Chapter 2: Sustainable Communities FM2.1 Modification: M2.3 Paragraph 2.3 Response Ref: Respondent (s): M0032AC Mr N Goy a. Summary of Representation Capitalise ‘Pplanning Ppolicy Gguidance’ for consistency with new text b. Suggested Rewording As indicated in a. above c. Officer Comment Typographical error noted. d. Officer Recommendation NON-MATERIAL CHANGE – amend wording as set out in a. above FM2.2 Modification: M2.5 New Paragraph 2.4a Response Ref: Respondent (s): M0032A Mr N Goy a. Summary of Representation Replace as follows for plain English. b. Suggested Rewording The Strategy presents a new “purpose” which has been adopted as the new framework goal for sustainable development It states: “the goal of sustainable development is …” c. Officer Comment The text is a precis of a sentence in “One future – different paths”, the UK’s new (2005) framework for Sustainable Development. This new Strategy is different from the previous one in several ways. The language used helps to reflect these differences. d. Officer Recommendation NO CHANGE HIGH QUALITY, RESOURCE EFFICIENT DEVELOPMENT FM2.3 Modification: M2.20 New Paragraph 2.14a Response Ref: Respondent (s): M0032AE Mr N Goy a. Summary of Representation Title of new section, above M2.20 New Paragraph 2.14 in the modifications document, punctuation: resource-efficient b. Suggested Rewording As indicated in a. above c. Officer Comment Punctuation error noted. d. Officer Recommendation NON-MATERIAL CHANGE – amend wording as set out in a. above PROTECTION OF NATURAL AND HISTORIC ENVIRONMENTS FM2.4 Modification: M2.43 New Paragraph 2.32b Response Ref: Respondent (s): M0031G Government Office for London a. Summary of Representation Reference to Planning Policy Guidance should be updated b. Suggested Rewording PPG9 has been superseded by PPS9 c. Officer Comment Amend reference accordingly d. Officer Recommendation NON-MATERIAL CHANGE – amend reference in paragraph to read ‘PPS9’ DEVELOPMENT FOR SAFE, LIVEABLE COMMUNITIES FM2.5 Modification: M2.49 New Paragraph 2.32h Response Ref: Respondent (s): M0032AF Mr N Goy a. Summary of Representation To be consistent with the Inspector’s terminological recommendation in M3.3 (accepted by the Council), in the first sentence of the paragraph ‘special needs’ should be replaced with ‘supported’, i.e.: supported special needs housing b. Suggested Rewording As indicated in a. above c. Officer Comment Inconsistency with accepted Inspector’s recommendation noted. d. Officer Recommendation NON-MATERIAL CHANGE – amend wording as set out in a. above FM2.6 No Modification Number Strategic Map Response Ref: Respondent (s): M0032AG Mr N Goy a. Summary of Representation While the Inspector has recommended no changes to the Map this will result in ‘Westow Hill’ being left on the map. Westow Hill is the name of one road in Upper Norwood and is not the name of a hill or a place name. Biggin Hill and the Motorways are not named on the Map. b. Suggested Rewording N/A c. Officer Comment The representation does not relate to a modification and is therefore not duly made. In any event, the Strategic Map is not intended as a definite map of the area surrounding Bromley. The town centres shown are categorised and named in accordance with the UDP’s of the respective boroughs in which they lie, as indicated in the key. For instance, the District Centre which straddles the boundaries of Croydon and Lambeth is called ‘Upper Norwood in the former and ‘Westow Hill’ in the latter. Local Town Centres in Bromley are not named, nor are any of the roads or motorways. d. Officer Recommendation NO CHANGE Chapter 3: Strategic Objectives FM3.1 Modification: M3.5 Housing: New Objective 4 Response Ref: Respondent (s): M0026A Greater London Authority a. Summary of Representation The borough wide affordable housing target does not meet the Mayor’s strategic target of 50%. No explanation of special circumstances has been provided to justify a departure from the London-wide need. The replacement UDP therefore needs modification to increase the provision of affordable housing supply and the range of choice available to all residents in London and to be in general conformity with the London Plan. b. Suggested Rewording N/A c. Officer Comment The new housing objective together with the housing target figure reflect the decision of the Council following the Public Inquiry as agreed at the meeting of the Development Control Committee on the 30th August 2005 and set out in the Schedule of Proposed Modifications (M4.21). d. Officer Recommendation NO CHANGE FM3.2 Modification: M3.24 Green Belt and Open Space: Objective 1 Response Ref: Respondent (s): M0032B Mr N Goy a. Summary of Representation In support of the Council’s decision not to accept the Inspector’s modification to relocate the words “Green Chain” to Objective 3. b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE - support noted FM3.3 Modification: M3.33 Recreation, Leisure and Tourism: New Objective 4 Response Ref: Respondent (s): M0032C Mr N Goy a. Summary of Representation In support of the new objective valuing the importance of Crystal Palace Park b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE - support noted FM3.4 Modification: M3.35 New paragraph 3.7a – Crystal Palace park Response Ref: Respondent (s): M0027A Crystal Palace Community Association. M0032D Mr N Goy a. Summary of Representation Objection to the omission of a sentence from the Inspector’s proposed wording. b. Suggested Rewording Insert between the 1st and 2nd modification sentences: “It is surrounded by residents of five Boroughs and its future should be planned with the full participation of the local community and neighbouring borough authorities” c. Officer Comment The sentence was omitted in error and should be re-introduced d. Officer Recommendation NON-MATERIAL CHANGE – Amend paragraph 3.7a to read: “Crystal Palace Park is a regional park of strategic importance for south east London with significant Victorian heritage. It is surrounded by residents of five Boroughs and its future should be planned with the full participation of the local community and neighbouring authorities. Any proposals will be brought forward…” M0032D Mr N Goy a. Summary of Representation There is a grammatical error in the paragraph. b. Suggested Rewording Correct last sentence to read: “It is envisaged that refurbishment or redevelopment will be necessary in the future and as a consequence the complex of buildings is designated as a Major Developed Site” c. Officer Comment Agreed d. Officer Recommendation NON-MATERIAL CHANGE – Amend the sentence as shown in b. above. Chapter 4: Housing OBJECTIVES FM4.1 Modification M4.4 New Objective 4 Response Ref: Respondent (s): M0026B Greater London Authority a. Summary of Representation The objection relates to the fact that the borough wide affordable housing target does not meet the Mayor’s strategic target of 50%. b. Suggested Rewording N/A c. Officer Comment The new housing objective together with the housing target figure reflect the decisions of the Council following the Public Inquiry and the meeting of the Development Control Committee on the 30th August 2005. The figure is based on the realistic assessment of supply and local circumstances which militate against achieving a 50% target. Acceptance of a 10 unit threshold however would raise the figure of affordable housing likely to be achieved (see FM4.8 below) d. Officer Recommendation CONSEQUENTIAL CHANGE - Amend Objective 4 to read: “To seek the provision of at least 2840 3160 additional affordable homes….” LOCAL CONSIDERATIONS FM4.2 Modification: M4.13 Paragraph 4.9 Response Ref: Respondent (s): M0036A Taylor Woodrow Development a. Summary of Representation In support of the Council’s adoption of the Inspector’s recommendation to modify Paragraph 4.9 so that meeting the housing needs of the Borough is given the same emphasis as recognising and protecting the exceptional environmental quality. b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE - support noted HOUSING SUPPLY FM4.3 Modification: M4.14 Policy H1 Response Ref: Respondent (s): M0031A Government Office for London a. Summary of Representation Whilst the recent housing performance in the borough has improved when measured against the London Plan annualised monitoring figure, the shortfall identified by the Inspector is not fully addressed. The current housing strategy of the Council will fail to deliver sufficient homes against the minimum target as set out in the London Plan. The Council therefore should consider bringing forward an early review of housing policies to achieve a robust and deliverable strategy for meeting the overall housing requirement in the borough. b. Suggested Rewording N/A c. Officer Comment The policies relating to housing supply have been modified to reflect the decision of the Council following the Public Inquiry and the meeting of the Development Control Committee on the 30th August 2005. However, the points made warrant further investigation. This will be undertaken as part of the planning policy team’s work programme in preparing a Local Development Framework for the borough. The Local Development Scheme will be amended accordingly to include the preparation of an appropriate Development Plan Document. d. Officer Recommendation NO CHANGE – but consider a review of housing policies as part of the Local Development Framework FM4.4 Modification M4.14 Policy H1 (and related Chapter 16) Response Ref: Respondent (s): M0030A Asprey Homes Ltd M0039A Crest Nicholson M0028A Castlefort Properties Ltd. a. Summary of Representation Objections relating to the supply of housing in Bromley and the failure to allocate further sites to meet the housing target. In failing to implement the Inspector’s recommendations in their entirety, the Council is abrogating its responsibility to plan for the future housing needs and requirements of the residents of the borough. b. Suggested Rewording Allocation of further sites for housing Delete Modification 4.14 Allocation of land r/o 91-117 Copers Cope Road for housing in the Schedule of Proposal sites c. Officer Comment Housing sites are allocated in accordance with the decision of the Council following the Public Inquiry and the meeting of the Development Control Committee on the 30th August 2005. However, the points made warrants further investigation through the LDF process (but see also comment in FM4.3.c. above). d. Officer Recommendation NO CHANGE FM4.5 Modification: M4.14 Policy H1 Response Ref: Respondent (s): M0040A Temple Homes a. Summary of Representation The modification to Policy H1 does not reflect the recommendations of the Inspector. The annual target in Bromley is not being achieved, which is why the Inspector recommended the identification of reserved sites. The Council should take on board the recommendations of the Inspector and modify the policy. b. Suggested Rewording - Add a schedule of reserved housing sites; - Add new wording to indicate the time scale in which sites would be released; - Add new text identifying a ‘plan, monitor and manage’ approach as well as trigger points for the release of reserve sites. - Include the Land at Cockmannings Lane, Orpington as a reserve site. c. Officer Comment The Council has considered the Inspector’s recommendations but, for the reasons outlined in the proposed modifications, has chosen not to implement them in respect of the above matters. But see comment in FM4.3.c. above. d. Officer Recommendation NO CHANGE FM4.6 Modification: M4.14 Policy H1 (vi) Response Ref: Respondent (s): M0024A Linden Homes South East M0036B Taylor Woodrow a. Summary of Representation Objecting to criterion (vi) which refers to the density/accessibility table in Policy H7. The density figures in the table in Policy H7 do not accord with the density figures as set out in the London plan and therefore the Council is unlikely to achieve its housing supply target. b. Suggested Rewording Criterion (vi) should refer to the density matrix of the London Plan c. Officer Comment Criterion vi) is amended as a consequence of meeting GOL objection M0031C to Policy H6 (see FM4.14 below). See also covering report, paragraphs 3.8, 3.12 and 3.13. d. Officer Recommendation FURTHER MODIFICATION - Amend Criterion (vi) as follows: “(vi) Making the most efficient use of sites, in accordance with the density/accessibility matrix at in Policy H7 Table 4.2 FM4.7 Modification M4.14 Policy H1 criterion (v) and (vi) Response Ref: Respondent (s): M0035A Legal & General Assurance Society a. Summary of Representation Criterion (v) ignores the other equally important component of mixed use policy in which enhancing a mix of uses and creating more sustainable development can be achieved by introducing additional single uses, such as residential into an area. The reference to table in Policy H7 in (vi) does not accord with the London Plan. b. Suggested Rewording Reword the criterion in Policy H1 as follows: “(v) seeking housing development in and close to town centres in order to enhance the overall mix of uses or to introduce a mix of uses into individual developments; (vi) make the most efficient use of sites in accordance with the density/accessibility Table 4B.1 in the London Plan (or an equivalent replicated table in the UDP). c. Officer Comment The wording of criterion (v) reflects the decision of the Council following the UDP Inquiry and the decision of Development Control Committee on the 30th August 2005 in accordance with the Inspector’s recommendation. Criterion (vi) is amended as a consequence of meeting GOL objection M0031C to Policy H6 (see FM4.14 below). d. Officer Recommendation See FM 4.6.d Above. AFFORDABLE HOUSING FM4.8 Modification: M4.21 Policy H2 Response Ref: Respondent (s): M0031C Government Office for London a. Summary of Representation Objection to the affordable housing threshold of 15 units. There is an apparent potential to increase affordable housing supply by lowering the threshold from 15 units to 10 units. b. Suggested Rewording Modify the policy to refer to sites capable of providing 10 or more units gross or of 0.4 hectares or more. c. Officer Comment The threshold of 15 units reflects the decision of the Council following the Public Inquiry and the Development Control Committee meeting of the 30th August 2005. However, the covering report of this agenda item provides support for accepting a reduction of the threshold in line with the GOL suggestion. Failure to modify the threshold runs to risk of prompting a ‘direction’ from the Secretary of State. Consequential amendments will be required to supporting paragraphs 4.18 and 4.20 as set out below. The affordable housing figure in Objective 4 is also amended (see FM 4.1.d above). Further modification to paragraphs 4.18 and 4.19a retain the 2DD reference to calculating affordable housing using habitable rooms rather than dwellings or units (see covering report paragraph 3.10). d. Officer Recommendation FURTHER MODIFICATION - Amend first paragraph of Policy H2 to read: “In order to meet the needs of the Borough, affordable housing will be sought on all housing sites of 1510 dwellings or more, or housing sites of 0.5 0.4ha or larger, irrespective of the number of dwellings. On all sites at or above this threshold negotiations will take place to determine the number of affordable dwellings to be provided…” Consequential changes to Paragraph 4.18 (M4.28), 4.19a (M4.29) and 4.20 (M4.30) Paragraph 4.18 The Council’s target for provision of affordable housing up to 2016 is based on the results of the Housing Capacity Study (HCS)(LPAC 1999) and other realistic sources of supply likely to come forward during the plan period, including vacant units brought back into use. Approximately 350 affordable housing units are to be provided on identified sites. Applying the 35% requirement on sites of 15 10 units or more would yield approximately 1290 1461 affordable units on windfall sites; using HCS data, it is estimated that some 1200 units might be contributed on sites of up to 10 units including conversions. This overall target of 2840 3160 units would comprise approximately 852 948 intermediate units and 1988 2212 social-rented units allowing for some flexibility as the 70:30 split will only apply to sites granted permission in the second half of the Plan period. Proposal Sites identified for housing purposes will be expected to contribute affordable housing in line with the 35% policy requirement. The quota will usually be applied to the number of units habitable rooms. The Council will advise applicants of the mix of units on individual sites that will be required to meet local needs. Paragraph 4.19a “In negotiating the level of affordable housing the Council will seek the provision of 35% of dwellings habitable rooms on a site unless material considerations indicate otherwise. In these negotiations the principal considerations will be:” Paragraph 4.20 “The Government aims to promote mixed and balanced communities [PPG3 para 10], so off-site provision or payments in lieu will rarely be acceptable. On sites capable of accommodating 15 10 units/0.5 0.4ha or more, off-site provision or a payment in lieu may be acceptable in exceptional circumstances if applicants are able to demonstrate that on-site provision would be practically difficult. If off-site provision is offered, the onus will initially be on the developer to find and provide an alternative site. Where the other site falls below the 1510-unit/0.5 0.4ha threshold, the 35% requirement will be applied to the total capacity of both sites. “ FM4.9 Modification: M4.21 Policy H2 Response Ref: Respondent (s): M0026D Greater London Authority a. Summary of Representation Objection in respect of the affordable housing target of 35%, which is not consistent with the Mayor’s current London Plan policies which should take account of the 50% target for London. The London Plan also encourages Council’s to seek a threshold of lower than 15 units. b. Suggested Rewording Modify the borough-wide target to reflect the London Plan strategic target and increase housing supply and the range of choice available. c. Officer Comment The text reflects the decision of the Council following the Public Inquiry and the meeting of the Development control Committee on 30 August 2005. The reasons, which the Council considers militate against the achievement of a higher affordable housing target in the Borough, are set out in the Proposed Modifications. The Director of Social Services & Housing has provided further comment in Annex 3 to the covering report of this agenda item (see also FM4.1 above). d. Officer Recommendation NO CHANGE FM4.10 Modification: M4.21 New Policy H2A Response Ref: Respondent (s): M0026C Greater London Authority a. Summary of Representation Support for new Policy H2A dealing with the circumstances where payments in lieu may be acceptable and amending the definitions of affordable housing in accordance with the London Plan. b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE - Support noted. SUPPORTED HOUSING FM4.11 Modification: M4.34 Policy H3 Response Ref: Respondent (s): M0036C Taylor Woodrow a. Summary of Representation Objection is made to the amendment to Policy H3 whereby the Council are only part in accordance with the Inspector’s recommendation. In the Inspector’s recommendation, supported housing should contribute to the overall quantum affordable housing. The Council have misinterpreted the views of the Inspector whose recommendation does not mean that supported housing would only be provided on affordable housing sites. b. Suggested Rewording Accept the Inspector’s recommendation to reword policy H3 along the following lines: “On sites where affordable housing is to be provided negotiations will take place for Supported Housing in place of some or all of the affordable housing, where it can be demonstrated that there is a requirement for Supported Housing to meet the needs of specific identified groups.” c. Officer Comment The Policy has been modified to reflect the decision of the Council following the Public Inquiry and the meeting of the Development Control Committee on 30th August 2005. For reasons set out in the proposed modifications the Council has chosen not to implement the Inspector’s recommendation in full. d. Officer Recommendation NO CHANGE ACCESSIBLE HOUSING FM4.12 Modification: M4.38 Paragraph 4.26 Response Ref: Respondent (s): M0026E Greater London Authority a. Summary of Representation In support of the proposed text which includes a cross reference to the London Plan Policy 3A.4 which requires all new housing to be built to Lifetime Homes standards. b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE - Support noted. GYPSIES AND TRAVELLING SHOW PEOPLE FM4.13 Modification: M4.43 Paragraph 4.30 Response Ref: Respondent (s): M0031B Government Office for London a. Summary of Representation There are significant levels of unmet need for Gypsy and Traveller site provision in the borough which should be addressed. b. Suggested Rewording The site provision should be addressed through site allocations in Development Plan Documents. c. Officer Comment The text reflects the Inspector’s recommendation. However the GOL point warrants further investigation. This will be undertaken as part of the work programme in preparing a DPD as part of the Local Development Framework for the borough. d. Officer Recommendation NO CHANGE – but include site allocation as part of the local Development Framework preparation (see FM4.3.c above). HOUSING DESIGN FM4.14 Modification: M4.44 Policy H6 Response Ref: Respondent (s): M0029A M0030B M0031D M0036D M0039B Mr J Read Asprey Homes Government Office For London Taylor Woodrow Crest Nicholson a. Summary of Representations In general the objections relate to the Council’s failure to modify the Policy in accordance with the Inspector’s recommendation with particular objection to Criterion (i) of the Policy which refers to density ranges as set out in policy H7. The objections also relate to the unlikely meeting of the Borough’s future housing needs. b. Suggested Rewording Modify Criterion (i) to refer to the density Location and parking matrix of the London Plan. c. Officer Comment The text in criterion (i) reflects the decision of the Council following the Public Inquiry and the meeting of the Development Control Committee on the 30th August 2005. However, GOL objection M0031D reiterates that the UDP should meet the requirements of national guidance and be in general conformity with the density standards of the London Plan. Without general compliance will almost certainly result in the Council being ‘directed’ by the Secretary of State to modify the Policy as indicated below (see also covering report paragraphs 3.12 and 3.13). d. Officer Recommendation FURTHER MODIFICATION - Amend Criterion (i) of Policy H6 to read: “(i) The development complies with the density ranges set out in the table in Policy H7 density / location matrix at Table 4.2 below. Insert after criterion (vii): Table 4.2 Density / location matrix (habitable rooms and dwellings per hectare) Predominant housing type Detached and linked houses Terraced houses & flats Mostly flats Location Accessibility Index Setting Sites within 10 mins walking distance of a town centre 6 to 4 Central 650 – 1100 hr/ha 240 –435 u/ha Urban 200 – 450 hr/ha 55 – 175 u /ha 450 –700 hr/h 165 –275 u/ha Suburban 200 – 300 hr/ha 50 – 110 u/ha 250- 350 hr/ha 80 – 120 u/ha Sites along transport corridors & sites close to the town centre 3 to 2 Urban 200 – 300 hr /ha 50 – 110 u/ha 300 – 450 hr/ha 100 –150 u/ha Suburban 150 – 200 hr/ha 30 – 65 u/ ha 200 – 250 hr/ ha 50 – 80 u /ha Currently remote sites 2 to 1 Suburban 150 – 200 hr/ha 30- 50 u/ha hr/ha – Habitable rooms per hectare, u/ha – Units per hectare” Consequential amendments i) Rename the policy section: HOUSING DENSITY AND DESIGN. ii) In Policy H1 (vi) – amend reference to Policy H7 (see FM4.6.d above) iii) In Paragraph 4.34 – delete to reference to Policy H7 (see also FM4.17 below) iv) In Paragraph 4.36 – amend 4th sentence to read: “Lower residential densities that that outlined in Policy H7 Table 4.2 will usually be required…” v) Paragraphs 4.17 and 4.23 – replace reference to Policy H7 with Policy H6 vi) In cross-reference boxes - delete references to Policy H7. FM4.15 Modification: M4.4 Policy H6 Response Ref: Respondent (s): M0032AH Mr N Goy a. Summary of Representations A typographic error in criterion (vi). b. Suggested Rewording “…priority to pedestrians and cyclists…” c. Officer Comment Agreed d. Officer Recommendation NON-MATERIAL CHANGE – amend criterion (vi) as indicated in b. above. FM4.16 Modification: M4.47 Paragraph 4.33 Response Ref: Respondent (s): M0036E Taylor Woodrow a. Summary of Representations Support for the adoption of the Inspector’s recommendation to reword the fourth sentence of paragraph 4.33. b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE - Support noted FM4.17 Modification: M4.48 Paragraph 4.34 Response Ref: Respondent (s): M0036F Taylor Woodrow a. Summary of Representations Objection to the Council’s failure to amend paragraph 4.34 in accordance with the Inspector’s recommendation to delete the reference to Policy H7 in the last sentence. b. Suggested Rewording Delete the reference to Policy H7. c. Officer Comment Reference to Policy H7 is deleted as a consequence of the modification to Policy H6 (see FM4.14 above). d. Officer Recommendation CONSEQUENTIAL CHANGE – Delete the words (see Policy H7 on residential densities below) from the last sentence. FM4.18 Modification: M4.49 Paragraph 4.35 Response Ref: Respondent (s): M0032E Mr N Goy a. Summary of Representations In support of the Council’s retention of the explanatory text resisting ‘tandem housing development’. b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE – Support noted. FM4.19 Modification: M4.50 Paragraph 4.36 Response Ref: Respondent (s): M0032F Mr N Goy a. Summary of Representations In support of the Council’s retention of the explanatory text resisting ‘backland housing development’. b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE – Support noted. HOUSING DENSITY FM4.20 Modification: M4.54 Policy H7 Response Ref: Respondent (s): M0029B M0030C M0031E M0035B M0036G M0039C M0026F Mr J Read Asprey Homes Government Office for London Legal and General Assurance Society Ltd. Taylor Woodrow Crest Nicholson Greater London Authority a. Summary of Representations In general the representations are in objection to the retention of Policy H7, contrary to the Inspector’s recommendation, with particular objection to the non conformity with the London Plan, the undersupply of housing and the failure to allocate additional sites for housing. An objection is also raised to the deletion of the word “minimum” from the text and table. b. Suggested Rewording Policy H7 should be either deleted and replaced by reference to the density location and parking matrix in the London Plan (Table 4B.1) or modified to place a greater emphasis upon and support for higher densities. c. Officer Comment As a consequence of amendment to Policy H6 to incorporate the London Plan density matrix, Policy H7 is no longer required and can be deleted (see FM4.14 above). d. Officer Recommendation FURTHER MODIFICATION Delete Policy H7 Consequential amendments i) Merge paragraph 4.40 into paragraph 4.31 to read: “Government advice promotes the efficient use of previously-developed land (PPG3 para 57), both to help meet housing requirements and to achieve more sustainable patterns of development. Good design and layout help to make best use of previously-developed land, as well as improving the quality and attractiveness of residential areas (PPG3 para 54). This is the basis for the concept of sustainable residential quality (SRQ) which links the need to build more efficiently while also improving quality. Often this will be at a greater intensity than has historically occurred. In particular, more intensive development may be sought in town centres and other places with good public transport accessibility (para 58).” ii) Delete paragraphs 4.41, 4.42 and 4.43 iii) Incorporate paragraphs 4.44 and 4.45 as 4.34a and 4.34b. FM4.21 Modification: M4.54 Policy H7 Response Ref: Respondent (s): M0032G Mr N Goy a. Summary of Representations In support of the Council’s retention of Policy H7. b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation Support noted. But, see FM4.20.d above. FM4.22 Modifications: M4.55, M4.56, M4.57, M4.58, M4.59, M4.60 Policy H7 and Paragraphs 4.40-4.45 Response Ref: Respondent (s): M0036G Taylor Woodrow a. Summary of Representations In objection to the retention of Policy H7 and the supporting paragraphs 4.40-4.45 with particular regard to the non-conformity with the London Plan. b. Suggested Rewording Deletion of Policy H7 and Paragraphs 4.40-4.45 and replace with reference to the ‘Density Location and Parking Matrix’ (Table 4B.1) of the London Plan. c. Officer Comment See FM4.20.c above d. Officer Recommendation See recommendation FM4.20.d above. Chapter 5: Transport LOCAL CONSIDERATIONS FM5.1 Modification: M5.16 Paragraph 5.9 Response Ref: Respondent: M0016A Transport for London a. Summary of Representation TfL note, but make no comment with regard to, the Council’s compliance with the Inspectors recommendation not to modify the text by introducing reference to the Tramlink extension to Crystal Palace. b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE TRANSPORT DEMAND FM5.2 Modification: M5.22 Paragraph 5.13 Response Ref: Respondent: M0029C Mr Jonathan Read a. Summary of Representation The modification incorporates the additional sentence as recommended by the Inspector, however, it neglects to replace “shows” with “indicates” as suggested in the Pre-Inquiry Changes and recommended by the Inspector. Additionally it is suggested that “showing” should be replaced by “indicating”. b. Suggested Rewording Replace “shows” with “indicates” and “showing” with “indicating”. c. Officer Comment The PIC was omitted in error. It would also be consistent to replace “showing” with “indicating”. Suggested changes agreed for reasons of clarity. d. Officer Recommendation NON-MATERIAL CHANGE – Amend Paragraph 5.13 to read: “The accessibility levels are calculated using the Transport for London PTAL Calculator. Map [5.1] shows indicates levels of accessibility, with level 1 showing indicating least accessible locations…” PARKING FM5.3 Modification: M5.29 Policy T3 Response Ref: Respondent: M0035C Legal & General Assurance Society Ltd (represented by Burnett Planning & Development Ltd) a. Summary of Representation The reference to “other measures to minimise the need for parking” does not make sense in the context of justifying exceeding the maximum parking standards. b. Suggested Rewording This should be explained or deleted. c. Officer Comment The modification is made in accordance with the Inspector’s recommendation for the reasons set out in the Schedule of Proposed Modifications. d. Officer Recommendation NO CHANGE FM5.4 Modification: M5.33 Paragraph 5.22 Response Ref: Respondent: M0035D Legal & General Assurance Society Ltd (represented by Burnett Planning & Development Ltd) a. Summary of Representation The explanatory text does not go far enough in reflecting the London Plan, specifically with regard to car-free housing b. Suggested Rewording “The London Plan sets out maximum parking standards for residential and non-residential developments. The Council has adopted these standards. The Council will particularly support reduced car parking provision in areas of good transport accessibility such as Bromley town centre which has a PTAL rating of 6A. In applying the standards to residential developments the Council recognises that an element of car-free housing should be included in Bromley town centre given its accessibility.” c. Officer Comment As recommended by the Inspector the modified paragraph takes account of the London Plan and reflects the decision of the Council following the Public Inquiry. There is no reason to highlight Bromley town centre specifically. d. Officer Recommendation NO CHANGE UNMADE ROADS / UNADOPTED HIGHWAYS FM5.5 Modification 5.72 Policy T17 Response Ref: Respondent: M0032I Mr N Goy a. Summary of Representation In support of the Council’s decision not to accept the Inspector’s recommendation to delete the policy relating to unmade roads. b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE - support noted SERVICING OF PREMISES FM5.6 Modification 5.82 Policy T21 Response Ref: Respondent: M0032J Mr N Goy a. Summary of Representation In support of the Council’s decision not to accept the Inspector’s recommendation to delete the policy relating to rear servicing. b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE - support noted Chapter 6: Conservation and Built Environment DESIGN OF NEW DEVELOPMENT FM6.1 Modification: M6.14 Policy BE1 Response Ref: Respondent (s): M0032K Mr N Goy a. Summary of Representation A) Delete “..imaginative and “ from criteria (i). This would preclude development that would harmonise with existing character of a residential road; fitting in with existing houses might be deemed unimaginative. B) Reinstate “where appropriate” caveat for suitable access for people with impaired mobility. Without this all residential development would require access ramps. b. Suggested Rewording A) “(i) Development should be imaginative and attractive to look at” B) “(vii) Where appropriate, suitable access and facilities should be provided for people with impaired mobility…” C) Drafting comment – Remove capitals at beginning of clauses and add ‘and’ before the last clause. c. Officer Comment The reworded policy accords with the Inspector’s recommendation as set out in the Proposed Modifications. Policy H6 covers housing design matters. Consideration will be given to removing capitals at the beginning of clauses throughout the Plan at reprinting stage. d. Officer Recommendation NO CHANGE MIXED-USE DEVELOPMENTS FM6.2 Modification: M6.20 New Policy BE1A Response Ref: Respondent (s): M0035E Legal and General Assurance Society Limited a. Summary of Representation National guidance refers to the need to promote mixed-use development where it is appropriate, but not insist on it. The reference to “expect” should be amended to “encourage” so to reflect that a more balanced judgement will be used in each case rather than a rigid policy requirement. The Policy should interpret the proper context for mixed-use developments as set out in the London Plan. Criteria (iii) should clarify that over–dominance may not be harmful and that the over dominance will be considered with reference to the wider area and not solely the development site. The Policy requires an additional criterion to consider the need for the type of use proposed. b. Suggested Rewording New Policy BE1A The council will encourage proposals, in appropriate cases, to incorporate a mix of land uses. In considering when to promote a mix of uses the Council will have due regard to: (i) land use needs and priorities (ii) the character and diversity of the surrounding area (iii) the scale and nature of the proposed development; and (iv) whether the extent of the proposals would demonstrably lead to a harmful over- dominance of a single use in the area within which the development is located c. Officer Comment The Inspector supported the wording of the Policy as published and recommended no change other than its location within the Plan. d. Officer Recommendation NO CHANGE FM6.3 Modification: M6.21 Paragraph 6.13a Response Ref: Respondent (s): M0035E Legal and General Assurance Society Limited a. Summary of Representation The supporting paragraph should emphasise Policy BE1A in that a single use added to an area can also add to the variety and diversity. It is not necessary to require more than one use in every development. b. Suggested Rewording “…The incorporation of an element of mixed use, such as residential use, into business and commercial development schemes for businesses and commercial uses and the introduction of new single uses into an area such as residential use in town centres, can add variety and diversity…” c. Officer Comment The text as published reflects the Council’s decision following the Public Inquiry for the reasons agreed by Development Control Committee on 27 July 2005 and set out in the Proposed Modifications. The paragraph suitably explains the policy as accepted by the Inspector. d. Officer Recommendation NO CHANGE FM6.4 Modification: M6.22 Paragraph 6.13b Response Ref: Respondent (s): M0035E Legal and General Assurance Society Limited a. Summary of Representation The paragraph goes too far in setting secondary use test for single use development. The emphasis should be on encouragement and promotion. b. Suggested Rewording “To ensure a balanced mix of uses, planning permission will be resisted where failure to incorporate a secondary use would have a demonstrably harmful effect upon the character, diversity or vitality of the area. Applicants proposing single uses on sites considered suitable for mixed uses, as defined on the Proposals Map and designated for mixed use schemes, will need to justify should demonstrate why they believe a mixed use development is not needed and/or achievable by reference to land use planning needs, physical constraints, commercial viability or in terms of the site’s single use’s contribution to meeting land use planning needs and its contribution to the overall mix of uses within the area.” c. Officer Comment The text as published reflects the Council’s decision following the Public Inquiry for the reasons agreed by Development Control Committee on 27 July 2005 and set out in the Proposed Modifications. The paragraph suitably explains the policy as accepted by the Inspector. d. Officer Recommendation NO CHANGE RAILINGS, BOUNDARY WALLS AND OTHER MEANS OF ENCLOSURE FM6.5 Modification: M6.35 Policy BE6 Response Ref: Respondent (s): M0035L Mr N Goy a. Summary of Representation Supports the Council’s retention of the policy. b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE – Support noted DEMOLITION OF LISTED BUILDINGS FM6.6 Modification: M6.39 New Policy BE7A Response Ref: Respondent (s): M0035L Mr N Goy a. Summary of Representation Error in drafting clauses. Clause (iv) should be a supporting paragraph. b. Suggested Rewording Policy BE7A (Demolition of Listed Building) Applications for planning permission… (iii) there will be substantial planning benefits for the community from redevelopment, which would decisively outweigh the loss from the resulting demolition. (iv) A condition will be imposed to ensure that the demolition will not take place until a contract has been let for the carrying out of the development that necessitates the demolition A condition will be imposed to ensure that the demolition will not take place until a contract has been let for the carrying out of the development that necessitates the demolition c. Officer Comment Suggested change agreed; clause (iv) was inserted in error d. Officer Recommendation NON-MATERIAL CHANGE – Amend the policy as indicated in b. above HIGH BUILDINGS AND THE SKY LINE FM6.7 Modification: M6.68 Policy BE13 Response Ref: Respondent (s): M0026G Greater London Authority M0035F Legal and General Assurance Society Limited a. Summary of Representation The policy should not stray in to issues of use of a tall building. Clause (iii) should be deleted or cross reference made to new Policy BE1A and there should be clarification of the fact that the mixed use policy objectives can be satisfied by a single use development that provides an enhanced mix of uses in the area as a whole. (Legal and General Assurance Society Limited) The policy criteria should more closely reflect those of the London Plan. It is not clear what is meant by “mixed use at effective densities”. (Greater London Authority) b. Suggested Rewording Delete clause (iii) or cross-refer to Policy BE1A c. Officer Comment The text as published was suggested by the Inspector and reflects the Council’s decision following the Public Inquiry for the reasons agreed by Development Control Committee on 28 July 2005. The matter of single –use schemes in the context of Policy BE1A was considered at the Public Inquiry, however no modification was recommended by the Inspector to the Policy, proposed as a Pre-inquiry change. “Mixed use at effective densities” reflects the desire for mixed use having regard to the scale of development. By virtue of the scale of high building developments, the mix of uses proposed will be relevant to their determination. A cross-reference to the new Policy BE1A should be inserted into the cross-reference box following para 6.44. d. Officer Recommendation NON-MATERIAL CHANGE – add cross-reference as indicated in c. above FM6.8 Modification: M6.69 Paragraph 6.42 Response Ref: Respondent (s): M0026G Greater London Authority a. Summary of Representation The text adopts a restrictive approach but without clearly explaining what aspects of the local character could be affected by tall buildings and why. b. Suggested Rewording N/A c. Officer Comment The text as published was recommended by the Inspector and reflects the more accepting tenor of Policy BE13. Unlike many other London Boroughs there are few buildings in Bromley that significantly exceed the general height of buildings and therefore the introduction of additional high buildings will evidently affect the skyline and local character, and will be required to be a positive enhancement. The impact on local character does not require further clarification. e. Officer Recommendation NO CHANGE SHOPFRONTS FM6.9 Modification: M6.74 Policy BE15 Response Ref: Respondent (s): M0032N Mr N Goy a. Summary of Representation Supports retention of the policy b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE – Support Noted ADVERTISEMENTS AND HOARDINGS FM6.10 Modification: M6.84 Policy BE17 Response Ref: Respondent (s): M0032O Mr N Goy a. Summary of Representation Supports retention of Policy BE17. Deletion of Policy BE18 has caused the FIC to add Urban Open Space to the list of designated areas to be omitted. This should be added to BE17 Remove “should” from the beginning of clauses as this is already at the end of the opening sentence. b. Suggested Rewording Advertisements, hoardings and signs should:… (iii) should generally not be located in residential areas, the Green Belt, and Metropolitan Open Land and Urban Open Space; and c. Officer Comment Changes agreed d. Officer Recommendation Non-Material Change - Added text as shown in b. above and delete “should” from the beginning of clause ii, iii, iv and v. SATELLITE DISHES FM6.11 Modification: M6.97 Policy BE20 Response Ref: Respondent (s): M0032O Mr N Goy a. Summary of Representation Objects to the deletion of policy text without adding to explanatory text. b. Suggested Rewording Add new paragraph after Policy: “Satellite dishes on listed buildings are controlled under Sections 16(2) and 66(1) of Listed Buildings Act” c. Officer Comment The text reflects the recommendation of the Inspector for the reasons set out in the Proposed Modifications. The requirements of the Listed Buildings Act do not need to be quoted. d. Officer Recommendation NO CHANGE Chapter 7: Natural Environment FM7.1 Modification: M7.10 Policy NE1 Response Ref: Respondent (s): M0032AI Mr N.Goy a. Summary of Representation Numbering error ‘(ii)’ appears twice b. Suggested Rewording delete numbering c. Officer Comment Typographical error noted, reword criteria (ii) to read: (ii) (ii) the value and interests of … d. Officer Recommendation NON-MATERIALCHANGE – Amend as indicated in c. above Chapter 8: Green Belt & Open Space OBJECTIVES FM8.1 Modification: M8.1 Objective 1 Response Ref: Respondent: M0032Q Mr N Goy a. Summary of Representation The retention of the reference to the Green Chain in this objective is welcomed b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE – Support noted STRATEGIC CONSIDERATIONS FM8.2 Modification: M8.11 Paragraph 8.6 Response Ref: Respondent: M0037A Crown Golf (Represented by Terence O’Rourke Ltd) a. Summary of Representation Whilst supporting the modification in principal, the respondent wishes to see the inclusion of additional text. They consider it important for sports facilities located within the Green Belt or Metropolitan Open Land to be allowed the opportunity to consolidate and improve services provided on site, if such action enhances the area and benefits surrounding communities. b. Suggested Rewording Insert an additional sentence to the paragraph: “Such facilities should be allowed to consolidate and improve services provided on site, if such action will enhance the area and benefit surrounding communities.” c. Officer Comment The modification is updating the Strategic Considerations section by quoting from the London Plan. The suggested additional wording is therefore inappropriate. d. Officer Recommendation NO CHANGE GREEN BELT FM8.3 Modification: M8.18 Policy G1 Response Ref: Respondent: M0032AJ Mr N. Goy M0037A Crown Golf (Represented by Terence O’Rourke Ltd) a. Summary of Representation Mr. Goy: 1. Spelling, fourth line - inappropriateness 2. It would help better identify the clauses if the second set of clauses in this now very long policy were labelled, say a-f. Otherwise we have two lots of overlapping Roman numeral-ed clauses which will be a source of confusion. 3. The second clause (iv) should remain referring to ‘building … is’ and not the plural, as the rest of the policy refers to a ‘building’ in the singular form. 4. Spelling, second clause (vi) – replace ‘countyrside’ with ‘countryside’ Crown Golf: Support the modifications b. Suggested Rewording As set out in the summary of Mr. Goy’s representation in a above. c. Officer Comment The spelling and grammatical errors 1, 3 and 4 are noted and the appropriate corrections should be made. In the case of 2, the potential for confusion is noted and appropriate changes to the numbering of these clauses should also be considered. Crown Golf’s support for the modifications is noted. d. Officer Recommendation NON MATERIAL CHANGE - Correct the spelling and grammatical errors identified and re- number the second set of clauses relating to the re-use of a building as a continuation of the roman numeral sequence, i.e. (v) to (x). METROPOLITAN OPEN LAND FM8.4 Modification: M8.26 Policy G2 Response Ref: Respondent: M0041A Mottingham Residents’ Association a. Summary of Representation Support the wording of the policy as drafted by the Inspector, but object to the wording in the Modification, which appears to be the result of a typographical error as the Council resolved to accept the exact wording as put forward by the inspector. b. Suggested Rewording The paragraph beginning “The material changes of use of land ……..” , should read: “The material change of use of land or engineering and other operations within MOL will be inappropriate unless it they maintain the openness and do not conflict with the purposes of including land in MOL. The re-use of a building in MOL will be inappropriate unless it meets all of the following criteria:” c. Officer Comment Typographical errors noted d. Officer Recommendation NON-MATERIAL CHANGE - Correct the wording of the policy as set out in b. above. For clarification and consistency, re-number second set of clauses (vi) to (xi) (see reasoning in M8.18 above) NATIONAL SPORTS CENTRE MAJOR DEVELOPED SITE FM8.5 Modification: M8.33 paragraph 8.18d (previously 8.18a) Response Ref: Respondent: M0032R Mr N. Goy a. Summary of Representation Delete either ‘Brief’ or ‘framework’ from the new text. The Development Control Committee meeting of 13th December 2005 was informed that the LDA’s ‘planning framework’ was a non-statutory document. Should it be in the UDP? Also, the modification-document explanatory text here, and elsewhere in the document, states that the Park is ‘now the responsibility of the GLA’. This is not true. The GLA has an option to lease the Park, which it may exercise by March 2009. The Park is the responsibility of Bromley Council. There is a similar option to lease the National Sports Centre, which must be exercised by March 2006. b. Suggested Rewording Delete either the word ‘Brief’ or ‘framework’ c. Officer Comment The word ‘Brief’ in the Modification should have been included in the text to be deleted; this is a typographical error. There is no reason, legal or otherwise, why ‘non-statutory’ documents should not be referred to in a UDP. The objection to the reference to the present and future ownership of the Park and NSC is ‘not duly made’ as it refers to the reasons for the modifications, which is not part of the UDP. d. Officer Recommendation NON-MATERIAL CHANGE - Delete the word ‘Brief’ in the final sentence of the paragraph. METROPOLITAN OPEN LAND FM8.6 Modification: M8.51 Policy G8 Response Ref: Respondent: M0032AK Mr N. Goy a. Summary of Representation Typographical error, the word ‘the’ in the third line of the modified policy should be part of the text which has been deleted. b. Suggested Rewording “…if it is the detrimental …” c. Officer Comment Typographical error noted. d. Officer Recommendation NON-MATERIAL CHANGE - Amend the wording of the Policy as set out in b. above. URBAN OPEN SPACE FM8.7 Modification: M8.60 Paragraph 8.37 Response Ref: Respondent: M0026H Greater London Authority a. Summary of Representation Policy G10 makes reference to both residential and indoor sports as being inappropriate. This accords with the London Plan, however, the text of this paragraph only refers to residential as being unacceptable. In order to be consistent and for the avoidance of doubt, ‘indoor sports development’ should be included in the supporting text along with residential as being inappropriate. b. Suggested Rewording N/A c. Officer Comment The additional wording should be included in the paragraph for consistency. d. Officer Recommendation NON-MATERIAL CHANGE - Amend paragraph 8.37 as follows: The primary purpose of this policy is to protect the open character of these smaller open spaces. Clause (i) of the policy recognises that additions or extensions may be necessary, provided that they are related to and essential for the function of the existing main use. In this context, residential and indoor sports development will not be regarded as an acceptable related uses. Chapter 9: Recreation, Leisure and Tourism OUTDOOR RECREATION AND LEISURE FM9.1 Modification: M9.14 Policy L1 Response Ref: Respondent (s): M0032AL Mr N Goy M0026I Greater London Authority a. Summary of Representation The first sentence should be singular to comply with the clauses which are singular. For the avoidance of doubt the policy should refer to ‘outdoor’ recreation in the first sentence. Clause (iii) is loosely worded and should better reflect the terminology of the London Plan. b. Suggested Rewording “A pProposals for outdoor recreational uses on land designated…provided that: (iii) The activities associated with ancillary to the use or development proposed are low-key small scale and do not adversely affect…” c. Officer Comment Suggested changes agreed. d. Officer Recommendation NON-MATERIAL CHANGE – Amend the policy as indicated in b. above FM9.2 Modification: M9.14 Policy L1 Response Ref: Respondent (s): M0037C Crown Golf (Represented by Terence O’Rourke Ltd) a. Summary of Representation The reworded policy is too restrictive towards ‘open-air recreational uses’ which are identified in Policy G1 as appropriate ‘exceptional’ developments. b. Suggested Rewording Revert to the 2DD wording which stated that the Council will “support and encourage the development open-air recreational uses for the enjoyment of the Green Belt” c. Officer Comment The modification accords with the Inspector’s recommendation to reword the policy for the reasons set out in the Proposed Modifications. d. Officer Recommendation NO CHANGE Chapter 11: Town Centres and Shopping RETAIL AND LEISURE DEVELOPMENT FM11.1 Modification: M11.26 Policy S6 Response Ref: Respondent (s): M0031F Government Office for London a. Summary of Representation Since the Inquiry PPG6 has been replaced with PPS6. In terms for the sequential approach, in looking at business models, alongside scale, format and car parking, the local planning authority should take account of the scope for disaggregation. A reference to this should be included in the policy b. Suggested Rewording Insert wording into criterion starting “the applicant can demonstrate...” to the effect that the applicant has taken in to account the scope for disaggregation. c. Officer Comment Agree the change to bring policy inline with Government guidance. d. Officer Recommendation NON-MATERIAL CHANGE - Amend third criterion to read: “(iii) the applicant can demonstrate that they have been flexible about the format, scale, design,and car park provision and the scope for disaggreation in the sequential search for sites.” Chapter 12: Biggin Hill Airport & Environs OBJECTIVES FM12.1 Modification: M12.1 Objective 1 Response Ref: Respondent (s): M0001A Crofton Residents’ Association M0003A Cudham Residents’ Association M0004A Flightpath M0005A Mr C.J.Cadman M0006A Holwood Park Avenue Residents’ Association Ltd M0007A Chislehurst Society M0010A Mr M.J. Flynn M0011A Woldingham Parish Council M0012A Farnborough Park Estate Ltd M0015A Bromley Friends of the Earth M0017A Petts Wood & District Residents’ M0019A Bromley Common Action Group M0020A Keston Park (1975) Ltd M0021A Grange Residents’ Association M0022A Hayes Village Association M0033A Leesons Residents’ Association M0038A Mrs N.D.Lawrence a. Summary of Representation Support the proposed amendment to the Objective b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE – support noted FM12.2 Modification: M12.1 Objective 1 Response Ref: Respondent (s): M0025A Biggin Hill Airport Ltd a. Summary of Representation The partial acceptance of the Inspector’s recommendation fails to recognise the economic importance of the Airport and nearby business area to the local economy and fails to ensure its long-term sustainable future. b. Suggested Rewording Objective as proposed by the Inspector amended to read: “To seek to ensure a sustainable long- term future…..” c. Officer Comment The Inspector’s recommendation was accepted in part only for the reason given in the Proposed Modifications; the proposed amendment does not alter the Council’s reasoning. d. Officer Recommendation NO CHANGE FM12.3 Modification: M12.2 Objective 2 Response Ref: Respondent (s): M0001B – M0038B See list in FM12.1 above a. Summary of Representation Object to the words “and regional” being added to the Objective. The draft Master Plan refers to the airport as a ‘local’ airport. b. Suggested Rewording Delete the words “and regional” c. Officer Comment Notwithstanding the subsequent definition in the draft Master Plan, business users from the London region or beyond use the Airport. This is recognised in the Government White paper and accepted by the Inspector. d. Officer Recommendation NO CHANGE FM12.4 Modification: M12.3 Objective 3 Response Ref: Respondent (s): M0001C – M0038C See list in FM12.1 above a. Summary of Representation Support retention of Objective 3 b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE – support noted FM12.5 Modification: M12.3 Objective 3 Response Ref: Respondent (s): M0025B Biggin Hill Airport Ltd a. Summary of Representation The Council has not given sound reasons for rejecting the Inspector’s recommendation. The UDP is a statement of land use planning policies and not a vehicle for a reminder of the operational terms of the lease. That is a matter for the Council as a landowner rather than a planning authority and no evidence was submitted to the UDP Inquiry about the land use implications of the lease. b. Suggested Rewording N/A c. Officer Comment The text as published reflects the Council’s decision following the Public Inquiry for the reasons agreed by Development Control Committee on 28 July 2005 and set out in the Proposed Modifications. New evidence is not required to justify the decision; the land-use implications of the lease are self-evident and are the implicit basis of some of the policies in Chapter 12. d. Officer Recommendation NO CHANGE STRATEGIC CONSIDERATIONS FM12.6 Modification: M12.5 Paragraph 12.2 Response Ref: Respondent (s): M0001D – M0038D See list in FM12.1 above a. Summary of Representation Support the update of the paragraph to accord with the Government White Paper b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE – support noted LOCAL CONSIDERATIONS FM12.7 Modification: M12.9 Paragraph 12.6 Response Ref: Respondent (s): M0001E – M0038E See list in FM12.1 above a. Summary of Representation Support the addition of the extra text in paragraph 12.6 b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE – support noted FM12.8 Modification M12.9 Paragraph 12.6 Response Ref: Respondent (s): M0018A Mr S.A. Brown a. Summary of Representation BHAL is trying to alter the lease and undertaking operations contrary to the lease requirements as set out in paragraph 12.6 b. Suggested Rewording N/A c. Officer Comment The day-to-day operation of the operating criteria of the lease is not a matter for the UDP d. Officer Recommendation NO CHANGE FM12.9 Modification: M12.10 Paragraph 12.7 Response Ref: Respondent (s): M0025C Biggin Hill Airport Ltd a. Summary of Representation There is no evidence to support the assertion that references in the London Plan are not directly relevant to Biggin Hill which is incontrovertibly an airport in the South East and must therefore be covered by the Mayor’s intention to maximise the benefits of the inter-relationships between such airports and London. b. Suggested Rewording Incorporate the Inspector’s recommended modification in paragraph 12.3 (rather than paragraph 12.7) c. Officer Comment Biggin Hill Airport is not mentioned by name in the text or marked on any maps in the London Plan. A reference quoting from the appropriate policy of the London Plan (Policy 3C.6) is added to paragraph 12.3 (see Modification M12.6). d. Officer Recommendation NO CHANGE LOCAL ENVIRONMENT FM12.10 Modification: M12.13 Policy BH1 Response Ref: Respondent (s): M0001F – M0038F See list in FM12.1 above a. Summary of Representation Support the retention of Policy BH1 b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE – support noted FM12.11 Modification: M12.13 Policy BH1 Response Ref: Respondent (s): M0025D Biggin Hill Airport Ltd a. Summary of Representation Policy BH1 is intended to be the main development control policy for all development proposals at or relating to BHA. As such, if it is to be retained, national policy requires that it must clearly state that a balance will be drawn between the economic benefits of such development and its environmental impacts. The absence of any recognition of the need for such a balance merely emphasises the Inspector’s conclusion that the UDP offers only a half-hearted recognition of the airport, and that the policy as proposed appears to suggest that consideration of need or potential benefits would be ignored in the quest for minimising environmental harm. b. Suggested Rewording Retain the Inspector’s recommended modification to Policy BH1. c. Officer Comment The text as published reflects the Council’s decision following the Public Inquiry, for the reasons accepted by the Development Control Committee on 28 July 2005 and set out in the Proposed Modifications. The retained policy supports Objective 1 and together with other policies which foster development provides a comprehensive framework for the airport. d. Officer recommendation NO CHANGE FM12.12 Modification: M12.14 Paragraph 12.10 Response Ref: Respondent (s): M0001G – M0038G See list in FM12.1 above a. Summary of Representation Support the retention of paragraph 12.10 b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE – support noted NEW DEVELOPMENT FM12.13 Modification: M12.17 Paragraph 12.12 Response Ref: Respondent (s): M0001H – M0038H See list in FM12.1 above a. Summary of Representation Support the deletion of Area 4 from the MDS b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE – support noted FORMER RAF MARRIED QUARTERS (AREA 2) FM12.14 Modification: M12.25 Paragraph 12.16 Response Ref: Respondent (s): M0001I – M0038I See list in FM12.1 above a. Summary of Representation Support the deletion of the sentence which refers to the transfer of footprint to Area 1 of MDS b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE – support noted EAST CAMP (AREA 3) FM12.15 Modification M12.26 Policy BH6 Response Ref: Respondent (s): M0025E Biggin Hill Airport Ltd a. Summary of Representation The Inspector’s recommendation is simple and direct and takes into account the guidance given in Annex C to PPG2. No reason is given for the rejection of this recommendation, other than the reiteration of the Council’s approach which was not accepted. The modification introduces a test which is not part of PPG2. This would cause confusion and be the subject of dispute at any future local inquiry b. Suggested Rewording Accept the Inspector’s rewording. c. Officer Comment The text as published reflects the Council’s decision following the Public Inquiry for the reasons agreed by Development Control Committee on 28 July 2005 and set out in the Proposed Modifications. The text reflects guidance in paragraphs C3 and C4 of Annex C. d. Officer Recommendation NO CHANGE RESIDUAL UNDEVELOPED LAND (AREA 4) FM12.16 Modification: M12.28 Policy BH7 Response Ref: Respondent (s): M0001J – M0038J See list in FM12.1 above a. Summary of Representation Support the deletion Policy BH7 and removal of Area 4 from the MDS b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE – support noted FM12.17 Modification: M12.29 Paragraph 12.18 Response Ref: Respondent (s): M0001K – M0038K See list in FM12.1 above a. Summary of Representation Support the deletion paragraph 12.18 since Policy BH7 is deleted b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE – support noted SAFETY FM12.18 Modification M12.31 Paragraphs 12.19, 12.19a, 12.19b (and Policy BH8) Response Ref: Respondent (s): M0025 Biggin Hill Airport Ltd a. Summary of Representation Although BHAL are not objecting to any of the proposed changes, this is on the understanding that the special consultation procedures referred to in the proposed paragraph 12.19a will be strictly observed by the Council in future. Failure to do so would be a breach of national policy and the UDP. The change to Policy BH8 is also acceptable. b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE Chapter 14: Environmental Resources SUSTAINABLE AND ENERGY EFFICIENT DEVELOPMENT FM14.1 Modification: M14.22 Policy ER5 Response Ref: Respondent (s): M0026K Greater London Authority a. Summary of Representation The London Plan Policy 4A.9 uses the term “wherever feasible” and not ‘viability’. Viability could be construed as relating to financial considerations only rather than both financial and technical issues. b. Suggested Rewording Replace viable with feasible c. Officer Comment The wording is consistent with the Inspector’s recommendation. However, the replacement of ‘viable’ with ‘feasible’ would ensure consistency with the London Plan. d. Officer Recommendation NON-MATERIAL CHANGE - Reword last sentence of Policy to read: “Where it is proposed not to include renewable energy generation, the applicant will be expected to demonstrate that the installation of such equipment is not feasible viable or appropriate because of the type of development, its location or design.” FM14.2 Modification: M14.22 Policy ER5 Response Ref: Respondent (s): M0032AM Mr N.Goy a. Summary of Representation A word is missing the in sentence: “All new development (new build or conversion) will be expected to either include or make suitable???????? for the following energy-efficiency measures:” b. Suggested Rewording N/A c. Officer Comment A word is not missing from the sentence, though the intention of Inspector’s wording could be clarified. d. Officer Recommendation NON-MATERIAL CHANGE – Amend Policy ER5 to read: “All new development …will be expected to either include or make suitable for be capable of accommodating the following energy-efficient measures:” FM14.3 Modification: M14.32 Paragraph 14.15 Response Ref: Respondent (s): M0032S Mr N.Goy a. Summary of Representation The modification seeks to negate the purpose of the paragraph from opposing renewable energy facilities on designated areas such as the Green Belt because of the adverse impact on the landscape, to allowing then under ‘very special circumstances’ quoting PPS22. Since mobile phones mats and floodlights have been successfully refused on visual impact grounds, a loophole should not be created to allow, for instance, wind turbines. b. Suggested Rewording Re-instate paragraph 14.15 of 2DD UDP c. Officer Comment The modification complies with guidance in PPS22, Para 13. It states that “when located in the green belt, elements of many renewable projects will comprise inappropriate development, which may impact on the openness of the Green Belt. Careful consideration will therefore need to be given to the visual impact of projects, and developers will need to demonstrate very special circumstances that clearly outweigh any harm by reason of inappropriateness and any other harm if projects are to proceed. Such very special circumstances may include the wider environmental benefits associated with increased production of energy from renewable sources.” d. Officer Recommendation NO CHANGE CONTROLLING DEVELOPMENT IN FLOOD RISK AREAS FM14.4 Modification: M14.55 Policy ER13 Response Ref: Respondent (s): M0032T Mr N.Goy a. Summary of Representation Current clause (i) alone is inadequate in protecting the number of people possible affected by flooding b. Suggested Rewording Add clause (iii) from second deposit draft as clause (i), namely: “In flood zones…new development or the intensification of existing development will not be permitted where it would: (i) increase the number of people or properties at risk from surface water flooding” c. Officer Comment The Inspector considered the same objection at the Public Inquiry and her recommended wording reflects the guidance in PPG25. The policy is concerned with all development and not just residential. d. Officer Recommendation NO CHANGE Chapter 15: Implementation PLANNING OBLIGATIONS FM15.1 Modification: M15.23 Policy IMP5 Response Ref: Respondent (s): M0036H Taylor Woodrow Development & Ravensbourne College (Represented by Star Planning & Development) a. Summary of Representation The objection is to the decision not to modify Policy IMP5 or the supporting text. b. Suggested Rewording Include the policy tests based on Circular 05/2005 within the supporting text. c. Officer Comment The decision not to modify the policy accords with the Inspector’s recommendation. Since there is no modification the objection is not duly made. The policy tests are included in the Council’s draft supplementary Planning Document on Planning Obligations, currently in preparation. d. Officer Recommendation NO CHANGE Chapter 16: Proposal Sites FM16.1 Modification: M16.1 Proposal Site 2- Quinetiq Premises, Golf Road Bromley Response Ref: Respondent (s): M0002A Mr Filby a. Summary of Representation Support for allocation of site for housing as site is already being developed. b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE – Support noted FM16.2 Modification: M16.4 Proposal Site 5a – Worsley Bridge Road Response Ref: Respondent (s): M0030D Asprey Homes a. Summary of Representation Site has been removed from MOL and allocated for housing in line with consultant’s advice. Other sites that were also suggested have been rejected. This is inconsistent, and insufficient reasoning has been given for this inconsistency. b. Suggested Rewording Include the four sites recommended for allocation by consultants in the Schedule of Proposals. c. Officer Comment The modification of the MOL boundary reflects the decision of the Council following consideration of the NLP consultants report by Development Control Committee on 30 August 2005 for the reasons set out in the Proposed modifications. d. Officer Recommendation NO CHANGE FM16.3 Modification: M16.5 Proposal Site 5b – Land Adjacent Clock House Station Response Ref: Respondent (s): M0032U Mr N.Goy M0040B Temple Homes a. Summary of Representation Objection to site being allocated for housing. The site would lack suitable amenity space and would be affected by noise and disturbance from the station. Emergency access to the site would be impinged. There is no need to allocate the site, as a planning application would be sufficient. There is no evidence that the site is deliverable. Temple homes suggest the Land at Cockmannings Lane, Orpington be added as a proposal site for housing. b. Suggested Rewording Delete Proposal 5b from the Schedule of Proposals c. Officer Comment The Clock House site was identified by the NLP consultants report as a sequentially preferable site for housing and as such is allocated for housing. The Inspector suggested allocating suitable sites, which would help meet the housing supply target. The Council accepted the NLP consultants report that the Cockmannings Lane Green Belt site was not considered suitable for housing. d. Officer Recommendation NO CHANGE FM16.4 Modification: M16.6 Proposal Site 5c - Ravensbourne College of Design and Communication Response Ref: Respondent (s): M0013V Ravensbourne College a. Summary of Representation Support the adoption the Inspector’s recommendation to remove the MOL allocation and include the site in the Schedule of Proposals. b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE – Support noted FM16.5 Modification: M16.12 Proposal Site 9 – Crystal Palace Park Response Ref: Respondent (s): M0032V Mr N.Goy a. Summary of Representation Supports the recommendation to retain the MOL designation b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE – Support noted FM16.6 Modification: M16.21 Proposal Site 18 - Churchill Theatre Response Ref: Respondent (s): M0032W Mr N.Goy a. Summary of Representation Supports the deletion of proposal site. b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE – Support noted 17: Appendices & Glossary APPENDIX II: PARKING STADARDS FM17.1 Modification 17.18 New Paragraph II.17 Response Ref: Respondent (s): M0035G Legal & General Assurance Society Ltd (represented by Burnett Planning & Development Ltd) a. Summary of Representation The parking standards are not prescribed exactly as in the London Plan Table A4.2. b. Suggested Rewording The “mostly flats” category should encourage less than 1 space per unit in areas of high public transport accessibility. The supporting text should also emphasise that: “Bromley town centre is the most accessible location in the Borough with a PTAL rating of 6A. It is a Central location having regard to the categories in the London Plan table 4B.1, and the Council will support an element of car-free housing in high density flatted developments in Bromley town centre” c. Officer Comment The revised table is in general conformity with the London Plan and reflects the decision of the Council following the Public Inquiry and the meeting of the Development Control Committee on the 30th August 2005. There is no reason to highlight Bromley town centre specifically, and the relevance of Table 4B.1 is already mentioned in the text. d. Officer Recommendation NO CHANGE APPENDIX III: CONSERVATION AREAS FM17.2 Modification M17.22 Paragraph III.4 Response Ref: Respondent (s): M0032X Mr N Goy a. Summary of Representation In addition to the modifications to the addresses already made in accordance with the Inspectors recommendation, all the Conservation Area and Article 4 address details should be reviewed and further amended for clarification. b. Suggested Rewording 6. Beckenham, St George’s, High St., Beckenham 14. Cator Rd, Penge 20. Copers Cope Road, Beckenham c. Officer Comment The proposed rewording aids clarification. It may also be appropriate to add 5. Beckenham Place Park, Beckenham 41. Shortlands Road, Bromley d. Officer Recommendation NON-MATERIAL CHANGE - Amend list as indicated above FM17.3 Modification M17.37 GLOSSARY Response Ref: Respondent (s): M0032AD Mr N Goy a. Summary of Representation A number of modifications quote PPS1 references to social inclusion, which should be referred to in the Glossary. b. Suggested Rewording Include definitions for “social inclusion”, “inclusive…development”, “inclusive design” and “inclusion” c. Officer Comment “Social Exclusion” is already defined in the Glossary. These terms are widely used and are understandable in the context of the paragraphs in which they appear. d. Officer Recommendation NO CHANGE 18: Proposals Map FM18.1 Modification: M18.1 Map of Strategic Views and Skyline Ridges Response Ref: Respondent: M0032Y Mr N Goy a. Summary of Representation The Inspector requested that Map 9.1 of the Adopted UDP be reinstated. Restore the important viewing arcs as per Adopted UDP map and use a map no less clear than the Adopted UDP map as background (e.g. colour and pixellation detracts). b. Suggested Changes As above c. Officer Comment The main elements of Map 9.1 in the adopted UDP have been accurately portrayed on the plan included in the Modifications document. The arcs will be included in the final version and the definition of the base map will be improved when the plan is re-printed. d. Officer Recommendation NO CHANGE FM18.2 Modification: M18.5 Bethlem Royal Hospital Major Developed Site Response Ref: Respondent (s): M0044A London & Maudsley NHS Trust (Represented by David Lock Associates Ltd) a. Summary of Representation Support the modification to show the Medium Secure Unit in the MDS. b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE – Support noted FM18.3 Modification: M18.17 Ravensbourne College (built site) – Removal of MOL designation and identification as a Major Developed Site Response Ref: Respondent (s): M0013B Ravensbourne College (Represented by GVA Grimley LLP) M0036I Taylor Woodrow (Represented by Star Planning & Development) a. Summary of Representation Both respondents support the modification b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE – Support noted FM18.4 Modification: M18.18 Ravensbourne College (woodland site) – Removal of MOL and Major Developed site designations and designation as Urban Open Space Response Ref: Respondent (s): M0013C Ravensbourne College (Represented by GVA Grimley LLP) M0036J Taylor Woodrow (Represented by Star Planning & Development) a. Summary of Representation Both respondents support the modification b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE – Support noted FM18.5 Modification: M18.20 Holy Trinity School, Plaistow Lane – Removal of MOL & Green Chain designations from built portion of the site. Response Ref: Respondent: M0008A Links Residents’ Association a. Summary of Representation There has been much development along Plaistow Lane already; a development on this site would be a step too far. b. Suggested Change Reinstate MOL designation c. Officer Comment The Council accepted the Inspector’s recommendation to modify the MOL boundary for the reasons agreed by the Development Control Committee on 30th August 2005. The potential, or otherwise, for development of the site has no bearing on the reason for its designation. The respondent also requested information regarding the protection of an ‘icehouse’ on an adjoining site, this does not relate to the modifications and has been dealt with separately. d. Officer Recommendation NO CHANGE FM18.6 Modification: M18.24 Land Adjacent to Pickhurst Green – Removal of UOS designation. Response Ref: Respondent: M0009A Mr & Mrs M Compton M0034A Mr & Mrs Russell a. Summary of Representation One of the respondents makes reference to letters which they wrote in connection with an enforcement case, and to an appeal decision concerning applications for residential development of the site in 2003. They maintain that the UOS designation has until now thwarted attempts to erect a dwelling on the site. b. Suggested Change Reinstate UOS designation c. Officer Comment The Council accepted the Inspector’s recommendation to modify the UOS boundary for the reasons agreed by the Development Control Committee on 28th July 2005. The Inspector was informed of the 2003 appeal decision at the Public Inquiry. d. Officer Recommendation NO CHANGE FM18.7 Modification: M18.28 Land Adjoining Clock House Station – Designation as Proposal site 5b. Response Ref: Respondent: M0032Z Mr N. Goy a. Summary of Representation See Modification M16.5 b. Suggested Change None c. Officer Comment See Modification M16.5 d. Officer Recommendation NO CHANGE FM18.8 Modification: M18.29 Ravensbourne College – Proposal Site 5c Response Ref: Respondent (s): M0013D Ravensbourne College (Represented by GVA Grimley LLP) M0036K Taylor Woodrow (Represented by Star Planning & Development) a. Summary of Representation Support the modification to include the site in the Schedule of Proposals b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE – Support noted FM18.9 Modification: M18.31 Crystal Palace – Deletion of Proposal Site 9 Response Ref: Respondent (s): M0026J Greater London Authority M0032AA Mr N. Goy a. Summary of Representation Support the modification b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE – Support noted FM18.10 Modification: M18.34 Churchill Theatre – Deletion of Proposal Site 18 Response Ref: Respondent (s): M0032AB Mr N. Goy a. Summary of Representation Support the modification b. Suggested Rewording N/A c. Officer Comment None d. Officer Recommendation NO CHANGE – Support noted