Kennington Park London SW9 6DE. Local Plan - Development Management Policies Document (Proposed Submission Version)
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1 Comment. Agent Ms Claire Evans (766642) Old Church Court SW8 1NZ Consultee (766655) Event Name Workspace Group Plc Chester House Kennington Park SW9 6DE Local Plan - Development Management Policies Document (Proposed Submission Version) Comment by Workspace Group Plc ( ) Comment ID 1 Response Date 28/06/13 17:25 Consultation Point Status Submission Type Policy DMI 2 Mixed Use Former Industrial Employment Areas (MUFIEAs) ( View ) Submitted Web Version 0.1 Legal compliance Do you consider the DPD is legally compliant? Yes Soundness Do you consider the DPD is sound? No Unsound Do you consider the DPD is unsound because it is not: (1) Justified (2) Effective (3) Consistent with national policy Powered by Objective Online page 1
2 Reasons for compliance and soundness Please give details of why you consider the DPD is not legally compliant or is unsound. Please be as precise as possible. If you wish to support the legal compliance or soundness of the DPD, please also use this box to set out your comments. We have concerns with relation to the addtional text under point a of DMI 2 relating to the requirement for new development within the MUFIEAs to undertake a Retail Impact Assessment where the proposal includes retail floorspace in excess of 300sqm. It is unclear why the provision of a retail space greater than 300sqm 'within' the town centre MUFIEAs should be required to undertake a retail impact assessment (and effectively be considered as 'out-of-town' retail development). The NPPF is clear that town centres should be at the heart of their communities and policy should support their viability and vitality and that retail uses (alongside leisure, tourism, office) uses should be directed to town centre locations as a first preference. The NPPF is also clear that impact assessments are only required to support retail developments 'outside' town centres (where the unit proposed is greater than 2,500sqm). The current drafting of the policy (as proposed) appears to be inconsistant with these NPPF objectives and could prejudice against the decision of retail uses as part of a comprehensive mixed use scheme on designated MUFIEA sites within the town centre. Changes necessary for legal compliance and soundness Please set out what change(s) you consider necessary to make the DPD legally compliant or sound, having regard to the test you have identified in the question above (Justified/ Effective/ Consistent with National Policy/Positively prepared) where this relates to soundness.you will need to say why this change will make the DPD legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible. Delete new insertion within paragraph 'a' relating to retail impact assessments or insert additional text to confirm that this requirement will only apply to MUFIEAs outside the designated town centre. Participation at oral part of examination If your representation is seeking a change, do you consider it necessary to participate at the oral part of the examination? YES, I wish to participate at the oral examination Reasons for participation at oral part of examination If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: The Workspace Group is a major land owner and operator of small business space for SME's within the borough. The group is also progressing the redevelopment of the Wandsworth Business Village site within Wandsworth Town Centre and is therefore keen to participate fully in the formation of new policy. Powered by Objective Online page 2
3 Comment. Agent Ms Claire Evans (766642) Old Church Court SW8 1NZ Consultee (766655) Event Name Workspace Group Plc Chester House Kennington Park SW9 6DE Local Plan - Development Management Policies Document (Proposed Submission Version) Comment by Workspace Group Plc ( ) Comment ID 2 Response Date 28/06/13 17:27 Consultation Point Table 3.1 ( View ) Status Submission Type Submitted Web Version 0.1 Legal compliance Do you consider the DPD is legally compliant? Yes Soundness Do you consider the DPD is sound? No Unsound Do you consider the DPD is unsound because it is not: (1) Justified (2) Effective Reasons for compliance and soundness Powered by Objective Online page 1
4 Please give details of why you consider the DPD is not legally compliant or is unsound. Please be as precise as possible. If you wish to support the legal compliance or soundness of the DPD, please also use this box to set out your comments. We note the Councils amendments to Policy DMH3 in recognition of the need for one bed accomodation in the intermediate and private rented sector. However in our view, greater flexibilty should also be introduced into part 'b' to support the provision of a greater number of one bed units for market accomodation - particularly on sites within the Boroughs town centres (or other central locations which are likely to be particularly attractive to first time buyers and small households). In our view, the maximum provision of one bed market accomodation should be increased to 35-40% in town centre sites. Changes necessary for legal compliance and soundness Please set out what change(s) you consider necessary to make the DPD legally compliant or sound, having regard to the test you have identified in the question above (Justified/ Effective/ Consistent with National Policy/Positively prepared) where this relates to soundness.you will need to say why this change will make the DPD legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible. Amend text within section 'b' of the policy to reflect an increased percentage of one bed market accomodation as stated above. Participation at oral part of examination If your representation is seeking a change, do you consider it necessary to participate at the oral part of the examination? YES, I wish to participate at the oral examination Reasons for participation at oral part of examination If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: The Workspace Group is a major land owner and operator of small business space for SME's within the borough. The group is also progressing the redevelopment of the Wandsworth Business Village site within Wandsworth Town Centre and is therefore keen to participate fully in the formation of new policy. Powered by Objective Online page 2
5 Comment. Agent Ms Claire Evans (766642) Old Church Court SW8 1NZ Consultee (766655) Event Name Workspace Group Plc Chester House Kennington Park SW9 6DE Local Plan - Development Management Policies Document (Proposed Submission Version) Comment by Workspace Group Plc ( ) Comment ID 3 Response Date 28/06/13 17:33 Consultation Point Status Submission Type Policy DMS 3 Sustainable design and low-carbon energy ( View ) Submitted Web Version 0.1 Legal compliance Do you consider the DPD is legally compliant? Yes Soundness Do you consider the DPD is sound? No Unsound Do you consider the DPD is unsound because it is not: (1) Justified (2) Effective (3) Consistent with national policy Powered by Objective Online page 1
6 Reasons for compliance and soundness Please give details of why you consider the DPD is not legally compliant or is unsound. Please be as precise as possible. If you wish to support the legal compliance or soundness of the DPD, please also use this box to set out your comments. Whist we support the general principle of the sustainable design and construction policy, we consider that the policy should be applied flexibly and take into account viability and other potential challenges to achieve these standards. In accordance with the thrust of the NPPF we consider that policies should support and encourage developments coming forward. Changes necessary for legal compliance and soundness Please set out what change(s) you consider necessary to make the DPD legally compliant or sound, having regard to the test you have identified in the question above (Justified/ Effective/ Consistent with National Policy/Positively prepared) where this relates to soundness.you will need to say why this change will make the DPD legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible. We consider that the text within part 'a' and part 'b' should be worded more flexibly and acknowledge viability and other potential challenges which could make it difficult to achieve these standards. Participation at oral part of examination If your representation is seeking a change, do you consider it necessary to participate at the oral part of the examination? YES, I wish to participate at the oral examination Reasons for participation at oral part of examination If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: The Workspace Group is a major land owner and operator of small business space for SME's within the borough. The group is also progressing the redevelopment of the Wandsworth Business Village site within Wandsworth Town Centre and is therefore keen to participate fully in the formation of new policy. Powered by Objective Online page 2
7 Comment. Agent Ms Claire Evans (766642) Old Church Court SW8 1NZ Consultee (766655) Event Name Workspace Group Plc Chester House Kennington Park SW9 6DE Local Plan - Site Specific Allocations Document (Proposed Submission Version) Comment by Workspace Group Plc ( ) Comment ID 1 Response Date 28/06/13 17:29 Consultation Point Status Submission Type Wandsworth Business Village, Buckhold Road/Broomhill Road, SW18 ( View ) Submitted Web Version 0.1 Legal compliance Do you consider the DPD is legally compliant? Yes Soundness Do you consider the DPD is sound? No Unsound Do you consider the DPD is unsound because it is not: (1) Justified (2) Effective Powered by Objective Online page 1
8 Reasons for compliance and soundness Please give details of why you consider the DPD is not legally compliant or is unsound. Please be as precise as possible. If you wish to support the legal compliance or soundness of the DPD, please also use this box to set out your comments. We note that the paragraph on 'Infrastructure' confirms that the Community Infrastructure Levy will be used to contribute to the provision of strategic infrastructure as identified in the Council's Regulations 123 list. The amended wording does not take into account viability for future schemes. We consider that the amended wording should state "Subject to viability" further contributions may be secured by planning and/or highway legal agreements where works on-site or in the vicinity are neccesary to mitigate the development. Changes necessary for legal compliance and soundness Please set out what change(s) you consider necessary to make the DPD legally compliant or sound, having regard to the test you have identified in the question above (Justified/ Effective/ Consistent with National Policy/Positively prepared) where this relates to soundness.you will need to say why this change will make the DPD legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible. Insert the words 'Subject to viability' before the second sentence within the 'Infrastructure' paragraph. Participation at oral part of examination If your representation is seeking a change, do you consider it necessary to participate at the oral part of the examination? YES, I wish to participate at the oral examination Reasons for participation at oral part of examination If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: The Workspace Group is a major land owner and operator of small business space for SME's within the borough. The group is also progressing the redevelopment of the Wandsworth Business Village site within Wandsworth Town Centre and is therefore keen to participate fully in the formation of new policy. Powered by Objective Online page 2
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