Agenda item

BROMLEY'S RESPONSE TO THE DRAFT LONDON PLAN CONSULTATION

Minutes:

Report DRR18/002

 

The New Draft London Plan was released for public consultation in early December 2017.  When adopted, the new Plan would replace the current London Plan (2016) and, as part of Bromley’s Development Plan, would be used in decision making on planning applications along with the UDP/Local Plan and Bromley Town Centre Area Action Plan. 

 

Members were requested to consider the key aspects of the Consultation Draft, together with officers’ comments (attached as Appendix 1).  Bromley’s response, based on these comments, would be prepared for Executive approval on 7 February and submitted before the deadline of Friday 2 March. 

 

The Chairman highlighted key elements of the document namely the suggested increase in housing supply, removal of the minimum parking standards, the increase in affordable housing (by possibly 50% in some cases) and the potential removal of the Docklands Light Railway potential for Bromley.

 

Councillor Michael noted the Mayor's proposal to remove all mention of building on garden land and considered that as a Borough, this was something which should be guarded against.  As far as she was aware, this was still a part of the National Planning Policy and as such suggested the Council request that reference to building on garden land be reinstated.  The Chief Planner confirmed that garden land was excluded from the definition of previously developed land as a national matter.  Were this eventually to become a London Plan policy, in most cases more weight would be given to the London Plan than the one at national level.  This had been acknowledged as a problem in the report currently before Members.

 

Policy SD7 (paragraph 5, page 44 of the report), referred to Petts Wood and West Wickham being given "medium" potential for residential growth.  Councillor Fawthrop queried how this had been determined within the draft London Plan as there was in fact, no potential at all for residential growth in the Petts Wood Area of Special Residential Character.  Even on the Petts Wood west side there was little or no scope for growth.  The Council's response should therefore be robust in pointing out that Petts Wood was an Area of Special Residential Character which was not suitable for residential development.  Officers agreed to draft some wording and consult with Councillor Fawthrop on this matter.

 

In regard to Town Centres and Residential Use (page 43), Councillor Brooks emphasised the need for caution as the majority of the Borough’s town centres operated as Business Improvement Districts (BIDs) and it was essential to ensure development did not abut onto retail areas and reduce footfall as this would result in the provision of smaller shops and in turn lead to less money being put into BIDs which would be seriously detrimental to the Borough's high streets.  In this regard, a more robust policy was required.

 

Councillor Joel raised concerns with the proposed new housing provision target of 1,424 dwellings per annum. Whilst the erection of high rise blocks were being encouraged, he questioned where the majority of the required units could be accommodated.  He also queried the definition of affordable housing.

 

Councillor Fawthrop agreed with the comment on page 49 of the report which supported a design-led approach to development sites.  However, he suggested it be strengthened in terms of the context and character of designs. 

He was also disappointed with the response to Policy D9 - Basement Development (page 51).  The Chief Planner and officers were fully aware of negative issues arising from basements and the recommended comments should therefore be amended to say the Council was aware of negative issues and would initiate local restrictions in the near future.

 

Page 60 of the report alluded to a policy target for off-site or cash-in-lieu contributions of 50% affordable housing which was not viable and would undermine the policy and prevent homes being built.  This should be robustly set out in the Council's comment.

 

Councillor Brooks emphasised the need to retain a good percentage of affordable housing within Bromley.  He noted that whilst housing officers worked extremely hard to provide affordable homes, they were not always located within the Borough.

 

Councillor Joel alluded to the change of use from offices to residential units however, the Council needed to provide mixed developments which would ensure continued employment in areas.  The conversion of large offices to small units for people in start-up businesses would be an option to consider.

 

Referring to the new policy on gypsy and traveller accommodation (page 69), Councillor Michael requested that the comment include the point that many people in this community were now living in settled accommodation and had been for many years.  For those who did not, there was currently no shortage of pitches in the Borough.

 

Councillor Fawthrop suggested the comment in relation to Burial Space (page 74), include the Council’s resistance to the development of mausoleums in the Borough as these were a waste of land.

 

Councillor Huntington-Thresher reiterated the concern regarding the lack of protection for garden land.  She also made reference to infill development within the curtilage of a house (page 56, clause d) and (clause e) where the presumption meant approving small housing developments unless it would give rise to an unacceptable level of harm to residential privacy.  The comments on page 57 to combat this was not strong enough as it suggested the benefits of additional housing would always outweigh the benefits of amenity space.  As it stood, it could easily be argued that additional housing could be established in areas with a large amount of amenity space.  She suggested a specific clause for garden land be included in the Plan.  Councillor Rideout reported that gardens were reclassified 15 years ago as greenfield sites and were no longer known as brownfield sites which gave the Council the required protection from garden-grabbing; this was confirmed by the Chief Planner.

 

In relation to housing and density, Councillor Mellor highlighted certain cases where developments had yet to be built some three years after planning permission was granted.  The applicant would then reapply for permission and again no building would materialise which resulted in the land being laid fallow for six years. Councillor Mellor suggested that the Chairman, through the Leader, make representations to the Government and Members of Parliament requesting that developments be carried out within a much shorter timescale.

 

Councillor Joel queried the definition of ‘the heat island effect’ which was stated in the comment relating to Policy GG3 on page 39 of the report.  The Planning Officer advised that the heat island effect was something which commonly happened around densely developed areas and agreed to provide Councillor Joel with further information.

 

The Chief Planner confirmed that in the majority of cases, the adopted London Plan policies could be given more weight than the National Planning Policy. 

 

Councillor Dean confirmed the London Plan would start to influence the Council’s decisions once it had been consulted upon, ratified and formalised towards the end of 2019.

 

Referring back to Policy SD7 (page 44), Councillor Fawthrop suggested the comment should state that the policy of ‘one size fits all’ top-down centralisation actually could not apply in conservation areas and areas of residential character.

 

The Chief Planner highlighted the very significant increase in the annual housing target, equating to annual development in the order of the Trinity Village (Blue Circle) development. 

 

Councillor Brooks reported that as the Borough’s wards were progressively built upon, it may become necessary to review ward boundaries.

 

RESOLVED that the key aspects of the New Draft London Plan be noted and with the incorporation of DCC Members’ comments, be recommended to the Executive to form the basis of Bromley’s formal response.

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