Panel Report on the draft Replacement London Plan

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Draft Replacement

London Plan

Report of the Panel: Volume 1 - Report

March 2011

Examination in Public

28th June - 8th December 2010

4/03 Kite Wing

Temple Quay House

2 The Square



Direct Line:

0117 372 8174

Customer Services:

0117 372 6372

Fax No:

0117 372 8782


Boris Johnson

The Mayor of London

City Hall

The Queen’s Walk

More London

London SE1 2AA

Date: 11 March 2011

Dear Mayor

Panel Report on the draft Replacement London Plan

We have pleasure in submitting to you our Panel Report following the Examination in Public of the draft Replacement London Plan. The Examination in Public was conducted at City Hall on 32 days between 28 June and 8 December 2010.

Our report contains our conclusions and recommendations on the changes which we consider should be made to the draft Replacement London Plan in the light of the Examination, including the consideration of the Minor Alterations and the early and further suggested changes that you put forward prior to and during the Examination. As stated in the Overview to the report, we hope that our conclusions generally endorsing the draft as suggested for revision together with our specific recommendations will enable the publication of the Replacement London Plan at an early date.

We would like to thank all those who participated in the Examination. Our thanks are also due for the technical support of Chris White and Tom Stanley, Planning Officers with the Planning Inspectorate and to the Panel Assistant, Nicholas Rogers as well as support staff within City Hall. We also record our special gratitude to Carmel Edwards, our Panel Secretary, for everything she did to ensure a successful Examination.

Yours faithfully

P G Robottom D C Lavender

Peter Robottom David Lavender


Chair Panel Inspector


Page No.




Non-Technical Summary & Overview


Chapter 1

Context and Strategy

  • Introduction – Procedural Soundness

  • Issue 1 – Treatment of Proposed Changes

  • Issue 2 - The Level of Detail and the Structure of Policies

  • Issue 3 - The Appropriateness of the Vision and Objectives

  • Issue 4 - The Nature of the Over-arching Spatial Policy







Chapter 2

London’s Places

  • Introduction

  • Policies 2.1 – 2.3 Linkages

  • Policy 2.4 The Olympic Legacy

  • Policy 2.5 Joint Working

  • Policies 2.6, 2.7 and 2.8 Outer London

  • Policy 2.9 Inner London

  • Policies 2.10, 2.11 and 2.12 The Central Activities Zone (CAZ)

  • Policies 2.13 and 2.14 Opportunity Areas, Intensification Areas and Areas for Regeneration

  • Policy 2.15 Town Centres

  • Policy 2.16 Strategic Outer London Development Centres

  • Policy 2.17 Strategic Industrial Locations

  • Policy 2.18 Green Infrastructure














Chapter 3

London’s People

  • Introduction

  • Policies 3.1 Ensuring Equal Life Chances for All and 3.2 Addressing Health Inequalities

  • Policy 3.3 Increasing Housing Supply

  • Policy 3.4 Optimising Housing Potential

  • Policies 3.5 Quality and Design of Housing Developments, 3.6 Children and Young People’s Play and Informal Recreation Facilities, and 3.7 Large Residential Developments

  • Policy 3.8 Housing Choice

  • Policy 3.8 Housing Choice and Policy 3.9 Gypsies and Travellers (including Travelling Showpeople)

  • Affordable Housing

  • Policy 3.10 Mixed and Balanced Communities

  • Policy 3.11 Definition of Affordable Housing

  • Policy 3.12 Affordable Housing Targets

  • Policy 3.13 Negotiating Affordable Housing

  • Policy 3.14 Affordable Housing Thresholds

  • Policy 3.15 Existing Housing

  • Social Infrastructure

  • Policy 3.17 Protection and Enhancement of Social Infrastructure

  • Policy 3.18 Healthcare Facilities

  • Policy 3.19 Education Facilities

  • Policy 3.20 Sports Facilities





















Chapter 4

London’s Economy

  • Introduction

  • Policy 4.1 Developing London’s Economy

  • Policies 4.2 Offices and 4.3 Mixed Use Developments and Offices

  • Policy 4.4 Managing Industrial Land and Premises

  • Tourism, Arts and Creative Industries(Policies 4.5-4.6)

  • Retail and Town Centre Development (Policies 4.7-4.8)

  • Policy 4.9 Small Shops

  • New and Emerging Economic Sectors (Policies 4.10-4.12)










Chapter 5

London’s Response to Climate Change

  • Introduction

  • Climate Change Mitigation and Adaptation

  • Policy 5.5 Decentralised Energy Networks, and Policy 5.6 Decentralised Energy in Development Proposals

  • Policies 5.9 Overheating and Cooling, 5.10 Urban Greening, and 5.11 Green Roofs and Development Site Environs

  • Policies 5.12-5.15 Flooding and Water Issues

  • Policies 5.16, 5.17, 5.18 and 5.19 Waste Issues

  • Policies 5.21 Contaminated Land and 5.22 Hazardous Substances

  • Policy 5.20 Aggregates










Chapter 6


  • Introduction

  • Policy 6.1 Strategic Approach to Integrating Transport & Development

  • Policy 6.2 Providing Transport Capacity and Safeguarding Land for Transport (including Table 6.3), Policy 6.3 Assessing Effects of Development on Transport Capacity, Policy 6.4 Enhancing London’s Transport Connectivity

  • Policy 6.5 Funding Crossrail and Other Strategically Important Transport Infrastructure

  • Policy 6.6 Aviation

  • Policy 6.7 Buses, Bus Transits, Trams, Policy 6.8 Coaches

  • Policy 6.9 Cycling, Policy 6.10 Walking

  • Policy 6.11 Smoothing Traffic Flow and Tackling Congestion, Policy 6.12 Road Network Capacity

  • Policy 6.13 Parking

  • Policy 6.14 Freight, Policy 6.15 Strategic Rail Freight Interchanges (SRFIs)












Chapter 7

London’s Living Places and Spaces

  • Introduction

  • Policy 7.1 Building London’s Neigbourhoods and Communities and Policy 7.2 An Inclusive Environment

  • Policy 7.3 Crime

  • Policies 7.4 Local Character, 7.5 Public Realm and 7.6 Architecture

  • Policy 7.7 Location and Design of Tall and Large Buildings

  • Policies 7.8, 7.9 and 7.10: Heritage Issues

  • Policies 7.11 and 7.12: View Management

  • Policy 7.13 Security

  • Policies 7.14 Improving Air Quality and 7.15 Reducing Noise and Enhancing Soundscapes

  • Policies 7.16 Green Belt, 7.17 Metropolitan Open Space and 7.18 Protecting Local Natural Space and Addressing Local Deficiency

  • Policies 7.19 Biodiversity and Access to Nature and 7.20 Geological Conservation

  • Policies 7.22 and 7.23: Open Land Uses

  • Policies 7.24-7.30 Waterways















Chapter 8

Implementation, Monitoring and Review

  • Introduction

  • Policy 8.2 Planning Obligations

  • Policy 8.3 Community Infrastructure Levy

  • Policy 8.4 Monitoring and review (including Table 8.1 Key Performance Indicators)








Appendix 1: Panel Recommendations



This is the report of the Examination in Public (EiP) that we were appointed to hold into the Draft Replacement London Plan.

The Greater London Authority submitted the Draft Replacement London Plan to the Secretary of State in October 2009. The consultation period closed on 12 January 2010. During this period and shortly thereafter there were a total of 944 respondents to the submission consultation and related documents making approximately 7,166 points of response. A first Minor Alteration (waste arisings and apportionments and corrections) was published on 7 December 2009 with a deadline for comments of 1 February 2010. This attracted 17 respondents raising 43 points for the Panel’s consideration. A second Minor Alteration (Gypsies and Travellers) was published on 23 March 2010 with a deadline for comment of 11 May 2010. This attracted 326 respondents raising 338 further points for the Panel’s consideration. A third Minor Alteration (Gypsies and Travellers and Aggregates) was published on 13 September 2010 with a deadline for comment of 25 October 2010 and attracted 482 respondents raising 629 points.

Arrangements were made for conducting and reporting on the Examination in Public as expeditiously as possible. The key stages were:

Publication of initial draft Matters and Participants: 25 March 2010

Preliminary Meeting 30 March 2010

Final list of initial Matters and Participants issued 13 May 2010

Examination in Public – opening prior to recess 28 June 2010

Examination in Public – adjourned for summer recess 16 July 2010

Examination in Public – resumption after recess 6 Sept 2010

Examination in Public – adjourned until deferred sessions 15 Oct 2010

Examination in Public – deferred sessions opened 7 Dec 2010

Examination in Public – closed after deferred sessions 8 Dec 2010

The Examination sat for a total of 32 days. The Preliminary Meeting and the Examination sessions were held in the Assembly Chamber, City Hall, apart from the final day which was held in a Committee Room.

Technical Seminars were held to introduce sessions on 2 additional days (21 June and 4 October) and Panel Tours on 2 more to various locations and viewpoints referred to in the Plan or at the Examination in East and West London respectively (15 and 22 September). Site visits by individual Panel Members were also made on a number of other occasions including 13 April, 30 June, 14 July and 6 October to the Olympic Park and nearby areas, various riverside and central London locations and to particular Opportunity, Intensification and Regeneration Areas referred to at the Examination.

Some 282 organisations and individuals were invited to participate at the EiP. Many Councils of London Boroughs, the Corporation of the City of London and the representative body for London Councils took the opportunity to participate as did initially the Government Office for London (GOL) on behalf of Department for Communities and Local Government (DCLG). There were also representatives of development and business interests including umbrella bodies such as London First and the Home Builders Federation together with representatives of a wide range of community interests such as the Just Space Network, London Forum of Civic and Amenity Societies and groups representing minorities and those with disabilities. Learned societies such as the Town and Country Planning Association and academic interests also made significant contributions, as did a number of individuals.

Following the close of the EiP we completed and submitted this report via the Planning Inspectorate in early February 2011.

During the Examination process new announcements and items of relevant information continued to appear, including material requested by the Panel from the Mayor and other participants. The statement by the Secretary of State for Communities and Local Government to the Examination on 12 July on localism and the Mayor’s response on 16 July necessitated a postponement of the close of the Examination to consider the Mayor’s Alterations to withdraw or modify certain targets and allow for the necessary advertisement of material changes to the Plan. This postponement also enabled consideration to be given to the implications of Government amendments to the Community Infrastructure Levy scheme. The deferred sessions were held on 7 & 8 December 2010.

Information that came out after submission of the Draft Replacement London Plan but before the final close of the EiP was able to be taken into account by the Panel and participants. We do not believe that there is anything in publications issued after the close of the EiP and prior to submission of our report that would have caused us to reach materially different conclusions or recommendations. However, where the new material comprises statements of Government policy, for example the publication of the Localism Bill on 13 December 2010, the statement on HS2 of 20 December 2010, the amendments to PPG13 on 3 January 2011 and publication of the White Paper: Creating Growth, Cutting Carbon: Making Sustainable Local Transport Happen by Department for Transport on 19 January 2011, regard has been had to such material.

This report is not intended to give a full account of the Matters discussed in the EiP, although it generally follows the same order, with the main chapters corresponding to the EiP Matters and chapters in the DRLP. Where appropriate, we draw upon points made in discussion and in various submitted documents in order to show how and why we arrive at our conclusions. Where we recommend changes to London Plan policies and supporting text our recommendations give specific wording. We also endorse the generality of the suggested changes put forward by the Mayor at the outset of the Examination and during the course of its sessions. Specific endorsement is given where we consider that the changes are of substance and significance for the soundness of the Plan. In the interests of brevity these recommendations are highlighted in the text where they occur and otherwise set out in separate Annexes. We have also identified in unboldened italics (e.g. paras 2.122, 3.56, 5.72, 5.90 and 6.20) a small number of places where additional clarity might be helpful to users of the Plan, but which do not warrant formal recommendations.

Extensive though some of the chapters are, we consider they are the minimum necessary to give the supporting arguments for our recommendations and comments, those other than endorsement of suggested changes put forward by the Mayor being kept as few as possible in order to reflect the new emphasis on localism. In the Overview below we have picked out the key points and lessons, some of which go wider than the specific recommendations.
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