where proposals come forward within wider area masterplans or as part of a series of coordinated developments. The penultimate sentence suggests that tall buildings will only be permitted in certain locations, which is too prescriptive. It is not clear whether the policy refers to existing or planned prevailing heights. In criterion 1 amend “outstanding” to ‘high quality’. In criterion 10, amend the first part to read “Preserve

or enhance the …the significance of a … heritage asset….” Delete the list of locations in favour of a criterion driven approach. Delete the final sentence. Add a new criterion to the effect ‘#. They are located in

an existing poor urban setting which can be to be repaired or enhanced and where they are sited such that they may bring environmental or amenity benefits to the surrounding area’



Suggested that small open spaces could be up to 2 ha. REP.LP.058 Austin Mackie on behalf of British Telecom

692 S.8

Considers that a policy which requires the application of the exception test to non-allocated sites will adversely affect the ability of a significant part of HWFI to deliver the change and growth identified in the plan. As such development plan targets and wider aspirations such as environmental enhancement and new public realm will be seriously undermined. Seeks amendment to the second paragraph of the policy to read.. “Where development is proposed within Flood Zones 2 or 3 and is outside a Site Allocation or Growth Area…..”


669 1.1 N/A REP.LP.058 Austin Mackie on behalf of British Telecom

698 1.1Re-phrase to make clear that development should have regard to heritage assets where relevant and that in assessing new development, the LPA will have regard to the ability of any scheme to reflect and enhance the overall vision for the area.


699 1.1 Add new criterion :“introduce new residential uses and activity that adds to the overall mix of uses” “accord with the principles of a site allocation” “contribute to the vision for the sub area” Amend existing criterion 1 and 2 to reflect

that a differing approach to existing employment floorspace should take place outside of employment clusters. Existing criterion 3 should be amended to refer to heritage assets.


700 1.2 Supported. Unlike other policies, 1.2 appropriately refers to character rather then ‘heritage-led’. The latter should only refer to specific areas as per 1.4 beliow REP.LP.058 Austin Mackie on behalf of British Telecom

701 1.3Support. REP.LP.058 Austin Mackie on behalf of

British Telecom

702 1.4Supported. REP.LP.058 Austin Mackie on behalf of

British Telecom

703 1.5Whilst we support the general improvement of the public realm within the area, we are unable to identify within the evidence base any support for the site specific allocation of open space in SA1.3. Further evidence required.


670 1.6The policy on height is too prescriptive – delete and rely on a modified BN.10 REP.LP.058 Austin Mackie on behalf of

British Telecom

704 1.6 It is suggested that the prevailing height is 20m. This is clearly not the case. 20m appears to be the LPA’s aspiration, but is equally unjustified. It is considered to be unsound to have a strict height reference

within policy, espcially in an area where (i) existing heights are varied and (ii) significant new development and change is proposed. Delete.REP.LP.058 Austin Mackie on behalf of

British Telecom

676 Sub Area 1 Support for HWFI as a growth area. REP.LP.058 Austin Mackie on behalf of British Telecom

659 Sub Area 1 The site allocation as recommended below will ensure that the Local Plan is positively prepared, effective and deliverable and that it not only accords with the tests of soundness, but also the NPPF’s emphasis

upon delivering sustainable development.REP.LP.058 Austin Mackie on behalf of

British Telecom

660 Sub Area 1 The allocation is justified on the basis that the alternative of a policy or criteria driven approach to the site would not provide sufficient certainty that the site would deliver key Local Plan objectives for not simply the site, but the wider Sub Area.


661 Sub Area 1 The existing buildings are limited in their form and flexibility and are not readily adaptable for alternative employment generating uses. Their character is not compatible with the Local Plan’s aspirations for the

area. REP.LP.058 Austin Mackie on behalf of

British Telecom

37

662 Sub Area 1

The following plan sets out LLDC’s broad parameters for this key connection between the station and the heart of the new neighbourhood centre and significant section of Fish Island. The BT site sits directly

on this route and effectively severs it at a critical section. The route will require a significant part of the BT land, rendering the site operationally unviable. Securing and delivering the route therefore requires a comprehensive approach to the site that can only be achieved via a site allocation – a policy approach would not offer any certainty.


663 Sub Area 1 Having regard to its significant location, a change in the character of the site is necessary if plan-wide objectives such as heritage-led regeneration are to be successfully delivered. Having regard to its unique context, a site allocation is therefore justified and necessary.


664 Sub Area 1 Suggested Text: Site Allocation SA1 / Hepscott Road / Rothbury Road: Mixed-use development including residential, employment, and active frontage uses. REP.LP.058 Austin Mackie on behalf of

British Telecom

693 Sub Area 1 General vision supported REP.LP.058 Austin Mackie on behalf of

British Telecom

694 Sub Area 1 In keeping with the main plan key diagram, this one for the sub area should indicate that residential and mixed-use development is appropriate outside of defined employment designations and the supporting text amended to reflect this too.


695 Sub Area 1 We consider that it is inappropriate to place an undue emphasis upon existing built character when many areas clearly have no prevailing character. REP.LP.058 Austin Mackie on behalf of British Telecom

696 Sub Area 1 We do not consider that the evidence base justifies a housing figure as low as 4,500 REP.LP.058 Austin Mackie on behalf of British Telecom

697 Sub Area 1 N/A REP.LP.058 Austin Mackie on behalf of British Telecom


The Plan has unnecessarily strong emphasis upon heritage character-led development. It imposes an unnecessary level of constraint upon the form of development and stifles high quality development. This is particularly relevant to HWFI. Concern that there is an increasing emphasis upon employment development and the protection of employment space where this lies outside of defined core employment/commercial areas.The plan should place greater emphasis upon the areas where residential development is achievable and where residential development will be seen as a regeneration driver. It



The first para’ and those that follow are arguably quite inward looking and principally focus on the role and opportunity of the Park. REP.LP.058 Austin Mackie on behalf of British Telecom

705 See REP.LP.056. REP.LP.059 William Chamberlain706 See REP.LP.024 REP.LP.060 Andrew Wernick707 See REP.LP.024 REP.LP.061 Charlene Michael

708 See REP.LP.056. REP.LP.062 Andreas Lang, Public Works limited

710 Sustainability

Natural England considers that the Publication version of the Local Plan is sound in terms of having been positively prepared, justified, effective and consistent with national policy. The changes which have been made from the last round of consultation have made the document more coherent. The inclusion of Sustainable Urban Drainage Systems (SUDS) in policy in the Local Plan is welcomed and helps strengthen the document in terms of its consistency with the National Planning Policy Framework (NPPF), falling better into line with paragraph 99, in particular. This will help to tie in with the other Green Infrastructure (GI) work that has already been carried out across the site and will continue to form a key element of all new development that takes place across the plan area. There has been liaison with Natural England during the Plan making process, helping to ensure that the duty to co-operate is met. Our previous correspondence (dated 12th February 2014) has been taken on board and actions have been taken with regard to the inclusion of SUDS wherever possible as above are welcomed.

REP.LP.063 Natural England


The document is sound in terms of having been positively prepared, justified, effective and consistent with national policy. The changes which have been made from the last round of consultation have made the document more coherent although there has been some change to policy numbering this hasn’t affected the content of said policies.

REP.LP.063 Natural England

713 1.1Part 1 of policy 1.1 is unnecessary as it in part repeats the provisions of draft policy B.1 with regards to the approach to existing employment floorspace. It is also inconsistent with policy B.1 which recognises that an increase in job densities as opposed to floorspace quantum can be appropriate.

REP.LP.064 Quod

712 SA1.4In L&Q’s view, ancillary retail uses should also be added to the uses listed as appropriate for the site. In L&Q’s view, the location of the non-residential ground floor frontage is an unnecessary constraint that

would undermine the design of the redevelopment and should be removed.REP.LP.064 Quod

715 SA1.3Support REP.LP.065 Austin Mackie on behalf of

O’Shea Ltd and Galliard

Homes Ltd

716 SA1.3

Map to extend active frontages along the canal) blend all active frontages/non-resi GF frontages) REP.LP.065 Austin Mackie on behalf of O’Shea Ltd and Galliard

Homes Ltd

717 SA1.3There is no support on the evidence base for either the quantum or form of open space required. REP.LP.065 Austin Mackie on behalf of


Homes Ltd

718 SA1.3

Public realm provision may not be open. Delete “…and public realm improvements” REP.LP.065 Austin Mackie on behalf of O’Shea Ltd and Galliard

Homes Ltd

719 SA1.3Waste: The second part of the criterion is unnecessary and would potentially not allow the waste license matter / policy to be addressed at a strategic scale. Delete from “Any such proposal……” REP.LP.065 Austin Mackie on behalf of


Homes Ltd

720 SA1.3Add and active Class A frontages to the list of uses under comprehensive development. In addition to ‘employment, residential and creative use’ reference should be made to active frontages. REP.LP.065 Austin Mackie on behalf of


Homes Ltd721 SA1.3

Phasing is inaccurate REP.LP.065 Austin Mackie on behalf of O’Shea Ltd and Galliard

Homes Ltd

723 B.1

Bullet 4 suggests should maintain or re-provide B2/B8 floorspace. This rules out redevelopment of warehouse with B1c workshop and see no reason why B2/B8 should be protected outside designated clusters and see nothing in supporting text to explain this. Would be sensible to allow changes to B1 and many examples of modern large warehouses employing few people have been redeveloped to create schemes with equivalent amount of B1 space with significant increases in job levels. Protecting warehouses goes against LLDC objectives of strengthening foundations of creative and cultural uses. Policy should protect employment pace but allow for changes between B1-B8 and other commercial uses. Support reference to job densities within 5b and feel this should assist greatly in providing flexibility whilst reference to re-provision of floorspace gives a clear alternative. Flexible approach should apply to all B use classes.

REP.LP.066 Tim Gaskell, CMA

38

724 B.2

Support Hackney Wick Neighbourhood Centre designation as a positive change, also support point 6 to allow complementary residential. Plan fails to mention live work in glossary and for allocation at Wick Lane is major omission. Often live work another word for loft-living with design placing emphasis on residential with too small workspace ceasing to be occupied for employment. However idea behind this sound and appropriate for HWFI, a good example being ACME studios’ live work programme to meet artist needs. Living element is ancillary to studio and deliberately refers to them as work-live. Plan should

include a policy on this and look at following ACME model or similar. ACME often advises local authorities on requirements and benefits of work/live artist spaces.


725 Business Growth

The Plan needs to consider Live / Work REP.LP.066 Tim Gaskell, CMA

727 BN.16 We object to the same “preserve or enhance” test being applied to designated assets as well as non-designated assets. REP.LP.066 Tim Gaskell, CMA726 BN.9 Seeks inclusion of view along the Greenway REP.LP.066 Tim Gaskell, CMA

728 1.1

Policy 1.1 outlines that the overall level of employment floorspace in the sub area should be retained at point 1. This seems at odds with Policy B.1, which takes a more flexible approach, with reference to job densities.

Objects to point 2 and the lack of support for B1a uses outside the Hackney Wick Station area, in favour of B1b, c, B2 and B8 uses.


730 1.6

We support the general flexible approach taken to building heights in the Local Plan, as set out in Policy BN.10, but object to Policy 1.6 as this is at odds with BN.10. In the first instance, the 20 metre reference seems a rather random, arbitrary figure. How was it arrived it and what is the justification? Paragraph 10.14 says this is the existing prevailing building height, but without evidence, we cannot agree.


731 SA1.1For Site SA1.1, we would question the requirement for the overall amount of existing employment floorspace (B Use Class) within the allocation boundary to bemaintained.


732 SA1.6Support REP.LP.066 Tim Gaskell, CMA

729 Sub Area 1 Figure 30. Inclusion of building at the north east corner of Wallis Road and Berkshire Road as heriatge building is inappropriate and should be removed. Change term Assets to Structures. REP.LP.066 Tim Gaskell, CMA

733 CI.1There is no detail about the level of community infrastructure (health centres, schools, corner shops etc) in the local area that would ensure that the communities needs were met - especially for those without their own transport and with limited mobility.

REP.LP.067 Francis Basset, Newham Friends of Earth

735 BN.10Policy does not provide an adequate safeguard against tall buildings overpowering the local community. REP.LP.067 Francis Basset, Newham

Friends of Earth

734 BN.7Detail needed regarding the proportion of natural to manmade space. REP.LP.067 Francis Basset, Newham

Friends of Earth

737 Vision

Supports the Plan’s Vision and the clear framework for land use change and management that it sets out. Considers that It is correct to establish and maintain locally distinctive neighbourhoods to meet

housing needs and increase prosperity through a growth in business and quality jobs. This ensures conformity with the London Plan. Providing opportunities for the local community and delivering transformational change does however require a balance and realism if the Plan is to be deliverable and positively prepared in accordance with NPPF paragraph 182. GPH also supports the identification of the Pudding Mill Lane area as a key district for change in the Corporation’s 2031 vision subject to specific comments on the Pudding Mill SIte Allocation SA4.3. Recommend removal of the Site from the Economic

Cluster and OIL designations in the Plan’s Written Statement (see Table 2 Reference B.1b6) and Proposals Map, removal of the Employment Designation in Figure 35: Sub Area 4 key diagram. Support for the

Site’s inclusion within Site Allocation SA4.3, removal of the Employment Designation within Site Allocation SA4.3. Allow buildings above 21m within Site Allocation SA4.3 where compliance with the principles

outlined in Policy BN.10 can be achieved.

REP.LP.068 Barton Wilmore on Behalf of Gold Pot Holdings

738 B.1

Objects to the identification of the Cooks Road site as part of an Employment Cluster as it no longer makes a meaningful contribution to supply recognised initially by the downgrading from a Strategic Industrial Location (SIL) to an Other Industrial Location (OIL) in the Core Strategy. Employment activity on the site has since significantly reduced and is now only partially let and only occupied by small businesses on temporary leases. Market testing has not identified any meaningful interest or potential consistent with general trends identified in the Employment Study evidence base. Accommodation is dated, is in close proximity to existing and planned residential, is possibly contaminated, and with no meaningful re-occupation or re-development interest for large-scale employment use means the value as a potential, viable and deliverable employment cluster has diminished. Need to explore alternative land use options to contribute to wider Pudding Mill Lane area objectives. Some job potential on site but is expected to be focussed towards localised community needs and of a lesser scale than industries within SIL, OIL and clusters. Should remove site from designated OIL to avoid an over-supply of industrial sites and allow Plan to focus on delivery of better located sites with greater prospect of reoccupation or redevelopment for B Class use. OIL designation is incompatible with surrounding / planned land uses and is not justified within the evidence base. Amendment would achieve soundness, particularly Para 22 of NPPF.


739 SA4.3

Generally support, but have specific objections to the detailed elements of the Allocation as presented in the policy. Object to employment designation. This is unsound and should be removed. Removal of this onerous policy requimrent would allow GPH to forumate a viable mixed use and residential led shcme which can meet genuing small scale employment needs and deliver residential growth. Such an apporach dould also create a far more positve frontage to the River Lea and a beneficial and visually attractive entracne to this part of hte LDDC area when viewed from west and south west. To retain the site for industrial use would undermine this and only lead to long term vacancy and incompatiblity with surrounding uses. There is also no sound justification presented in the Plan or its evidence base for the restriction of development height in the area to up to 21 metres from ground level. There are already examples of higher buildings in the policy area, so it is clear that an appropriate form of development can be achieved and there is no reason to impose such a level of control. The restriction on height should therefore be removed. Development in the area should instead be judged against Policy BN.10 in order to determine whether it is an appropriate design approach or not.


741 B.3

Policy is not sound as fails to address how temporary uses will connect with and meet local needs. Concern that rather than addressing convergence aims may be a promotional device. Policy fails to highlight importance of creative and cultural uses for the long term. Such industries are linked to other businesses within the area through supply chains. Should not be demoted to temporary uses. Should expand text to require temporary uses to be sought from local communities and implementation of proposals as part of the long term strategy. Wording should be added to make clear that cultural and creative uses are part of the economy in the long term and have potential to be long term rooted within the area.

REP.LP.069 Mara Ferreri

742 Sub Area 1 The Draft Plan fails to take full account of the Adopted Fish Island Area Action Plan (2012). Particularly with reference to the designation of the Hackney Wick Hub Area. REP.LP.070 Lee Melin

744 B.1Object to policy and criterion 5a which requires maintenance or re-provision of equivalent industrial floorspace within B2/B8 Classes outside clusters. This is overly restrictive and could undermine maximisation mixed use redevelopment opportunities for outside clusters, such as 24-26 White Post Lane. This goes against national planning policy to positively plan for development and infrastructure so is unsound. Policy should recognise that alternative forms of employment can contribute to the economy without same use and floorspace as traditional forms of industry. For example, SME's can be accommodated within residential-led mixed use development. Policy criteria 5(c)- 5(h) are unclear and undermines the effectiveness of the Local Plan. For example, unclear whether there is an expectation for 2 years of marketing

REP.LP.071 Gerald Eve LLP, Sulzer Dowding

39

745 B.2Welcome Neighbourhood Centre at Hackney Wick covering retail, leisure, employment and residential. This will support regeneration of surrounding sub area and acknowledge that sites adjoining the centre including on White Post Lane have opportunity to contribute to mixed use development delivery as indicated by Hackney Wick and Fish Island Design and Planning Guidance.


746 SP2 Welcome commitment to exceed target of 1471 but should include commitment to maximising capacity as part of mixed use development. REP.LP.071 Gerald Eve LLP, Sulzer Dowding

748 1.1 There may be exceptions where small scale B1(a) office use could be appropriate as part of mixed use development outside of the allocated Neighbourhood Centre. REP.LP.071 Gerald Eve LLP, Sulzer Dowding

747 Sub Area 1 The identified housing numbers are unlikely to sufficiently capture available housing capacity which may be deliverable in the short term. It is therefore not considered effective in delivering housing capacity in the short term.


750 Vision

Considers that if the Plans objectives are to be met that it is essential that its planning policy is sound and robust and provide certainty for developers. Without this it considers development will not be forthcoming in the quantum required to deliver the objectives. Considers that the current evolving schemes at 60 Dace Road and 4 Roach Road represent important development opportunities on two key sites within Fish Island that will bring about numerous planning benefits and that the early delivery of the right form of viable and deliverable development on this site can only help to promote the wider area and attract the scale, form and nature of development sought. It is important the policy in the emerging Local Plan does not frustrate this potential.

REP.LP.072 Montagu Evans on behalf of Constable Homes Limited.

751 VisionSupports the identification of Fish Island Mid as a ‘mixed-use growth area’ within the overarching vision for the Legacy Corporation area, as set out on page 15. Fully supports Policy SD.1 Sustainable

Development.REP.LP.072 Montagu Evans on behalf of

Constable Homes Limited.

752 B.1

Part 5 states proposals on employment land outside employment clusters shall maintain or re-provide B2/B2 or maintain or re-provide B1 or increase job density and wording within Para 4.10. The FIAAP (FI4.3) supports the redevelopment of former industrial land for mixed uses, including residential, where meet a number of criteria, including maintaining or increasing employment density and retaining or refurbishing heritage assets. We support retention within Local Plan where recognises that case can be made for the loss of existing industrial floorspace that does not support the optimum levels of employment. There are a number of sites within Fish Island which are underutilised and which are better suited to alternative employment purposes to maximise employment opportunities at increased employment densities. Policy should give further emphasis in relation to the reuse of buildings of heritage value for employment where in accordance with FIAAP, but other Local Plan policies. Para 4.7 gives more justification in terms of diversity of offer and ability to transform and grow displays potential with cultural and creative alongside other heavier industries, office, retail and leisure. Para 4.8 notes that strengthening creative and cultural industries with new economic uses at Hackney Wick and Fish Island stimulate growth. Paragraph 4.11 states support for employment floorspace to accommodate existing businesses including the creative, productive and cultural industries. Support thrust of policy to enable growth of a diverse economic offer but are concerned of risk that area becomes too focussed on ‘creative

and cultural industries’. It important is to ensure that new uses are complementary to area’s character. While cultural industries have a role to play suggest that wording clarifies that such uses will not be

prioritised above other viable and appropriate employment uses that meet identified local and strategic needs.


753 B.4

Support B4 principles which refer to provision of low cost and managed workspace. Support recognition that providing affordable workspace is next level beyond starter units for establioshed businesses. Policy should be more robust through clarification of net loss of employment. Should amend to “ Does not result in a net loss of active and viable employment space or of the number of employees”. Supportive

of principle set out within part 4 of target rents of 75% below historic market levels., but no guidance of the ‘market’ area but a year given. This is too inflexible and unclear potentially producing skewed results

impacting upon viability. Should have flexibility on case by case basis with respect to market area and time period.


754 SP2

Policy refers to maximising housing and infrastructure provision within new neighbourhoods thorough delivering in excess of target, providing for size and tenure requirements. Support thrust of policy but emphasis on family housing delivery should be tempered with recognition not appropriate in certain locations. Affordable housing target has been set in absolute terms at 35%, support recognition of need to facilitate development and viability as considerations and London Plan policy stipulating need to encourage rather than restrain residential development. Need appreciation of relationship between viability and affordable housing to ensure residential development delivered.


755 H.1

Policy confirms a high requirement for 1 beds in market and affordable/social rented; 2 bed in market and larger than 3 beds particularly within intermediate tenures. States in supporting text that will consider detailed mix of dwelling sizes and consider individual site circumstances including location, viability and maintenance of mixed and balanced communities. Certain sites will be less appropriate for family units. Paragraph notes that London Plan density matrix is useful tool however other considerations will be made including location, constraints, transport accessibility, connectivity and capacity; management, occupancy and tenure of the development; and convergence aims. Support this recognition as critical to ensure appreciation of Para 3.28 of London Plan which states rigorous of housing density is crucial to realising optimal site potential but is start of planning housing development so not appropriate to mechanistically apply Table 3.2 of London Plan. Its density ranges for particular locations are broad, enabling account to be taken of other relevant factors i.e. local context, design and transport capacity.


757 BN.10

The policy goes on to state that tall buildings should be located within the Centre boundaries outlined within the Local Plan. In our view the wording of this latter element of the policy is unnecessarily restrictive, and could unwittingly prevent the development of tall buildings in suitable locations outside of the identified centres.


758 BN.16

Supported REP.LP.072 Montagu Evans on behalf of Constable Homes Limited.

756 BN.4Support Policy BN.4 REP.LP.072 Montagu Evans on behalf of


759 Objective 4

The plan should recognise and confirm that PTAL levels of specific sites will change following improved local connectivity including new bridges and routes in line with Objective 4. This will have implications for the types of development that would be acceptable on particular sites. Stratford International Station operates as a multimodal transport hub and will have a draw beyond the typical walking or cycling catchment considered as part of a formal PTAL assessment.


761 1.1Concerned that the emphasis given to creative and cultural industries could frustrate proposals for other viable employment uses. We also request that clarification is inserted into this policy regarding the acceptability of redevelopment proposals that succeed in increasing employment density if not specifically employment floorspace.


762 1.4Policy 1.4 must ensure applications are informed by a full and robust assessment of what constitutes the value of designated and undesignated assets so as to avoid blanket protection that is unsubstantiated and can frustrate development opportunities.


763 1.6We have some concerns with the wording of Policy BN.10 and request that this amended to ensure it is clear that tall buildings are acceptable in appropriate locations (i.e. not only within identified centres), subject to certain criteria.


40

760 Sub Area 1 Support Vision REP.LP.072 Montagu Evans on behalf of


764 Objective 3 The waterways can help deliver and maintain the Local Plan objectives for the regeneration of the surrounding environment. REP.LP.073 Canal and River Trust

765 BN.2Change text for waterways policy so that it states that the policy expects development proposals that effect the waterways environment to improve existing moorings. REP.LP.073 Canal and River Trust

766 BN.3Clarification that biodiversity enhancement measures should not encroach on navigation and waterway functions and any proposal near the waterways should be designed with early engagement with the Canal & River Trust.

REP.LP.073 Canal and River Trust


Correction to spelling. Include reference to Town and Country Planning Association’s Policy Advice Note: Inland Waterways (2009) within the evidence base references at page 123. REP.LP.073 Canal and River Trust

770 T.10 The Trust supports the use of the waterways for both passenger and freight transport. The second paragraph of the policy should state “…facilitate the introduction of a range of moorings and other waterway-

related infrastructure”.


768 T.4 Supportive of policy T.4 and the reference to the use of waterways as routes for pedestrians and cyclists. REP.LP.073 Canal and River Trust769 T.9 Support REP.LP.073 Canal and River Trust

772 SA1.8 The proposed boundary for Sweetwater does not include the waterspace, although this is clearly an intrinsic part of the area’s character. We are also concerned that only half of Carpenters Road Lock is

included within the area, although this will become a popular amenity hub as one unit.REP.LP.073 Canal and River Trust

771 Sub Area 1 Objecting to the proposed bridges across Old Ford Locks (at the southern end of the Hackney Cut) and across the Bottom Lock on the Hertford Union Canal. REP.LP.073 Canal and River Trust774 SA3.3 Are should incorporate land up to and including the waterspace as is disconnected to leave out, preventing development of this valuable waterside and opportunities for mooring. REP.LP.073 Canal and River Trust775 SA3.5 Should be reference to reinstatement of original towpath. REP.LP.073 Canal and River Trust

773 Sub Area 3 Should be references to proposed activated waterspaces within Olympic Legacy Waterways Strategy. This includes leisure uses providing waterspace access. Vision should reference these opportunities for active and regenerated waterways.


776 4.1 Section should refer to waterbus stop installed on the towpath, which could provide a valuable connection for the existing and future communities. REP.LP.073 Canal and River Trust

777 Vision See REP.LP.015 (Section Response Entry 136) REP.LP.074 Karen Tang on behalf of Acme Studios

778 SP1See REP.LP.046 (Response entry 475) REP.LP.074 Karen Tang on behalf of

Acme Studios

779 B.1B.1 is unsound as it does not provide enough support to retain employment and industrial land. The importance of retaining industrial land should be strengthened. Technological and maker growth take place in workshops and yards as well as offices. Should have more discussion of conclusions of Economy Study particularly important for businesses within Carpenters District which are long-standing and keen to expand. Fails to recognise importance of local employment in terms of lifetime neighbourhoods. To be sound should include employment cluster within Carpenter District and should remain in industrial use. Can provide employment within Sub Area 3 in addition to the retail jobs. B.1 should acknowledge importance of retaining employment sires in terms of lifetime neighbourhoods and reducing need to travel.

REP.LP.074 Karen Tang on behalf of Acme Studios

780 B.2 See REP.LP.046 (Response entry 477) REP.LP.074 Karen Tang on behalf of Acme Studios

781 B.4 See REP.LP.046 (Response entry 478) REP.LP.074 Karen Tang on behalf of Acme Studios

782 B.5The inclusion of this policy is supported in so far as It recognises the economic impacts and benefits that managed workspace can bring, including the reference to demonstrating viability. REP.LP.074 Karen Tang on behalf of

Acme Studios

783 SP2

Affordable homes target does not reflect a proportion of FALP target which is important given number of homes to be delivered, the 2013 London SHMAs identification of backlog need and need for affordable particularly within the Growth Boroughs. Affordable homes are crucial to convergence. To be sound annual target should be 595 a proportion of 106598 FALP target. Does not address need to maintain range of tenures needed within area. Without social rented much of gross affordable will not emerge without protection of existing. Cost of affordable rent and intermediate are beyond means of households in need and failure to protect existing social rented adversely impacting on convergence. This was highlighted in large numbers to previous consultation. To be sound should safeguard existing residential units including social rented and land.

REP.LP.074 Karen Tang on behalf of Acme Studios

784 H.2 See REP.LP.024 (Response entry 249) REP.LP.074 Karen Tang on behalf of Acme Studios

785 CI.1See REP.LP.024 (Response entry 250) REP.LP.074 Karen Tang on behalf of

Acme Studios

786 CI.2 See REP.LP.046 (Response entry 483) REP.LP.074 Karen Tang on behalf of Acme Studios

788 BN.11 See REP.LP.015. (Response entry 148). REP.LP.074 Karen Tang on behalf of Acme Studios

787 BN.6 See REP.LP.015 (Response entry 146) REP.LP.074 Karen Tang on behalf of Acme Studios

789 T.6See REP.LP.015 (Response 155) REP.LP.074 Karen Tang on behalf of

Acme Studios

790 SP5 See REP.LP.015 (Response 157) REP.LP.074 Karen Tang on behalf of Acme Studios

791 S.2 See REP.LP.015 (Response entry 158) REP.LP.074 Karen Tang on behalf of Acme Studios

792 S.3See REP.LP.015 (Response entry 159) REP.LP.074 Karen Tang on behalf of

Acme Studios

793 3.1See REP.LP.024 (Response entry 258) REP.LP.074 Karen Tang on behalf of

Acme Studios

794 3.2See REP.LP.024 (Response entry 259) REP.LP.074 Karen Tang on behalf of

Acme Studios

795 SA3.4 See REP.LP.024 (Response entry 260) REP.LP.074 Karen Tang on behalf of Acme Studios

41

796 IN.2

Seeks the following minor amendments to the Reasoned Justification Paragraphs for Policy IN.2 (Paragraphs 7.6 and 7.7): "7.6 The LLDC is the waste planning authority for its area by virtue of its role as a planning authority. The Four Boroughs have responsibility for waste planning authorities for the Legacy Corporation area are the four Boroughs (Hackney, Newham, Tower Hamlets and Waltham Forest)within the remainder of their area. Each borough has, or will have within the lifetime of this Local Plan, an adopted waste plan or waste planning policies. The adopted ............. The Legacy Corporation will work closely with these two Boroughs the North London Boroughs and other key stakeholders to make ........... 7.7 The London Plan identifies waste apportionment targets ..... However, the Legacy Corporation will cooperate with the four Boroughs in seeking to meet the Borough apportionment targets and strategy for waste. When determining planning applications, these targets........"..

REP.LP.075 North London Waste Plan

797 See REP.LP.024 REP.LP.076 Osedebamen Okojie

817 SP1

See REP.LP.056 (Response entry number 576) REP.LP.077 Tobias Hug on behalf of the HWFI Development Community Group (list submitted separately) Katie Schöffmann

798 B.1

Marketing strategies should be for 5 preceding years rather than 2 as will allow occupancy of industrial employment space. Economy study shows great demand for B2/B8 and B1 workspace alongside diminishing availability of industrial land as a result of release through Fish Island AAP. Is evidence to suggest Wick Lane Wharf have not marketed space sufficiently despite S106 agreements and clear demand. Needs to be more guidance within Para 4.15 for notional block typologies for how B2 uses can be provided within mixed use development as within Economy Study Part C and HWFI Design and Planning Guidance

REP.LP.077 Tobias Hug on behalf of the HWFI Development Community Group (list submitted separately) Katie Schöffmann

799 B.1

Should flexibly design new employment floorspace to maximise uses and take-up including access and management. Mixed use developments should be designed to maximise forms and types of employment uses to be incorporated into the development including B1 and some forms of B2 through good design and vertical and horizontal integration. Needs to be more guidance here for notional block typologies and how B2 uses can be provided within mixed use developments. Recommendations are within the Economy Study Part C and HWFI Design and Planning Guidance.


818 B.1

Support efforts for retention of employment and industrial land but policies do not go far enough. Importance of retaining land for dirty industrial is under recognised. Growth of new technology and maker revolution will not occur in offices but in workshops and yards. More detail of Economy Study needs to be drawn out and reflected so unsound. Should include employment cluster at Carpenters Estate within Table 2. Existing workspace should remain in employment use to provide jobs for local people including light industrial. Land occupied by growing businesses, provide local jobs and training and are valued by local residents. Need this form of employment within the Sub Area in addition to retail jobs within the town centre to achieve convergence. Recent industrial land releases have been three times higher than London Plan targets. Due to residential land values there is pressure to convert employment sites. Development should not stifle the thriving and resilient local economy documented in the Economy Study. The option of significantly increasing job densities within B2/B8 use B.1 5 (b) will increase pressure to redevelop existing employment spaces, reducing likelihood of re-provision of industrial typologies and that existing businesses can be accommodated in new developments. Should delete ‘or significantly increase job densities within B use classes’ from Policy B.1 5(b) as giving option will increase pressure to

develop, reduce likelihood of re-provision of industrial uses and less likely existing businesses can be re-accommodated. Cultural, artistic, manufacturing and making, and food businesses celebrated in Economy Study require space to work and cannot be accommodated within higher-density office spaces. Policy should highlight the importance of local employment which has failed to consider this in terms of NPPF requirements of economic, social and environmental sustainable development. To ensure B.1 is sound: Should Add definitions for Locally Significant Industrial Sites and Other Industrial Location. B.1 and supporting text should strength retention of local employment sites in terms of delivering lifetime neighbourhoods and reducing the need to travel. Should make a link between homes and jobs in order to convergence and sustainable development.


819 B.2

Should add wording to encourage town centre uses contributing to local economy through multiplier effects and local supply chains, including with existing local businesses. Little investment from new town centre developments, such as Westfield, re-circulates in the local area and office workers could leave without spending in the local economy. Growth of Stratford Metropolitan Town Centre could be at the expense of other town centres. It is not clear that the duty to cooperate has been fulfilled on this matter, nor London Plan and NPPF requirements for positive planning to support town centres. Adverse impacts of the Town Centre extension on the existing Stratford Shopping Centre, which provides affordable goods and services, spaces for young people to socialise and skateboard had not been addressed. Table 3 does not show how key existing assets in Hackney Wick will be integrated with new development, and there has been a lack of engagement with community and business groups in Hackney Wick and Fish Island in plans for new neighbourhood Centre nor at new district town centre at Bromley by Bow. To be sound should amend to encourage town centre uses that contribute to the local economy through local multiplier effects and local supply chains. Should address the LLDC’s duty to co-operate in terms of adverse impacts on other town centres.


820 B.3

See REP.LP.056 (Response entry number 554) REP.LP.077 Tobias Hug on behalf of the HWFI Development Community Group (list submitted separately) Katie Schöffmann

821 B.4

See REP.LP.056 (Response entry 587) REP.LP.077 Tobias Hug on behalf of the HWFI Development Community Group (list submitted separately) Katie Schöffmann

800 B.4

Should propose form of managed dual use live work as a potential affordable workspace model. Evidence from LLDC Work Live study awaiting. Should explicitly name a studio provider as part of planning applications as well as written into S106 with detail to tenure, management and design.


822 B.5


823 B.6


816 Business Growth


REP.LP.077 Tobias Hug on behalf of the HWFI Development Community Group (list submitted separately) Katie

814 BN.10

All new and developing centres are specified as appropriate for tall buildings. This assumes that tall buildings are an essential part of regeneration. Locations need to be specific and justified. REP.LP.077 Tobias Hug on behalf of the HWFI Development Community Group (list submitted separately) Katie Schöffmann

42

815 BN.11

See REP.LP.015. (Response entry 148) REP.LP.077 Tobias Hug on behalf of the HWFI Development Community Group (list submitted separately) Katie

812 BN.2

See REP.LP.015. (Response entry 145) REP.LP.077 Tobias Hug on behalf of the HWFI Development Community Group (list submitted separately) Katie Schöffmann

813 BN.6


804 SP4


805 IN.1


806 IN.2

Considers Policy IN.2 to be unsound. Considers that In planning terms the LLDC has a responsibility to address how it will deal with waste within its boundaries and should specifically set out how it will co-operate with the surrounding boroughs on waste. There is clearly a link between policy IN.2 and policies in Section 8. There are possibilities of delivering innovative waste self-sufficiency measures that could / should be referred in this policy.


807 Infrastructure


811 T.10

See REP.LP.015. (Response entry 156) REP.LP.077 Tobias Hug on behalf of the HWFI Development Community Group (list submitted separately) Katie Schöffmann

808 T.4

See REP.LP.015 (Response Entry 153) REP.LP.077 Tobias Hug on behalf of the HWFI Development Community Group (list submitted separately) Katie Schöffmann

809 T.5See REP.LP.015 (Response entry 154) REP.LP.077 Tobias Hug on behalf of the

HWFI Development Community Group (list submitted separately) Katie

810 T.6

See REP.LP.015 (Response 155) REP.LP.077 Tobias Hug on behalf of the HWFI Development Community Group (list submitted separately) Katie Schöffmann

801 1.1

Cross reference B.3 and H.7. REP.LP.077 Tobias Hug on behalf of the HWFI Development Community Group (list submitted separately) Katie Schöffmann

802 1.4

Policy 1.4: Bullet Point 3: We suggest that this be worded to specifiy the re-use of heritage assets for affordable workspace provision in particular. REP.LP.077 Tobias Hug on behalf of the HWFI Development Community Group (list submitted separately) Katie Schöffmann


See REP.LP.056 (Response entry 562) REP.LP.077 Tobias Hug on behalf of the HWFI Development Community Group (list

825 BN.10 Supported REP.LP.078 GL Hearn on behalf of Vastint UK

824 BN.9Strongly objects to the identification of a Key View northwards along Sugar House Lane, as proposed in Figure 17 REP.LP.078 GL Hearn on behalf of

Vastint UK

828 4.1Support the new District Centre at Bromley by Bow. We welcome the policy requirement (item 1) for individual development within the allocation to ‘achieve’ or ‘be part of’ a comprehensive development of the

Bromley-by-Bow Site Allocation Area and support the mix of uses proposed in item 2. We also support the requirement to respond positively to adjacent waterways and the Listed Buildings at Three Mills (item 3). In relation to item 4, we consider that specific reference should be made to the provision of an ‘All-Movement-Junction’ to serve the District Centre.

REP.LP.078 GL Hearn on behalf of Vastint UK

829 4.2 Object to a secific reference to an underpass adjacent to Bromley-By-Bow Station and would suggest the wording 'improving the pedestrian links to Bromley-by-Bow Station. REP.LP.078 GL Hearn on behalf of Vastint UK

830 4.3 Support for policy 4.3 REP.LP.078 GL Hearn on behalf of Vastint UK

43

831 4.4

Policy 4.4 should say preserve or enhance the character of the conservation area not preserve and enhance. Current wording is unsound as not consistent with national policy. The site allocation text requiring a park of 1.2ha is considered unsound. Exceeds the size of the park in the now lapsed permission PA/11/02423/LBTH. he entire Bromley-by-Bow South area (i.e. south of the link road between the approved bus bridge and Hancock Rd), extends to 5.66ha so to require a fifth of this area for a park risks prejudicing the delivery of the wider development. This would be unsound by being contrary to national policy and specifically paragraph 173 of the NPPF. In addition, reference to a library as a community facility is questioned as although it was included in the previous (now expired) planning permission, we are aware that there is currently no appetite for operating such a facility here. We suggest a more generic ‘community facilities’ is referred to.


832 SA4.1

Considers that the site allocation is unsound due to its lack of effectiveness, given that the northern part of the site has an extant planning permission with a number of identified and secured planning contributions secured through a S106 Legal Agreement, while the southern half has particular challenges in terms of delivery of the major social infrastucture requirements identified and considers that it it unreasonable to require the delivery of these. SUpports a comprhensive approach to the site but not 'comprehnsive development. Seeks b hatching identifying the District Centre should be extended further north as far as the new (approved) road which will link Hancock Road to the new (approved) bus bridge through to Sugar House Lane. Allowing greater fexlisblity will enhance prospects of development being delivered. Consider foodstore will be relocated somewhere in this location. One of the key Development Principles is the need for future development to demonstrate that it will contribute to ‘comprehensive development’ (of the Bromley-by-Bow Site Allocation area) by virtue of a

Masterplan Approach’ and ‘phasing of development across the overall site’. Support a ‘Masterplan Approach’ which is linked to phased development across the wider site, however the Masterplan should

incentivise delivery rather than stifle development, so to achieve that needs to respect commercial drivers.As a consequence we seek a masterplan that is flexible; to enable the landowners to progress their land ownerships either together or failing that individually but adhering to a wider masterplan to ensure and facilitate the delivery of key infrastructure.Considers that fully comprehensive development has been an aspiration of the Local Planning Authority (previously London Thames Gateway Development Corporation (LTGDC) and now LLDC) for many years now but has failed, primarily due to land ownership and the inability of any single party to acquire the entire area necessary, despite a CPO in 2011.There should be acknowledgement as in the adopted Bromley-by-Bow Masterplan 2012 that there are complex land ownerships here, making comprehensive development unlikely (para 3.2.2) needs to be reflected in this Local Plan, which should recognise that comprehensive development could equally be achieved through the submission of separate planning applications complying with a single wider masterplan for this site allocation. Supports the requirement set out in development principle 3, that new development respond positively to the adjacent waterways, listed buildings and conservation area at Three Mills. However, we strongly object to the requirement in development principle 4 that new buildings across the entire area should be predominantly 18m. Such a prescriptive policy will lead to a homogenous development of 5 or 6 storey buildings despite the fact that some parts of the site, particularly adjacent to the A12 could be considerably taller, as evidenced in the area. Indeed the previous (now expired) permission for the redevelopment of this area including an accent tower adjacent to the A12 of 20 storeys was deemed acceptable.


832 SA4.1Considers this policy is unsound as it is contrary to national policy which enshrines a ‘presumption in favour of sustainable development’ as a golden thread running through policy making and decision taking

(NPPF para 14). It is also considered to be unsound in terms of its impact on the effectiveness of the plans such a prescriptive height restriction could prejudice the delivery of development. This would be contrary to the objectives of the plan and contrary to national policy in the NPPF. A more appropriate approach in relation to building heights and one which would better reflect the ‘presumption in favour’ set

out in national policy would be for each application for development to be considered on its merits and against national and local policy including the tall buildings policy contained in this document (Policy BN


833 SA4.2

We support the allocation of the Sugar House Lane site as a new medium density mixed use site. However the current planning permission (Ref. No. 12/00336/LTGOUT/LBNM permits business use falling within classes A1 – A4, and B1 without restricting it to cultural and creative). The allocation should reflect this permission rather than now specifying cultural and creative business.

In relation to Development Principle 2, and in reference to the proportion of family units, this allocation should reflect the recent 10 year planning permission which includes 39 per cent 3-bed plus, not the 40 per cent as suggested in this draft document.In relation to Development Principle 3, we reiterate our previous comment in relation to Policy 4.4, notably that national policy requires proposals affecting Conservation Areas to preserve or enhance the conservation area, not preserve and enhance. To go beyond national policy in terms of the test that new development have to satisfy would make this policy unsound.


834 SA4.3

We object to the limited extent of Pudding Mill and the fact it is focussed tightly around Pudding Mill DLR Station. We consider it should be extended to include all the land between the DLR rail track and High St Stratford and between the A12 in the West and Bow Back River in the east in order to improve the masterplanning of the whole area and prevent the promotion and approval of individual buildings that have no relationship with neighbouring buildings. A large number of vacant retail premises already exist along that part of Stratford High St immediately south of the Pudding Mill Site Allocation. These units have high visibility to traffic, buses and front the Cycle Superhighway, so would give the proposed local centre more prominence. They would therefore benefit from consideration as part of a comprehensive approach to development in this area.


826 Sub Area 4

Support key connections shown on Figure 36, but should be clear that these are illustrative and not fixed - inparticular northernmost diagonal conection south of Three Mills Lane between the A12 and Three Mills Lane. Prescriptive routes will restrict design opportunities and could prejudice the delivery of development.


827 Sub Area 4 Vision for Sub-area 4Reference should be included in the vision to provision of the all-movements junction on the A12 as part of the Bromley-by-Bow South redevelopment to form a District Centre. We also suggest reference is made specifically to improved pedestrian links across the A12 to Bromley-by-Bow tube station, rather than in the general way it is currently stated.


843 Our AreaNew homes target should be updated in line with the relevant evidence base for housing allocations, to ensure compliancy with the London Plan. The figure should also be updated to address any discrepancies across the Plan. See comments on Objective 2, Page 41. Update housing target in line to meet Tests 1 to 4.

REP.LP.079 GVA on behalf of Workspace Group Limited

844 Vision

Recommends the wording in para. 1.2 is revised as follows: Stratford has become a Metropolitan Centre with an international role, a home or focus for international businesses served by international trains and quick links to airports, with universities and cultural institutions alongside the commercial, retail and sporting centres. Universities have established a reputation for undergraduate and postgraduate education with associated research and development activity, and businesses are an important part of the local economy, particularly around Stratford Waterfront and where appropriate, in the Pudding Mill neighbourhood.


845 Objective 1Suggest amendment “business, employment generating uses and quality jobs to Objective 1 and additional wording to introductory text: “and expansion in where viable the establishment of research ..... skills

and training opportunities that meet their needs. - Recognising that such opportunities can come forward from a range of sources and not simply through traditional employment floorspace. Support Objective 1 in aim to create jobs, business and promote the area as a visitor and tourist destination however require sound evidence base to retention/ release of employment land that takes account of flexibility over the


846 SP1Suggest additional wording "supporting the changing needs of the economy over the plan period" within introduction to policy. REP.LP.079 GVA on behalf of

Workspace Group Limited

847 B.1

Should amend policy and supporting text as suggested : “2. Ensuring new provision is flexible and viable, meeting the ....” 4. Only allowing proposals providing equivalent use, in either job densities or and floorspace...” ; a) Maintain or re-provide equivalent industrial

floorspace or job numbers within B2/B8 Use Classes subject to location; or b) Maintain or re-provide equivalent employment floorspace or job numbers within B1 Use Classes or significantly increase job densities within B Use Classes”. 4.8”..... Opportunities for research and development, such as in particular around Pudding Mill, will seek to embrace technologies to complete the economic profile of the area

where viable.” 4.14 “The intention of the policy is to maintain or where relevant rationalise and improve the quality and function of employment outside...” “....Where density is applicable, the Any additional jobs

created should meet local requirements”. “ . 4.15 Under Bullet 5 (a), where the premises are within, or most recent permanent use is within, B2/B8 industrial uses, equivalent floorspace or job numbers shall be

maintained ....””..... In these circumstances the equivalent employment floorspace or job numbers to be re-provided should be in the form of workshops which are compatible with mixed-use development,

including within B2 Use Classes, in the first instance; or proposals should significantly increase job density within B Use Classes, appropriate to location, ...”


44

848 B.1

Should amend text in para 4.15 to “Only where a convincing case for a loss of employment floorspace or density, or job numbers, including through conversion....” in order to reflect the evidence base to allow

for further flexibility over the plan period. Should recognise that each employment sites varies in quality and number of people employed and should recognise changing viability considerations over the plan period, to meet test of soundness 3. From reviewing planning approvals it is understood that specific site viability circumstances have been taken into account for the re-provision of employment uses where a more stringent policy may have prevented sites coming forward. Newham policy has allowed for level of flexibility without adverse impact on the provision of employment floorspace but improvement on the quality of jobs, and/ or job numbers alongside other benefits such as housing. FALP has increasing priority for housing delivery. Should amend to allow flexibility to meet all of the Tests of Soundness.


849 B.4

Should amend policy to add reference within Para 4.30 to "new and redeveloped managed or low cost workspace" and "where the quality of existing floorspace is enhanced" after mixed use development..Scheme viability should be based upon a viable proportion being delivered of delivery within each phase the initial phases of larger schemes. These changes should be made to reflect the evidence base as set out in comments provided for Section 4, Objective 1, Page 19, which should allow for further flexibility over the plan period.


850 B.6

Policy should be updated in line with proposed changes to reflect amendments in evidence base set out within comments on Objective 1 to ensure positively prepared, justified, effective and consistent with national policy.


852 SP2

Should amend policy and supporting text as suggested: “2. Providing for identified size and tenure requirements, particularly family housing in affordable all tenures and market housing where there is demand,

and where the site lends itself to family housing..” 5.3 “...Where appropriate, self-build opportunities shall also contribute towards the housing supply alongside the re-designation of other land uses, such as

employment land, dependent on economic factors of supply and demand. Plans need be in conformity with national policy and the London Plan and be positively prepared based on a strategy which seeks to objectively meet assessed development requirements. Reasonable to assume that affordable housing delivery will fluctuate over the plan period, depending on viability which should be reflected. Demand for private family housing is led by the market and where units meet this need will be more viable and able to provide a higher provision of affordable housing, including relevant mix. Should update SP.2 to allow for this flexibility. Requirement for larger family homes should be flexible and considered on a site by site basis. Paragraph 5.3 states that delivery within the last five years of the plan is less certain and that the 5% buffer may not be possible on a rolling five-year basis beyond this. Given FALP housing emphasis in particular higher densities and delivery of housing within Opportunity Areas, text should reflect that other sources for housing could include the re-designation of employment land to meet Tests of Soundness 3 and 4.


853 H.1

5.3 “...Where appropriate, self-build opportunities shall also contribute towards the housing supply alongside the re-designation of other land uses, such as employment land, dependent on economic factors of

supply and demand. Plans need be in conformity with national policy and the London Plan and be positively prepared based on a strategy which seeks to objectively meet assessed development requirements. Reasonable to assume that affordable housing delivery will fluctuate over the plan period, depending on viability which should be reflected. Demand for private family housing is led by the market and where units meet this need will be more viable and able to provide a higher provision of affordable housing, including relevant mix. Should update SP.2 to allow for this flexibility. Requirement for larger family homes should be flexible and considered on a site by site basis. Paragraph 5.3 states that delivery within the last five years of the plan is less certain and that the 5% buffer may not be possible on a rolling five-year basis beyond this. Given FALP housing emphasis in particular higher densities and delivery of housing within Opportunity Areas, text should reflect that other sources for housing could include the re-designation of employment land to meet Tests of Soundness 3 and 4.


855 H.2Para 182 of the NPPF sets out that plans should be effective and capable of being delivered over the plan period so should add to "5. Balancing any other relevant contributions provided through development" to recognise that any financial and other contributions should be balanced against overall scheme viability. Should update supporting text to allow flexibility for providing larger, family-type housing where appropriate and viable.



The Draft LLDC Local Plan highlighted that the Marshgate Business Centre had not been included within the list of allocated housing sites within Appendix 8 of the Mayor’s Strategic Housing Land Availability

Assessment nor the estimates of housing delivery within the December 2013 Draft Local Plan Appendix Tables. Request that the additional capacity for the site be included within the pipeline supply in line with timescales for delivery. Whilst the timescales for the delivery of site have been updated within Site Allocation SA4.3, Table 13 - Remaining Capacity’ has not been updated and includes a reduction in housing allocations. Housing Allocation should be checked for accuracy. Request that clients site is included with a

capacity of 250-350 new homes. Outlines that FALP provides Increased emphasis on housing delivery and NPPF requires Local Planning Authorities to identify and update supply of deliverable sites sufficient to provide five years worth of housing against their housing requirements with an additional buffer of 5%. The supporting text of Policy SP.2 of the Draft Local Plan acknowledges the five per cent buffer will be met for the first five years, but it may not be possible on a rolling five-year basis. It is expected that a more flexible policy test for the release of employment for mixed use residential led development, including at Marshgate Business Centre.



Should amend objective 2: “• Delivering approximately at least 24,000 new homes within a range of sizes and tenures that meet local and market demands. Comments on previous Plan version stated that

Marshgate Business Centre had not been included within the list of sites within Appendix 8 of the Mayor’s SHLAA nor the estimates of housing delivery within the Draft Local Plan (December 2013) appendix

table. Stated that the additional capacity for our site should be included for 250 – 350 homes from 2015. In Consultation Report it was agreed that allocation within the tabled housing delivery appendix would

be included but not the case within Appendix 2. This includes a reduction in housing numbers without permission over the plan period to 1,206 homes. This is not in line with the timescales for delivery within Site Allocation SA4.3. Should check for accuracy prior to submission, and include site as being delivered from 2015/2016 to 2019/2020 with a capacity of 250-350 new homes. Evidence base and target should be accurate to be based on objectively assessed needs and 2 (justified and the most appropriate strategy) which is particularly important as the plan is struggling to meet its five per cent buffer on a rolling five-year basis beyond the first five years of the plan. Local Plan should reflect the new priority focus of housing in FALP with accurate data. Inclusion of FALP revised sections paras 3.16b, 3.19, 2.17. Should amend objective to reflect need for housing and additional capacity for site should be included within Table 13 “Remaining Capacity” of Appendix 2. Based on London Plan densities and our imminent

application submission, the Marshgate site is capable of delivering between 250 and 350 residential units and is scheduled for delivery in 2015/2016 to 2019/2020. Should amend wording to meet soundness tests.



To meet soundness test in terms of need assessed requirements should add reference to "This Plan will seek to optimise land to reflect the desperate housing need and comply with the Draft Further Alterations to the London Plan (2014)". Paragraph date states London Plan density matrix is useful tool but consider should support FALP thrust which provides further focus on optimising housing delivery within Opportunity Areas. This is important in context Para within Plan stating that last five years of Plan period delivery is less certain where a 5% buffer may not be possible. Optimising delivery will be important to exceed housing target over period.


856 BN.1Supports the policy's emphasis on local identity. REP.LP.079 GVA on behalf of


859 BN.10

As set out within the CABE/ English Heritage guidance, where it is demonstrated that no harm arises that cannot be mitigated in terms of townscape, environmental impacts and infrastructure capacity, development of significant height and scale should be considered acceptable. Amended wording to reflect this is suggested and to allow for appropriate flexibility (Test of Soundness), in line with the Further Alterations to the London Plan (2014) Tall Buildings policy and general thrust to provide more housing within Opportunity Areas, to meet housing targets (Test of Soundness 4). Suggested amended wording to meet Tests of Soundness 3 and 4.


857 BN.2Suggest change to policy regarding moorings. Support for the policy emphasis on enhancing and opening up waterways for public use. In respect of moorings, these should be applicable in line with the relevant tests within the NPPF for Planning Obligations, and be secured only where relevant.


45

858 BN.4

The policy should be appropriately flexible to reflect individual site circumstances where greater benefits to development exist, and whereby minimal impact will occur, in line with Test 3 of the NPPF. REP.LP.079 GVA on behalf of Workspace Group Limited

861 SP4

add "dependent on scheme viability in the context of the total planning obligations package for development" to the end of SP4. Test of soundness 1 and 3 sets out a duty for Local Plans to be deliverable, and accordingly a reference to viability in respect of the whole package of contributions should be included within the policy.


860 Infrastructure Suggest adding 'Delivering new development' to the bullets listed under Objective 4. REP.LP.079 GVA on behalf of


862 S.2Seeks additional wording within Policy S.2 within the fourth paragraph as follows: Where these targets cannot be met on site, and until any nationally recognised Allowable Solutions system is in place, a financial contribution to the Legacy Corporation Carbon Off-setting Fund will be required subject to viability.


863 S.3

We supports the LLDC‟s commitment to minimising carbon dioxide emissions and connecting to heat networks, and welcome the inclusion of connections where these are feasible and viable. REP.LP.079 GVA on behalf of Workspace Group Limited

865 4.2Suggested addition to text of policy 4.2 L after "...to serve the anticipated needs of development within the Sub Area, where viable and considered within the wider planning obligations package for development."


866 SA4.2

Suggest rewording as follows: Site Allocation SA4.3: "Pudding Mill. A new medium-density, mixed-use area, including a significant and diverse element of new and replacement business floorspace, including spaces suitable for small- and medium-sized businesses; a new Local Centre adjacent to Pudding Mill DLR Station and Pudding Mill Lane; new homes including a significant element of family housing; new Local Open Space and public realm. Cumulatively across the Pudding Mill Site Allocation, 25 per cent non-residential floorspace should be achieved optimised where demonstrated to be viable and where

there is an identified need, with a predominantly industrial floorspace use mix in the area to the west of Cooks Road and around the Crossrail portal. Landowners will need to work together to bring forward comprehensive schemes that are capable of achieving the ambitions for development of the site allocation and delivering identified infrastructure needed for the site as a whole. Development principles •

Heights of approximately up to 21 metres from ground level are appropriate on this site unless taller buildings can be demonstrated appropriate in townscape terms, except for including some taller elements in the Local Centre (see Policies B.2 and BN.10)."The Draft Plan has been revised to seek to secure 25% non-residential employment floorspace across the Pudding Mill area cumulatively across the allocation rather than a total of 25% which allows for more flexibility. However, this is not considered flexible enough for development to come forward over the plan period, and we would question the assumptions for the basis of this figure in line with comments provided as set out within the evidence base comments provided for Section 4, Objective 1, Page 19 above.In respect of building heights, a flexible approach should be taken whereby if demonstrated appropriate in townscape terms, heights should not be restricted, particularly given the requirement to deliver more residential uses in Opportunity Areas, as set out within the Draft Further Alterations to the London Plan (2014). Suggested amended wording to meet all of the Tests of Soundness.


837 SA4.3

Welcomes many of the revisions made to the employment chapter. However outlines that the policy position that a cumulative 25% replacement employment / non-residential floorspace can be achieved within the Sub Area 4 “Pudding Mill” should be revisited as should the policy tests for the release of employment land. From reviewing the evidence base, we would suggest that a proportion of the approved pipeline

office supply is re-allocated from the Central London Office Market to the Local Market at the Here East/ Stratford International Quarter developments within the Employment Land Review (URS, 2014), given the lack of evidence to support this approach. This accordingly results in an oversupply of approximately 30% for office type floorspace over the plan period. It is noted that there is declining demand for B2/ B8 floorspace over the plan period. Where there is take up of B2/ B8 floorspace, this is to more preferable locations in places such as Beckton. There is no proof that Pudding Mill, within the medium term, can attract “high technology research and innovation activities” . It is not clear why the methodology for apportioning office type floorspace to the Central London Market at Here East/The Stratford International

Quarter has been chosen; nor is it clear why the relevant policies and supporting text have been worded as proposed, having regard to the evidence base and Tests of Soundness outlined above. The removal of the 25% employment / non-residential reference is suggested alongside a more flexible approach for Policy B.1 which would ensure compliancy with the Paragraph 182, 158 and 173 of the NPPF. It is noted that the sites and the scale of development identified in the plan should not be subject to such a scale of obligations and policy burdens that their ability to be developed viably is threatened. Further justification for this and other detailed points in respect of Employment are provided in other cells.


839 SA4.3The mix of land uses and building heights should be guided by site specific circumstances at SA4.3. REP.LP.079 GVA on behalf of


840 SA4.3The LLDC Employment Land Review (May 2014, URS); and The Pudding Mill Land Use and Design Framework (2014, Rick Mather Architects) require further review in order to meet the test of soundness. REP.LP.079 GVA on behalf of


842 SA4.3Outline of LLDC role. Recommend the wording in para. 1.2 is revised and updated to allow for changing circumstances and appropriate flexibility over the plan period. Suggest amended wording to recognise required flexibility (Test 3).


867 SA4.3Revise local centre boundary so it is consistent accros the document. Proposals map different to that within SA4.3. REP.LP.079 GVA on behalf of


864 Sub Area 4

We support the vision for Sub Area Four. It provides a balanced approach to the needs of the area and allows for appropriate flexibility of uses. REP.LP.079 GVA on behalf of Workspace Group Limited


Suggested new text into 14.7 "The policies and Site Allocations in this Local Plan, alongside the mechanisms set out in this section, will help to secure the delivey of that infrastructure, taking into

consideration the full package of any benefits provided from development." Note that the proposals map shows a different boundary for the Pudding Mill Local Centre compared to allocation SA.4.3REP.LP.079 GVA on behalf of


869 Appendicies

Recommendations: We re-iterate that additional capacities for Marshgate Business Centre and 14 Marshgate Lane should be included within the Draft Plan, including addressing discrepancies and providing accurate phasing for the Marshgate site including projected housing delivery figures (250-350 new homes scheduled for delivery 2015/2016 to 2019/2020) across all areas of the plan. In line with our comments on Objective 2, Page 41, we recommend that the discrepancy in housing numbers across the plan is updated. Suggested amended wording to meet all of the Tests of Soundness.


46

870 SP1Welcome intentions of section but could be enhanced. Intention to promote social enterprise could be enhanced through mention of policies to support social enterprise for example through incubation support, affordable workspace and procurement. Should be greater focus on potential of asset such as social enterprises, training and development providers that support existing local communities’ access new

employment opportunities such as Bromley by Bow Centre and Community Links.

REP.LP.080 Bromley by Bow Centre

871 SP1Could strengthen policy to acknowledge importance of retaining local employment sites for delivering lifetime neighbourhoods, reducing need to travel and creating successful neighbourhoods. REP.LP.080 Bromley by Bow Centre

872 B.3Could expand to seek proposals for temporary interim uses are developed through community involvement, including that of social enterprise incubation projects, in design and implementation of proposals and long-term strategy.


873 B.4Should enhance policy through acknowledging importance of affordable workspace in lifetime neighbourhoods and mention that low cost provision would be supported to provide space for existing industries to grow.


874 B.5Should define and explore concept of supporting local people to gain skills and employment training opportunities for example through community based lifelong learning programmes and initiatives to engage local communities, schools and families.


875 B.6Policy should mention how schools and families can be involved in the development of higher education, research and development, increasing connections with local communities enabling access to opportunities.


876 SP5

Considers that the policy would benefit by the addition of an additional point: ‘Ensuring that development supports the creation of lifetime neighbourhoods, a strong local economy and local jobs to - reduce the

need to travel, transport costs and levels of air pollution’.


877 Sub Area 4

We welcome the plans for the development of Sub Area 4. Specifically with respect of the Bromley by Bow area we believe that the plans would benefit from consideration of further measures to improve connections between the existing community of Bromley by Bow with the proposed new District Centre. These might include further improved crossing points over the A12, including consideration of above ground options such as provided by the installation of traffic lights.We would be interested to understand the results of any impact analysis in relation to this development and the wider Bromley by Bow area, for example on existing retail businesses.


879 Our Area

Note brief historical profile and historic environment fails to be considered as an environmental asset. Should refer to heritage assets within environmental issues and challenges and opportunities section. REP.LP.081 English Heritage

880 Vision

While the need for brevity is understood, the changes from the previous version of the Plan which have reduced the number of objectives has has unfortunately resulted in the omission of a direct reference to the historic nvironment.Recommends that objective 3 is amended to refer to the historic environment, in accordance with the NPPF, paras 61 and 126, and objective 9 of the last consultation draft of the Local Plan. This could be included as follows: ‘Create a high-quality built and natural environment that integrates new development with waterways, green space and the historic environment’

REP.LP.081 English Heritage

883 SP3Importance of the historic environment stated in other policy documents and the NPPF. Suggest amending the title of the policy and one of the bullet points within the policy to include the historic environment. REP.LP.081 English Heritage

882 Objective 3 Support and reference to heritage value in the preceding text in relation to Objective 3. . REP.LP.081 English Heritage

884 BN.1

Amend Point 2 and 3 of Policy BN.1.- Amend point 2 to ‘Urban Fabric: respect existing typologies, including those of heritage value, and draw cues from the form of the area…’

- Amend pint 3 to ‘Architectural and historic context: enhance the architectural setting and heritage values appropriate to the area within which development is proposed. Careful consideration should be given

to architectural and historic style, materials ….’

REP.LP.081 English Heritage

885 BN.16Suggest policy wording should align with the NPPF. REP.LP.081 English Heritage


The plan would benefit from changes to ensure that the historic environment is considered to be in alignment with the NPPF. REP.LP.081 English Heritage


Weakening of this component of the plan relating to the historic environment in comparison to the previous consultation version. REP.LP.081 English Heritage


Seeks minor changes to reference list REP.LP.081 English Heritage

887 Sustainability Appraisal

Concern that the SA report does not identify the potential weakening of the policy framework and plan objectives in relation to the historic environment. REP.LP.081 English Heritage

889 Business Growth

Plan does not present policy on hot food takeaways or betting shops in context of retail policy or centres. Should make a clear case on this. REP.LP.082 LB Waltham Forest

890 Business Growth

A lot of work been done on entry level employment for local residents but challenge to improve prospects for local people at higher level jobs. Should strengthen employment policy in relation to training and importance of visitor economy.

REP.LP.082 LB Waltham Forest

891 Infrastructure The issues of infrastructure provision including transport, social and other physical infrastructure should be better clarified in the structure of LLDC Local Plan. It should be noted the importance of IT infrastructure in securing high grade employment uses and business development. LBWF requests LLDC to consider the implications of population growth from development in the surrounding boroughs. A joint and coordinated approach to infrastructure delivery is necessary.


892 Infrastructure LBWF is concerned that the LLDC proposed local plan policies on Waste Planning matters. In particular the nearest Waste recycling site is situated at ByWaters site near Leyton area. LLDC Local Plan should include ways of improving waste and re-cycling distribution and planning in view of the proposed development and growth regeneration in the LLDC Local Plan. The proposed Waste Plan policies should provide better waster planning contingency plans to support the increased population and housing growth in the local area.


888 Sub Area 2

Considers that Eton Manor must provide world-class sporting and recreational facilities that are affordable, family-friendly and open to all. Job and training opportunities for local people should also be a major consideration when determining the best use of this site. Welcomes the ommission of reference to allotments at Eton Manor Manor. Objects to the orientation of the site that turns it back on the Borough. Emphasises the regeneration and investment in the Leyton area and a new bridge at Ruckholt Road provides for good quality pedestrian access to Eton Manor. Given the isolated nature of the site, the provision of a new access at its northern point is vital to encouraging local people into Eton Manor and, by extension, the Queen Elizabeth Olympic Park. The LLDC Local Plan should be consistent with the LBWF policies in its Core Strategy, Development Management Policies Local Plan and the Northern Olympic Area Action Plan.


47

893 B.1

Retention of employment land welcomes but policy has complex formula for B classes which is blunt instrument compared to detail within evidence supporting needs of cultural and creative industries. Relationship between digital and physical work in support of maker revolution is complex and does not involve clean software work but for example architectural robotics where workshops and yards are valuable assets. These are not necessarily compatible with mixed use but there is much work to be done in specifying types of space needed and mix of typologies to not simply apply the basis generic idea of 'compatible' uses.

REP.LP.083 Plot London

894 B.3Temporary uses should be connected to needs of immediate existing community rather than to attract attention. Too often used for promotional purposes rather than local needs. More sophisticated policy would have set some strategic community building goals. Connection of interim uses to strategic development of creative and cultural industries is too vague.


895 B.4

Stated LLDC goal is to support diverse and resilient local economy with focus on arts, creative and cultural practices where provision of low cost workspace is important. This is undermined by including reference to viability and where it complements plans for wider area. Affordable and viable workspace should be direct goal of developments and not just S106 matter. Commitment to strategy supporting live work environments and managed workspace at affordable rates should be possible. In real world low cost is not 75% of market rent. Businesses in HWFI need a range of space supporting long term growth. Creative industries suffer from lack of long term affordable tenure protection o high churn. Creative talent is often seen as a loss-leader to generate area-buzz and then is priced out through gentrification. Evidence of this throughout London. So gradual shift of creative industries eastwards with inability to put down long term roots in area deprives neighbourhood that host industries of long term multiplier effects in job creation, reputation, visitor economy.


896 B.5Policy is undeliverable as needs more detail on convergence initiatives, objectives and mechanisms REP.LP.083 Plot London

897 B.6Should include initiatives, objectives, and mechanisms for lifelong learning REP.LP.083 Plot London

898 B.2

Policy is not based on robust or up-to-date evidence and it is inflexible and incapable of responding to future changes. Table 3 indicates that Stratford Town Extension will provide approximately 55,000 sq.m (NIA) of additional comparison floorspace across the whole of the town centre to 2030, focused to the centre-east. Retail and Leisure Requirements Review (RLRR) adopts very dated household shopper survey information pre-dating opening of Westfield Stratford City (WSC) which had a substantial impact on shopping patterns in both the local and wider area. Study applied adjustment to the 2007 comparison goods shopping patterns to factor in the opening of this development. Analysis suggests WSC will attract only 30% of its trade from the 12 study area zones, with 70% coming from inflow from unspecified areas which is too small to adequately assess the need for further floorspace at Stratford so not robust or sound. Impact analysis for WSC relies too much on PBA’s judgements. Should commission a new

household survey covering the primary catchment area of Stratford to estimate base year shopping patterns with WSC and other developments. Should not seek to specify a retail floorspace figure because of the uncertainties inherent with long term projections beyond 2021 as identified within the study. Capacity forecasts are subject to regular review throughout the study period, given the considerable population growth, expected. Should remove floorspace figures as are indicative only and need to be regularly reviewed. Policy indicates that main town centre uses shall be focused according to the scale, format and position in the retail hierarchy identified in Table 3 but no mechanism to control scale and format of development within centre boundaries as not required to comply with the sequential and impact tests. Stratford new and expanded Metropolitan Centre a special case so important that nature and scale of development does not harm other centres or the retail hierarchy. Should amend policy to ensure the impact of further retail expansion is appropriately tested.

REP.LP.084 Nathaniel Lichfield on behalf of Intu Properties plc

899 B.2Extent of town centre boundary and extension are shown. Proposals Map and figure indicate development parcels surrounding the centre are within the Metropolitan Centre. B.2 only requires impact assessment over 2500sqm outside Metropolitan Centre . Given unsound evidence in support of this the boundary should be redrawn to exclude the development parcels.


900 Business Growth

Questions whether the Duty to Cooperatehas been met in respsct of the Plans approach to retail and leisure in proposing the extension of Stratford Town Centre and its designation as a Metropolitan Centre, including the identification of capacity for 55,000 sq metres of comparison retail floorspace within the Metropolitan Centre. Considers that this is a considerable amount of space that could potentially have a significant effect in one or more local authority area.


901 BN.10 The East End Preservation Society believes that tall buildings are in many places inappropriate and do not respond to the character of the East End for example at Hackney Wick, partly covered by an important conservation area, and Bromley by Bow District Centre which is adjacent to the listed Three Mills.

REP.LP.085 East End Preservation Society

902 SP1 Support REP.LP.086 Deloitte on behalf of UCL903 B.3 Support, in particular for requirement that interim uses should not impact the delivery of allocations. REP.LP.086 Deloitte on behalf of UCL904 B.6 Support. REP.LP.086 Deloitte on behalf of UCL

905 SP2

Support policy. Important that is flexible to enable objectives to be delivered in parallel with Mayor's Olympicopolis vision. Understands Appendix 2 is not intended to be exhaustive list of housing sites but to demonstrate that the housing target can be met. As such sites not safeguarded by SP.2 and acknowledge that some sites may not be developed for housing. There is potential for residential to be provided on alternative sites to Stratford Waterfront either through intensification on sites within Appendix 2 or through sites not identified for use within the Plan. This is reflected in supporting text which states that residential land may be released where an equivalent number of residential units or floorspace is re-provided across all applicable sites’.

REP.LP.086 Deloitte on behalf of UCL

906 H.4 Support for link between HEI and student provision, consistent with the FALP. REP.LP.086 Deloitte on behalf of UCL907 BN.10 Support. REP.LP.086 Deloitte on behalf of UCL912 BN.6 Support for modification to MOL and LOS since pevious plan. REP.LP.086 Deloitte on behalf of UCL

908 Infrastructure

Infrastructure/Sub Area 3: The additional detail of Figure 24 on page 116 and Figure 34 on page 194 is welcome. However, UCL requests that a minor change is made to Figure 24 and 34, to identify the potential for enhancements to walking and cycling routes along Montfichet Road and across to the ArcelorMittal Orbit, linking Stratford Regional Station and the Southern QEOP (i.e. replacing the dashed red line with a dotted red line).UCL considers that there is an opportunity to create policy support for future environmental enhancement of this route, reflecting proposals for Stratford Waterfront and the Southern QEOP.


910 SA3.2 Support REP.LP.086 Deloitte on behalf of UCL

911 SA3.3Discussed minor changes to allocation to provide clarity in the interpretation to reflect aspirations for Stratford Waterfront. Understands that will publish these changes prior to submission. REP.LP.086 Deloitte on behalf of UCL

909 Sub Area 3Vision is supported. Previous representations sought amendments to SA3.2 and SA3.3 to make clear academic and cultural uses would be acceptable as alternative to LCS permission in accordance with SP1 and Olympicopolis vision. This approach has been carried through into Publication Plan, including proposed minor changes to allocations following discussions between UCL and LLDC.


913 Vision See REP.LP.015 (Section Response Entry 136) REP.LP.087 Joseph Alexander

914 SP1 See REP.LP.046 (Response entry 475) REP.LP.087 Joseph Alexander

915 B.1B.1 is unsound as it does not provide enough support to retain employment and industrial land. The importance of retaining industrial land should be strengthened. Technological and maker growth take place in workshops and yards as well as offices. Should have more discussion of conclusions of Economy Study particularly important for businesses within Carpenters District which are long-standing and keen to expand. Fails to recognise importance of local employment in terms of lifetime neighbourhoods. To be sound should include employment cluster within Carpenter District and should remain in industrial use.

REP.LP.087 Joseph Alexander

916 B.2 See REP.LP.046 (Response entry 477) REP.LP.087 Joseph Alexander

917 B.4See REP.LP.046 (Response entry 478) REP.LP.087 Joseph Alexander

918 B.5 No target to monitor effectiveness of B.5 which places LLDC in weaker position to secure jobs and training for local residents. Need to set targets to demonstrate direct benefit to excluded and disadvantages residents. Target should be set for proportion of construction and end user hobs for local residents for participation in skills and employment training initiatives.


919 SP2 See REP.LP.024 (Response entry 248) REP.LP.087 Joseph Alexander

48

920 H.2 See REP.LP.024 (Response entry 249) REP.LP.087 Joseph Alexander921 CI.1 See REP.LP.024 (Response entry 250) REP.LP.087 Joseph Alexander922 CI.2 See REP.LP.046 (Response entry 483) REP.LP.087 Joseph Alexander924 BN.11 See REP.LP.015. (Response entry 148) REP.LP.087 Joseph Alexander923 BN.6 See REP.LP.015 (Response entry 146) REP.LP.087 Joseph Alexander

925 T.6 See REP.LP.015 (Response 155) REP.LP.087 Joseph Alexander

926 SP5 See REP.LP.015 (Response 157) REP.LP.087 Joseph Alexander

927 S.2 See REP.LP.015 (Response entry 158) REP.LP.087 Joseph Alexander

928 S.3 See REP.LP.015 (Response entry 159) REP.LP.087 Joseph Alexander

929 3.1 See REP.LP.024 (Response entry 258) REP.LP.087 Joseph Alexander

930 3.2 See REP.LP.024 (Response entry 259) REP.LP.087 Joseph Alexander


There does not appear to be any docuementation that confirms the long term viability of the Olympic parkland and questions whether any studies have been done to support a suistainable and viable park. REP.LP.087 Joseph Alexander

932 SA3.4See REP.LP.024 (Response entry 260)


933 BN.2The policy is not sufficient to protect public access to all parts of the waterways and clarity on rights of access is necessary. Community should be updated on progress such as biodiversity and construction/development works that impact the waterways. For summary of the rest of the content please see summary to REP.LP.015.

REP.LP.088 Secondary Modern Community Association

934 Our AreaLocal Plan is in general conformity with the London Plan. Asked to consider the following matters. Noted Policy 2.4 text is taken from the FALP so may be subject to change. REP.LP.089 GLA

935 B.1 Policy should confirm that large scale offices should be located within the defined town centres or office locations. REP.LP.089 GLA

936 B.2Policy should confirm edge of centre uses should only be permitted when sequential test with acceptable impacts demonstrated. REP.LP.089 GLA

937 Business Growth

Table 3 should clarify that floorspaces also include leisure and service uses. REP.LP.089 GLA

939 Objective 2 Amend from 'approximately' 24000 new homes to 'deliver more than' REP.LP.089 GLA941 H.3 Should confirm accommodation would be for older people. Reference 2014 GLA evidence showing increased need. REP.LP.089 GLA

942 H.5Insert "and through discussions with neighbouring boroughs" after "provide for the needs of gypsies and travellers generated within its area" to better accord with London Plan policy 3.8Bi. REP.LP.089 GLA

943 H.6

Bullet 6 suggests that examples of such accommodation might comprise delivery of conventional homes might be set out on sites identified for C3 housing or which might be more suitable for C3 by their location. Conventional housing might also be defined for example as C3 self-contained housing. The nature of the license should be confirmed, for example reference to 2004 Housing Act.

REP.LP.089 GLA


Change 'London as a whole" to "'as well as helping meet London's strategic need for new homes" within Para 5.1 REP.LP.089 GLA


Paragraph 5.3 -Add "and the target rolled forward as appropriate." after "'will be kept under review within the Authority Monitoring Report (AMR)." REP.LP.089 GLA

944 BN.2Note that the waterways will be used for tranpsort to carry freight, waste and construction materials by activating and maintaining indicative trade moorings. REP.LP.089 GLA

946 SP4Consider revise wording to read "'3. DLR double tracking at Stratford toUDLR double tracking between Bow and Stratford.".

REP.LP.089 GLA

945 IN.2The policy could usefully confirm that the LLDC will cooperate with the GLA and TfL in respect of strategic waste management, as well as the four boroughs. REP.LP.089 GLA

947 Infrastructure

Paragraph 7.11 Add "walking and cycling" to the end of point 5. Paragraph 7.12 TFL support interatnation trains stopping at Stratford. New sentence at end of parargraph "Improved strategic links should not adversely affect London Overground or frieght services in the LLDCS area". Paragraph 7.13 revise wording to " the Legacy Corpriaotn area already has direct DLR links to London City Airport and coach links to Stansted Airport and from 2019 via Crossrail to Hetahrow." (remove reference to direct Heathrow service).

REP.LP.089 GLA

948 T.3Revise point 5 to read "'Will result in improvements to walking and cycling." REP.LP.089 GLA

949 T.4

This is generally supported; although Point 4 might be more clearly worded and would benefit from a separate cycle parking reference. The reference to London Plan parking standards could also be a new sentence and have a similar point for cycle parking - e.g. to state that London Plan cycle parking standards should be exceeded wherever possible as set out later in policy T9. The reference to cycle hire in point 6 could then be included in the cycle point. • Paragraph 7.21 - Revise to: Car ownership per household has decreased dramatically in the last ten years according to the 2001 and 2011 censuses, and

road traffic in London is generally decreasing, however congestion is expected to increase given residential and employment growth in the area." It should also be clarified if the car ownership figure is for LLDC area, constituent boroughs or across London. • Street network - TfL welcomes the revised title but the policy could usefully include a cross-

reference to policy BN1 about place. • Figure 23 - Should the title be "Street network" and all the A11 Bow Road west of Bow Roundabout is TLRN and therefore should be shown in red rather than as

SRN/green. Figure 24- Key connections• TfL will continue to work with LLDC and local authorities to identify improvements to key connections. • The figure and key should clarify the dark red circles - if they represent key intersections to be

enhanced, rather than "principal connection improvements", then this is important to clarify- some circles show solid lines, some show dotted lines. • The figure could include railway lines in a similar way to road

network,which would help to make the barriers railway lines create clearer, e.g. for the red circle at Hackney Wick station. • The connection at Frankin Street should be removed and the connection at Bromley-

by-Bow station included (see sub-area section for details). • The routes around Stadium Island should be checked. • The figure should take into account the proposed improvements for cycling to Ruckholt

Road, which are part of the Waltham Forest mini-Holland programme -this should be an on-road connection to be improved.

REP.LP.089 GLA

49

950 T.8

Revise wording to read "1. Be at a low level appropriate to its location with minimum levels of provision in locations with the highest levels of public transport accessibility and planned transport infrastructure." Revise wording to read "4. Not take precedence over the incorporation of open space,public realm,amenity space or pedestrian and cycle connectivity within and around the development." As there is just one reference to, 3, to off-street parking,are the other points all relating to onstreet I public realm parking?

REP.LP.089 GLA

951 T.9

Subject to other responses, it could be better to separate out pedestrians and cyclists - especially if requirements differ, not always necessarily the same. There are various other descriptions which could be added to the "'safe, direct..." list, such as step-free, smooth,uncluttered, but it may be easier to just keep reference as in bullet 1 to "'best practice guidance at the time". Also revise first sentence to: The Legacy Corporation will promote and support the provision of safe streets and other dedicated routes for walking and cycling..." (to avoid suggesting that walking and cycling only need to catered well for on certain identified routes). Paragraph 7.33 - In a similar style to reference to lCDS, suggest "'Provision for walking should be in accordance with the appropriate general and route-specific requirements set out in TfL's Pedestrian Design Guidance and Streetscape Guidance [which will be published soon]." Paragraph 7.34- Tfl welcomes the references to the strategic walking and cycling routes. It is considered that the Capital Ring could be diverted or alternative optional route(s) provided to through the QEOP, as and when feasible. Tfl can provide assistance in discussions around this topic such as updating maps, signing and wayfinding, both in the area and for online/printed resources.

REP.LP.089 GLA

953 4.2

The sub-area section and this policy does not explicitly refer to the "'Bow Vision" project, which includes many of the new connections referenced in Policy 4.2, and on which Tfl, llDC and local boroughs will continue to work together. Figure 36 and SA4.1 -These show a 'principal connection improvement' on the A12 at a location near Franklin Street (to the west). An at-grade pedestrian crossing at Franklin Street was excluded from the short-listed options for Bow Vision due to buildability & road safety concerns. The plans should be amended to remove the "'principal connection improvement" at that location. The plans should also be amended to include the pedestrian underpass adjacent to Bromley-by-Bow station, which is included as item 2 in Policy 4.2.Policy 4.2 - Should be corrected to read "'3.... a new all-movements junction on the A118 to improve access to and from Sugar House lane..."

REP.LP.089 GLA

952 Sub Area 4 Vision text and SA4.3 have incorrect references to Pudding Mill DLR Station rather than Pudding Mill Lane DLR Station. REP.LP.089 GLA954 BN.2 At QE2 the road drainage needs to be retro-fitted with sustainable drainage systems to remove the pollutants before they reach a water body. REP.LP.090 Thames 21

956 Vision See REP.LP.015 (Section Response Entry 136) REP.LP.091 London Tenants Federation

958 SP1

Is necessary to build local supply chains in order to connect major development to organic growth of existing businesses. If not done new investment will not remain in the area, e.g. few businesses report they benefitted from the Games through procurement processes, more commonly reporting disruption and loss of business. New economics foundation work on local multipliers show how inward investment remains in area generates value through multiplier effects. here is only brief mention of promoting social enterprise with no policies to support this and insufficient focus on existing economic assets in the policy. The Economy Study should be summarised; existing centres providing valued skills and training for local people should be mentioned (e.g. the Building Crafts College, Bromley by Bow Centre and Community Links); show how convergence aims will be achieved through growth of economic assets growth and development. Should set out measurable targets to meet aims of convergence and economic development and mention social enterprise in SP1. Should add net direct and local jobs within Table 1. Estimate for employment growth arising from existing businesses also required.

REP.LP.091 London Tenants Federation

959 B.1 See REP.LP.054 (Response entry 552) REP.LP.091 London Tenants Federation


961 B.3 See REP.LP.015 (Response Entry 140) REP.LP.091 London Tenants Federation

962 B.4See REP.LP.054 (Response entry 555) REP.LP.091 London Tenants Federation



957 Business Growth



965 SP2

Policy title does not reflect London plan's aims to optimise rather than maximise housing delivery. Title doesn't reflect need for sustainable development and lifetime neighbourhoods. Should be amended to "Optimising housing and infrastructure provision to create lifetime neighbourhoods". Affordable homes target does not reflect a proportion of FALP target which is important given number of homes to be delivered, the 2013 London SHMAs identification of backlog need and need for affordable particularly within the Growth Boroughs. Affordable homes are crucial to convergence. To be sound annual target should be 595 a proportion of 17000 FALP target. Does not address need to maintain range of tenures needed within area. Without social rented much of gross affordable will not emerge without protection of existing. Cost of affordable rent and intermediate are beyond means of households in need and failure to protect existing social rented adversely impacting on convergence. This was highlighted in large numbers to previous consultation.


966 H.1

Policy doesn't adequately address need for larger 4 and 5 bedroom homes and could result in delivery of too many 2 bedroom homes. To be sound should set targets for 3, 4 and 5 bedroom homes. Evidence is weak and out of date. ORS study depends on information from 2008-10 before introduction of affordable rents. Fails to address diversity of need essential in east London with a diversity of communities. To be sound new needs assessment should be commissioned and should insert date of when carried out within the Plan. Policy is not effective and states housing developments should have no unacceptable adverse impacts on mix and balance of the proposed area but with no detail on how this is to be monitored. Should set measuring of this out in policy.


967 H.2

Policy H2 does not have up to date evidence base, having adverse impact on low income households and convergence. Policy depends on households eligible for social rented to access affordable rent homes covered by housing benefit. No evidence to support this, particularly for large bedroom sized homes. No breakdown of households that might be able to afford capped or discounted rents without access to benefits compared to social rented. No assessment of potential adverse impact of affordable rents compared to social rents particularly for those not dependent on benefits, or potential increase in levels of in-work poverty. No evidence of households previously private renting but now had to move out of borough [Newham] to facilitate their rent covered by housing allowance.


968 H.3Policy not effective without measurable objectives or targets. London Plan does not set indicative benchmark for older persons' housing for the area this could be done within the policy in cooperation with the boroughs on how it can meet their benchmarks. To be sound should set measureable targets.


969 H.4 See REP.LP.051 (Response entry 539) REP.LP.091 London Tenants Federation

970 H.5Policy is inadequate in equalities terms. Only one site has been allocated and appears to fail o consider sites alongside larger new development that might provide opportunities for links with communities in permanent housing. Should more clearly consider gypsy and traveller communities in terms of sustainable neighbourhoods.


971 H.6Policy refers to affordable housing but is unclear what is meant by this. HMOs generally within private rented, not conforming to planning definitions of affordable housing. To be sound further clarity on whether reference to affordable housing is that defined within London Plan policy 3.10.


50

972 H.7Policy is not sound as it is not clear if genuinely means homes confirming to planning definitions of affordable housing. To be sound need clarity on whether reference to affordable housing is defined in the London Plan


974 CI.1 See REP.LP.049 (Response entry 520) REP.LP.091 London Tenants Federation

975 CI.2 See REP.LP.046 (Response entry 483) REP.LP.091 London Tenants Federation

978 BN.10 All new and developing centres are specified as appropriate for tall buildings. This assumes that tall buildings are an essential part of regeneration. Locations need to be specific and justified. REP.LP.091 London Tenants Federation

979 BN.11 See REP.LP.015. (Response entry 148) REP.LP.091 London Tenants Federation

976 BN.2 See REP.LP.015. (Response entry 145) REP.LP.091 London Tenants Federation

977 BN.6See REP.LP.015 (Response entry 146) REP.LP.091 London Tenants Federation

980 SP4 See REP.LP.056 (Response entry 563) REP.LP.091 London Tenants Federation

981 IN.1 See REP.LP.015 (Response entry 150) REP.LP.091 London Tenants Federation

982 IN.2 See REP.LP.015 (Response entry 151) REP.LP.091 London Tenants Federation

973 Infrastructure See REP.LP.049 (Response entry 519) REP.LP.091 London Tenants Federation

983 Infrastructure

paragrapahs 7.10 and 7.11 are not sound. There is s disconnect in the aims of delivering sustainable possibly walkable and lifetime local neighbourhoods and the delivery of national and international connections. Not clear on relationship between the 10 transport policies and there could be tensions between them. If the key aim is prioritising cycling and walking then there should also be a reduction in focus on wider transport connectivity including national and international.


987 T.10See REP.LP.015. (Response entry 156) REP.LP.091 London Tenants Federation

984 T.4 See REP.LP.015 (Response Entry 153) REP.LP.091 London Tenants Federation

985 T.5 See REP.LP.015 (Response entry 154) REP.LP.091 London Tenants Federation

986 T.6 See REP.LP.015 (Response 155) REP.LP.091 London Tenants Federation

988 SP5See REP.LP.015 (Response 157) REP.LP.091 London Tenants Federation

989 S.2 See REP.LP.015 (Response entry 158) REP.LP.091 London Tenants Federation

991 S.3See REP.LP.015 (Response entry 159) REP.LP.091 London Tenants Federation

992 S.4 See REP.LP.015 (Response entry 160) REP.LP.091 London Tenants Federation

993 2.1

Policies 2.1 – 2.4 and site allocations SA 2.1, SA 2.2 and SA 2.3 are unsound because they do not provide the housing choice promised, there should be provision of a community land trust and other types of

small scale affordable housing, they should Integrate well with the surrounding low rise housing estates in Waltham Forest and respond to their social conditions. They do not make clear how many tall buildings there will be above the proposed building heights, and at what height or provide for retention or relocation of existing employment uses. They do not specify what community facilities will be delivered, respond to the very poor air quality on the A12 and Leyton Road, East Village, a new Local Centre, has too much retail. It should have a wider mix of uses with specific reference to a lifetime neighbourhood. The retail offer needs to be diverse, with small, independent shops and affordable workspace.


994 3.1 See REP.LP.024 (Response entry 258) REP.LP.091 London Tenants Federation

995 3.2See REP.LP.024 (Response entry 259) REP.LP.091 London Tenants Federation

996 SA3.4 See REP.LP.024 (Response entry 260) REP.LP.091 London Tenants Federation

997 Sub Area 4


the canal/ river areas. • The site allocations should recognise the need for traffic calming along the Blackwall Tunnel Approach Road; a key issue for improving connections • New development should integrate




Delivery and Implementation - this section is unsound because no targets are identified in most of the monitoring criteria. Open Space/ Biodiversity improvements aren’t measured. The target is to maintain

what it is like at the moment. There is no monitoring of impacts outside of the LLDC area e.g. on the existing Bromley by Bow neighbourhood.REP.LP.091 London Tenants Federation


Considers that the Plan is generally unsound, difficult to navigate and mixes usual key themes into different sections. It combines development management policies and site allocations in the same docuement in a way that is not easily manageable and does not always highlight when policies are development management policies. It considers that key themes set out in London Plan Policy 2.4 have not been adequately explored in the Plan. It is not clear about how new and existing communities within the LLDC area will be integrated. Considers that there is a hugh gap in identifying how the closure of the deprivation gap within the LLDC area/Growth Boroughs will be measured and monitored. Considers that the Duty to Cooperate with the surrounding boroughs and the Growth Boroughs is inadequately addressed. To be sound it considers that the Local Plan in total• should be better organised into key theme areas that are easy to navigate

• given that this is three planning documents rolled into one those different parts need to be better arranged and easily identifiable.

• Key policy directions in London Plan policy 2.4 should be thoroughly integrated in the local plan policies.

• Detailed monitoring over the plan period of a group of target households should be carried out. This should also occur in the growth boroughs.


999 See REP.LP.024 REP.LP.092 Pirameena Saravanamuthu

51

1000 See REP.LP.024 REP.LP.093 Mrs M Saravanamuthu

1001See REP.LP.024 REP.LP.094 Piraveena Saravanamuthu

1002 Sub Area 1 I would like to encourage redrafting so that the whole of ‘sub area one’ could be included in encouraging builders/developers to mix live/work into residential/commercial schemes. My second concern relates to

clauses which set out with the best of intentions, yet paradoxically, perhaps, produce second or third rate design quality.REP.LP.095 Martin Richman

1004 Vision

Finds the document difficult to read. Considers that the Plan does not clearly set out • How the strategic policies are adding to national and regional policy by providing locally distinctive interpretation and

standards• Which policies are to be read as Development Management policies (in some sections there is a clear sign posting, in others this is missing)

• Whether the site allocations are providing a brief for new development proposals or are confirming development that is already happening on the ground. Feels the document lacks coherence with strategic

policies containing themes that are addressed in different sections. The DUty to cooperate is partcularly important but there is no narrative to explain the relationship between the LLDC, boroughs or the relationship with the Mayor of London and the GLA. Considers that the sections of the Plan are not clear about who is responsible for implementing policies. Consultation events organised by the LLDC have often been unhelpful with the “consultation staff” not privy to key information. Considers that LLDC as a whole has not fostered a genuinely inclusive approach to community consultations with displacement,

unfulfilled promises from the Olympics (and whether indeed LLDC takes responsibility for promises made by ODA and LOCOG) and the governance of development in the LLDC area (no community or voluntary sector representatives on the LLDC Board) presenting a problem at the community level raising concerns about legal compliance. See also summary of Vision comment from REP.LP.091 for remainder which is a common standard response.

REP.LP.096 Just Space

1006 SP1See REP.LP.091 (Response entry 958) REP.LP.096 Just Space

1007 B.1 See REP.LP.054 (Response entry 552) REP.LP.096 Just Space

1005 B.1 Businesses included within the Economy Study were not contacted that Local Plan published or receive copy of document. Consultation has been insufficient and inadequate in reference to requirement of NPPF to engage with businesses.


1008 B.2 See REP.LP.015 (Response entry 139) REP.LP.096 Just Space1009 B.3 See REP.LP.015 (Response Entry 140) REP.LP.096 Just Space

1010 B.4See REP.LP.054 (Response entry 555) REP.LP.096 Just Space

1012 B.6 See REP.LP.015 (Response entry 143) REP.LP.096 Just Space

1013 SP2 See REP.LP.024 (Response entry 248) REP.LP.096 Just Space

1014 H.2

Policy H2 does not have up to date evidence base, having adverse impact on low income households and convergence. Policy depends on households eligible for social rented to access affordable rent homes covered by housing benefit. No evidence to support this, particularly for large bedroom sized homes. No breakdown of households that might be able to afford capped or discounted rents without access to benefits compared to social rented. No assessment of potential adverse impact of affordable rents compared to social rents particularly for those not dependent on benefits, or potential increase in levels of in-work poverty. No evidence of households previously private renting but now had to move out of borough [Newham] to facilitate their rent covered by housing allowance. To be sound affordable rent affordability should be updated including assessment of affordability of affordable rented homes. Should set out target date for achieving this.


1015 H.3To make sound there should be a target for specialist housing for older persons derived from needs assessment integrating health and housing. Should include adaptations and conversions with preventative services so older persons can remain in home. Specialist housing should include other communities that exist within the area including those on waterways. Should include reference to co-housing and self/custom build. Should acknowledge that alternative housing models can fulfil needs.


1016 H.4Policy unsound as no parameters for what would be affordable student provision, and according to NUS research academic institutions charge between £88 and £155 a week for a 38 week period and units are charging average of £280 over 52 weeks. No guidance as to what would be over-concentration of student accommodation. Need to define affordable student accommodation in context of average student incomes and rents by University and the maximum amount of student purpose built accommodation permitted in a neighbourhood as a proportion of housing or floorspace.


1017 H.5

Support LGTUs argument that the SCI has not been followed without efforts to engage with gypsy and traveller communities and support organisations; the duty to cooperate has not been met without effective engagement with LB Newham to understand needs within close proximity of the boundary given promise of relocation. That objectively assessed needs arising within Newham have been ignored and that the allocation alone cannot meet the need for 19 pitches. To be sound need to assess additional sites at White Post Lane, Bartrip Street North and Chapman Road Depot.


1018 H.6Policy unsound as does not state considerable need for low cost private rented is not stated and no protection against replacement for new build housing which helps meet local housing supply targets but is not affordable or social rented. To make sound importance of HMOs in meeting housing need should be acknowledged and the role of affordable housing within the policy needs to be clarified.


1019 H.7Policy provides little support for encouraging large scale investors to improve standards within the private rented sector through longer tenancies, decent housing standards and capped rent increases. To be sound policy should provide positive and practical support for contribution of PRS in meeting overall housing needs including need for affordable, decent and secure housing.


1021 CI.1 See REP.LP.049 (Response entry 520) REP.LP.096 Just Space1022 CI.2 See REP.LP.046 (Response entry 483) REP.LP.096 Just Space1026 BN.10 See REP.LP.091 (Response entry 978) REP.LP.096 Just Space1027 BN.11 See REP.LP.015. (Response entry 148) REP.LP.096 Just Space

1023 BN.2 See REP.LP.015. (Response entry 145) REP.LP.096 Just Space

1024 BN.6 See REP.LP.015 (Response entry 146) REP.LP.096 Just Space

1025 BN.8

The policy is unsound because it does not identify areas which lack children’s play space. It provides only a limited list of possibilities for play space and does not take account of the needs of teenagers. It does

not address the affordability of the play space. The LLDC has not produced a Play Strategy and in the absence of a stategy has not cooperated with the Boroughs to assess needs and agree appropriate standards. For the policy to be sound there should be a figure which maps existing play space according to different typologies. A list of possible youth facilities should be included, such as youth clubs, skate parks, ice skating and roller skating links.


1028 IN.2 See REP.LP.015 (Response entry 151) REP.LP.096 Just Space1020 Infrastructure See REP.LP.049 (Response entry 519) REP.LP.096 Just Space1030 T.10 See REP.LP.015. (Response entry 156) REP.LP.096 Just Space1029 T.6 See REP.LP.015 (Response 155) REP.LP.096 Just Space

1031 SP5 See REP.LP.015 (Response 157) REP.LP.096 Just Space

1032 S.2 See REP.LP.015 (Response entry 158) REP.LP.096 Just Space

1033 S.3 See REP.LP.015 (Response entry 159) REP.LP.096 Just Space

52

1034 Sub Area 1

• The Vision and Policy 1.1 do not stress the importance of retaining the existing and vibrant cultural and artistic practices

• Allocations do not have designations for affordable workspace

• There is no policy to promote affordable workspace

• The building height of 20 metres is the top end of the existing range


1035 Sub Area 2

Considers that Policies 2.1 - 2.4 and site allocations SA2.1, 2.2 and 2.3 are unsound as they do not: • Provide the housing choice promised pre-Olympic Games. There should be provision of a community land

trust and other types of small scale affordable housing.• Integrate well with the surrounding low rise housing estates in Waltham Forest and respond to their social conditions.

• Make clear how many tall buildings there will be above the proposed building heights, and at what height.

• Provide for retention or relocation of existing employment uses. For example, the loss of local jobs at Leyton Road North and the Chobham Farm site.

• Specify what community facilities will be delivered. For example, the Legacy Communities Scheme for the Chobham Manor site.

• Respond to the very poor air quality on the A12 and Leyton Road.

• East Village, a new Local Centre, has too much retail. It should have a wider mix of uses with specific reference to a lifetime neighbourhood. The retail offer needs to be diverse, with small, independent shops

and affordable workspace. Existing residents are considered to have difficullty with the names given to the new neighbourhoods which will not foster collective identiy when using common facilities inside and outside the new areas, handicaping bridge building between new and old communities. Existing residents cannot afford to live in Chobham Manor and feel that its facilities are out of their reach.


1036 3.1 See REP.LP.024 (Response entry 258) REP.LP.096 Just Space1037 3.2 See REP.LP.024 (Response entry 259) REP.LP.096 Just Space1038 SA3.4 See REP.LP.024 (Response entry 260) REP.LP.096 Just Space

1039 Sub Area 4


the canal/ river areas. • The site allocations should recognise the need for traffic calming along the Blackwall Tunnel Approach Road; a key issue for improving connections. • New development should integrate




See REP.LP.056 (Response entry 562) REP.LP.096 Just Space


Introduction to representation stating that the Plan is not sound or Legally compliant. REP.LP.096 Just Space

1011 See REP.LP.015. REP.LP.096 Just Space

1041 Sub Area 1 Objecting to the proposed bridges across Old Ford Locks (at the southern end of the Hackney Cut) and across the Bottom Lock on the Hertford Union Canal. REP.LP.097 Tom Ridge, Adam English

and Melissa Parker

1042 See REP.LP.024 REP.LP.098 Yakub A Mohamed1043 See REP.LP.024 REP.LP.099 Giuseppe Cifonelli 1044 See REP.LP.024 REP.LP.100 N E Sparkes1045 See REP.LP.024 REP.LP.101 Nusrath Jahan Tapadar1046 See REP.LP.024 REP.LP.102 Anjuman Uddin1047 See REP.LP.024 REP.LP.103 Numan Uddin1048 See REP.LP.024 REP.LP.104 Sirajun Nahar Khanom

1049 See REP.LP.024 REP.LP.105 Mohammed Ashrad Uddin Tapadar

1050 See REP.LP.024 REP.LP.106 Urmin Khan1051 See REP.LP.024 REP.LP.107 Sazzad Khan

1052 SA3.4

Residents of Carpenters Estate unable to attend meetings. Officers taking part in consultation are paid public money, which is not the case for residents. Request for what housing can be reproved. Concern about price achieved for existing housing. Developers want to buy estate at low price but is a key development. Concern about conditions of existing block of housing.

REP.LP.108 Habibur & Farina Khan

1053 See REP.LP.024 REP.LP.109 Fitzroy Williams1054 See REP.LP.024 REP.LP.110 Tia-J'Nae Murray1055 See REP.LP.024 REP.LP.111 Janiz Murray1056 See REP.LP.024 REP.LP.112 Seamus Clarke1057 See REP.LP.024 REP.LP.113 Bradley Linard1058 See REP.LP.024 REP.LP.114 Jason Williams1059 See REP.LP.024 REP.LP.115 Dolores John-Phillip1060 See REP.LP.024 REP.LP.116 Sheva Williams1061 See REP.LP.024 REP.LP.117 Kenneth Dannine1062 See REP.LP.024 REP.LP.118 Brian Finch1063 See REP.LP.024 REP.LP.119 M Finch

1064 Vision


residents in these Boroughs and the Boroughs key role in the delivery of the Local Plan • The high importance of creating job opportunities for local people and ensuring the diversity of the economic offer

• The successful integration of existing communities, like the Carpenters estate and at Bromley by Bow, through measures such as lifetime neighbourhoods.

• Commitments to positively improve the social and environmental conditions in the area and a comimitment to retain traditional tyoes of family housing, respecting the historic character of the area and offering

a choice of housing.

REP.LP.120 Carol Richards

1065 SP1 See REP.LP.046 (Response entry 475) REP.LP.120 Carol Richards

1066 B.1

B.1 is unsound as it does not provide enough support to retain employment and industrial land. The importance of retaining industrial land should be strengthened. Technological and maker growth take place in workshops and yards as well as offices. . Should have more discussion of conclusions of Economy Study particularly important for businesses within Carpenters District which are long-standing and keen to expand. Fails to recognise importance of local employment in terms of lifetime neighbourhoods. To be sound should include employment cluster within Carpenter District and should remain in industrial use. Can provide employment within Sub Area 3 in addition to the retail jobs. N.1 should acknowledge importance of retaining employment sires in terms of lifetime neighbourhoods and reducing need to travel.

REP.LP.120 Carol Richards

53

1067 B.2 See REP.LP.046 (Response entry 477) REP.LP.120 Carol Richards1068 B.4 See REP.LP.046 (Response entry 478) REP.LP.120 Carol Richards

1069 B.5 See REP.LP.087 (Response entry 918) REP.LP.120 Carol Richards

1070 SP2 See REP.LP.024 (Response entry 248) REP.LP.120 Carol Richards1071 H.2 See REP.LP.096 (Response entry 1014) REP.LP.120 Carol Richards1072 CI.1 See REP.LP.024 (Response entry 250) REP.LP.120 Carol Richards1073 CI.2 See REP.LP.046 (Response entry 483) REP.LP.120 Carol Richards1075 BN.11 See REP.LP.015. (Response entry 148) REP.LP.120 Carol Richards1074 BN.6 See REP.LP.015 (Response entry 146) REP.LP.120 Carol Richards

1076 T.6 See REP.LP.015 (Response 155) REP.LP.120 Carol Richards

1077 SP5 See REP.LP.015 (Response 157) REP.LP.120 Carol Richards1078 S.2 See REP.LP.015 (Response entry 158) REP.LP.120 Carol Richards

1079 S.3 See REP.LP.015 (Response entry 159) REP.LP.120 Carol Richards

1080 3.1 See REP.LP.024 (Response entry 258) REP.LP.120 Carol Richards1081 3.2 See REP.LP.024 (Response entry 259) REP.LP.120 Carol Richards1082 SA3.4 See REP.LP.024 (Response entry 260) REP.LP.120 Carol Richards

1083 Vision See REP.LP.120 (Response Entry 1064) REP.LP.121 Rev. David Richards

1084 SP1 See REP.LP.046 (Response entry 475) REP.LP.121 Rev. David Richards

1085 B.1 See REP.LP.120 (Response Entry 1066) REP.LP.121 Rev. David Richards

1086 B.2 See REP.LP.046 (Response entry 477) REP.LP.121 Rev. David Richards1087 B.4 See REP.LP.046 (Response entry 478) REP.LP.121 Rev. David Richards1088 B.5 See REP.LP.087 (Response entry 918) REP.LP.121 Rev. David Richards1089 SP2 See REP.LP.024 (Response entry 248) REP.LP.121 Rev. David Richards1090 H.2 See REP.LP.096 (Response entry 1014) REP.LP.121 Rev. David Richards1091 CI.1 See REP.LP.024 (Response entry 250) REP.LP.121 Rev. David Richards1092 CI.2 See REP.LP.046 (Response entry 483) REP.LP.121 Rev. David Richards1094 BN.11 See REP.LP.015. (Response entry 148) REP.LP.121 Rev. David Richards1093 BN.6 See REP.LP.015 (Response entry 146) REP.LP.121 Rev. David Richards

1095 T.6 See REP.LP.015 (Response 155) REP.LP.121 Rev. David Richards

1096 SP5 See REP.LP.015 (Response 157) REP.LP.121 Rev. David Richards

1097 S.2 See REP.LP.015 (Response entry 158) REP.LP.121 Rev. David Richards1098 S.3 See REP.LP.015 (Response entry 159) REP.LP.121 Rev. David Richards1099 3.1 See REP.LP.024 (Response entry 258) REP.LP.121 Rev. David Richards1100 3.2 See REP.LP.024 (Response entry 259) REP.LP.121 Rev. David Richards1101 SA3.4 See REP.LP.024 (Response entry 260) REP.LP.121 Rev. David Richards1102 See REP.LP.024 REP.LP.122 Folu Fabikun1103 See REP.LP.024 REP.LP.123 Ndubisi Umeh1104 See REP.LP.024 REP.LP.124 Gretta White1105 See REP.LP.024 REP.LP.125 Kevin [unknown]1106 See REP.LP.024 REP.LP.126 Usher Patel1107 See REP.LP.024 REP.LP.127 Susan Wooldridge1108 See REP.LP.024 REP.LP.128 William Mitchell1109 See REP.LP.024 REP.LP.129 Henry Mwanga1110 See REP.LP.024 REP.LP.130 Busisiwe Mkatte1111 See REP.LP.024 REP.LP.131 David John1112 See REP.LP.024 REP.LP.132 Adeyeni Onibudo1113 See REP.LP.024 REP.LP.133 Juliette Blackett1114 See REP.LP.024 REP.LP.134 Mahid Miah1115 See REP.LP.024 REP.LP.135 Murad Miah1116 See REP.LP.024 REP.LP.136 Moiram Begum1117 See REP.LP.024 REP.LP.137 Abdul Malik1118 See REP.LP.024 REP.LP.138 Joyce Bryant1119 See REP.LP.024 REP.LP.139 M Ford1120 See REP.LP.024 REP.LP.140 Doreen Ward1121 See REP.LP.024 REP.LP.141 Rudeen February1122 See REP.LP.024 REP.LP.142 Rohan Fraser1123 See REP.LP.024 REP.LP.143 Mr Benn1124 See REP.LP.024 REP.LP.144 Frank Foster1125 See REP.LP.024 REP.LP.145 Tee Fabikun

54

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