City of London

Draft Local Plan

Comments

March 2013

The City of London Draft Local Plan was issued for public consultation during January – March 2013. The following comments were received in response to the consultation.

Draft Local Plan Comments List Unique Number ID First Name Last Name Organisation Agent

1 1537 Anonymous Anonymous 2 1490 Bruce Badger 3 128 Jane Bartlett 4 1535 Chris Beard SQ Guernsey Ltd DP9 5 163 Mollie Bickerstaff 6 1493 Chris Boden 7 1524 Mike Bottomley Universities Superannuation Scheme Deloitte 8 202 Andrew Brabin 9 1489 Toby Brown

10 237 Paul Burley Kingston Estates Montagu Evans 11 237 Paul Burley Globalgrange Ltd Montagu Evans 12 326 David Coleman 13 331 Barnaby Collins DP9 14 1505 Gianetta Corley 15 1510 David Cox 16 423 Paul Drury Historic Royal Palaces Drury McPherson Partnership 17 1497 Steve Dzasko 18 1518 Maureen Flannery 19 490 Julie Fox City of London Conservation Area Advisory Committee 20 495 Rose Freeman The Theatres Trust 21 1517 Hannah Gibbs Living Streets 22 1533 Matt Gore British Land DP9 23 549 Helen Greenalgh Indigo Planning

24 1530 Sakiba Gurda London Borough of Islington 25 568 Martin Hall GVA 26 1491 Nicholeen Hall 27 574 David Hammond Natural England 28 602 Jeffrey Hennessey City of London Labour Party 29 1526 Robert Harris Guide Dogs for the Blind 30 1502 Alan Hesketh London Borough of Hackney 31 622 Gerald Hine 32 627 Vicky Hobart City of London Health and Wellbeing Board 33 1513 James Honeyman 34 1496 David Honeyman 35 665 Peter Hunter 36 1519 Thomas Hyde Building Research Establishment 37 1492 Philip Jameson Thames Water Savills 38 1525 Oliver Jefferson Turley Associates 39 709 Rory Joyce Tate Gallery Deloitte 40 1516 Ben Kelly Wildstone Property Ltd 41 1531 Ben Llewellyn Environment Agency 42 797 Clare Loops London Borough of Bexley 43 1532 Harry Manley Barts and the London NHS Trust Deloitte LLP 44 1498 Richard Massett Licensed Taxi Drivers’ Association 45 1503 Catherine McGuinness 46 415 Stewart Murray Mayor of London 47 1506 Al Karim Nathoo 4C Hotel Group 48 1520 Stephen Nelson Highways Agency 49 1514 Brian O'Donnell London Borough of Camden 50 1508 Lisa O'Donnell Westminster City Council

51 1499 Simon O'Regan 52 1501 Penny O'Regan 53 974 Lucy Owen Port of London Authority 54 1515 Graham Packham 55 1521 Donald Pedley 56 1522 Henrika Priest 57 1051 Jeremy Randall City Property Association Gerald Eve 58 1054 Andrew Ransome Workspace Group Plainview Planning 59 1507 Mary Rawlinson DPP One 60 1527 Patrick Reedman Eagle Crest Business Holdings Ltd Montagu Evans 61 1449 Yarema Ronish 62 607 Marissa Ryan-Hernandez London Borough of Tower Hamlets 63 1136 Graham Saunders English Heritage 64 1149 Fred Scott 65 1512 Julian Shirley Blackstone Group DP9 66 1509 Valerie Shrimplin Gresham College 67 1539 David Smith Valad Europe Indigo Planning 68 1193 Jane Smith Barbican Association 69 1203 Ralph Smyth City Cyclists 70 1528 Catherine Stephens Drake and Morgan CgMs Consulting 71 1488 David Stephens 72 1270 Chris Thomas Outdoor Media Centre Chris Thomas Ltd 73 1270 Chris Thomas British Sign and Graphics Association Chris Thomas Ltd 74 1523 Joe and Patricia Timothy 75 1511 Guy Treweek 76 1330 David Waller 77 1536 John Watson Scottish Widows Investment Partnership (SWIP)/Endurance Land Scott Brownrigg Planning

*NB: The ID number refers to the identification number in the City of London Consultation Database.

78 1485 Cynthia White 79 1504 Carl Whitley-Jones RBS Group 80 1385 David Williams Lloyds Chambers CBRE 81 570 Ginny Hall Mobile Operators Association Mono Consultants Ltd

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From:To:Subject: January 2013 Draft Local Plan - CommentsDate: 02 March 2013 12:14:34

Dear City Planning Officer,

My comments on the January 2013 Draft Local Plan:

1. Transparency: The draft local plan is a great example of making processestransparent. It is important that the actions of the City to implement theplan are also transparent. Public meetings should be recorded and therecordings made publicly available (as recommended by Eric Pickles, Secretary of State for Communities and Local Government) (Also, this iseasy and cheap to do). The City should make it easy for interested partiesto track progress on particular issues perhaps by a blog or twitter, but thespecific mechanism is less important than there being something at all. e.g.the last time I looked in the planning system is was not possible to get alink to a document which could be shared ... everyone would have to plodthrough the search system ... not good enough these days.

2. Consistency: Particularly with regard to the Barbican Estate there should bea consistent goal. An example of this *not* working is the new seating onthe Ben Jonson highwalk and also on St. Giles Terrace. The new seatspopped up in just these two spots with no view on estate-wide consistencyat all. Also, a consistent goal would allow works to be scheduled in a saneorder, e.g. again the Ben Jonson highwalk: the City replacing the seats andthinking about significant work on the gardens, while knowing that theentire highwalk leaks like a sieve and needs to have a waterproofmembrane installed which will mean removing *everything* from thehighwalk right down to the base concrete slab.

3. Signage: This gets a mention in the draft plan, but the current lack ofsignage and inconsistency in existing signage really is a joke. I, and Isuspect most other Barbican residents, have stopped to help people whoare hopelessly lost and sometimes quite distressed (missing a show or atrain). Consistent (there's that word again) signage to major landmarkswould help people navigate around more easily. Contributing to on-linemaps (e.g. Google Maps) to help people get about would be good too.

4. Noise: Active sound monitoring system are absolutely possible these daysand could help with the implementation of the City of London NoiseStrategy. Sensors and computers are much cheaper than people and canconstantly measure sound levels. Such a system would provide acontinuous sound map of the City allowing environmental health officers(who we still need!) to see and respond to problems as they happen,without the current need for a victim of a noise nuisance (plus, of course,the 6 month wait while the victim is required to gather evidence, all thetime suffering from the noise).

5. Air Quality: Some of the most polluted air in Europe is in the City ofLondon. This needs to be addressed as a high priority because it's killingpeople. A 20 MPH speed limit would help as would establishing a trendtowards less (or even zero) polluting vehicles. The goals should be setnow. Every policy decision which could affect air quality should be requiredto trend towards the goal.

Could you please confirm you have received my comments? Could you pleasealso let me know what will happen with my comments?

Thanks again for the plan and inviting feedback. I hope my feedback helps. It isintended to be constructive and hope it is seen in that light.

Regards, Bruce Badger

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From: Jane Bartlett Sent: 11 March 2013 16:17To: DBE - Local PlanSubject: RE: City of London Draft Local Plan

Follow Up Flag: Follow upFlag Status: Flagged

Good Afternoon 'DBE' Having spoken directly to Paul Bennett following his evening presentation at the Guildhall, and prior to this event written comprehensive notes on the subject, I sincerely regret that I will not now be able meet your consultation deadline later this afternoon (re: the Draft Local Plan), having in recent days been notified -- as a full-time resident of Queenhithe (Queen's Quay) -- of the commencement, as of the beginning of April, of 2.5 years of major demolition and rebuild of a hotel complex less than 5 metres from my bedroom and lounge-room. Understandably, this is matter that I must now give my fullest attention to, in that this development makes my full-time home uninhabitable. Not wanting to merely feedback in self-interest, I would however want to cite this as an all too real example of the failure of the current Plan and Strategy, as regards its practical 'on-the-ground' interpretation and application. To the best of my ability and as much as my resources would allow I engaged positively and actively with the Planning process and indeed spoke at the relevant Planning committee as an objector who in many respects was supportive of both the scheme and those who had proved to have the vision, ambition and determination to pursue it, so as to come up with both a 'workable' design and the finance to make it happen. However the commitments that was made at that Planning meeting and during an earlier site-visit to my home by the developer's surveyer and PR agent -- for the development team to stay in contact and come back to me with a solution to the indisputable impacts on my home -- as well as later assurances made by the managing agent of Queen's Quay, representing CoL as my freeholder -- that a suitably qualified professional would be made available to assist in the negotiation of 'neighboury matters' -- have not been honoured. No contact made, no solution offered. And it would seem that the City Corporation as the Planning authority has not felt inclined let alone compelled to monitor and enforce this aspect and direct consequence of the Planning permission it granted, despite members expressing genuine concerns, at the time of giving the scheme their formal approval, that my quality life would indeed be seriously compromised by this development. Whilst I acknowledge and respect the need to act for the 'greater good', the fact that the City of London's existing Planning framework and corporate strategy has not been able to safe-guard my rights as a resident -- as enshrined in my lease and the law more generally (and even though the City of London is my freeholder as well as the Planning authority) -- means that the reality of the last 12 months has now left me with little choice but to initiate legal action in order to protect my home, a process that will involve both the Comptroller and City Solicitor, and the development's representatives. This is a process that I can ill afford in terms of time or money. And I very much regret that it is the enactment of the City Corporation's current Planning policy and plan, and the actions of it's officers inconjunction with the commercial entities that the planning process serves, that has made this legal action necessary while also making it my responsibility to both research and fund the legal representation I now

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need. And so, meanwhile, I will endeavour to write up my questions and points in response to the draft Plan with a view to submitting these to the DBE at a later date, which indeed will be the soonest possible, so that these can at least be added to public record even if not taken account during the finalisation of the CoL's Local Plan. Prior to which, my one request would be that the City Corporation considers how it might make officers available to advise those residents who are adversely impacted by the schemes to which it grants permission, not least by requiring applicants to fund this support as well as the provision of an independant third-party advisor to negotiate all neighbourly matters reasonably raised in a timely manner as part of the Planning process. In summary, I would want to repeat the fact that CoL's current Planning policy has been unable to afford me as a resident what should be considered as nothing more or less than fundamental protection from unacceptable levels of noise and air-borne pollution, loss of privacy, and light nuisance -- from the development and subsequent 24-hour operation of a hotel complex immediately outside the windows of the principal living areas of my home. The Plan also does not provide for a common-sense and mutually-beneficial 'mediative' approach to resolving very specific issues arising from mix-use development in one of the four established, designated areas of residential accommodation in the City. Consequently CoL's Planning policy coupled with misrepresentations by the developer in this instance will result in my full-time home becoming uninhabitable as of the beginning of April or sometime soon after. What do the City's Planners reasonably expect me to do? Jane Bartlett

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CPB/DP2963 11 March 2013 Dear Sir/Madam DRAFT CITY LOCAL PLAN Representations on behalf of SQ Guernsey Ltd Please find below representations on the City’s Draft Local Plan on behalf of SQ Guernsey Ltd. The justification for changes to the Core Strategy policies In his report to the Planning & Transportation Committee of 27th November 2012, the City Planning Officer states that the purpose of proposed alterations to twelve of the Core Strategy policies is to bring them into greater conformity with the NPPF, ‘or to take account of minor wording changes or provide further clarification’. The report summary states ‘A small number of alterations to the Core Strategy’s adopted policies are proposed to bring it up to date. These are complemented by 67 development management policies which are largely derived from the existing UDP policies plus some new policies to address new issues that have arisen’. Paragraph 4 of the Officers Report to Committee advises that the changes to Core Strategy policies relate only to the NPPF, and that ‘some changes to the supporting text of policies is also needed for updating and consistency with the development management policies’. Paragraph 14 of the Officers Report outlines the new planning issues which have arisen since the UDP was adopted in 2002 - i.e. those informing the new development management policies. This includes the issue of uses other than offices becoming ‘financially more attractive to developers’, which might undermine the City’s business role. As a result, this paragraph notes that ‘changes to the Core Strategy policies for offices and housing and new development management policies providing protection for buildings or sites suitable for offices are proposed’ (our emphasis). The Foreword to the plan separately indicates that changes to Core Strategy policies are proposed ‘to reflect significant changes in development trends since [the Core Strategy’s] adoption in 2011’. In reading all of the above together, we are not clear on the justification for certain changes to Core Strategy policies relating to non-office uses – in particular housing. We question, and seek clarification on, the extent to which there has been such a significant change in this particular development trend since the adoption of the Core Strategy in September 2011 to

City Planning Officer Department of the Built Environment City of London The Guildhall London EC2P 2EJ

justify the changes proposed to certain of the adopted Core Strategy policies – in particular CS9 and CS21. Changes to CS21: Housing A number of alterations are proposed to Core Strategy Policy CS21: Housing. This includes two significant, material changes to the way in which the policy operates:

• The way in which suitable locations for new housing is identified changes from ‘to and near existing communities’ and instead reads ‘to identified residential areas’; and

• The approach to affordable housing provision on new housing developments changes from an elective on or off-site policy to one which requires on-site provision as a priority, with off-site being allowed only ‘exceptionally’.

We have set out our concerns relating to the first proposed change above under the justification for changes since the adoption of the Core Strategy in September 2011. We seek further justification from the City as to why changes in development trends since September 2011, or the new policies of the NPPF, require this particular change. In respect of the approach to affordable housing, paragraph 50 of the NPPF states that local planning authorities should:

“where they have identified that affordable housing is needed, set policies for meeting this need on site, unless off-site provision or a financial contribution of broadly equivalent value can be robustly justified (for example to improve or make more effective use of the existing housing stock) and the agreed approach contributes to the objective of creating mixed and balanced communities. Such policies should be sufficiently flexible to take account of changing market conditions over time.”

The proposed alterations to CS21 would make off-site provision ‘exceptional’, permitted only if a viability study demonstrates to the City Corporation’s satisfaction that on-site provision is not viable. There is also no reference to the feasibility of incorporating on-site affordable housing being a consideration. The NPPF contains no requirement to demonstrate that on-site provision is not viable, nor does it promote off-site provision only in exceptional circumstances. It states that policies should meet this need on site ‘unless off-site provision or a financial contribution of broadly equivalent value can be robustly justified’. An example of justification for off-site affordable housing provision is provided in the NPPF. This is ‘where more effective use can be made of the existing housing stock’, but this could also include where the available housing resources could be maximised, where off-site provision might better meet the identified housing need or where site specific circumstances make on-site provision impractical. We consider that the City is a unique location in respect of affordable housing, given the difficulties of providing affordable housing on-site as a result of high commercial land values, the lack of available donor sites for off-site provision and generally lower levels of social infrastructure provision in comparison to other London boroughs. The current elective approach to affordable housing provision recognises this situation and allows for a pragmatic response on a site-by-site basis. It is particularly suitable because it supports the pooling of contributions to maximise the use of the available resources beyond the City’s boundaries – a benefit which we consider to outweigh any dis-benefit in terms of mixed and balanced communities. Although the

NPPF retains on-site provision as a priority, it allows for provision off-site or as a financial contribution where this can be robustly justified, and advocates flexibility to allow response to changing market conditions. Paragraph 3.74 of the London Plan (2011) and Paragraph 4.4.30 of the Mayor’s Housing Supplementary Planning Guidance (2012) recognise that the combination of economic uncertainty and limited affordable housing grant availability may mean that to maximise affordable housing output greater use of off-site provision may be required. As such we consider that the proposed alterations would not bring the Local Plan into full conformity with the NPPF. We propose that the words ‘exceptionally’ and ‘if a viability study demonstrates to the City Corporation’s satisfaction that on-site provision is not viable’ be removed and replaced with ‘where it can be robustly justified’. This would allow for a full and proper consideration of all the factors which influence the ability and sensibility of where and how affordable housing is provided. We respectfully request that our comments are taken into account. We reserve the right to supplement these representations in due course and would welcome an opportunity to discuss them with your officers as appropriate. Should you have any queries in connection with these representations, please contact Chris Beard or Jonathan Smith of this office. Yours faithfully DP9

The City Planning Officer Department of the Built Environment City of London By email to

12 February 2013

Dear Sir

City of London Draft Local Plan

Thank you for the opportunity to comment on the latest draft local plan for the City. I live in the City. Living here, especially compared to the other London Boroughs where I have lived (Kingston, then Islington, then Camden) is a delight. I’d like to help keep it that way, although recognise there is little I can do. Here are a few thoughts on the draft Plan, hoping they are of some relevance.

I thought the Plan seemed to be a reasonable balance between protecting existing assets and accepting the necessity of change.

Omissions, things I looked for and did not find, were:

Anything on signage. Should the City have a policy regarding the quantity and appearance of signs, or is that something taken out of the City’s hands by other authorities?

The bridges. I expected to find some mention of how the bridges are to be maintained and protected. Is that too dealt with in some other way?

The fact that many visitors come to the heart of the City, not just to St Paul’s, to see certain buildings of architectural interest. Their pilgrimage isn’t made easy, and the stewards of the buildings show little interest as a rule. Could the City do more to promote itself as a highlight on the architectural pilgrimage trail?

Provision, in the section on waste, for dog waste. There are many dogs exercised in the City, but few (if any?) dog waste bins. Is this too detailed?

I was pleased to see the intention to maintain the presence of Smithfield market, and to see an acknowledgement of the beneficial effect of fountains in public spaces. We don’t have enough fountains.

I was interested to see core strategic policy CS10 on design, and can only assume the exceptionally dreary new Farringdon station on Cowcross Street got through the City’s planning scrutiny before the City was committed to promoting a high standard of design in buildings.

Finally, and I recognise it is an unpopular view, I consider too much fuss is made, in the draft plan and in general, about the noise from late night entertainment. Living on West Smithfield I have found it is easy enough to become accustomed to noise at night and to sleep through it. I would rather see scarce resources spent on more important issues than stopping people from enjoying themselves in the evenings.

Yours sincerely

Mollie Bickerstaff

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From: Chris Boden Sent: 07 March 2013 09:24To: DBE - Local PlanSubject: Local plan submissionAttachments: image001.jpg; image002.jpg; image003.jpg

Good Morning.   I write both as a local resident in a block of flats in the City (

and as a business elector on the City Ward List for many years (Knightrider House, Knightrider Street, London, EC4V 5JT) to request that consideration is given to amending the draft local plan upon which consultation is currently being undertaken.   I would like to request that consideration be given to including a specific provision in the Local Plan stating that there should, unless there are exceptional circumstances, be a strong presumption against granting permission for the development of any new licensed premises (or granting the change of use of any existing premises to licensed premises) where such premises are in or are immediately adjacent to existing developments in the City which are primarily residential, on the grounds of the need to preserve the residential amenity of existing developments. This request follows the attempts made in recent to turn the basement of Victoria House, Tudor Street EC4 into a nightclub, which appear to demonstrate the need for the Corporation of the City of London to have more robust development policies to protect the interests of local residents throughout the City in such circumstances.    With Kind Regards,   Chris Boden   

 

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From: Andy Brabin Sent: 03 February 2013 20:48To: DBE - Local PlanSubject: City of London Draft Local Plan

Follow Up Flag: Follow upFlag Status: Completed

Dear Sir/Madam,  I am writing to request that the following ideas are considered for inclusion in the City of London Local Plan.  1. CIRCLE / H & C / MET LINE STATIONS  

Barbican Station to be made accessible by the installation of elevators from platform to ticket hall, ticket hall to street level and finally street level to the walkway that passes over Aldersgate St. 

 

Moorgate Station to be made accessible by the installation of elevators from outer circle platform to ticket hall then  ticket hall to street level. 

 

Liverpool St to be made accessible by the installation of elevators from platform to ticket hall, ticket hall to street level. Additionally at the main tube ticket office some step free access from the main railway concourse to the underground ticket office area.  

 2. ALL UNDERGROUND TICKET OFFICES  To be staffed for full period of service. As the City increases its shopping and entertainment facilities as well as the continued increase in visitors, both tourists and business, a decent level of transport services is required to ensure that people have an easy visit to The City and can find information and purchase tickets easily as well as feel secure and safe and I believe that staffed ticket offices offer this.  3. CITY THAMESLINK  To have a Sunday service.  4. CITY THAMESLINK / BLACKFRIARS  Ticket offices to be open for full period of service.  As the City increases its shopping and entertainment facilities as well as the continued increase in visitors, both tourists and business, a decent level of transport services is required to ensure that people have an easy visit to The City and can find information and purchase tickets easily as well as feel secure and safe and I believe that staffed ticket offices offer this. 

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 5. ST PAULS STATION  Elevators to be provide step free access from street level to the ticket hall.  6. CYCLING  All cycle lanes and advance stop lines to be treated with green cycle lane tarmac.  More on street cycle parking with road space reallocated to cycle parking.  7. KERB DROPS  A review of all kerb drops to ensure that they are accessible 24 / by having double yellow lines.  All kerb drops to be free of flooding which frequently renders them unusable.  8. 20 MPH ZONES  Fully support the introduction of 20mph zones.   I look forward to my ideas being considered.  Faithfully  Andy Brabin 

  

 

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From: Toby Brown Sent: 13 March 2013 15:56To: DBE - Local PlanSubject: Local resident comment

I am a resident of the City of London. I understand that the common council members for Castle Baynard have suggested that the local plan include an explicit provision that there be a strong presumption against granting planning permission for any new licensed premises in or near existing developments in the Cit which are primary residential. In short, I write in support of such a presumption being part of the local plan. Residential areas should not be blighted by licensed premises which invariably create noise, rubbish and drunken people. Yours sincerely Toby Brown

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1. Introduction

These representations relate to the January 2013 draft of the City of London’s Local Plan. They are made on behalf of Kingston Estates. 2. Representations

OBJECTION – Core Strategic Policy CS1: Offices and related Policy DM1.1 – Protection of Office Accommodation Whilst the City’s existing and future role in providing a significant amount of office floorspace in London is recognised, we object to the addition of the following text to proposed Core Strategic Policy CS1:

“Protecting existing office accommodation where there are strong economic reasons why the loss of offices would be inappropriate, including losses that would prejudice the primary business function of the City, and the variety of accommodation required by the business City.”

We also object to the related development management policy, proposed Policy DM1.1 which reads as follows:

“To refuse the loss of existing (B1) office accommodation to other uses where the building or its site is considered to be suitable for office use and there are strong economic reasons why the loss would be inappropriate. Losses would be inappropriate for any of the following reasons: • prejudicing the primary business function of the City; • jeopardising the future assembly and delivery of large sites; • removing existing stock for which there is demand in the office market or long term need; • introducing uses that adversely affect the existing beneficial mix of commercial uses.”

We object because there is no objective basis or criteria in the draft Plan for the assessment of the propositions in these proposed policies, in particular: 1. what constitutes “strong economic reasons” and how these should be assessed;

2. what scale or amount of loss of B1 floorspace would be considered as prejudicing the primary business function of the City, either individually or cumulatively;

3. evidence in relation to the variety of accommodation required by the business City;

4. how demand for existing stock should be assessed by applicants;

5. what constitutes a “large site”;

6. whether other factors, such as other parties’ ownership of adjacent sites and those parties’ intentions, will be taken into account in assessing the likelihood of assembling a “large site”;

7. in the event that two or more sites, in theory, could be assembled but are for whatever reason are not, the amount of time which must elapse before redevelopment of one of the sites on its own may take place;

8. the timescales for the demonstration of “long-term need” for existing stock;

9. what is considered to be an “existing beneficial mix of commercial uses”;

10. changes to the “existing beneficial mix of commercial uses” which would be considered to have an “adverse effect”; and

11. whether the use of the term “adverse effect” is appropriate, or whether the test should be one of ‘harm’ to the development plan strategy.

Soundness of Proposed Policies Given that the above questions arise from the policies as currently proposed, we consider they are unsound because:

LOCAL PLAN REPRESENTATIONS  CITY OF LONDON LOCAL PLAN

JANUARY 2013 DRAFT VERSION

Page 2 of 4

• they have not been positively prepared because they are not based on objectively assessed

requirements / needs; because they do not set out realistic timescales; and because they are not sufficient flexibility to adapt to rapid change;

• they are not fully justified in terms of evidence base to support the aims of the draft policies; and

• they will not be effective because it is not explained how the policy objectives will be achieved; and because it is unclear how all of the variables will be monitored (and thus landowners will not have certainty in relation to the future potential of their sites).

Remedy The City Corporation should re-draft the policies so that they set out clear criteria for the change of use of B1 offices to other uses. The criteria should be: capable of being objectively assessed by landowners; prepared with reference to up-to-date evidence; and capable of being regularly monitored by the City Corporation. OBJECTION – Core Strategic Policy CS21: Housing and Related Policy DM21.1 – Location of New Housing (a) Absence of Geographical Definition of Residential Areas

We object to part 1 (i) of proposed Core Strategic Policy CS21 which says that the City will guide new housing development to identified residential areas, and to the first line of proposed Policy DM21.1 which sets out the same proposition.

“Residential areas” are shown schematically on the Figure B (the Key Diagram, page 21) and on Figure Z (page 190) of the draft Plan. They are not identified on a geographical basis anywhere in the proposed Plan or on the Policies Maps.

Thus it is impossible for applicants to have any certainty in relation which sites are or are not in “residential areas” and therefore whether the proposed policy is applicable. It is also unclear why the “residential areas” shown on the Key Diagram have been identified (in terms of how many units in a particular area would constitute a concentration of residential uses). Soundness The draft policies are therefore not effective as it is unclear how they will meet the Plan’s vision and objectives in relation to housing delivery.

(b) Absence of Satisfactory Evidence Base Paragraph 3.21.23 of the draft Plan says that all housing sites in the City are windfall sites. Notwithstanding our comments above, there is no evidence to suggest that the identified “residential areas” can or will accommodate the annual target number of dwellings set for the City by the Mayor of London. Soundness The draft Plan is therefore not positively prepared as it does not identify and maintain a rolling supply of specific deliverable sites sufficient to provide five years’ worth of housing against the City’s housing requirements. It is not justified as there has been no technical analysis that housing can be accommodated. It is not effective as it is unclear how the proposed policies will meet the Plan’s vision and objectives.

Page 3 of 4

(c) Absence of Objective Criteria for Assessment of Applications We object to part 1 (iii) of proposed Core Strategic Policy CS21 which says that the City will refuse new housing where it would prejudice the primary business function of the City and the comprehensive redevelopment of potential large office sites. We also object to the first four bullet points of proposed Policy DM21.1 which say that new housing will only be permitted where development would not:

• prejudice the primary business function of the City;

• jeopardise the future assembly and delivery of large office sites;

• remove existing office stock for which there is demand or long term need; and

• adversely affect the existing beneficial mix of commercial uses. We object because there is no objective basis or criteria in the draft Plan for the assessment of the propositions in these proposed policies, in particular: 1. the scale of residential floorspace that would be considered as prejudicing the primary

business function of the City;

2. what constitutes a “large office site”;

3. whether other factors, such as other parties’ ownership of adjacent sites and those parties’ intentions, will be taken into account in assessing the likelihood of assembling a “large office site” and therefore whether smaller sites should be released for uses other than offices;

4. the amount of time which must elapse before the “future delivery” of a site as part of a large office development is considered to be unrealistic;

5. the timescales for the demonstration of “long-term need” for existing stock;

6. what is considered to be an “existing beneficial mix of commercial uses”;

7. changes to the “existing beneficial mix of commercial uses” which would be considered to have an “adverse effect”; and

8. whether the use of the term “adverse effect” is appropriate, or whether the test should be one of ‘harm’ to the development plan strategy.

Soundness

Given that the above questions arise from the policies as currently proposed, we consider they are unsound because:

• they have not been positively prepared because they are not based on objectively assessed

requirements / needs; and because they do not set out realistic timescales;

• they will not be effective because it is not explained how the policy objectives will be achieved; and because it is unclear how all of the variables will be monitored (and thus landowners will not have certainty in relation to the future potential of their sites).

(d) Absence of Flexibility

We object to the limiting of housing to “residential areas” given that this is overly-restrictive. There may be sites which are outside of “residential areas” which are no longer suitable for the City’s preferred land use (B1 offices) and which, if developed for residential use, would not present amenity concerns either in terms of the amenity of residential occupiers or in terms of the operation of businesses around those sites. Thus, residential use may be the most sustainable use of such sites. Proposed Core Strategic Policy CS21 and proposed Policy DM21.1 do not incorporate sufficient flexibility to respond to such circumstances.

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Soundness

In relation to this matter, we consider these proposed policies to be unsound because they have not been positively prepared given that they are not based upon a presumption in favour of sustainable development, and because they are not flexible.

Remedy The City Corporation should:

• delineate the geographical extent of “residential areas” on the Policies Maps;

• demonstrate that the housing target set for it by the Mayor of London can be accommodated on sites within the “residential areas”;

• re-draft the policies so that they set out clear criteria for the grant of planning permission for residential uses on sites outside of “residential areas”.

Montagu Evans LLP 25 February 2013 (PD8430)

Page 1 of 2

1. Introduction

These representations relate to the January 2013 draft of the City of London’s Local Plan. They are made on behalf of Globalgrange Ltd. 2. Representations

OBJECTION – Pargaraph 3.13.2 We object to the proposed text of paragraph 3.13.2 which reads:

“The LVMF defines a Protected Vista for the Tower of London. Any development in the Wider Setting Consultation Area in the background of this Protected Vista should preserve or enhance the viewer’s ability to recognise the landmark and appreciate its Outstanding Universal Value. City sites have the potential to be intrusive in the view because of their relative proximity to the Tower. It is likely that proposed new development in the City which exceeds the threshold plane will not be acceptable as it will not preserve the view.”

The ‘defined threshold plane’ is described at paragraphs 43 and 44 of the 2012 London View Management Framework (‘LVMF’) thus:

“In some Designated Views, a Protected Vista is specified. A Protected Vista is a geometrically defined area that generally represents a rising or falling sight line between an Assessment Point and the Strategically Important Landmarks of St Paul’s Cathedral, Palace of Westminster or the Tower of London, and continues for some distance into the background. It has a defined threshold plane above Ordinance [sic] Datum that conforms to this sight line. “All development that exceeds the threshold plane of the Protected Vista will be subject to specific Visual Management Guidance and consultation and referral procedures, to ensure that it will preserve or enhance the viewer’s ability to recognise and appreciate Strategically Important Landmarks in the Designated View.”

The proposed text at paragraph 3.13.2 of the draft Local Plan could imply that no development above the ‘threshold plane’ will be acceptable, and it is our experience that policy is applied in this manner. It is clear, however, that such an approach is not the intention of the LVMF; according to the LVMF, development which would exceed the ‘threshold plane’ is subject of consultation and referral procedures, not automatic refusal of planning permission.

Such development would also be subject of Visual Management Guidance which, in the case of the Tower of London, is set out on pages 215 to 217 of the LVMF. It is clear from paragraphs 420 and 421 of that Guidance that development may appear in the background of the view of the Tower of London from Queen’s Walk, excepting the Protected Silhouette of the White Tower. Paragraphs 420 and 421 read as follows:

“The Protected Silhouette should not be altered by development appearing in its background when viewed from any point between Assessment Points 25A.2 and 25A.3. “New buildings in the background of the view must be subordinate to the World Heritage Site and respect its historic significance. They should not contradict the townscape ensemble of the Tower of London juxtaposed against predominantly trees in its immediate setting and buildings that tend to be horizontal in mass and scale further behind and to the sides.”

The proposed wording of paragraph 3.13.2, therefore, goes beyond the position taken in the LVMF.

LOCAL PLAN REPRESENTATIONS  CITY OF LONDON LOCAL PLAN

JANUARY 2013 DRAFT VERSION

Page 2 of 2

Soundness of the Proposed Text The proposed text is unsound because it does not plan positively and does not conform with the provisions of the London Plan and specifically with the LVMF SPG which articulates London Plan policy. Remedy The City Corporation should re-draft the text as follows:

“The LVMF defines a Protected Vista for the Tower of London. Any development in the Wider Setting Consultation Area in the background of this Protected Vista should preserve or enhance the viewer’s ability to recognise the landmark and appreciate its Outstanding Universal Value. City sites have the potential to be intrusive in the view because of their relative proximity to the Tower. It is likely that proposed new development in the City which exceeds the threshold plane will not be acceptable as it will not preserve the view. Development proposals will be assessed against the criteria in the LVMF.”

Montagu Evans LLP 20 February 2013 (PD8207)

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Miller, Richard

From: David Coleman Sent: 19 January 2013 18:35To: DBE - Local PlanSubject: Comments on draft local plan January 2013

My comments on the draft local plan. I strongly support policy DM3.5 and its associated policies on night-time entertainment . I would object to any watering down. However its efficiency would be much enhanced if it was given a spatial dimension. This is surely a key feature of planning policies, helpful to developers as well as those who might be affected by development? The maps/figures helpfully identify residential areas in broad terms. The effectiveness of DM3.5 would be improved with the addition of:

3) Proposals for large scale night-time entertainment premises and related uses and the extension of existing premises which would result in them becoming large scale, will not normally be permitted in or near residential areas.

and: 3.3.16a Large scale will be judged according to the pattern of likely use as well as absolute capacity. A venue where customers come and go in small numbers is likely to be more acceptable than a venue where most customers arrive and/or leave over a short period of time. So, for example, a larger capacity restaurant may be more acceptable than a club. DAVID COLEMAN

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From: Barnaby Collins Sent: 08 March 2013 15:17 To: Shadbolt, Peter; Beckett, Paul Subject: Draft Local Plan Peter/Paul, I have read through the draft and although I am not representing any party I make an observation below. Para 3.4.5 refers to CIL and that S106 will be retained only for affordable housing provision, training and skills and the City’s Local Procurement Initiative. This seems to conflict with the text below that in Policy CS4 which includes additional financial and non-financial obligations, largely reflecting the existing SPG. On a different matter, I wonder if it would be helpful if para 3.16.11 (Construction Logistics Plans) could make it clear that it relates to new build projects. Whilst I am sure that some conversions of say an office building to resi still qualifies as ‘construction’ I am sure that the intention isn’t that a CLP applies to a change of use application. Kind regards. Barnaby Collins Partner direct: mobile: e-mail: dp9 100 Pall Mall London SW1Y 5NQ telephone: 020 7004 1700 facsimile: 020 7004 1790 website: This e-mail and any attachments hereto are strictly confidential and intended solely for the addressee. It may contain information which is privileged. If you are not the intended addressee, you must not disclose, forward, copy or take any action in relation to this e-mail or attachments. If you have received this e-mail in error, please delete it and notify

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From: Gianetta Corley Sent: 08 March 2013 17:11To: DBE - Local PlanSubject: Draft CoL Local Plan 2013

Follow Up Flag: Follow upFlag Status: Completed

Dear Sirs, The aspirations expressed in the CoL Draft Local Plan are commendable and are fitting for preserving and presenting London as a World leading Capital City which provides imaginatively for its: daytime workers businesses visitors nightlife providers and customers heritage assets I attended the Open Meeting on Tuesday 26th March at 6.30pm in Guildhall and was pleased to have the opportunity to listen to the presentation and to the Q &A sessions. I make these points: a) as a resident I note that the requirements of residents in the City are not a particular priority for the CoL Corporation. I am aware of course that there are many conflicting interests in balancing the interests of residents as against those of incoming city workers. b) City residents have to fight constantly to keep down new threats of noise pollution from Licensed premises or from buildings with ventilation plants installed on the roofs, or from noisy early morning deliveries to food outlets. c) because the Barbican Estate was set up without a sinking fund, it is now ageing very significantly.Repair and maintenance work managed by the CoL has not been sufficient to keep the common parts at the high level of appearance the Estate once had. d) Due regard is not always paid to the architectural integrity of the original design of the whole Barbican Estate - which is Grade II* listed. e) In the CoL's search to 'enhance' a small piece of open space (St Giles Terrace) for the benefit of City workers the Streetscene furnishings are not of good design nor are they of good quality. The furnishings also offend the Grade II* listed architectural context in which they are set - as judged by professionals with expertise in this field such as architects etc. f) many Barbican residents are also, or have been in the past, City workers and deserve the same consideration in their home environments as with regard to their office space. g) It is hoped that the CoL will adopt a very thoroughly professional way of consulting with residents, listening to their views and paying real attention to the carefully made suggestons put forward by those who have committed themselves and their families to living in the City. Yours faithfully Dr Gianetta Corley

CITY OF LONDON DRAFT LOCAL PLAN - COMMENTS

3.18 FLOOD RISK

The Report deals with flood risk due to surface water, river flooding, and surcharged sewers. There is no mention of the rising groundwater level below the City. Since the large scale provision of surface water reservoirs and the cessation of well pumping, the deep groundwater level below the City has been rising at 1 to 4m/ year and will shortly reach the underside of foundations, deep basements and tube lines. The raised ground water pressure will roughly halve the bearing capacity of deep foundations and double the pressure on buried basement walls etc. This is regarded by the Standing Committee on Structural Safety (of both the Institution of Civil Engineers and of Structural Engineers -(SCOSS)) as one of the most serious current threats to structural stability. (See recent SCOSS reports). Old structures will also be affected. For example the shallow water levels around St. Pauls have been monitored for many years because of the likely effects of changes in water level on the structure. The City Plan should contain a discussion of the problem and a commitment to developing a policy. D W Cox PhD. MSc. BSc. MICE. FGS. CEng.

CITY OF LONDON DRAFT LOCAL PLAN - COMMENTS

3.19 OPEN SPACES & RECREATION

In recent years the open spaces and recreation facilities for children at the Golden Lane Estate have declined. In summary the Estate Nursery has closed, the associated play area is now an allotment bag garden, the children's' paddling pool has been grassed over and is used mainly by the public, the Youth club has moved from the clubrooms (now closed) to Fann St. (now Tudor Rose Court homes) and then to the City Education Centre, and is now defunct. Some after school activities are still provided at the Leisure Centre & Education Centre. Otherwise there is nowhere locally for approx. 100 persons aged 5-20 on the Estate to meet or play. The Richard Cloudesley School on the northern boundary of the Estate is currently being closed and developed as flats. It may be possible to reserve part of this new space for children's activities as partial redress. There should be some recognition of this problem in the Report. David Cox (Resident)

Drury McPherson Partnership Historic environment policy and practice

Partners Paul Drury FSA MRICS IHBC . Anna McPherson DipArch RIBA IHBC FRSA Drury McPherson Partnership . TELEPHONE . FACSIMILE . . E-MAIL Regulated by the RICS

11 March 2013 City Planning Officer Department of the Built Environment City of London PO Box 270 Guildhall EC2P 2EJ Dear Sir CITY OF LONDON DRAFT LOCAL PLAN CONSULTATION I am writing on behalf of Historic Royal Palaces in response to your consultation on the City of London Draft Local Plan. As you know, Historic Royal Palaces is responsible for managing, protecting and presenting to the public the unoccupied royal palaces in London, including the Tower of London, inscribed on the World Heritage list. In general, HRP welcomes the continuing recognition in this draft, in line with the adopted Core Strategy which it incorporates, of the importance of the historic environment, and in particular the fact that the City includes within its boundary a significant part of the setting of the Tower of London. Our detailed comments are limited to those matters in the consultation draft which have a bearing on the interests of Historic Royal Palaces in relation to the Tower of London. Comments on the text carried over from the Core Strategy normally relate only to additional factual matters that we suggest be updated. 3.10 Design The first bullet point in this interpolation in CS 3.10.1, The rich and diverse patterns of buildings and spaces which have become established have, to varying degrees, the following common characteristics:

• human scale reflected in the relationship between buildings and their surroundings;

has not always been reflected in development over the past three decades; so we welcome it being stated as a positive characteristic of the City, whose reinforcement is to be promoted under policy CS10: 1 and DM 10.1.

Drury McPherson Partnership Historic environment policy and practice

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3.12 Historic Environment 3.12.1 The final sentence should refer to a '[defined] local setting' rather than a 'buffer area'. The inscription on the World Heritage list does not include a buffer zone, nor is it proposed to define one. It would also be helpful to add, after significance, ('outstanding universal value'), which is the term used in the World Heritage Convention. The correct terminology is in fact used in Policy CS12. Policy DM12.1 'Sustain and enhance', which is the wording of the NPPF, para 131, would be preferable to 'protect and enhance' in point 1, partly for consistency, and partly because 'sustain' has a more positive, and where necessary pro-active, connotation (from the definition quoted in the EH Principles: 'maintain, nurture, affirm validity') The wording of 3.12.5 seems too compressed to be clear: we suggest: .....describing the significance of any heritage assets whose fabric or setting would be affected, including how their setting contributes to their significance.' 3.12.8 It could be helpful to refer here (as well as at 3.12.25) to the Mayor’s SPG World Heritage Sites – Guidance on Settings, with particular reference to the method recommended for assessing impact (based on ICOMOS guidance). Policy DM 12.2: Item (1) The statutory definition is 'preserve or enhance', rather than 'and enhance' since enhancement (rather than doing no harm) is not always necessary or even desirable to attempt. Item (3) as worded means that the policy would not apply to the demolition of buildings that make a positive contribution, should consent to do so be given. We suggest something like: 'Demolition in conservation areas will only be permitted after detailed plans for a replacement building or landscaping scheme have been approved and their implementation contractually secured.' We assume that no item (4) was intended, rather than the text being omitted. 3.12.12, second sentence, we suggest 'is unlikely to ' rather than 'may not' as better reflecting reality. Delivery Table, p123: ''Applying the recommendations of ....' should read ' Submitting periodic and reactive “State of Conservation Reports” to the UNESCO World Heritage Committee' (Action is for DCMS; Periodicity is every five years or in response to specific requests). What is missing from the WHS actions is 'Implementing the recommendations of the World Heritage Committee for the management of the site', which falls to HRP, the

Drury McPherson Partnership Historic environment policy and practice

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City and other planning authorities around the Tower, and the Mayor of London (Periodicity: Ongoing) Risk Management: 3.12.25 We suggest deleting 'in the past' from line 1, since it is again a live issue following the 2012 WHC meeting. The phrase 'strengthen the Tower’s dynamic visual position' seems to be derived from the idea of ‘Dynamic Visual Impact Study’. Perhaps something like ‘strengthen [or sustain?] the visibility of the Tower in the cityscape’ would be more meaningful to those unfamiliar with the jargon? 3.12.26 The second sentence needs to be amended to reflect the delivery, in August 2010, of the Tower of London Local Setting Study, which is referred to elsewhere in the draft. Delivery, final box; For 'State of Conservation Reports submitted by DCMS to the..' read 'Recommendations of the World Heritage Committee to DCMS....' A reference to the World Heritage Site Operational Guidelines would be helpful. 3.13 Protected views The proposed addition to 3.13.2 is particularly welcome. 3.14 Tall Buildings We have commented in relation to earlier iterations of the Core Strategy that what is now Figure N (p129), while argued to be technically correct, is practically misleading in omitting the Wider Setting Consultation Areas of the protected vistas, shown integrated with the viewing corridors a few pages earlier on Fig L (p126). It would be desirable add these to Fig N, perhaps with a different annotation, something like ‘Areas where the scope for tall buildings is constrained by strategic views’, which would reconcile the two diagrams with each other and the Mayor’s LVMF. We hope these comments are helpful; if you have any queries, or clarification would be helpful, please do not hesitate to contact me. Yours faithfully

Paul Drury Partner Cc John Barnes, HRP Tracy Simmons, HRP

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From: MAUREEN FLANNERY Sent: 27 February 2013 14:58To: DBE - Local PlanSubject: Draft local plans 2013

Please include these views in the local plans. As a local resident, I found to read and understand the whole document really difficult. I Attended one meeting, and the big picture is clear, encouragement of economic growth across the city. What I found missing was the things that effect me, sometimes are small things and when dealing with such a large organisation, many of my views get lost. The city will be building more residential accommodation, and it needs to build into the structure better ways of allowing local views into the bigger picture. Where you place a bench here or a sign can effect us, just as much as a large building. However the consultation method through officers of the City Of London is of poor quality, so I urge you to think more carefully at how you can listen and response to individual residents. We are bombarded with planning applications all around us, and many will effect our daily lives. We don't have the benefit of paid staff, so be creative in you consultations and listen more to what we think.. I did take time to attend the latest local plan meeting but some officers present really did not have suffient knowledge to be helpful. Regards MaureenFlannery

 

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From: Rose Freeman Sent: 27 February 2013 12:16To: DBE - Local PlanSubject: Draft Local Plan

Our Ref.: RF/4771 Draft Local Plan Thank you for your email of 14 January consulting The Theatres Trust on the new draft Local Plan which builds on the 2011 adopted Core Strategy. We have no objection to the minor amendments to the Visitors, Arts and Culture Section – Policies CS11 and DM11.1 - but our objections to Item 3 of Policy CS11 remain as before. We query the phrase ‘where they are needed’ in item 3 of Policy CS11. The criteria for their ‘need’ is covered in Policy DM11.1 on the following page and therefore we recommend this phrase is obsolete and should be deleted from Policy CS11.   Rose Freeman Planning Policy Officer The Theatres Trust 22 Charing Cross Road London WC2H 0QL Tel: 020 7836 8591 Fax: 020 7836 3302   

************************************************************************************************** Learn more about theatres with our online resource  Check out your local theatre on The Theatres Trust '   *************************************************************************************************** The contents of this email are intended for the named addressee(s) only. It may contain confidential and/or privileged information, and is subject to the provisions of the Data Protection Act 1998. Unless you are the named addressee (or authorised to receive it for the addressee you may not copy or use it, or disclose it to anyone else. If you receive it in error please notify us.   You should be aware that all electronic mail from, to and within The Theatres Trust may be  subject to public disclosure under the Freedom of Information Act 2000, and theconfidentiality  of this email and any replies cannot be guaranteed. Unless otherwise specified, the opinions  expressed herein do not necessarily represent those of The Theatres Trust or The Theatres  Trust Charitable Fund.   ***************************************************************************************************

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Living Streets response to City of London Draft Local Plan Living Streets is the national charity that stands up for pedestrians. With our supporters we work to

create safe, attractive and enjoyable streets, where people want to walk.

Living Streets are delighted to see the emphasis on creating enjoyable and accessible pedestrian

environments throughout the Draft Local Plan. We feel pedestrian needs have been well

considered in the plan and that the plan is certainly going in the right direction with regards to

creating safe, attractive and enjoyable streets where people want to walk. We do however feel

there are opportunities to make some stronger commitments to creating a world class pedestrian

environment in the City of London.

It is important that the pedestrian voice is strong within the Local Plan and the organisation in

general. City of London need to ensure that the needs of pedestrians (who account for the vast

majority of street users in the square mile) are not overshadowed by other groups and interests.

Improving the pedestrian environment needs to be embedded in the plan and in the approach of

the City of London. It is also crucial that policies are in place to ensure that the good values around

pedestrian needs within the plan are seen through.

New developments

It is crucial that any new large buildings or developments encourage their new occupants to travel

to and from them sustainably. We would suggest new buildings in The City have little or no parking

and that travel plans are made compulsory. A travel plan is a long-term management strategy for

an occupier or site that seeks to deliver sustainable transport objectives through positive action

and is articulated in a document that is regularly reviewed. Travel plans will help to ensure that the

new occupiers of a building are given every possible opportunity to travel in and out of The City in

a sustainable fashion. This will reduce the pressure on the road and public transport networks and

improve the health and wellbeing of these occupants as they switch to active travel modes.

Walking and cycling

Pedestrians and cyclists share many common objectives when it comes to urban planning. Slower

motor traffic speed, driver liability, reallocation of road space (for example wider pavements and

advanced stop lines), and greater enforcement of driving offences are key examples. However it

must be recognised that they remain two very different modes: mixing them together

inappropriately can cause fear, anxiety, insecurity and even serious injury or death. Therefore

Living Streets believes that promoting modal shift to cycling through urban design should not be

achieved at the expense of pedestrian space and amenity – but rather through the reallocation of

space away from motorised traffic. Where cycling and walking are mentioned together in the Local

Plan, thought should be give to whether they should be separated to reflect the different needs of

the users and the importance of pedestrians as the biggest road user in The City. At the very

least, improvements to cycling infrastructure should not affect the pedestrian environment

negatively, and ideally they should enhance the pedestrian experience.

The Mayors Vision for Cycling in London presents a good opportunity to improve the environment

for pedestrians too. Furthermore, Living Streets would recommend the creation of a network of

pedestrian friendly routes across the City of London in order that improvements are made on a

strategic basis and that they work towards creating safe, pleasant and attractive pedestrian routes

through the city. We would like to see these routes being designed and maintained to a minimum

standard, including standards on street clutter, lower traffic speeds and signage. These minimum

standards will ensure that The City continues to compete with other world centres from the

perspective of the street environment.

Delivery Strategy Living Streets is a key stakeholder in the City of London as we hold a Service Level Agreement

with the authority to improve the pedestrian environment and encourage people to walk more. As

such, we would like to be included in the Delivery Tables throughout the report, namely the

following:

Policy CS5 on page 71 under ‘Pedestrian Movement’

Policy CS6 on page 78 under ‘Pedestrian Environment’

Policy CS8 on page 90 under ‘Improving Connections and Linkages’

Policy CS16 on page 153 under ‘Walking and Cycling’

North of the City

Whilst it is good to see the commitment to improve pedestrian routes, we feel there needs to be

more emphasis on ensuring that the pedestrian environment can cope with the increased capacity

fuelled by Cross Rail.

Cheapside and St Pauls

At a recent meeting with Sir Nicholas Kenyon, the MD of The Barbican Centre, he explained that

nowadays people expect their journey to and from the attraction they are visiting to be part of the

cultural experience. Therefore, it is important that the pedestrian environment around museums

and cultural attractions in Cheapside & St Pauls is given particular care and attention to ensure it

meets the standards of these prominent visitor attractions.

Public Transport Streets and Walkways

Living Streets welcomes the emphasis on improving the environment for people on foot here but

we feel there could be an emphasis on promoting walking as the first choice for short journeys

within the city.

Open Spaces and Recreation

The Local Plan has a strong emphasis on the need to improve the pedestrian environment which

we support and welcome. We particularly welcome the approach to Open Spaces as destinations –

places to go and stay, rather than just places to pass through. We do however feel there could be

greater emphasis on reallocating space from motor vehicles in favour of space for pedestrians. We

fell there could be a stronger argument for reducing motor vehicle traffic in The City which would

mean less space will be needed for vehicles and can be given over to pedestrians instead. This

would have a marked positive effect on the pedestrian environment.

\\plndata\data_pln\devplan\city local plan\consultation responses\comments entered\22 draft local plan 11.03.2013 dp9 on behalf of british land.doc

JS/DP2626 11 March 2013 Dear Sir/Madam DRAFT CITY LOCAL PLAN Representations on behalf of British Land Please find below representations on the City’s Draft Local Plan (‘DLP’) on behalf of British Land. Policy DM 1.1 Paragraph 3.1.9 of the DLP indicates that the City needs to have a healthy supply of different types of office accommodation, including ‘large office buildings’. Paragraph 3.1.10 then goes on to summarise the character of different parts of the City (the ‘Key City Places’) and their ability to meet these requirements. We support what is said within these paragraphs, however we think that the text relating to the North of the City could be helpfully expanded to note that it is an appropriate location for large office buildings – in particular the area around Liverpool Street Station which is characterised by larger floorplate office buildings. We therefore suggest that the following sentence within 3.1.10:

“In the North of the City offices will benefit from the increasing accessibility provided by Crossrail.”

Could be changed to read:

“Parts of the North of the City around Liverpool Street Station and Moorgate are particularly appropriate for large office buildings, and will benefit from the increasing accessibility provided by Crossrail.”

This would reflect the particular appropriateness of this part of the City for accommodating more large office buildings given the concentration of modern, flexible office buildings that already exists in and around Broadgate. Policy DM 1.2

City Planning Officer Department of the Built Environment City of London The Guildhall London EC2P 2EJ

22 February 2013 Page 2

Policy DM 1.2 relates to the ‘Assembly and protection of large office sites’. In addition to the protection of sites which could accommodate new large office buildings, we think it is also important to safeguard existing large office sites and encourage the intensification of these sites. As such, we would propose to add a further bullet point to say that the City Corporation will ‘support the intensification of existing large office sites’. Policy DM 12.1 Policy DM 12.1 states that ‘the loss of routes and spaces that contribute to the character and historic interest of the City will be resisted’. We recognise the importance of historic routes and spaces and the contribution they make both to character and permeability/pedestrian movement, however there may be circumstances where other priorities (for example the assembly of a large development site) necessitate such a loss, and in such circumstances it might be possible to mitigate such a loss through provision of alternative or improved routes and spaces elsewhere. We would suggest that this is expanded to say ‘unless an appropriate alternative or mitigation can be provided.’ Policy DM 15.4 Policy DM 15.4 introduces a requirement for financial contributions for carbon off-setting. We consider that the draft policy is unclear on a number of things. In relation to the proposed policy wording and supporting text, we wish to raise the following concerns:

• There is no standard for how to calculate carbon emissions ‘for the lifetime of the building’. Building regulations do not do this, and so if this is to be agreed locally then it needs to do so in a way which is consistent with the Government’s zero carbon buildings policy and adopt nationally prescribed standards as required by the NPPF; and

• The Zero Carbon Hub report, which details ‘allowable solutions’, suggests that contributions for carbon off-setting would be linked to building regulations (not planning) but directed to local off-setting funds according to planning policy. It is possible that the Government may remove the idea of allowable solutions altogether, and so in the absence of clear national guidance on the issue we consider that it would be better to reserve much of the detail for supplementary planning guidance.

We would welcome further discussion with the City on this policy and the wider issues involved. Policy DM 15.6 Policy DM 15.6 relates to air quality. This includes a requirement to achieve maximum points for the pollution section of BREEAM or Code for Sustainable Homes assessments relating to NOx emissions. This is overly onerous. Historically, BREEAM has only addressed NOx emissions from boilers (on site), but now in the Pollution category under BREEAM, developments are required to assess all sources of space heating, and more recently cooling (under BREEAM 2011). Based on BRE guidance, these services that are electrically served from the National Grid, even if these are from zero carbon technologies such as air source heat pumps, are highly unlikely to achieve credits under the NOx emissions issue. This is due to the fact that the power stations supplying Grid-supplied electricity have significantly higher NOx emissions compared with on-site gas boilers, which are clearly within the developer’s control.

22 February 2013 Page 3

The GLA Energy Hierarchy specifically requires developments to consider connection to district heating networks (as part of the ‘Be Clean’ principle). This would therefore penalise those schemes that have been designed in accordance with the Energy Hierarchy, and beyond the remit of the developer, or potentially behind the City boundary. Therefore, by asking for maximum points under this credit the City is seeking to regulate air quality outside of its boundary. We would suggest that it would be more reasonable to re-word this sentence to require points in this category to be maximised as far as possible. We respectfully request that our comments are taken into account. We reserve the right to supplement these representations in due course and would welcome an opportunity to discuss them with your officers as appropriate. Should you have any queries in connection with these representations, please contact Chris Beard or Jonathan Smith of this office. Yours sincerely DP9

Dear Sir/Madam

LOCAL DEVELOPMENT FRAMEWORK – DEVELOPMENT MANAGEMENT

DEVELOPMENT PLAN DOCUMENT

We write on behalf of our client, the Valad Property Group, to provide

comments in relation to the above consultation document.

Housing

The Core Strategy identifies nine existing residential areas where further

development would complement the existing residential environment. We

understand that recent housing development which has occurred outside

existing areas has raised the question of whether new areas should be

identified. A further issue which we understand to be currently under

consideration is whether detailed boundaries for these areas should be defined

on the Proposals Map, or whether boundaries should remain diagrammatic

only.

Firstly, we consider that these boundaries should remain diagrammatic. This

option is preferable as it allows the Council more flexibility in considering

proposals for changes of use to residential use in this area. We therefore

support option (ii) relating to Issue 21.1 which is to

“Include a criteria-based policy in the Development

Management DPD for determining the location of new

housing development, including proposals for housing

outside of existing residential locations”

However, should it be decided that the Council choose to assign specific

boundaries identifying residential areas, as opposed to indicative locations, then

we request that Gough Square is included inside a specific boundary for the

Fleet street and Temples residential area (as it was called in the UDP), which is

located between Fetter Lane and Shoe Lane. A number of properties in

residential use currently exist in this area. Gough Square is less commercial in

nature and is one of the quieter parts of the area and is suitable for more

Department of Planning and Transportation

City Planning Officer

PO Box 270

Guildhall

London

EC2P 2EJ

By email and post

29 September 2011 Our ref. HG/CB/12900029

Page 2 of 2

housing in line with the Core Strategy which seeks to increase the amount of

housing in the City.

Offices

With regard to the protection of office accommodation, we understand that the

Core Strategy acknowledges the importance of providing a range of high quality

office accommodation to meet the varied needs of City office occupiers but its

focus is on key development sites. In this regard, we consider the Development

Management DPD should include a policy which deals with smaller sites and

promotes flexibility. We therefore suggest an alternative option to those put

forward, i.e. include a policy in the Development Management DPD that

promotes an appropriate mix of uses and maintains flexibility in terms of

alternative use of buildings/sites where appropriate.

We agree with option (ii) of Issue 1.4 which is to include a Policy in the

Development Management DPD seeking a balance of complementary uses

which does not detract from the City’s primary role as a centre of office-based

financial and business services.

Retailing

We also make comments relating to the protection of local retail facilities. We

agree with option (ii) of issues 20.4, to include a criteria-based policy in the

Development Management DPD allowing some flexibility for adjustments in the

provision of retailing where it can be shown that there is not a local need.

We request that the Council allow flexibility in policies relating to the loss of

private health facilities. The Core Strategy does not currently contain a policy to

resist the loss of private health care.

We trust that you will take these comments into consideration in progressing the

LDF Development Management DPD. It you have any queries, please do not

hesitate to contact me.

Yours faithfully

Helen Greenhalgh

Cc: Mr M Girling – Valad

Planning Policy222 Upper StreetLondon N1 1XR

T E

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11 March 2013

City Planning OfficerDepartment of the Built EnvironmentCity of LondonPO Box 270GuildhallLondon EC2P 2EJ

Dear Sir / Madam

Response to City of London draft Local Plan, January 2013

Thank you for providing us with the opportunity to comment on the City of London’s draft Local Plan. In general, the London Borough of Islington welcomes the various objectives and policies of the document, which will complement many of Islington’s own emerging and adopted Development Plan policies and allocations. Specific comments are provided in Appendix 1.

It is noted that many of the policies of the City’s adopted Core Strategy have been taken forward within the draft Local Plan. This is welcomed, as it will build on the continuing work being undertaken by our two local authorities on addressing cross-boundary and strategic matters.

Islington Council looks forward to further co-operation and engagement on the Local Plan as it is taken forward to adoption. If you have any questions regarding any matters raised in this letter please contact the Planning Policy Team at or on

Yours sincerely,

Sakiba GurdaPlanning Policy Team Manager

Appendix 1

Reference Comments

Policy DM1.1 (Protection of office accommodation)

Policy DM1.3 (Small and medium sized business units)

The support given to the existing office stock is welcomed. As the City office market spills over into the southern part of Islington, LB Islington affords similar protection to office stock and strategic sites in ‘fringe’ areas of the borough.

LB Islington also supports the approach to protecting units suitable for SMEs. It is considered that this is complementary to the approach taken by Islington’s adopted and emerging policies.

The North of the City (Section 3.5 and Policy CS5)

The spatial approach taken by the plan is supported, particularly in relation to The North of the City ‘Key City Place’.

LB Islington supports the description of this part of the City and considers that appropriate acknowledgement is given to cross-boundary linkages. We support the City’s intention to maintain the presence of Smithfield Market.

(NB we would point out that the term now used by the London Plan is Farringdon/Smithfield Intensification Area.)

Policy DM10.1 (New development)

LB Islington supports the approach taken by Policy DM10.1. This policy will ensure that visual context is given sufficient weight during the decision-making process, and will assist in implementing our shared objectives (e.g. managing local views to St. Paul’s Cathedral).

Policy DM11.3 (Location of hotels)

LB Islington recognises the need to balance hotel development with the protection of existing office space, and supports the approach taken by this policy to managing the development of hotels and apart-hotels in the City. It is considered that this will complement the approach taken by LB Islington’s emerging policies contained within the Finsbury Local Plan and Development Management Polices.

Policy CS13 (Protected views)

Policy CS14 (Tall buildings)

LB Islington supports the retention of Policy CS13. This will assist LB Islington in implementing its own emerging policy on local views which seek to retain views of St. Paul’s from specified viewpoints (consistent with the City’s St. Paul’s Heights view protection policy).

We also support the retention of Policy CS14. This policy complements Policy BC9 of Islington’s emerging Finsbury Local Plan, which identifies appropriate locations for tall buildings, based on urban design evidence which has taken full account of emerging tall building clusters within the City of London.

Policy CS18 (Flood risk)

Policy DM18.1 (Development in the City Flood Risk Area)

Policy DM18.2 (Sustainable drainage systems (SuDS))

Policy DM18.3 (Flood protection and climate change resilience)

LB Islington supports the strategic approach taken by Policy CS18 towards managing flood risk and the more detailed Development Management Policies which complement this. We consider that the approach proposed to be taken by the City to managing surface water flood risk will complement the way in which LB Islington will seek to manage flood risk through emerging DM Policies, and will minimiserisk from future flooding events.

Policy CS19 (Open spaces and recreation)

Policy DM19.1 (Additional open space)

Policy DM19.2 (Biodiversity and urban greening)

Policy DM19.3 (Sport/recreation)

Policy DM19.4 (Play areas and facilities)

LB Islington supports the strategic approach taken by Policy CS19 to managing and delivering open spaces and recreation facilities.

Like the City of London, many parts of Islington are deficient in open space, access to nature and recreation facilities. We support Development Management Policies DM19.1, DM19.2, DM19.3 and DM19.4, which will assist in reducing pressures on existing resources and deliver additional green spaces and recreation facilities.

Our ref: SGB/MH11/640

Your ref:

11 March 2013

Dear Sirs

CITY OF LONDON CONSULTATION ON DRAFT LOCAL PLAN – REPRESENTATION BY GVA

Thank you for consulting us as part of the consultation on the draft Local Plan. GVA acts on behalf

of various clients in the City of London providing planning and development advice.

GVA is supportive of a consolidated policy document that updates the adopted Core Strategy

(2011) and provides new detailed development management policies. However, there are a

number of thematic and specific considerations, which we have identified as key issues for our

clients and that we consider should be accounted for more fully in subsequent versions of the

emerging Local Plan. These are addressed in greater detail below.

Thematic Considerations

Growth

Commentary

There is currently a clear growth agenda at the national level seeking to optimise housing and

economic development. As part of the growth agenda, the Government published the National

Planning Policy Framework (NPPF) in March 2012, which sets an overarching emphasis on

encouraging new development and ensuring that it is not overburdened by the planning process.

At the heart of the NPPF is a presumption in favour of sustainable development, which should be

seen as a golden thread running through plan-making (Para 14). The NPPF states that the planning

process should proactively drive and support sustainable economic development to deliver the

homes, business and industrial units, infrastructure and thriving local places that the country needs

(Para 17). In doing so, planning should operate to encourage and not act as an impediment to

sustainable growth (Para 19).

GVA firmly supports these recent approaches and seeks to promote development coming forward

in the right place and at the right time to support growth. It is in this context that GVA considers

that the NPPF’s vision of growth should be emphasised further in policy at the local level.

City Planning Officer

Department of the Built Environment

City of London

PO Box 270

Guildhall

London EC2P 2EJ

gva.co.uk 2

Recommendations

Whilst the draft Local Plan makes reference to the NPPF’s presumption in favour of sustainable

development in the strategic policies, this is not fully reflected in the more detailed policies of the

Plan. Further consideration is therefore required to capture the spirit of the new policy guidance

and ensure that the Local Plan capitalises on the opportunities to deliver the growth that is

required over the plan period. A more detailed consideration of how specific policies of the Local

Plan can achieve this is set out below.

Flexibility

Commentary

Planning seeks to mediate competing pressures for the use and development of land. This is

regulated through legislation to ensure applications are guided by policy and managed flexibly. It

is for this reason that planning decisions should be taken in accordance with the adopted

Development Plan, unless material considerations indicate otherwise. This approach allows each

case to be assessed on its own merits and respond to its immediate context. The Local Plan should

make clear those situations in which it may be appropriate for flexibility to be applied in decision

making where other policy objectives can be delivered.

Recommendations

In its current form, the Local Plan does not provide sufficient flexibility and has made little

allowance in respect of either anticipated future growth or unwelcome contraction. Therefore, this

risks the ability of development to meet the identified needs of the City in the short and long term.

Each policy test should therefore make clear that, in those circumstances where it is neither

practical nor appropriate to comply with policy, the presumption in favour of sustainable

development will be applied and schemes will be assessed with regard to their overall benefits.

Further commentary on how specific policies in the Plan can provide sufficient flexibility to ensure

that future development meets the City’s world city objectives is set out below.

Viability

Commentary

The NPPF seeks to ensure the deliverability of development. In doing so, paragraph 173 states that

“to ensure viability, the costs of any requirements likely to be applied to development, such as

requirements for affordable housing, standards, infrastructure contributions or other requirements

should, when taking account of the normal cost of development and mitigation, provide

competitive returns to a willing land owner and willing developer to enable the development to

be deliverable”.

Viability is therefore a crucial consideration when determining applications for planning permission.

For this reason, GVA has worked with the Royal Institution of Chartered Surveyors in preparing the

guidance note on ‘Financial Viability in Planning’ (August 2012). It is accepted that, in certain

instances, financial planning obligations and other requirements may be necessary to mitigate

against the impacts of a development and ensure it is acceptable in planning terms. However, the

gva.co.uk 3

document advises that decision makers should balance these mitigation measures against

ensuring development is deliverable, having specific regard to scheme viability.

To avoid restricting the delivery of new development, schemes should be assessed on a site

specific basis. A less flexible approach has significant implications for development coming

forward. The costs incurred through the planning process therefore have a direct influence on the

amount, quality and use of land coming forward and could potentially inhibit development

proposals, which would otherwise have a positive impact for the City.

Recommendations

We consider that viability and deliverability are not given sufficient weight in the current drafting of

the Local Plan and this risks sufficient development in the City coming forward to maintain the

City’s position as the world’s leading international financial and business centre. We recommend

that an additional paragraph / section is included in the next version of the document to reflect

the importance of viability and, particularly, the requirement for development to provide

competitive returns to a willing land owner and willing developer to enable the development to

be delivered.

Specific Policies

Having regard to the thematic considerations addressed above, we set out representations to

specific policies in the draft Local Plan below based on particular topics.

Office

Core Strategic Policy CS1: Offices

We welcome the City’s aspiration to maintain a good supply of office floorspace (existing and with

extant planning permission) to meet occupier demand.

However, it is considered that the protection of existing office accommodation “where there are

strong economic reasons why the loss of office would be inappropriate” is overly restrictive. There

are likely to be particular instances where alternative uses that meet identified needs, such as

residential and hotel, are of greater benefit to the City by meeting its strategic objectives than the

retention of existing office stock.

In accordance with the NPPF, the policy should be sufficiently flexible so that development can

respond to the relative supply and demand of office space, as well as that of other land uses, in

order that the City is able to continue to compete with the other world financial centres.

Policy CS1 should therefore be amended to remove the blanket protection to existing office

accommodation and to promote alternative uses on appropriate sites, where the benefits of the

alternative uses outweigh the retention of the existing office accommodation.

Policy DM1.1: Protection of Office Accommodation

In seeking to implement the strategic policy, Policy DM1.1 sets out instances where the loss of

existing office accommodation would be inappropriate. This includes where a building or site is

considered to be suitable for office use and where “there is demand in the office market or long

term need”.

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It is acknowledged that there may always be demand from certain occupiers for office stock of

different types and quality. However, it is considered that, in some circumstances, this demand

may be better met elsewhere. In appropriate locations, the provision of alternative uses in place of

existing office stock can make better use of land within the City and achieve better planning

outcomes overall, such as new housing or townscape improvements that could not otherwise be

achieved by retention of the existing office stock.

There are also likely to be instances where an existing office building can be redeveloped to

provide a more efficient building that provides a higher density of employment within a lower

amount of floorspace. In such instances, this may only be deliverable by the provision of more

viable alternative uses, where appropriate, which can provide the competitive returns required to

facilitate the provision of better quality office accommodation and any other planning benefits,

such as townscape improvements. As such, the policy should not be so restrictive as to prevent the

most innovative and efficient use of the limited land supply available within the City.

Policy DM1.2: Assembly and Protection of Large Office Development Sites

We welcome that the City will promote the assembly and development of sites for large office

schemes in appropriate locations. However, there may be cases where there are no realistic

prospects of a large site coming forward for comprehensive development due to particular

constraints, such as land ownership patterns and environmental considerations. As such, more

piecemeal development may be a better response in seeking to meet the City’s development

targets and make the best use of sites.

In order not to unduly restrict growth within the City, the relevant section of the policy should be

amended as follows:

“The City Corporation will resist development and land uses in and around potential large sites that

would jeopardise their future assembly, development and operation, unless there is no realistic

prospect of the site coming forward for comprehensive development”.

Policy DM1.5: Mixed Uses in Commercial Areas

The principle of a mix of uses within office developments is supported. The specific mix and

quantum of uses brought forward in a development should be determined by the market in order

not to run the risk of undermining the viability of development or the vitality of the wider City

through vacancy.

The supporting text notes that there are parts of the City, which have an established special land

use or townscape character that would not benefit from the introduction of mixed uses at street

level, including tranquil open spaces and buildings within Conservation Areas whose character

would be harmed by conversion to other uses. However, the provision of a mix of uses in such

locations should not be restricted by policy and should be based on the particular merits of a

scheme having regard to the need to provide uses and services that can support the projected

growth within the City.

gva.co.uk 5

Housing

Core Strategic Policy CS21: Housing

It is noted that Policy CS21 of the draft Local Plan proposes to concentrate new housing “in

identified residential areas” and has removed the reference in the adopted Core Strategy, which

supports new housing near to existing residential areas.

It is considered that this approach is too restrictive and will constrain the ability of the City to meet

and exceed the London Plan’s minimum housing requirement. The NPPF requires planning to

proactively drive and support sustainable economic development through the delivery of new

homes (Para 17).

There may be opportunities to explore and develop innovative design solutions which enable

residential development to be brought forward alongside commercial uses without undermining

the City’s primary business function. Furthermore, the provision of new housing in appropriate

locations outside of “identified residential areas” can contribute to achieving other policy

objectives, such as maintaining and enhancing the viability and vitality of the City, particularly in

the evenings and at weekends, by providing a mix of uses.

As such, the following amendment to Policy CS21 is suggested:

“1i) Guiding new housing development to identified residential areas or other appropriate

locations where innovative design solutions create the opportunity to deliver residential

development alongside commercial uses without prejudicing the primary business function of the

City”.

Where it is considered viable and practical to provide affordable housing on-site or off-site as part

of a residential development, the policy should take account of the change to the definition of

affordable housing, set out in the NPPF and the London Plan, to include the affordable rent

product in order to maximise the amount of affordable housing that can be viably delivered.

Furthermore, the precise tenure split should be determined on a case by case basis having regard

to the site characteristics and viability. The policy should be updated to reflect this.

Policy DM21.1: Location of New Housing

It is considered that the policy should be amended on the same basis as set out above to allow

residential development in appropriate locations outside of identified residential areas.

Retail

Policy DM20.1 Principal Shopping Centres

We consider that the protection of existing retail frontage and floorspace within the Principal

Shopping Centres (PSCs) should be subject to market demand as this could compromise the

viability of development proposals, undermining the City’s world class city objectives.

gva.co.uk 6

In addition, we consider that policies to protect retail space also risk sustaining vacancy, which

would have a detrimental impact on the vitality of the City as a destination for workers, residents

and visitors.

The policy is also overly prescriptive as it seeks to maintain at least 70% of retail frontage within a

PSC in A1 use. The precise mix of retail uses within a retail frontage should be based on market

demand in order not to risk vacancy or compromise the viability of development proposals.

As such, the policy should be amended to allow the loss of retail frontage and floorspace within

the PSCs where it is demonstrated that there is no demand. The balance of retail uses within a retail

frontage should also be based on market demand.

Policy DM20.2: Retail Links

We do not consider that the blanket protection of retail frontage and floorspace within the Retail

Links is appropriate. The mix of uses within the Retail Links should be subject to demand in order to

ensure that development is deliverable and the policy should be updated to reflect this.

Policy DM20.3: Retail Uses Elsewhere in the City

The acknowledgement of market demand when considering planning applications for the loss of

retail units outside the PSCs and Retail Links is supported. However, it is considered that the

requirement for active marketing for a minimum of 12 months at reasonable terms is overly

prescriptive. A lack of demand could be demonstrated by other evidence, such as an assessment

of supply and demand or evidence that the retail unit is no longer suitable for its purpose. In order

not to risk the sustained vacancy of retail units within the City, the policy should be amended to

remove the requirement for a 12 month marketing exercise.

Student Housing

Policy DM21.7: Student Housing and Hostels

As stated above, it is considered that alternative uses, such as student housing, should be

promoted on appropriate office sites, where the benefits of the alternative uses outweigh the

retention of the existing office accommodation. This will result in the better use of sites and help

ensure that the City is able to continue to compete with the other world financial centres. As such,

the policy should be amended to promote student housing on existing office sites, where the

benefits of student housing outweigh the retention of the existing office accommodation.

It is also considered that the policy is overly restrictive as it requires that proposals for student

housing are supported by an identified further or higher educational institution for the housing of its

own students. This is likely to constrain supply and does not reflect the Government’s growth

agenda as it limits the number of parties who can bring development forward. Instead, the policy

should note that proposals for student housing should be supported by evidence of an identified

need.

gva.co.uk 7

Thames and the Riverside

Core Strategic Policy CS9: Thames and the Riverside

It is noted that Policy CS9 removes the reference in the adopted Core Strategy to permitting

residential and hotel development within the Thames Policy Area and, instead, seeks to maintain

the office presence on the river frontage in the form of an ‘office gateway’ between Water Lane

and Queenhithe.

Whilst the contribution of office stock in this location to the business function of the City is noted, it is

considered that the amendments to Policy CS9 to restrict alternative uses, such as residential and

hotel, are not sufficiently flexible and are likely to constrain development. Proposals for alternative

uses within the area should be considered on a case by case basis. It is noted that sites fronting the

River may be particularly appropriate for residential development, as the River can act as a buffer

to enhance residential amenity. This buffer means that residential development in this location is

less likely to prejudice the delivery of surrounding office sites than other sites within the City that are

more constrained. The provision of residential and hotel uses will contribute to a vibrant mix of uses

within this important City location. The Local Plan should therefore not restrict appropriate

development in this area.

As such, the ‘office gateway’ location on Figure I should be removed and Policy CS9 should be

amended to allow alternative uses in appropriate locations.

Heritage

Policy DM12.1: Managing Change Affecting All Heritage Assets and Spaces

The policy seeks to resist the loss of routes and spaces that contribute to the character and historic

interest of the City. It is noted that there may be instances where the loss of such routes or spaces is

necessary to achieve other strategic objectives, such as optimising the delivery of office

accommodation. This could be mitigated by, for example, the provision of new public space that

is of wider benefit.

As such, the policy should be amended to state that where proposals involve the loss of routes and

spaces that contribute to the character and historic interest of the City, applications will be

considered on a case by case basis having regard to the overall benefits of the scheme and,

particularly, the extent of any mitigation.

Policy DM12.2: Development in Conservation Areas

The policy states that the loss of heritage assets that make a positive contribution to the character

and appearance of a conservation area will be resisted.

In order to be in conformity with the NPPF (Para 133), the policy should make allowance for the

substantial harm or total loss of significance of a designated heritage asset, where it can be

demonstrated that the substantial harm or loss is necessary to achieve substantial public benefits,

as well as strategic City of London objectives, that outweigh that harm or loss, or where all of the

tests set out in Para 133 of the NPPF apply.

The policy should also refer to Para 134 of the NPPF, which states that where a development

proposal will lead to less than substantial harm to the significance of a designated heritage asset,

gva.co.uk 8

this harm should be weighed against the public benefits of the proposal, including securing its

optimum viable use.

Policy DM12.3: Listed Buildings

The policy should be updated in line with the NPPF, as set out above, to allow the harm or loss of

significance of listed buildings where the proposal meets the tests set out in Paras 133 and 134 of

the NPPF.

Tall Buildings

Core Strategic Policy CS14: Tall Buildings

We welcome that the City of London will continue to encourage tall buildings. We encourage the

City to continue to define the Eastern Cluster loosely and consider that it has the potential to

include all sites outside the areas identified as inappropriate for tall buildings.

We consider that, subject to demonstrating a townscape case, there is an opportunity for further

tall buildings to act as ‘outliers’ to the cluster, enhancing the City overall.

In addition, we consider that there may be an opportunity to put forward a convincing case for

tall buildings, albeit of a smaller scale, outside the cluster, including in more sensitive environments,

such as Conservation Areas. Proposals should be considered on their individual merits, taking

account of the wider benefits of the scheme and the characteristics of the site and surroundings.

Environmental

Policy DM15.4: Offsetting of Carbon Emissions

Any contributions sought towards the off-setting of carbon emissions should meet the criteria set

out in the NPPF, which states that planning obligations should only be sought where they meet all

of the following tests:

- Necessary to make the development acceptable in planning terms;

- Directly related to the development; and

- Fairly and reasonably related in scale and kind to the development (Para 204).

It is acknowledged that there are alternative methods of assessing the energy performance of a

development scheme, such as actual end energy usage. The outcomes of these methods should

also be taken into account when determining whether a contribution towards the off-setting of

carbon emissions is appropriate and necessary to make a development acceptable, in

accordance with the NPPF tests set out above.

Summary

GVA wishes to ensure that the emerging policy context for the City of London enables the delivery

of optimal schemes, which make the best use of the site and deliver better outcomes for the City.

It is therefore essential that the Local Plan provides a clear and succinct framework, giving

developers the confidence to invest and facilitate high quality development, with recognition

that, to promote sustainable development, a ‘competitive return’ is necessary.

gva.co.uk 9

We look forward to confirmation of receipt of these representations at the earliest opportunity and

would welcome the opportunity to meet with officers to discuss any part of our representations as

required. We also reserve the right to request to be heard by the appointed examiner at the public

examination.

If you have any queries, please contact Martin Hall (020 7911 2621) or Stephen Brown (020 7911

2335) of these offices.

Yours faithfully

GVA

DRAFT LOCAL PLAN.

As a City Resident I would like to make some comments on the Local Plan.

HEALTH.

It is anticipated that the number of workers and residents will grow over the next few years. With only one G.P.centre, The Neaman Practice, and the inadequate Minor Injuries Clinic at Bart’s, we need extra medical facilities within the City. This would enable workers to access advice during the working day rather than having to take leave to visit health care near home and residents could also be seen locally saving complicated journeys to other boroughs in London, saving the cost of using hospital transport.

PUBLIC TOILETS,

Considering the number of workers, residents and visitors in the City, public toilets are in short supply. Clean, accessible toilets are an essential part of everyday life and many more of these facilities are required all over the City. Business premises could be encouraged, just like on the continent, to allow the public to use their toilets.

OPEN SPACES

As stated in the draft the City’s open spaces will be stretched over the coming years so perhaps innovative rooftop gardens with easy access for all could be incorporated within future developments, an opportunity to create greener, environmentally friendly areas.to make us an even more pleasant place to visit. Just a few minutes daily in a garden environment improves well being.

BORIS BIKES

We are now seeing more and more bicycles in the City and bicycle parks. It would be an idea to locate the bike parks on the road rather than on the pavements, to discourage cyclists to cycle on the pavement, far too many of them do. Loss of any pavement space should be discouraged. On the corner of Golden Lane and Beech Street there is a” pull in area” on the road for the bikes This seems far more sensible, just like a “pull in” area for buses or taxis. Cyclists can sometimes be a danger to pedestrians.

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.

I am a disabled person and had intended to comment purely with disability as my main issue but my comments actually cover issues able bodied or disabled bodies relate to. Lifelong approach should be adopted to all plans as one never knows what the future holds.

All future planning should be undertaken with accessibility in mind. Access for everyone to everything. This just takes common sense and the advice of people who are willing to provide it. It is a privilege to live in the City and hopefully to work in. With thoughtful planning it could emerge as the most desirable financial centre for working and residing in.

Nicholeen Hall

City Resident.

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Date: 4 March 2013 Our ref: 75286 Your ref:

City Planning Officer Department of the Built Environment City of London PO Box 270 Guildhall EC2P 2EJ BY EMAIL ONLY

Customer Services Hornbeam House Crewe Business Park Electra Way Crewe Cheshire CW1 6JC

T 0300 060 3900

Dear Sir/Madam, City of London Draft Local Plan Thank you for your correspondence in respect of the above consultation document, seeking the views and of Natural England. Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development. Natural England must be consulted by the Local Planning Authority on planning applications that may impact on nationally protected nature conservation sites, and applications that require an Environmental Impact Assessment. The following is provided in response to the City of London Draft Local Plan Consultation Document. General Strategy Natural England support inclusion of the Planning Inspectorate Model Policy on the Presumption in Favour of Sustainable Development as a Core Strategic Policy. Spatial Strategy, Vision and Strategic Objectives Natural England support the ambition detailed within Strategic Objective 4; to ensure the City of London remains at the forefront of action in response to climate change and other sustainability challenges. Strategic Objective 5 (SO5) seeks to ensure provision of inclusive facilities and services as detailed within SO5 although it fails to address, the desire to increase the number of open spaces for public access as set out within the City Communities Vision. Natural England urge inclusion of the Vision within the objective as increasing the provision of open spaces could be beneficial to the natural environment by increasing local biodiversity and could contribute towards public health objectives. A World Financial and Business Centre Policies CS1 through CS4 and DM policies DM1.1 through DM1.5 detail how the City of London proposes to address SO1. The aim of SO1 is to maintain the City’s position as the world’s leading international financial and business centre. CS1 (Offices) and DM1.1 (Protection of Office Accommodation) aim to increase the supply of offices within the City. Natural England welcome CS1 criteria 5 which seek to protect existing office accommodation, in addition to the economic benefits outlined within the policy, this could also reduce the pressure for development on less sustainable sites.

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Natural England welcome policies DM1.2 through DM1.5 which seeks to ensure a sustainable use of the urban environment. Policy DM1.2 (Assembly and Protection of Large Office Development Sites), promotes the development of sites for large office schemes only in appropriate locations. Policy DM1.3 (Small and Medium Sized Business Units) encourages the development of offices that are flexible and adaptable, thus suitable for sub-division to create smaller and medium sized business units. This is considered to be a sustainable design solution which makes the best use of available space. Policy DM1.4 (Temporary Alternative Use of Vacant Office Buildings and Sites) permits the temporary use of vacant office buildings and sites by other uses where they would not produce unacceptable amenity conflicts. This ought to promote the use of under used buildings and sites, therefore reduce pressure for new development on less sustainable sites. Policy DM 1.5 (Mixed Uses in Commercial Areas) promotes a mix of commercial uses within office developments, therefore providing accessible, local support services for businesses and workers. Policy CS2 (Utilities Infrastructure) and DM2.1 (Infrastructure Provision and Connection) seek to co-ordinate infrastructure planning and delivery. Natural England welcome the approach outlined in criteria 1 to minimise the demand for power, water and utility services by ensuring demand management measures are incorporated within all development. This approach to reduce the demand on resources will assist the overall strategic approach to reducing greenhouse gas emissions. Policy CS3 (Security and Safety), details how design can promote a secure and safe urban environment. DM3.1 (Self-Containment in Mixed use Developments) encourages primary and secondary access points for mixed-use developments ensuring each use is separate and self-contained. DM3.3 (Crowded Places) seeks to address issues of counter-terrorism, DM3.4 (Traffic Management) seeks to implement traffic management procedures as security measures. Natural England has no comment on these policies. Natural England welcome the requirement detailed within Policy DM3.2 (Security Measures in new Developments and Around Existing Buildings) of an environmental impact assessment of security measures. Policy CS4 (Planning Contributions) seeks to manage the impact of new development through seeking contributions on or off site. Natural England support the range of provisions the contributions will be generated for, i.e. local community facilities, environment improvements, measures to adapt to climate change and transport service improvements Key City Places Core Strategic policies CS5 through CS9 address how delivery will be encouraged at five strategic areas. CS5 (The North of the City) seeks to ensure the City benefits from substantial public transport improvements, this is supported by Natural England as it ought to encourage sustainable transport options thereby contributing towards reducing CO2 emissions. Policy CS6 (Cheapside and St. Paul’s) seeks to develop the Cheapside and St Paul’s area as the City’s ‘high street’. Natural England welcome the range of criteria detailed within policy CS6 and in particular, criteria four and eight. These criteria encourage an increase of pedestrian links and the enhancement of the pedestrian environment. Enhanced pedestrian links and pedestrian environment may encourage walking as a means of sustainable travel which will help to reduce CO2 emissions by reducing the reliance on the private car as the preferred transport mode.

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Policy CS7 (Eastern Cluster) seeks to promote the eastern cluster area for office and employment development and tall buildings whilst enhancing streets and public realm and creating new open space and public transport. Natural England supports the priorities within the policy to create open space and public transport links as these can be both beneficial to the local environment. Policy CS8 (Aldgate) aims to regenerate the amenities and environment of the Aldgate area for business, residents, visitors and students by promoting development. Natural England note priority 3 and 4 of policy CS8 which aim to improve transport connections and pedestrian links. This may assist in promoting sustainable transport options as the favoured transport mode. Priority 4 seeks to enhance the public realm; this gives the opportunity to incorporate planting and greenery into the local environment which could contribute towards delivering of the City’s biodiversity duty. Policy CS9 (Thames and the Riverside) seeks to ensure that the city capitalises on its unique riverside location. Natural England note The River Thames is designated as a site of Metropolitan Importance for Nature Conservation (SMINC) and therefore requires an element of protection. Natural England welcome criteria 2 of the policy which seeks to further the aims of the Riverside Walk Enhancement Strategy through improving opportunities for biodiversity in line with the City of London Habitat Action Plan for the Thames foreshore. Natural England support criteria to resist permanent mooring of vessels and welcome the aim to maintain public and private access points to the River Thames from both land and water. This will promote public use of the open space and potentially The Thames Path National Trail. City Culture and Heritage Core Strategic Policies CS10 through CS14 and Development Management Policies DM10.1 through DM 12.5 address the City’s response to SO3; to promote a high quality of architecture and street scene appropriate to the City’s position at the historic core of London. Natural England has no comment on these policies. Policy CS10 (Design) and DM10.1 (New Development) promote high standard and sustainable design of buildings, streets and spaces. Natural England welcome the intention within CS10 to ensure development is designed to be sustainable i.e. ensuring access needs are met and delivering improvement of the environment, amenities, open space and play areas this could help encourage use of open space and could be beneficial to public health. Natural England welcomes the inclusion of Policies DM10.2 (Design of Green Roofs and Walls) and DM10.3 (Roof Gardens and Terraces). DM10.2 encourages the installation of green roofs on all appropriate developments. Green roofs can be beneficial to local biodiversity and assist meeting climate change adaptation objectives. DM10.3 encourages high quality roof gardens and terraces roof gardens, which also have the potential to improve the local biodiversity. DM10.4 (Environmental Enhancement) details how the City will work with developers to design and implement enhancement schemes for highways, public realm and other spaces. Natural England welcome this policy as it promotes sustainable design and landscaping which includes sustainable drainage, accessible and inclusive design. Natural England has no comment in regards to policies DM10.5 (Shop fronts) or DM10.6 (Advertisements). Policy DM10.7 (Daylight and Sunlight) resists development which would reduce day/sun light on open spaces, Natural England support this policy. Natural England support Policy DM10.8 (Access and Inclusive Design) which aims to achieve an environment that meets the highest standards of accessibility and inclusive design in all developments. Policy CS11 (Visitors, Arts and Culture) and DM11.1 (Protection of Visitor, Arts and Cultural Facilities) support the use of existing venues for cultural events, and seeks to maintain existing cultural facilities. Natural England welcome this initiative as it reduces the pressure for new development on less sustainable sites.

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DM11.2 (Public Art) seeks to enhance the public realm by protecting works of art. This may encourage the use of public open spaces and so may benefit public health, therefore Natural England welcome the policy. Natural England has no comment on policy DM11.3 (Location of Hotels). Policy CS12 (Historic Environment) and DM12.1 (Managing Change affecting all Heritage Assets and Spaces) seeks to conserve and enhance the City’s heritage assets and their settings, within which sustainable development including climate change adaptation measures must be sensitive to heritage assets. Natural England notes the challenging balance between meeting climate change adaptation measures and protecting heritage assets. DM12.3 (Listed Buildings) resists the demolition of listed buildings where possible preferring changes of use or alteration only. Natural England support Policy DM12.5 (Historic Park and Gardens) as it seeks to resist development which would adversely affect gardens of special historic interest, historic gardens and parks, which may be of ecological value. Policy CS13 (Protected Views) seeks to ensure the protection and enhancement of significant views including river prospects. This is welcomed as it may encourage public use of the riverside open space and increased physical fitness. Policy CS14 (Tall Buildings) seeks to ensure tall buildings are only delivered on appropriate sites; Natural England has no comment in response to this policy. Environmental Sustainability Policies CS15 through CS18 and DM 15.1 through 18.3 detail how the City of London aims to address Strategic Objective 4 incorporating sustainable development and climate change, public transport, streets and walkways, waste and flood risk issues. Natural England support Policy CS15 (Sustainable Development and Climate Change) and DM 15.1 (Sustainability Requirements). The overall aim of these two policies is to ensure a sustainable approach to development within the City. CS15 promotes the reuse of vacant or underused buildings over redevelopment. Where redevelopment is proposed, high sustainability standards are required in the design, construction and operation phases. Furthermore climate change adaptation measures are encouraged in all development. Policies DM 15.2 (Energy and CO2 emission assessments), DM 15.3 (Low and Zero Carbon Technologies) and DM 15.4 (Offsetting Carbon Emissions) encourage energy assessments for all major development proposals and the achievement of zero carbon buildings. DM 15.3 encourages developers to connect to existing decentralised energy networks, and DM15.4 encourages all feasible and viable on or near-site options for carbon emission reduction. Natural England support the intention to balance the emissions produced either through offsetting or other building practices as lower emissions help protect the future of the natural environment. Natural England welcomes Policy DM15.5 (Climate Change Resilience and Adaptation) which requires developers to provide Sustainability Statements with all major developments to demonstrate resilience to climate change. Policies DM 15.6 (Air Quality), DM 15.7 (Noise Pollution) and DM 15.8 (Contaminated Land) address the impact of development on these three issues. Natural England welcome the requirement of developers to consider the impact of their proposals on air quality and those which are likely to have an adverse effect on the City’s nitrogen dioxide levels will be resisted. Noise pollution by sensitive areas such as open spaces may have a detrimental impact on the local ecology therefore the intention to minimise any noise conflict is also welcomed.

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Natural England welcome the intention set out within Policy CS16 (Public Transport Streets and Walkways) to ensure new development will improve the sustainability and efficiency of travel in, to, from and through the City. Improving public transport encourages overall use, which is beneficial to the natural environment by reducing carbon emissions. Natural England supports this policy. Policies DM16.1 (Transport Impacts of Development), DM16.2 (Pedestrian Movement), DM 16.3 (Cycle Parking) and DM 16.4 (Facilities to Encourage Active Travel) encourage transport assessments to be prepared to accompany development proposals, these address the impact on the pedestrian environment, cycling infrastructure and the public transport, DM16.3 states onsite cycle parking must be provided in accordance with local standards and DM 16.4 aims to encourage active travel. These are welcomed by Natural England as they help encourage the uptake in the use of sustainable transport modes. Policy CS 17 (Waste) seeks to ensure the City’s waste is minimised where possible, and managed at the nearest available location. This is welcomed by Natural England. Policy CS18 (Flood Risk) intends to ensure the City remains at low risk from all types of flooding. Natural England support CS18 as flooding will cause adverse effects to the existing biodiversity within the flood risk area. Natural England welcomes policies DM 18.1 (Development in the City Flood Risk Area), DM 18.2 (Sustainable Drainage Systems SUDS) and DM 18.3 (Flood Protection and Climate Change Resilience), support CS18. City Communities Policies CS19 through CS22 and DM policies19.1 through 22.2 address the City’s response to Strategic Objective 5 which is to ensure the provision of inclusive facilities and services. Policy CS19 (Open Spaces and Recreation) seeks to encourage healthy lifestyles through improved access to open space, increasing the amount and the quality of open spaces and green infrastructure and enhancing biodiversity. This policy is strongly supported by Natural England. This policy will have various beneficial impacts on public health and the natural environment. Natural England also welcome policies DM 19.1 (Additional Open Space), DM 19.2 (Biodiversity and Urban Greening), DM 19.3 (Sport and Recreation) and DM19.4 (Play Areas and Facilities) which all support this core strategic policy. Policy CS20 (Retailing) aims to improve the quantity and quality of retailing and the retail environment. Natural England welcome criteria number four of the policy which seeks to improve the pedestrian environment and pedestrian links between retail centres. This may encourage movement by foot, linking in to the City’s pedestrian and sustainable transport objectives. Policy CS21 (Housing) seeks to protect the existing housing stock. CS21 is supported by DM policies DM 21.1 through DM21.7 which address amongst other issues; the location of housing, directing housing development to residential areas and loss of housing which resists the loss of existing stock. These are welcomed by Natural England as retaining the existing housing provision may reduce the pressure for development on less sustainable locations. Policy CS22 (Social Infrastructure and Opportunities) seeks to maximise the public access to suitable services and facilities within the City, this will be achieved by protecting and enhancing existing services and facilities and where there is an identified need providing new services. Policies DM 22.1 (Location and Protection of Social and Community Facilities) and DM 22.2 (Provision of Public Toilets) both support this core strategic policy. These policies are all supported by Natural England as local, accessible services and facilities may reduce the pressure for commuting. We really value your feedback to help us improve the service we offer. We have attached a feedback form to this letter and welcome any comments you might have about our service.

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For clarification of any points in this letter, please contact David Hammond on For any new consultations or issues, please contact Yours faithfully David Hammond Lead Advisor Land Use Ops Team

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Date: 27 March 2013 Our ref: 81314 Your ref:

Ms Janet Laban Senior Planning Officer Department of the Built Environment City of London BY EMAIL ONLY

Customer Services Hornbeam House Crewe Business Park Electra Way Crewe Cheshire CW1 6JC

T 0300 060 3900

Dear Ms Laban, City of London Draft Local Plan Sustainability Appraisal Thank you for your recent correspondence in respect of the above consultation document, seeking the views and comments of Natural England. Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development. The Corporation’s aspiration to provide additional open space, green roofs, Sustainable Urban Drainage systems (SUDs), thereby enhancing and increasing the biodiversity opportunities for the area are welcomed and supported. Under Chapter 3 – figure 4 the list of other plans and programmes relevant to the City Local Plan, includes the documents and plans that Natural England would expect to see under this section. The areas and issues considered are also those that Natural England would wish to see considered in such a document (Climate Change, Flood Risk and Biodiversity – paragraphs 3.2.5, 3.2.6 and 3.2.9 respectively). Figure 7 – Chapter 4 identifies the Corporation’s Sustainability objectives, twenty one is total. The sustainability Objectives listed can be broadly supported, and in particular the following; 11) To maintain and enhance biodiversity; 15) To anticipate, prepare for and adapt to the impacts of climate change. Appendix 5: Habitats Regulation Assessment Screening The approach and methodology used in the Habitats Regulation Assessment screening are appropriate and in line with the advice that would be offered by Natural England. The conclusion that no likely significant effects are considered to impact on relevant Natura 2000 sites can be agreed. Therefore, and in respect of the City of London Local Plan, there is no need to undertake and Appropriate Assessment. We really value your feedback to help us improve the service we offer. We have attached a feedback form to this letter and welcome any comments you might have about our service.

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For clarification of any points in this letter, please contact David Hammond on For any new consultations or issues, please contact Yours sincerely Daviod Hammond Lead Advisor Land Use Ops Team