AGENDA

Meeting:

OPDC Planning Committee

Date:

Wednesday 6 January 2016

Time:

6.00 pm

Place:

Committee Room 5, City Hall, The Queen's Walk,

London, SE1 2AA

Members of the OPDC Planning Committee are hereby notified and requested to attend the
meeting of the Planning Committee at 6.00 pm on Wednesday 6 January 2016 to transact
the business set out below.
This meeting will be open to the public, except for where exempt information is being
discussed as noted on the agenda. A guide for the press and public on attending and
reporting meetings of local government bodies, including the use of film, photography,
social media and other means is available at
https://www.london.gov.uk/sites/default/files/Openness-in-Meetings.pdf
Victoria Hills, Chief Executive Officer
Thursday 24 December 2015

Members of the Planning Committee:

William McKee (Chair)
Gordon Adams
Councillor Wesley Harcourt
Colin Haylock

Councillor Sarah Marquis

Stuart Robinson
Councillor Hitesh Tailor

Apologies for Absence

Declarations of Interest

Minutes of Previous Meeting (Pages 1 - 16)

Matters Arising

Draft Local Plan (Pages 17 - 750)

Scheme of Planning Delegations (Pages 751 - 766)

Statement of Community Involvement (Pages 767 - 804)

Planning Applications Received since 27 October 2015 (Pages 805 - 808)

Any Urgent Business

10

Date of the Next Meeting

The next meeting is scheduled to take place on Wednesday 17 February 2016 at
6pm in Committee Room 4, City Hall.

Agenda Item 3

MINUTES

Meeting: OPDCPlanningCommittee

Date:

Thursday12November2015

Time:

6.00pm

Place:

CommitteeRoom2,CityHall,TheQueen'sWalk,London,
SE12AA

Present:

William
McKee
CBE
(Chair)

Councillor
Wesley
Harcourt

Colin
Haylock

Councillor
Sarah
Marquis

Councillor
Peter
Mason

Stuart
Robinson



InAttendance:
Mick
Mulhern,
Director
of
Planning,
OPDC;

Claire
O'Brien,
Head
of
Development
Management,
OPDC;

Tom
Cardis,
Head
of
Planning
Policy,
OPDC;

Peter
Farnham,
Principal
Planning
Officer,
OPDC;

Dawn
Blackwell,
TfL
Legal;
and


Laura
Pelling,
OPDC
Committee
Secretary.







ApologiesforAbsence(Item1)

1


1.1

Apologies
for
absence
were
received
on
behalf
of
Gordon
Adams
and
Councillor
Tailor,
for

whom
Councillor
Mason
attended
as
a
substitute.





DeclarationsofInterest(Item2)

2


2.1

There
were
no
declarations
of
interest.





MinutesofPreviousMeeting(Item4)

3


3.1

DECISION

ThattheminutesofthePlanningCommitteemeetingheldon2September2015be
signedbytheChairasacorrectrecord. 










Page 1

4
4.1

5

5.1

5.2







5.3







6
6.1



6.2

6.3

MattersArising(Item3)



A
Member
asked
about
progress
on
the
delivery
of
the
Retail
and
Leisure
Needs
Study.
The

Director
of
Planning
confirmed
that
key
headers
from
the
study
would
be
brought
to
the

Committee
for
consideration,
and
that
the
final
study
would
form
part
of
the
consultation
on

the
Local
Plan.


GreaterLondonAuthorityOldOak&ParkRoyalOpportunityAreaPlanning
Framework(OAPF)(Item5)



The
Committee
received
the
report
of
the
Director
of
Planning,
which
provided
an
update
on

the
Boards
consideration
of
the
Old
Oak
&
Park
Royal
Opportunity
Area
Planning

Framework
(OAPF).
The
final
version
of
the
OAPF
had
been
submitted
to
the
Mayor
for

adoption.


The
Director
of
Planning
noted
that
the
OAPF
had
been
considered
by
the
Mayor
on
4

November
2015
and
had
since
been
approved.
The
final
OAPF
had
now
been
published
and

could
be
viewed
here:

https://www.london.gov.uk/sites/default/files/OAPF%20FOR%20WEB.pdf

DECISION
ThatthefinalversionoftheOldOak&ParkRoyalOpportunityAreaPlanning
Framework(OAPF)whichhadbeenagreedbytheBoard,includingtheminor
revisionsmadefollowingconsiderationbytheBoard,benoted.
ConsultationtoDesignateCumberlandParkFactoryConservationArea(Item6)



The
Committee
received
the
report
of
the
Director
of
Planning
recommending
that
the
Board

agree
to
a
public
consultation
on
the
proposal
to
designate
69-91
Scrubs
Lane,
formerly

known
as
Cumberland
Park
Factory,
as
a
Conservation
Area.


The
Principal
Planning
Officer
gave
a
presentation
to
the
Committee,
attached
in
Appendix
1.
The
Committee
was
asked
to
recommend
that
the
Board
agree
the
public
consultation
at

its
meeting
on
26
November
2015.
If
approved,
the
consultation
would
run
from
January
to

March
2016,
with
a
further
report
back
to
the
Planning
Committee
and
the
Board
in
spring

2016.


A
number
of
Members
voiced
support
for
the
proposal.
A
Member
asked
about
the
impact
of

the
conservation
area
on
adjacent
buildings.
The
Principal
Planning
Officer
stated
that

nearby
buildings
would
have
to
be
considered
within
the
setting
of
the
conservation
area.

Another
Member
asked
about
the
potential
risk
of
the
area
being
redeveloped
prior
to
the

Conservation
Area
being
designated.
The
Director
of
Planning
noted
that
this
was
a

possibility,
but
officers
were
working
with
current
landowners
in
developing
the
proposal.

Officers
were
also
working
with
Historic
England
who
had
assessed
the
area
and
found
that

this
site
was
suitable
as
a
conservation
area.
A
Member
asked
about
the
potential
for
Local

Listing
of
buildings
within
the
conservation
area.
The
Principal
Planning
Officer
stated
that
it

would
be
possible
to
consider
local
listings
in
the
future
based
on
the
merit
of
each
building.

Page 2

6.4



6.5







The
Chair
added
his
own
support
for
the
proposal,
and
noted
that
it
demonstrated
that
the

Corporation
was
looking
to
preserve
quality
sites
in
the
area
as
well
as
pursuing

developments
elsewhere.



DECISION
That:
a)

b)

7

7.1

7.2

7.3

7.4

7.5

7.6







TheproposaltoconsultonthedesignationoftheCumberlandParkFactory
ConservationAreabenoted;and
TheBoardberecommendedtoagreetoapublicconsultationonthe
proposeddesignation.

ApplicationtoDesignateHarlesdenNeighbourhoodPlanningForumand
NeighbourhoodArea(Item7)



The
Committee
received
the
reports
of
the
Director
of
Planning
regarding
the
application

submitted
to
designate
the
Harlesden
Neighbourhood
Area
and
Neighbourhood
Planning

Forum
within
the
Corporations
area.
The
Principal
Planning
Officer
gave
a
presentation
to

the
Committee,
attached
at
Appendix
1.

The
Principal
Planning
Officer
noted
that
the
majority
of
the
Neighbourhood
Area
fell
within

the
London
Borough
of
Brent
which,
as
a
result,
led
the
consultation
on
the
proposal.
LB

Brent
had
designated
the
Neighbourhood
Area
and
Planning
Forum,
for
those
areas
that
fell

within
Brent,
on
28
September
2015.


Five
responses
to
the
consultation
had
been
received,
all
supporting
the
proposal.
Officers

concluded
that
the
application
was
in
conformity
with
the
Town
and
Country
Planning
Act

1990
(as
amended)
and
relevant
Neighbourhood
Planning
Regulations.
Accordingly,
the

Committee
was
asked
to
recommend
to
the
Board
to
approve
the
designation
for
the

Neighbourhood
Area
and
Forum.


In
response
to
a
question
about
the
co-operation
between
the
Corporation
and
LB
Brent,
the

Director
of
Planning
stated
LB
Brent
had
led
on
this
work
to
date,
but
officers
would
take
a

leading
role
regarding
issues
concerning
Willesden
Junction
which
fell
within
the

Corporations
land.



A
Member
asked
about
the
Neighbourhood
Forums
role
in
determining
how
the
Community

Infrastructure
Levy
was
allocated.
Members
were
advised
that
officers
would
work
with
the

Forum
to
see
how
they
wanted
to
be
involved
with
such
decisions.
If
agreement
between
the

Forum
and
the
Corporation
could
not
be
reached,
the
Corporation
would
determine
how
such

monies
were
allocated.


DECISION
That:
a)

TheBoardberecommendedtodesignatetheareaasshownontheplanin

Page 3

Figure1ofthereportforwhichtheCorporationisthelocalplanning
authorityasaNeighbourhoodAreawhichshallbeaddedtotheHarlesden
NeighbourhoodAreasaspreviouslydesignatedbytheLondonBoroughof
Brenton28September2015;and

b)

8
8.1



8.2









9
9.1

IntheeventoftheBoarddesignatingpartofitsareapursuanttothe
recommendationabove,thattheBoarddesignatetheexistingHarlesden
NeighbourhoodPlanningForumastheNeighbourhoodForumforthepartof
theNeighbourhoodAreaforwhichtheCorporationisthelocalplanning
authority.

PlanningApplicationsReceivedSince14August2015(Item8)



The
Committee
received
the
report
of
the
Director
of
Planning
setting
out
the
list
of
all

planning
applications
received
by
the
OPDC
from
14
August
to
26
October
2015.


DECISION
Thatthelistofplanningapplicationsreceivedsince14August2015,appendedto
thereport,benoted.
AnyUrgentBusiness(Item9)



On
behalf
of
the
Committee,
the
Chair
expressed
his
deepest
condolences
following
the

death
of
Councillor
Dan
Filson
and
agreed
to
write
to
the
leader
of
the
London
Borough
of

Brent
to
pass
on
the
Committees
best
wishes
and
condolences
to
his
friends,
family
and

colleagues.

10

DateoftheNextMeeting(Item10)



10.1
The
next
meeting
was
scheduled
for
Wednesday
6
January
2016
at
6pm
in
Committee
Room

5,
City
Hall.






CloseofMeeting

11


11.1
The
meeting
ended
at
6.35pm.















Chairman




Date



ContactOfficer:
Laura
Pelling,
Secretariat
Officer;
Telephone:
020
7983
5526;


Email:
laura.pelling@london.gov.uk;
Minicom:
020
7983
5526

Page 4

$SSHQGL[

Page 5

PLANNING COMMITTEE

12 NOVEMBER 2015

Page 6

C U M B E R L A N D PA R K FA C T O RY
C O N S E R VAT I O N A R E A
D E S I G N AT I O N C O N S U LTAT I O N

OVERVIEW

Page 7

69 to 91
SCRUBS
LANE

R AT I O N A L E O F D E S I G N AT I O N
SUPPORTED BY DRAFT
APPRAISAL REPORT

Page 8

1. RETAIN BUILDINGS OF
SPECIAL HISTORIC
INTEREST
2. INFORM PLACEMAKING
3. GENERATE ECONOMIC
BENEFITS

NEXT STEPS
PRESENTATION TO OPDC BOARD
(26 NOV)

CONSULTATION ALONGSIDE LOCAL PLAN

(JAN TO MARCH 2016)

Page 9

REPORT BACK TO PLANNING COMMITTEE &

BOARD (SPRING 2016)

DESIGNATION (SPRING 2016)

DEVELOPMENT OF MANAGEMENT PLAN

(2016)

Page 10

HARLESDEN NEIGHBOURHOOD
AREA AND FORUM
D E S I G N AT I O N

OVERVIEW

Page 11

J O I N T A P P L I C AT I O N
TO L B B R E N T &
O P D C TO D E S I G N AT E
AREA AND FORUM
C O N S U LTAT I O N
U N D E R TA K E N I N
J U LY & A U G 2 0 1 5
MAJORITY OF AREA
WITHIN LB BRENT
LB BRENT IS LEAD
AUTHORITY
LB BRENT
D E S I G N AT E D A R E A
AND FORUM ON 28
SEPTEMBER 2015

A P P L I C AT I O N A S S E S S M E N T

C O N S U LTAT I O N 5 R E S P O N S E S I N S U P P O R T

POSITIVE ENGAGEMENT WITH THE FORUM DURING

T H E A P P L I C AT I O N P R O C E S S

Page 12

A P P L I C AT I O N F O R A R E A & F O R U M I S C O N S I D E R E D
TO M E E T L E G I S L AT I V E R E Q U I R E M E N T S

A P P L I C AT I O N A S S E S S M E N T
AREA (SECTION 61G)

Page 13

CLEAR MAP
C O M P R E H E N S I V E E X P L A N AT I O N O F H O W T H E
PROPOSED NEIGHBOURHOOD AREA HAS BEEN
DEFINED

A P P L I C AT I O N A S S E S S M E N T
FORUM (SECTION 61F)
CRITERIA

EVIDENCE

Page 14

The Forum is established for the express purpose of

promoting or improving the social, economic and
environmental well-being of an area;

Comprehensive information provided within

appendix 4 of the submitted application setting out
how the Forum intends to meet this requirement
and reflects the character of the area.

The Forums membership is open to individuals who

live in the neighbourhood area, individuals who work
there and individuals who are elected members for
the area;
The Forums membership includes a minimum of 21
individuals each of whom live in the area, work in the
area or are elected members for the area;

Confirmation that membership is open to individuals

who live, work or represent the area is stated in
appendix 4 of the submitted application.

The Forum has a written constitution.

Confirmation that the Forum currently has 61

members alongside a membership list is provided in
appendix 4 of the submitted application.
Demonstration that members are drawn from
different places in the area and from different
sections of the community within the submitted
application.
A written constitution is provided within appendix 4
of the submitted application.

NEXT STEPS

Page 15

P R E S E N TAT I O N TO O P D C B O A R D
(26 NOV)
E N G A G E M E N T & S U P P O R T TO F O R U M I N T H E
DEVELOPMENT OF THEIR NEIGHBOURHOOD PLAN:
PRE-SUBMISSION NEIGHBOURHOOD PLAN DEVELOPED
P R E - S U B M I S S I O N C O N S U LTAT I O N
SUBMISSION NEIGHBOURHOOD PLAN DEVELOPED
P U B L I C AT I O N O F S U B M I S S I O N N E I G H B O U R H O O D P L A N
SUBMISSION OF NEIGHBOURHOOD PLAN FOR
E X A M I N AT I O N
E X A M I N AT I O N
LOCAL REFERENDUM
OPDC ADOPTION

This page is intentionally left blank

Page 16

Agenda Item 5

Subject:

Draft
Local
Plan


Meeting
date:

6
January
2016

Report
to:

Planning
Committee

Report
of:

Director
of
Planning



FOR
DECISION


________________________________________________________________________



This
report
will
be
considered
in
public

________________________________________________________________________



1

Summary

1.1 This
report
includes
OPDCs
draft
Local
Plan
(Appendix
A).
The
draft
Local
Plan

includes
a
suite
of
policy
options,
supporting
information
and
consultation
questions.

Subject
to
the
agreement
of
Planning
Committee
and
Board,
officers
propose
to
consult

stakeholders
on
the
draft
Local
Plan
and
its
policies
for
a
period
of
8
weeks.


1.2 The
Local
Plan
is
supported
by
Appendix
B,
which
contains
the
Integrated
Impact

Assessment,
which
assesses
the
impacts
of
the
proposed
policies
in
the
Local
Plan

against
the
following
European
and
national
requirements
and
best
practise
approaches:

Sustainability
Appraisal
and
Strategic
Environmental
Assessment;

Health
Impact
Assessment;

Equalities
Impact
Assessment;
and

Habitats
Regulations
Assessment.

1.3 The
Local
Plan
is
further
supported
by
Appendix
C,
which
sets
out
a
summary
of
the

studies
that
support
the
Local
Plan.
These
studies
are
in
the
process
of
being
desk-top

published
and
would
be
published
alongside
the
draft
Local
Plan
as
supporting
evidence

for
the
preferred
policy
options.



1.4 This
report
seeks
to
invite
the
Planning
Committee
to
recommend
that
the
Board
agrees

to
consult
on
the
draft
Local
Plan
and
its
supporting
studies.



2

Recommendations

The
Planning
Committee
is
asked
to:

2.1 Comment
on
the
draft
Local
Plan
(Appendix
A),
the
draft
Integrated
Impact

Assessment
(IIA)
(Appendix
B),
and
the
draft
Summary
of
Supporting
Studies

document
(Appendix
C);
and

Page 17



2.2 Recommend
that
the
Board
agree
to
consult
on
the
draft
Local
Plan,
the

assessment
at
Appendix
B
and
the
studies
detailed
in
Appendix
C
and
that

minor
changes,
including
desk
top
publishing,
be
delegated
to
the
Director
of

Planning
in
consultation
with
the
Chair
of
the
Planning
Committee.




3

Background

3.1 The
Old
Oak
and
Park
Royal
Development
Corporation
(OPDC),
as
a
local
planning

authority,
is
responsible
for
the
preparation
of
planning
policy
for
the
area.
The
Local

Plan,
once
adopted,
will
be
OPDCs
key
planning
policy
document
for
the
area,
setting
a

blueprint
for
how
OPDC
will
guide
regeneration
over
the
next
20
years.


3.2 The
draft
Local
Plan
builds
on
the
detail
contained
in
the
draft
Old
Oak
and
Park
Royal

Opportunity
Area
Planning
Framework
(OAPF),
which
was
published
by
the
Mayor
in

November
and
which
was
considered
by
the
Planning
Committee
and
the
Board
in
July

and
September
2015.
The
OAPF
should
be
read
in
conjunction
with
this
draft
Local

Plan,
but
as
this
Local
Plan
progresses
through
its
various
regulatory
stages,
its
policies

would
accrue
greater
planning
weight
than
the
guidance
and
principles
in
the
OAPF.

3.3 Alongside
the
National
Planning
Policy
Framework
(NPPF),
London
Plan,
Old
Oak
and

Park
Royal
Opportunity
Area
Planning
Framework,
West
London
Waste
Plan

Development
Plan
Document
and
any
Neighbourhood
Plans,
OPDCs
Local
Plan
would

be
used
as
the
key
planning
policy
document
against
which
planning
applications
within

the
OPDC
area
will
be
assessed.

3.4 The
Local
Plan,
once
adopted,
will
be
a
Development
Plan
Document
(DPD),
which
is

part
of
the
Governments
planning
policy
system
introduced
by
the
Planning
and

Compulsory
Purchase
Act
2004.
Part
6
of
the
Town
and
Country
Planning
(Local

Planning)
(England)
Regulations
2012
sets
out
the
procedure
for
the
production
of

Local
Plans.


3.5 There
are
a
number
of
steps
in
the
production
and
adoption
of
the
Local
Plan:


-
Regulation
18
is
the
first
stage
of
consultation;


-
Regulation
19
is
the
second
stage
of
consultation;


-
Regulation
22
is
the
submission
stage,
when
the
Regulation
19
version
of
the
local

plan
is
submitted
to
Secretary
of
State
along
with
any
representations
received
during

public
consultation;

-
This
is
followed
by
an
examination
in
public,
which
is
undertaken
by
a
planning

inspector;
and

-
following
this
examination,
if
the
document
is
found
sound,
the
Local
Plan
is
adopted.


3.6 The
first
stage
of
public
consultation
(Regulation
18)
requires
local
planning
authorities

to
consult
stakeholders
on
thesubjectofalocalplanwhichthelocalplanning
authorityproposetoprepare
and
what
alocalplanwiththatsubjectoughtto
contain.
To
accord
with
these
requirements,
each
chapter
in
the
draft
Local
Plan
asks

stakeholders
to
suggest
any
additional/alternative
policy
themes
which
the
ODPC

ought
to
consider
(see
paragraph
4.1
below).

Page 18

3.7 The
OPDC
has
a
Duty
to
Cooperate
with
surrounding
authorities
and
various
other

bodies
as
prescribed
in
the
Regulations.
This
draft
Local
Plan
has
been
drafted
through

regular
engagement
with
other
public
sector
bodies,
including
the
London
Boroughs
of

Ealing,
Brent,
and
Hammersmith
and
Fulham,
who
are
the
host
boroughs
for
OPDC.

Officers
have
held
bi-weekly
meetings
with
these
three
local
authorities
since
July
2015

to
help
with
the
identification
of
policy
themes
and
the
formulation
of
policy
options

for
inclusion
in
the
Local
Plan.
Officers
from
the
three
local
authorities
have
been

provided
with
early
drafts
Local
Plan
and
have
already
contributed
to
the
preparation
of

this
draft
plan.
Officers
have
sought
to
include
these
comments
where
relevant
and

feasible.


4

Document
Structure

4.1 The
draft
Local
Plan
is
split
into
13
chapters.
A
summary
of
each
chapter
is
provided

below.


4.2 The
draft
Local
Plan
contained
in
Appendix
A
includes
a
limited
number
of
graphics
as

these
are
still
in
production.
The
final
draft
Local
Plan
will
be
desk-top
published,
to

make
the
plan
easier
to
read,
following
consideration
by
the
Planning
Committee
and

the
Board
(see
para
5.2).





Chapter

Summary

1. Introduction

Sets
out
how
to
comment
on
the
document,
how
to
use
the

document,
the
documents
legal
and
policy
status
and
a
background

to
the
opportunities
that
regeneration
of
the
OPDC
area
will
bring
to

the
UK,
London,
West
London
and
the
local
area

2. Spatial
Vision
and

Objectives

Sets
out
OPDCs
proposed
spatial
vision
and
objectives
for
the
area

and
a
proposed
mission
statement
for
how
OPDCs
planning

directorate
will
run
its
service.

3. Overarching
Spatial

Policies

Contains
five
overarching
spatial
policies
on
optimising
development,

land
use,
connections
and
open
spaces,
densities
and
building

heights
and
places.

4. Places

Sets
out
detailed
spatial
policies
for
10
defined
places
across
the

OPDC
area.
Stakeholders
are
asked
to
comment
on
the
proposed

content
for
each
place
and
to
suggest
if
there
are
any
additional

places
that
warrant
detailed
spatial
policies.

5. Sustainable

Development

Includes
just
one
preferred
policy
option,
which
sets
out
the
NPPF

requirements
for
a
presumption
in
favour
of
sustainable

development.

6. Design

Contains
policy
themes
dealing
with
character,
streets
and
public

realm,
amenity
space,
new
buildings,
heritage,
amenity
and
inclusive

design.

7. Housing

Contains
policy
themes
dealing
with
housing
supply,
housing
mix,

affordable
housing,
existing
housing,
housing
in
the
private
rented

sector,
shared
facilities
housing,
specialist
housing
for
older
people

Page 19

and/or
vulnerable
people,
gypsy
and
traveller
accommodation
and

student
housing.
The
chapter
also
includes
a
call
for
sites

consultation
under
the
housing
supply
policy.

8. Employment

Contains
policy
themes
dealing
with
employment
in
Park
Royal,

employment
in
Old
Oak,
open
workspaces
and
local
access
to

employment
and
training.

9. Town
Centre
uses

Contains
policy
themes
dealing
with
the
town
centre
hierarchy,

vibrancy
in
town
centre
uses,
retail
and
eating
and
drinking

establishment
needs,
culture,
sports
and
leisure
facilities,
visitor

accommodation
and
hours
of
operation
for
night
time
economy
uses.

10. Social
Infrastructure
Contains
policy
themes
dealing
with
education,
health,
community

facilities
and
public
houses.

11. Transport

Contains
policy
themes
dealing
with
walking,
cycling,
rail,
buses,

roads,
parking,
freight,
servicing
and
deliveries,
construction,

Transport
Assessments
and
Travel
Plans.

12. Environment


Contains
policy
themes
dealing
with
smart
technology,
water,
waste

management,
waste
minimisation
and
use
as
a
resource,
energy,

digital
communications
infrastructure,
green
infrastructure
&

biodiversity,
extraction
of
minerals,
air
quality,
noise
and
land

contamination.

13. Delivery
and

Sets
out
the
infrastructure
requirements
to
support
development,

Implementation

potentially
funding
options
to
deliver
the
infrastructure,
the

partnership
working
that
OPDC
is
undertaking
to
ensure
the
delivery

and
implementation
of
this
Local
Plan
and
potential
indicators
for

monitoring
the
Local
Plans
effectiveness.







Glossary

The
glossary
is
not
included
in
Appendix
A,
but
will
be
compiled
in

advance
of
public
consultation
on
this
draft
Local
Plan
and
will

provide
definitions
of
terms
in
the
draft
Local
Plan.

Local
Plan
Policy
Options
Structure

5.1 The
draft
Local
Plan
must
be
consistent
with
the
NPPF
and
be
in
general
conformity

with
the
London
Plan
respectively.
Both
the
NPPF
and
the
London
Plan
stipulate
what

policies
a
local
planning
authority
must
include
in
its
development
plan
and
to

demonstrate
this,
the
draft
Local
Plan
outlines
these
requirements
at
the
start
of
each

policy
theme.


5.2 The
OPDC
is
developing
an
evidence
base
to
support
this
local
plan.
Part
of
this

evidence
base
is
an
Integrated
Impact
Assessment
contained
in
Appendix
B
and
a

number
of
supporting
studies,
which
are
summarised
in
Appendix
C.


5.3 As
a
result
of
the
need
to
be
consistent
and
in
general
conformity
with
the
NPPF
and

London
Plan
respectively,
coupled
with
the
emerging
evidence
base
from
OPDCs

supporting
studies,
the
majority
of
policies
in
the
draft
Local
Plan
are
expressed
as

preferred
policy
options.
Alternative
policy
options
are
presented
where
relevant.

Stakeholders
are
also
asked
to
comment
on
all
policies
and
to
suggest
alternative

options
if
they
do
not
agree
with
the
preferred
policy
option.


5.4 The
general
approach
for
each
policy
is
set
out
below.





Page 20

Figure
-
Preferred
Policy
Options
Structure




Policy
Title

Key
Issues

Sets
out
what
issues
the
policy
option
should
be
looking
to
contend
with

Policy
Context

Sets
out
relevant
national
and
regional
policies
that
this
policy
would
need
to
be

consistent/in
conformity
with

Preferred
Policy
Option

Justification

Text
explaining
why
the
preferred
policy
option
has
been
identified
and
what
evidence

supports
it

Alternative
Policy
Options

Sets
out
realistic
alternatives
for
the
policy
and
explains
potential
positive
and
negatives

of
the
alternative
and
why
at
this
stage
the
option
is
not
preferred

Consultation
Questions

Inviting
comments
on
the
preferred
policy,
alternative
options
or
suggestions
of
other

alternatives

6

Next
Steps

6.1 If
agreed
by
the
Committee,
Appendices
A,
B,
and
C,
will
be
taken
to
the
Board
meeting

on
25
January
2016
which
will
then
decide
whether
or
not
to
agree
to
consult
on
the

draft
Local
Plan
and
its
supporting
studies.

6.2 If
agreed,
the
draft
Local
Plan
would
then
be
finalised.
This
will
include
finalising

graphics
and
minor
alterations
to
text.
This
work
will
also
involve
the
complete
desk-top

publishing
of
the
draft
Local
Plan.

6.3 Consultation
would
then
be
launched
in
early
February
and
would
run
for
a
period
of
8

weeks.
During
the
consultation
drop-in
public
exhibitions
will
be
held
at
different
times

and
locations
to
appeal
to
different
audiences.
There
will
be
a
series
of
themes

workshops
around
the
Local
Plan
policy
areas
and
geographical
place
areas.
The
OPDC

will
use
social
media
as
a
way
of
engaging
with
a
different
audience.
A
hashtag
will
be

created
so
that
comments
and
views
can
be
tracked,
as
well
as
dedicated
online

discussions
around
particular
topics.
The
OPDC
will
work
with
partners
to
publicise

workshop
and
public
exhibition
dates
through
traditional
media
and
social
media.

6.4 The
graphic
below
identifies
the
longer
term
programme
for
the
Local
Plan,
which

includes
a
second
consultation
in
autumn
2016.


6.5 As
part
of
the
outcome
from
this
consultation,
officers
would
summarise

representations
received
through
consultation
on
this
draft
Local
Plan
and
set
out
how

it
has
sought
to
address
these
comments
in
the
redrafting
of
the
Local
Plan.
This
2nd

consultation
would
be
followed
by
an
independent
Examination
in
winter
2016,
with

potential
adoption
in
spring
2017.

Page 21



7

Financial
Implications

7.1 All
costs
related
to
Local
Plan
will
be
contained
in
OPDCs
allocated
budget
for
2015-16

and
2016-17.

8

Legal
Implications

8.1 No
legal
implications
arise
from
this
report
and
it
is
consistent
with
the
Corporations

legal
framework.



9

Appendices

Appendix
A:
Draft
Local
Plan

Appendix
B:
Integrated
Impact
Assessment

Appendix
C:
Summary
of
Supporting
Studies





List
of
Background
Papers:

None






Report
originator:

Tom
Cardis,
Head
of
Planning
Policy,
OPDC

Telephone:


020
7983
5552

Email:



tom.cardis@opdc.london.gov.uk

Page 22

Appendix A

DRAFT LOCAL PLAN

REGULATION 18
DRAFT
DECEMBER 2015

1

Page 23

CONTENTS
1. Introduction
2. Spatial Vision and Objectives
3. The Overarching Spatial Policies
OSP 1: Optimising growth
OSP 2: Land use
OSP 3: Connections and open spaces
OSP 4: Densities and building heights
OSP 5: Places
4. The Places
P1: Old Oak South
P2: Old Oak North
P3: Old Oak High Street
P4: Grand Union Canal
P5: Park Royal
P6: Park Royal Centre
P7: North Acton
P8: Scrubs Lane
P9: Old Oak West
P10: Wormwood Scrubs
5. Sustainable development
SD1: Sustainable development
6. Design
D1: Strategic Policy for Design
D2: Streets and public realm
D3: Open space
D4: New buildings
D5: Alterations & extensions
D6: Heritage
D7: Building user amenity
D8: Inclusive design
7. Housing
H1: Strategic Policy for Housing
H2: Housing supply (including a Call for Sites)
H3: Housing mix
H4: Affordable housing
H5: Existing housing
H6: Housing in the Private Rented Sector
H7: Housing with shared facilities
H8: Specialist housing for older people and/or vulnerable people
H9: Gypsy and Traveller accommodation
H10: Student housing
2

Page 24



8. Employment
E1: Strategic Policy for Employment
E2: Old Oak
E3: Park Royal
E4: Open workspaces
E5: Local access to employment and training
9. Town Centre Uses
TC1: Strategic Policy for Town centre uses
TC2: Town centre hierarchy
TC3: Vibrancy
TC4: Retail and eating and drinking establishment needs
TC5: Culture, sports and leisure facilities
TC6: Visitor accommodation
TC7: Hours of operation for night time economy uses
10. Social Infrastructure
SI1: Strategic Policy for Social infrastructure
SI2: Education
SI3: Health
SI4: Community facilities
SI5: Public houses
11. Transport
T1: Strategic Policy for Transport
T2: Walking
T3: Cycling
T4: Rail
T5: Buses
T6: Roads and Streets
T7: Parking
T8: Freight, servicing and deliveries
T9: Construction
T10: Transport Assessments and Travel Plans
12. Environment and Utilities
EU1: Strategic Policy for Environment and Utilities
EU2: Smart
EU3: Water
EU4: Waste management
EU5: Circular economy and resource efficiency
EU6: Decentralised Energy
EU7: Digital communications infrastructure
EU8: Green infrastructure & biodiversity
EU9: Extraction of minerals
EU10: Air quality
EU11: Noise
EU12: Land contamination
13. Delivery and Implementation
3

Page 25

1. INTRODUCTION
[Figure XX: map of OPDC area]
FOREWORD
Chairs Foreword
Old Oak and Park Royal Development Corporation (OPDC) has been in existence for less
than a year and this first draft of the Local Plan represents a huge step forward for the
Corporation in beginning to shape the area.
Old Oak and Park Royal is set to become the UKs largest development project and most
successful industrial location. It can provide unparalleled opportunities for the UK, London
and local communities. The area is set to be transformed into one of Londons key
destinations, better connected than perhaps anywhere else in the UK. This transformation
brings with it significant opportunities to deliver much needed homes and jobs that can
support Londons growth. New communities will grow up supported by a full range of
infrastructure and services. However, the area needs to not only be a place to live and work,
but one to visit and enjoy, time and again. These elements will be brought together to create
a real sense of place with a series of high quality neighbourhoods and spaces, that locals
and Londoners will be proud of and flock to.
In November 2015, the Mayor adopted the Old Oak and Park Royal Opportunity Area
Planning Framework (OAPF), which sets out a clear strategy for the redevelopment of the
area around the planned Old Oak Common Station, whilst also outlining the need to protect
and intensify Park Royal as a key cog in Londons economy.
This first draft of the Local Plan builds on the OAPF and once adopted, will provide a clear
blueprint for how this area will be regenerated to deliver a thriving new part of London. As a
document for consultation, this draft Local Plan sets out a series of suggested preferred
policies, policy options and alternative options for how this critical regeneration project could
be planned for over the next 20 years. It provides substantially more detail than the OAPF
and is supported by a vast array of studies that OPDC officers have been developing over
the past few months. Guiding the development of a significant new part of London requires
flexibility. The Local Plan will help to set those key parameters to allow a great new place to
develop and change over time. The many pieces of work the planning team has progressed
will ensure that the approach we take across Old Oak and Park Royal is the right one and
that it delivers a best practice, innovative and sustainable approach.
This is your chance to help shape these policies and I am delighted to introduce this draft
Local Plan and its supporting studies for public consultation.
HOW TO COMMENT ON THE DOCUMENT
Overview
OPDCs Local Plan will be the key planning policy document for the OPDC area. It will
contain policies that will be used in the determination of planning applications and that will
shape how the area will be developed over the next 20 years and deliver a new thriving
heart of London.
This version of the Local Plan is a draft document. It has been specifically produced for
public consultation and this is an opportunity for you to comment on and shape Local Plan
4

Page 26



policy for this area. This is your chance to make representations on what policies you think
the Local Plan ought to contain. Throughout the document we have set out consultation
questions to help stimulate responses but as a consultation document, you can comment on
any element of the draft Local Plan and its supporting studies.
It would be helpful for us if when responding you could clearly set out which page number,
paragraph, policy, diagram, image or question your comment relates to. Alternatively, please
use the Local Plan Consultation Response Form which sets out the different elements of the
document to help you to record your comments clearly against the corresponding section.
When and how to respond
Public consultation runs from XX February 2016 to XX March 2016.
Respond by email to: localplan@opdc.london.gov.uk
Respond by post to:
Local Plan Consultation,
Old Oak and Park Royal Development Corporation,
City Hall,
Queens Walk,
London SE1 2AA
How to find out more
Visit our dedicated website
All documents can be read and downloaded from XXXX
You can also send us your comments via our quick response online form or download the
full form to email us a longer consultation response.
Drop-in to a public exhibition or workshop
OPDC will hold a number of drop-in sessions, as well as workshops for specific policy issues
in the Old Oak and Park Royal area on the below days to enable local people to discuss
proposals and provide their views in person:
Date

Event Information

Location

Dates and venues to be inserted once confirmed

View a hard copy

Paper copies of this draft Local Plan and its supporting studies are available to view during
normal office hours at the following locations:
- Harlesden Library, NW10 8SE;
- Old Oak Community Centre, Braybook Street, W12 0AP; and
5

Page 27



-

City Hall, Queens Walk, London, SE1 2AA

Alternatively, hard copies of this Local Plan can be made available on request by contacting
OPDC, either via email or by post (see above).
Tweet questions during a Question & Answer session
At the following dates and times, officers will be ready to take your questions on anything to
do with the draft Local Plan. Tag your tweet #AskOPDC and the team will try to respond to
as many questions as possible and record comments as consultation feedback where
relevant.

Table to be populated with dates and times once these are firmed up

What happens next

Figure XX shows the various stages that this draft Local Plan will need to go through before
it can be adopted and published. This involves two rounds of public consultation before
submission to the Secretary of State for independent examination.
Following consultation on this draft of the Local Plan, OPDC officers will produce a report
that summarises the comments received as part of this consultation and provide a response
to these comments. This response will explain how comments received during public
consultation have been considered in the production of the next draft of the Local Plan.

STATUS OF THE DOCUMENT

Legal Status
1.1
This document will be a Development Plan Document (DPD) and is part of the
Governments planning policy system introduced by the Planning and Compulsory Purchase
Act 2004.
1.2
Part 6 of the Town and Country Planning (Local Planning) (England) Regulations
2012 sets out the procedure for the production of Local Plans. This version of the Local Plan
constitutes the consultation required under Regulation 18.
6

Page 28

Policy Status
1.3
Alongside the National Planning Policy Framework (NPPF), London Plan, Old Oak
and Park Royal Opportunity Area Planning Framework, West London Waste Plan DPD and
any Neighbourhood Plans, OPDCs Local Plan, once adopted, will be the key planning policy
document against which planning applications within the OPDC area will be assessed (see
figure XX).
1.4
The policies in the Local Plan must be consistent with the NPPF and in general
conformity with the London Plan. To make this relationship clear, each policy in this
consultation draft document is supported by a policy context section which sets out the
relevant NPPF and Local Plan policies underpinning the draft Local Plan policy (see How to
use this document section below).
1.5
Once adopted, OPDC will be able to adopt Supplementary Planning Documents
(SPDs) to this Local Plan. SPDs can provide more detailed policies and guidance to policies
contained in this Local Plan and can be a helpful way of drilling into a greater detail for a
policy theme or a particular location.

Relation to Local Authority planning documents

1.6
As OPDC progresses its Local Plan, the weight of Local Authority DPDs and SPDs
covering parts of the OPDC area will diminish as they are superseded by the growing
material weight of OPDCs Local Plan. The exception to this rule is the West London Waste
Plan, which was adopted by OPDC Board in July 2015 as a DPD.
Relationship with the Old Oak and Park Royal Opportunity Area Planning Framework
1.7
The Old Oak and Park Royal Opportunity Area Planning Framework was adopted by
the Mayor in November 2015 as Supplementary Planning Guidance (SPG) to the Mayors
London Plan (2015). As SPG to the London Plan, the document is a significant material
consideration in the determination of planning applications in the OPDC area. This existing
7

Page 29



OAPF has helped to inform the policy themes and draft policies in this Local Plan. The
OAPF should be read in conjunction with the Local Plan, but as this draft Local Plan
progresses through its various regulatory stages, its policies would accrue greater weight
than the guidance and principles in the OAPF.
Duty to Cooperate
1.8
The duty to cooperate is a legal requirement set out in the Localism Act. It requires
local planning authorities and public bodies to engage constructively, actively and on an
ongoing basis to maximise the effectiveness of Local Plan preparation in the context of
strategic cross boundary matters. In accordance with the Duty to Cooperate, OPDC has
been working closely with these authorities and bodies in the production of this draft Local
Plan and in the preparation of other planning policy and development management and
infrastructure delivery matters.

HOW TO USE THE DOCUMENT

1.9
In order to keep the document spatial and succinct, the draft Local Plan does not look
to re-iterate national or regional policy where this provides sufficient policy detail. This
document should therefore be read in conjunction with the National Planning Policy
Framework (NPPF), associated National Planning Practice Guidance (NPPG) and the
Mayors London Plan.
1.10 The document is structured around a series of policy themed chapters. At the start of
each chapter, the draft Local Plan sets out the policy themes that the chapter covers and
invites stakeholders to suggest additional policies that may be required to cover specific
policy issues.
1.11 Within each chapter there are a series of policies which take two forms: preferred
policies or policy options.
1. Preferred policies.
1.12 Where there is a preferred policy this is made clear in the Local Plan. The justification
and policy basis for it being a preferred option is provided.
1.13 Where there are realistic alternative approaches that could be taken to the preferred
policy, these have been set out. We are inviting stakeholders thoughts on these alternatives
and suggestions of other alternatives through the consultation questions. Figure XX presents
how the preferred policies are structured.
Figure XX: Preferred Policy Options Structure
Policy Title
Key Issues
Sets out what issues the policy option should be looking to contend with
Policy Context
Sets out relevant national and regional policies that this policy would need to be
consistent/in conformity with
Preferred Policy Option
Justification
Text explaining why the preferred policy option has been identified and what evidence
supports it
8

Page 30



Alternative Policy Options
Sets out realistic alternatives to the preferred policy option and explains potential
positive and negatives of the alternative and why at this stage the option is not
preferred
Consultation Questions
Inviting comments on the preferred policy, alternative options or suggestions of other
alternatives
2. Policy Options.
1.14 Where there is not a preferred policy then a series of options are presented and
these tend to be more draft in nature. Figure XX presents how the policy options are
structured.
Figure XX: Policy Options Structure
Policy Title
Key Issues
Sets out what issues the policy option should be looking to contend with
Policy Context
Sets out relevant national and regional policies that this policy would need to be
consistent/in conformity with
Policy Options
Sets out the policy options that OPDC could consider taking and potential strengths and
weaknesses identified for each option
Consultation Questions
Asks questions of the policy options and invites suggestions for alternative options for
consideration
1.15 For the next draft of the Local Plan, the key issues and policy context section will
be removed from the polices to make the document more streamlined, but it was felt helpful
to include in this draft for consultation to inform stakeholders of the issues being contended
with and the national and regional policy context that the policy is working within.
Supporting evidence documents
1.16 This draft Local Plan is supported by a number of supporting evidence documents.
Figure XX sets out these supporting documents and their relation to the draft Local Plan.
OPDC has produced a Summary of Supporting Studies document which provides an
executive summary for each of the studies, including details on the studies key outputs and
recommendations. These supporting evidence documents have also been listed in the key
evidence sections at the start of chapters where they are of relevance. These documents
are in draft and may be amended post consultation. We are therefore inviting stakeholders to
provide comments on these supporting documents as part of this consultation on the Local
Plan. All supporting studies are available on OPDCs website or in hard copy at the locations
identified on page xx.
1.17 Of particular importance is the Integrated Impact Assessment (IIA). The IIA fulfils the
statutory requirements for a Sustainability Appraisal (SA) and Strategic Environmental
Assessment (SEA) (in a manner that incorporates the requirements of the European Unions
SEA Directive (2001/42/EU) and the transposing UK Regulations). The approach also fulfils
the requirements for Health Impact Assessment, Equalities Impact Assessment and
Community Safety Impact Assessment. All draft Local Plan policy options, including the
alternative policy options, have been appraised in OPDCs IIA.
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1.18 A public consultation was held on the IIA Scoping Report between 4th September and
9th October 2015, in accordance with regulation 12(5) of the SEA Regulations. The Scoping
Report consultation presented the suggested scope of the IIA for comment. Consultation
responses have been used to amend the scope to reflect stakeholders and the communitys
comments. Relevant documentation can be found on the OPDC website.
1.19 A Habitats Regulation Assessment (HRA) Screening exercise is also being carried
out in accordance with European Council Directive 92/43/EEC on the Conservation of
natural habitats and of wild flora and fauna (the Habitats Directive). The role of this exercise
is to determine whether the emerging content of the draft Local Plan will generate an
adverse impact on the integrity of a Natura 2000 site. For the OPDC area, these sites are
Richmond Park and Wimbledon Common. Relevant emerging HRA screening information
accompanies this draft Local Plan as part of the IIA. A full Screening Report will be produced
for the next version of the draft Local Plan.
THE OPPORTUNITY

1.20 The OPDC area covers the Old Oak Common and Park Royal Opportunity Areas in
the Mayors London Plan (2015), which together are identified as having the capacity to
deliver a minimum additional 25,500 homes and indicative 65,000 jobs. The London Plan
identifies Old Oak alone as having the capacity to deliver a minimum 24,000 homes and
55,000 jobs representing London and the UKs largest regeneration project. This scale of
development has far reaching benefits at a national, regional, west London and local scale.
Park Royal is Europes largest industrial estate and is a vital cog in the London economy,
accommodating over 1,500 businesses employing over 36,000 people. The Mayors London
Plan (2015) identifies that through redevelopment and intensification, it has the potential to
deliver an additional 10,000 jobs and a minimum of 1,500 additional homes.
For the UK
1.21 The OPDC area and particularly Old Oak is set to be transformed in 2026 with the
opening of Old Oak Common Station, which will connect London Crossrail and National Rail
services to the newly built High Speed 2 line in a station nearly the size of Waterloo,
accommodating over 250,000 passengers a day. The creation of this new station will
dramatically improve transport accessibility in the immediate area, across London and also
across the entire UK. Passengers will need to change trains at Old Oak if they are travelling
to and from the north and Londons two largest airports - London Heathrow and London
Gatwick. London Heathrow will be just 8 minutes from Old Oak Common via London
Crossrail, whilst journeys from the north to Gatwick via Old Oak Common will be 15 minutes
shorter via the West London Line. The new station will also dramatically increase the
nations access to Central London and the West End, which will be just 10 minutes from Old
Oak via Crossrail.
1.22 Centred on this new transport super-hub, the OPDC area constitutes the UKs largest
regeneration project. This development potential could bring enormous rewards for the
national economy, with the new jobs having the potential to generate billions of pounds for
the UK economy. Likewise, the additional 25,000+ homes the area could deliver will
contribute to combatting the nations housing shortage as well as contributing billions of
pounds to the UK through housing consumption.
For London

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1.23 The scale of development in Old Oak and Park Royal will make a significant
contribution to Londons growing need for homes and jobs. Strategic transport infrastructure
provision in the OPDC area will also help transform access across London both within the
city and to the rest of the UK.
1.24 Londons population has never been higher and London-wide, the Mayor has
identified the need for an additional 49,000 homes per annum to meet Londons housing
needs over the next 20 years. At 24,000 homes, Old Oak Common represents Londons
largest Opportunity Area in terms of its capacity for new homes and ability to secure a range
of housing types and tenures.
1.25 Across the OPDC area there is the capacity to deliver an additional 65,000 jobs of
which approximately 55,000 would be in Old Oak and 10,000 in Park Royal. Together, this
represents the largest quantum of new jobs in London outside of the City and this could help
further strengthen Londons economic output and role as a world city. Millions of people will
be within an hours journey time of Old Oak, making the new office hub an attractive location
for employers.
1.26 In support of these new homes and jobs, there will be opportunities for a number of
supporting ancillary uses. At over 135 hectares of developable land, Old Oak provides
particular opportunities for a range of supporting uses. OPDC has developed a Cultural
Principles document to consider how OPDC will work to facilitate the continued growth in
Londons cultural offer to further cement Londons position as the worlds cultural capital and
to embed culture within the area.
1.27 The transport improvements resulting from the provision of the Old Oak Common
Station will provide London-wide benefits. Approximately one third of Londoners accessing
HS2 will board trains at Old Oak. This will bring Londoners within 38 minutes of Birmingham
and fast access to other UK cities, such as Leeds, Manchester, Liverpool and Newcastle.
Within London itself, connectivity between London Overground and Crossrail will enhance
accessibility for many residents and employees across London.
For west London
1.28 West London is predominantly residential in character. The vast majority of its
housing stock is made up on Victorian, Edwardian and inter-war housing. Like much of
London, west London has in recent years suffered from a chronic housing shortage and
particularly a shortage in affordable housing. West Londons Opportunity Areas are the main
locations for delivering these new homes and together, these have the capacity to deliver an
additional 84,000 homes. The OPDC area is anticipated to have a significant impact on west
Londons housing supply providing over 30% of these new homes and within this, the
opportunity for a significant amount of new affordable homes.
1.29 Economic activity in west London is centred on its town centres (such as Shepherds
Bush, Hammersmith, Ealing and Wembley) and employment estates (such as Park Royal
and the Golden Mile in Brentford). The economy of west London is to a large degree related
to its position between Heathrow - London and the UKs largest airport and the West End
and City Londons economic powerhouses. As with housing, West Londons Opportunity
Areas are likely to be the key centres for the delivery of new employment and the London
Plan (2015) identifies that together, these Opportunity Areas could deliver 94,000 jobs. Of
this over 65% of the jobs could be delivered within the OPDC area. Park Royal is already a
vital cog in the economic engine of west London, currently providing over 36,000 jobs. An
additional 10,000 jobs here will help with the growth of existing sectors and potential for new
sectors to emerge and establish themselves. In Old Oak, the creation of a new commercial
hub around Old Oak Common Station will help drive forward the economy of west London
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and help west London to continue to compete with other parts of the London and wider
south-eastern economy.
1.30 Transport infrastructure provision in Old Oak will have a significant impact on
accessibility and growth across west London. The new station on the North London Line at
Old Oak Common Lane will provide connections to Crossrail and HS2 for residents from
locations such as Richmond and Gunnersbury (the Golden Mile) and via Willesden Junction,
locations such as Wembley Opportunity Area and Harrow. On the West London Line, a new
station at Hythe Road will provide connections to Crossrail and HS2 for locations such as the
White City and Earls Court and West Kensington Opportunity Areas. The OPDC area is also
well connected to the wider west London area by the strategic road network. Both the A40
and A406 (North Circular) provide for direct connections to other locations in west London,
although both suffer from heavy traffic congestion.
For the local area
1.31 The immediate context of the OPDC area contains some of the most deprived areas
in the country. Locations such as Harlesden and Stonebridge are ranked within the top 10%
most deprived wards nationally and have issues with income deprivation and health. The
OPDC area and particularly Old Oak currently severs many of the communities bordering
the OPDC area. New development has the opportunity to overcome this severance and knit
together this part of west London. The scale of transformation planned in the OPDC area
could further spur the regeneration of these surrounding areas and help to unlock additional
development and growth. OPDC is developing a Socio-Economic Regeneration Strategy
which will identify mechanisms to ensure that surrounding communities benefit from
employment opportunities both during and post-construction. OPDC is also working with
surrounding local authorities to plan for the integration of the OPDC area into the wider
hinterland. OPDC will work with the boroughs to develop fringe masterplans. These
masterplans will consider the potential for better connectivity and permeability between
OPDC and these areas. Figure XX shows the areas currently under consideration and these
include:
-

White City Opportunity Area and north of White City. White City is currently being
transformed with the expansion of Westfield, development of Imperial Colleges
White City Campus and redevelopment of the BBC Television Centre. Its OAPF was
adopted in 2013 and development in this area is well underway. Coordinated public
realm improvements could deliver better connectivity between the OPDC area and
White City. Economic synergies will also be explored such as the potential for
Imperial College to continue to grow its west London campus and look to Park Royal
today and Old Oak in the future to provide scale-up incubator space, student and
staffing accommodation and teaching facilities;
Harlesden Town Centre, which currently suffers from significant economic
deprivation. Improved connections between it and the OPDC area and employment
and training initiatives provide significant opportunities for residents and businesses
in Harlesden to benefit from regeneration. OPDC and Brent Council have established
a Harlesden sub-group to coordinate projects and strategies for the area;
Kensal Canalside Opportunity Area, which is immediately to the east of the OPDC
area and is identified as having the capacity to deliver a 2,000 new jobs and a
minimum 3,500 new homes. There will be opportunities to improve connections with
Kensal Canalside and OPDC will work with the Royal Borough of Kensington and
Chelsea to explore ways that this can be achieved;
Alperton, to the west of the OPDC area has been identified as a Housing Zone by
the Mayor of London with additional funding for the delivery of affordable housing.
The Alperton housing zone is identified as having the capacity to deliver over 3,000
homes; and
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-

Wembley Opportunity Area, which is less than 2 miles from the OPDC area and is
west Londons second largest Opportunity Area after Old Oak, has the potential to
deliver 11,500 homes and 11,000 jobs. In future, Wembley could potentially be better
connected to Old Oak through the provision of a spur to the West Coast Main Line,
but there are also opportunities for more short-term solutions to better connect
Wembley to the OPDC area.

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2. SPATIAL VISION AND OBJECTIVES

A SPATIAL VISION
A thriving part of London connected to the rest of the UK and internationally. Old Oak and
Park Royal will be a centre for innovation and growth that will shape west London and
strengthen Londons role as a global city. A new commercial hub with cultural uses,
alongside a diverse network of vibrant neighbourhoods, will help create a London destination
recognised as an exemplar in large-scale housing and employment led regeneration.
OBJECTIVES
Consolidating
1. Optimise a once in a lifetime opportunity created by High Speed 2 and Crossrail to
secure investment that will:
a. deliver a thriving new centre at Old Oak with much needed homes, a mix of
employment space and associated social and physical infrastructure;
b. protect and regenerate the Park Royal industrial area as a cornerstone of the
London economy.
Connecting
2. Accessible and high quality national, regional and local transport connections, focused
around a new world class station at Old Oak Common will catalyse comprehensive
regeneration with well-designed streets that will fully connect into surrounding areas.
Creating
3. Deliver a varied mix of uses, including cultural and catalyst uses, that support the growth
of a vibrant London destination.
4. Celebrate existing features of the Grand Union Canal, Wormwood Scrubs, Park Royal,
heritage assets, and local communities to help create a unique sense of place.
5. Utilise the scale of opportunity to embed and showcase exemplar standards of design,
smart technology and environmental, social and economic sustainability, during the
planning, construction and operation stages.
6. Be flexible and adaptable, both to the effects of a changing climate and future changes in
practices, including the circular economy and deliver an open and secure digital place.
Communities
7. Create a series of connected and inclusive lifetime neighbourhoods, designed to improve
the quality of life, enhance health and well-being, deliver social and economic benefits
for local communities and foster a sense of community and diversity.
OUR MISSION

Pro-actively lead the comprehensive and best practice planning of Old Oak and Park
Royal that complements the wider area.
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Enable the delivery of a liveable new place for a mix of residents, employees and
visitors, ensuring new development achieves the highest standards of design.
Work positively with stakeholders to unlock and coordinate the areas regeneration
potential.
Engage with, and support the participation of, local communities during the plan
making and development management processes.
Run a responsive, customer focused planning service.

CONSULTATION QUESTIONS
QVO1: Do you agree with the Spatial Vision?
QVO2: Do you agree with the Objectives?
QVO3: Do you agree with the mission statement?

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3. OVERARCHING SPATIAL POLICIES

OVERARCHING SPATIAL POLICIES
3.1

This chapter contains policies addressing the following policy themes:

-

OSP 1: Optimising growth;

OSP 2: Land use;
OSP 3: Connections and open spaces;
OSP 4: Densities and building heights; and
OSP 5: Places.

3.2
These policies provide the key overarching policy statements for the OPDC area.
They set the policy basis for the proceeding places (see chapter 4) and thematic polices
(see chapters 5-12).
Consultation Question
QOSPa: Are there any other overarching spatial policy themes that you think OPDCs
Local Plan should be addressing?

Evidence Base
Study
OPDC Development
Capacity Study
OPDC Cultural
Principles

OPDC Retail and

Leisure Needs Study
(RLNS)
OPDC Walking,
cycling and public
realm strategy
OPDC Green
Infrastructure
Strategy

Description
A study looking at the capacity of the OPDC area to
accommodate new homes and jobs.
A document showing how OPDC can contribute to
Londons position as the worlds cultural capital and
how embedding culture in development can assist
placemaking
A study looking at the need for retail and leisure
space in the OPDC area, which includes examples
of meanwhile/interim uses across London.
A strategy setting out recommendations for the
public realm, public open space and walking and
cycling infrastructure for the OPDC area.
A strategy reviewing existing GI assets, future GI
requirements, and identifying opportunities for
improving function, connectivity and integration with
other infrastructure.

Status
Draft completed
Draft completed

Draft completed

To be developed

To be developed

Policy OSP1: Optimising Growth

Key Issues
1. Londons population and economy is growing at an incredibly fast rate and there is a
need for development to keep abreast of this growing need to deliver over 1 million
new homes over the next ten years.
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2. Brownfield land plays a critical role in meeting this need and it is important to
optimise this opportunity where presented.
3. The OPDC area represents Londons and the UKs largest regeneration area and
can make a significant contribution towards meeting Londons growth.
4. The scale of regeneration planned at Old Oak and Park Royal, if planned correctly
and coordinated with growth in surrounding Opportunity Areas can help to shape
west London and support Londons role as a global city.
Policy Context
National
3.3
The National Planning Policy Framework (NPPF) requires planning to be a tool to
promote growth and meet the need to house people and continue the expansion of the UKs
economy and the prosperity of its residents.
Regional
3.4
The London Plan identifies Londons need to meet its projected population and
economic growth. The London Plan recognises that Opportunity areas are the capitals
major reservoir of brownfield land with significant capacity to accommodate new housing,
commercial and other development linked to existing or potential improvements to public
transport accessibility.
Preferred Policy Option:
OPDC will work with stakeholders and partners to ensure that development:
a) Optimises growth to deliver new homes and jobs and support the regeneration
of the area; and
b) Enables the creation of a new destination that will shape west London and
supports Londons role as a global city.
Justification
3.5
The OPDC area can play a critical role in meeting Londons need for homes and
jobs. In 10 years, this area will have unparalleled connectivity with a once in a lifetime
opportunity to optimise regeneration and development in the surrounding area.
3.6
Growth in the OPDC area will have benefits both locally and across the wider area.
During the 20 years of this Local Plan, the level of development envisaged, along with the
planned strategic infrastructure, will fundamentally change the geography of west London. It
is important that the new development in the OPDC area drives forward the economic
prosperity of its local and west London residents and businesses and also that opportunities
are taken to deliver development that supports and strengthens Londons role as a
competitive global city. This is explored in further detail in the Places (chapter 4) and Town
Centre Uses (chapter 9) Chapters.
Alternative Policy Options
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3.7
No reasonable alternative policy options have been identified as an alternative would
not be consistent with the NPPF or in general conformity with the London Plan.
Consultation Questions
QOSP1a: Do you agree with the preferred policy option? If not, what might you
change about the preferred policy?
QOSP1b: Are there any other policy alternatives that could replace the preferred
policy or should be considered as alternatives?
Policy OSP2: Land Use
Key Issues
1. OPDCs Local Plan must be in general conformity with the London Plan, which sets a
clear homes and jobs target for both the Old Oak (24,000 homes and 55,000 jobs)
and Park Royal (1,500 homes and 10,000 jobs) Opportunity Areas.
2. This scale of regeneration presents opportunities to provide facilities for local, subregional and London-wide needs.
3. It will be important to create vibrancy by encouraging a mix of uses and this should
include a mix of small to large scale catalyst uses.
Policy Context
National
3.8
The NPPF requires that planning policies aim for a balance of land uses within their
area so that people can be encouraged to minimise journey lengths for employment,
shopping, leisure, education and other activities, as well as delivering a wide choice of high
quality homes.
Regional
3.9
Annex A of the London Plan sets housing and jobs targets for the Old Oak Common
and Park Royal Opportunity Areas. The housing targets are minimum targets whilst the jobs
targets are indicative.
Preferred Policy Option:
OPDC will support proposals that contribute to the creation of a new part of London
by:
a) Delivering a new thriving centre at Old Oak that seeks to accommodate 24,000
homes and 55,000 jobs;
b) Protecting and regenerating the Park Royal industrial estate as a powerhouse
of the London economy accommodating 10,000 new jobs and 1,500 new
homes; and
c) Delivering a full mix of town centre, cultural and catalyst uses and associated
infrastructure within a new town centre hierarchy.

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Figure xx: Existing and proposed land uses (draft)

Justification
3.10 The OPDC area covers both Old Oak and Park Royal Opportunity Areas, two of
Londons most exciting opportunity areas. Together these form London and the UKs largest
regeneration project.
3.11 The OPDC area can make a significant contribution to Londons growing housing
need. The London Plan sets a requirement for the Old Oak and Park Royal Opportunity
Areas to deliver a combined minimum of 25,500 homes. OPDC has undertaken a
Development Capacity Study (DCS), which demonstrates how the OPDC area is capable of
achieving this target. OPDC will support proposals that help to deliver this target. Further
details on the way this target can be achieved are contained in the Housing and Places
Chapters and specifically Policy H2.
3.12 The scale of development planned in Old Oak could make a significant contribution
to housing need and have a profound impact on both the London and UK economy, with
early work showing how comprehensive regeneration at Old Oak could generate 7.1 billion
per annum of gross value added (GVA) for the UK economy.
3.13 Park Royal is the UKs largest industrial estate, currently employing over 36,000
people across over 1,500 businesses. Protecting the estate is vital to the London economy
and opportunities should also be taken to intensify its use where feasible, including the
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provision of new homes on sites not designated as Strategic Industrial Location (SIL) (see
policy E3).
3.14 The new population will need to be supported by a range of ancillary services. This
will take the form of new shops, culture, sports and leisure and social infrastructure such as
new schools, health centres and community space. In the first instance, these should serve
the new population living in the area. These facilities should also be of benefit for
communities surrounding OPDC and culture, sports and leisure uses could make a valued
contribution to London (see chapter 9).
Alternative Policy Options
3.15 No reasonable alternative policy options have been identified. This Local Plan must
be in general conformity with the London Plan and this sets clear homes and jobs targets for
the OPDC area.
Consultation Questions
QOSP2a: Do you agree with the preferred policy option? If not, what might you
change about the preferred policy?
QOSP2b: Are there any other policy alternatives that could replace the preferred
policy or should be considered as alternatives?
Policy OSP3: Connections and open spaces
Key Issues
1. The existing built environment creates significant severance and lacks integration with
surrounding areas. This should be addressed through a series of new and improved
connections and movement options.
2. Sufficient amounts of high quality open space should be provided to meet the needs of
local communities and at the same time, contribute to mitigating the impacts of climate
change.
Policy Framework
National
3.16 The NPPF identifies that:
development should establish a strong sense of place, using streetscapes and
buildings to create attractive and comfortable places to live, work and visit;
development should deliver places which promote clear and legible pedestrian routes
that encourage the active use of public areas; and
access to high quality open spaces and opportunities for sport and recreation can
make an important contribution to the health and well-being of communities.
Regional
3.17 The London Plan provides guidance for connections, public realm and open spaces
including:
delivery of secure, accessible, inclusive, connected, legible, uncluttered public realm
that relates to the local context, including heritage;

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incorporating the highest quality design, landscaping, planting, street furniture and
surfaces; and
delivery of new public open space to address areas of deficiency.

3.18 The Mayors Old Oak and Park Royal OAPF principles D1, D2, OO2 and OO3
provide guidance for delivering new and improve connections, public realm and open space
within Old Oak and Park Royal.
Preferred Policy Option:
OPDC will support proposals that deliver:
a) improvements to the existing street network, as well as a new street network
that connects stations, key destinations, neighbourhoods and surrounding
areas;
b) the highest standards of design for the public realm that can positively
accommodate change and innovation over time;
c) a well-connected and legible network of high quality and varied public,
communal and private open spaces to meet all needs; and
d) development that celebrates the existing open spaces of Wormwood Scrubs,
the Grand Union Canal, the canalside nature reserve, St. Marys Cemetery,
Wesley Playing Fields and Acton Cemetery.
Justification
3.19 Connecting Old Oak and Park Royal into London, west London and its local context
will be fundamental to the successful regeneration of this area. The key routes shown in
Figure XX will be key in achieving this. High quality public realm not only supports movement
but plays a key role in facilitating social interaction. Along these routes, there will be
locations where routes intersect that can become the focal point for new communities, such
as Grand Union Square. At these focal points, uses and activities that encourage vibrancy
will be supported. New connections will enable local communities to access services in and
around Old Oak and Park Royal. The public realm should be accessible to all people and
respond to changing needs.
3.20 Open space plays a key role in supporting the health and well-being of local
communities and is critical in delivering the green infrastructure network (see policy EU8).
New development should enable delivery of new and improved open spaces that support the
needs of a new community living and working across Old Oak and Park Royal. During the
development of Old Oak, there will also be a need for temporary open spaces to activate the
area and provide amenity for the early phases of development.
3.21 Bringing public, communal, private and temporary open space together provides an
opportunity to deliver a varied and well-used green grid across the life of the development.
Alternative Policy Options
3.22 No reasonable alternative policy options have been identified. The creation of
connected places served by open spaces that meet need is underpinned by national and
regional policy.
Consultation Questions
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QOSP3a: Do you agree with the preferred policy option? If not, what might you
change about the preferred policy?
QOSP3b: Are there any other policy alternatives that could replace the preferred
policy or should be considered as alternatives?
Policy OSP4: Densities and building heights
Key Issues
1. Delivery of high density development will optimise the areas excellent public transport
accessibility. This approach will contribute to Londons growth and competitiveness.
2. Intensification of Park Royal could support the industrial areas continued growth and
role in the London economy.
3. Well-designed high density and tall building development can play a positive role in
creating vibrancy and a sense of place. To be successful, such buildings should be
exemplar and ensure the creation of a liveable place and avoid poor quality
environments.
4. Changes to public transport accessibility identified in this draft Local Plan may require
changes to the spatial distribution of density set out in figure XX.
Policy Framework
National
3.23 NPPF identifies that decisions should aim to ensure that development optimises the
potential of sites to accommodate development.
Regional
3.24 The London Plan provides guidance for tall buildings and residential densities. Tall
buildings are promoted in Opportunity Areas and high densities are also promoted in areas
of good public transport accessibility.
3.25 The Mayors Old Oak and Park Royal OAPF principles D3 and OO4 provide
guidance for building heights and densities within Old Oak and Park Royal.
Preferred Policy Option:
a) OPDC will support proposals that deliver predominantly:
i.
the highest density development around Old Oak Common Station;
ii.
high density development around other rail stations and at key
destinations responding to the surrounding context;
iii.
medium densities at residential-led areas; and
iv.
lower densities at sensitive edges.
b) OPDC will support proposals that focus taller buildings at stations, key
destinations and where they contribute to placemaking.
Justification
3.26 High density housing, retail, employment space and social infrastructure is required
to help optimise the use of land in this area and to deliver both a new urban area and a high
performing industrial area.
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3.27 OPDC has developed a draft Development Capacity Study (DCS) for review and
comment alongside this draft Local Plan. This sets out OPDCs draft housing trajectory and
shows how the area could accommodate the targets set out in the London Plan. The
capacity analysis in the DCS identifies areas that could accommodate different densities.
Suggested density levels that may be appropriate in different locations are:

Highest - Old Oak Common Station and surrounds: in the region of 600 units per
hectare;
High - Stations and key destinations: in the region of 550 units per hectare;
Medium - Residential led areas: in the region of 405 units per hectare; and
Lower - Sensitive edges: in the region of 300 units per hectare.

3.28 The density ranges set out in this draft of the Local Plan are not predetermined
densities and are specific to Old Oak and Park Royal. These ranges will be used to guide
development proposals and demonstrate how the total quantum of development as required
by London Plan targets could be arranged on site. It is recognised that development on
particular sites may be carried out in a number of different ways and alternative proposals
could be considered appropriate if they accord with relevant planning guidance.
3.29 High density development is appropriate around stations. However, to the north of
Willesden Junction Station, around the proposed Old Oak Common Lane Station and to the
south of proposed Old Oak Common Station there are sensitive locations. In these locations,
development will need to strike a careful balance between optimising development and
responding positively to the surrounding existing context while achieving the highest
standards of design.
3.30 The high and highest densities identified are likely to exceed the London Plans
density matrix. However, the London Plan does note that it is not appropriate to apply the
density matrix mechanistically and that other factors should be taken into account such as
local context, design and transport capacity.
3.31 This draft Local Plan supports small to large scale catalyst uses where they
contribute to creating a sense of place and deliver vibrancy. The scale of catalyst uses may
have an impact on the distribution and range of densities. Small or medium sized catalyst
uses are assumed to be integrated as part of new mixed use development. However, large
scale catalyst uses may require a significant land take and be of a form which cannot be
easily integrated with housing and other commercial uses. As such, to accommodate large
scale catalyst uses, the distribution of development densities may need to be adjusted and
increased in locations to meet the homes and jobs targets set out in Annex A of the London
Plan. Please refer to OSP5 for further information and relevant consultation questions.
3.22 High density development does not directly equate to the delivery of tall buildings and
can be delivered across a range of building heights. High density development can include
tall buildings. Tall buildings must achieve the highest standards of design, be mindful of their
surrounding context and accord with the requirements set out in national guidance, the
London Plan and the draft preferred policy options of this Local Plan. Taller buildings should
be focused in the highest and high density areas identified above but there may be
opportunities for taller elements elsewhere where they contribute to coordinated place
making and create a moment of interest.
Alternative Policy Options

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3.23 No reasonable alternative policy options have been identified. Optimising densities in
Opportunity Areas and in areas of good public transport is underpinned by national and
regional policy.
Consultation Questions
QOSP4a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, are there any other policy alternatives that could
replace the preferred policy or should be considered as alternatives?
QOSP4b: Do you agree with the areas identified as sensitive locations?
QOSP4c: Are there any sensitive locations that could accommodate higher densities?
QOSP4c: Are there other locations where high density development and / or taller
buildings may be appropriate?
QOSP4d: Are there any locations where high density development and / or taller
buildings may not be appropriate?
QOSP4e: Could the suggested density ranges be amended and still deliver the
London Plan targets?

Policy OSP5: Places

Key Issues
1. National and regional guidance both recognise the importance of creating places in
which people want live, work, play and visit.
2. The scale of development proposed across Old Oak and Park Royal will significantly
alter the character of the area and will also have an impact on the character of
surrounding places.
3. There is an opportunity to create a series of new lifetime neighbourhoods and
connected areas that can help to overcome the areas current severance.
4. These places can start to develop their own character and each should celebrate
existing features.
Policy Context
National
3.24 The National Planning Policy Framework (NPPF) requires that planning authorities
develop policies based on an understanding and evaluation of its defining characteristics
and provide guidance for establishing a strong sense of place that responds to local
character and history, while not preventing or discouraging innovation.
Regional
3.25 The London Plan recognises the importance of place making. It sets out a series of
comprehensive design related policies that provide comprehensive guidance for delivering
Lifetime Neighbourhoods and for development to help reinforce or enhance the character,
legibility, permeability, and accessibility of neighbourhoods. It also provides guidance for
development to build on the positive elements of character and have regard to the form,
function, structure, scale, mass and orientation of a place.
Preferred Policy Option:
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OPDC will support proposals that:

a) Create a series of attractive and locally distinctive places (see figure xx) and
lifetime neighbourhoods;
b) Celebrate existing features of the Grand Union Canal, Wormwood Scrubs, Park
Royal, designated heritage assets and existing communities;
c) Demonstrate early engagement with existing residents and businesses to
inform placemaking;
d) Provide activation projects and meanwhile uses to help deliver early vibrant
places. Proposals over a certain size will be encouraged to submit a meanwhile
strategy; and
e) Deliver a mix of catalyst uses where they accord with the policies of this plan
and which could include uses such as culture, sports and leisure uses,
education and health institutions:
i.
Small and medium sized catalyst uses will be supported in town centre
locations or areas of high activity, which are integrated as part of mixed
use developments; and
ii.
Large scale catalyst uses will be supported where they generate
vibrancy and support placemaking.

Figure xx: Proposed places (draft)

Justification
3.26 The regeneration of Old Oak offers a once in a lifetime opportunity to deliver a new
part of London. At this early stage it is important that initial planning policies provide flexibility
to encourage and allow for changing circumstances to shape this area. As such, this draft
plan seeks to establish a number of key parameters to inform development.
3.27 Improving and creating new places within Old Oak and Park Royal is critical in
fostering a fine grain character. Recognising existing positive elements of the local context
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and local distinctiveness will help inform current and new areas and help foster and nurture a
sense of place. The Places Chapter (chapter 4) sets out detailed place specific policies
across the OPDC area. These policies seek to achieve a series of unique and connected
places that interrelate to one another and to surrounding areas. These suggested places are
listed in Table XX below.
Old Oak South
Old Oak North
Old Oak High Street
Grand Union Canal
Park Royal
Heart of Park Royal
North Acton
Scrubs Lane
Old Oak West
Wormwood Scrubs
3.28 Existing communities have a wealth of knowledge and are well placed to know what
currently does and does not work. This local knowledge is important to inform placemaking.
To best capture this local expertise, applicants are encouraged to engage at the earliest
opportunity with local communities and businesses in line with the requirements of OPDCs
Statement of Community Involvement (SCI). To supplement local knowledge, OPDC has set
up a Place review group, to review and comment on emerging proposals to ensure
development delivers a series of high quality, attractive and liveable places.
3.29 Meanwhile or pop-up uses can play a valuable role in creating an early sense of
place, by attracting innovative businesses to an area and creating a buzz. OPDCs SocioEconomic Regeneration Strategy will set out how it will support and foster workspace and
meanwhile uses to enable early employment uses and entrepreneurial activity.
3.30 OPDCs Cultural Principles provides examples of how the provision of culture and art
can help attract business start-ups and innovators to an area, whilst OPDCs Retail and
Leisure Needs Study (RLNS) identifies recent retail and employment- led meanwhile
schemes such as Boxpark Croydon, the Artworks in Elephant and Castle and Pop Brixton.
To support placemaking, OPDC will require developers providing a significant proportion of
homes and/or floorspace to submit a meanwhile strategy that sets out how development will
deliver vibrant interim uses and spaces to help to activate schemes within early development
phases.
3.31 Small to large-scale catalyst uses could act as a focus for early development. They
can also act as an attraction drawing people into an area and helping it to become a
recognised and successful part of London where people want to live, work, visit and play.
Such uses could include culture, sports, leisure uses, education and health institutions. The
provision of Central St Martins University of Arts at Kings Cross provides a recent
example of how such uses can help create an early sense of place. OPDC will work with
developers and providers to explore ways in which such uses could be attracted to help
accelerate development and regeneration.
3.32 The Places Chapter identifies four broad locations in which small, medium and largescale catalyst uses may be appropriate:
-

Old Oak South (P1);

Old Oak North (P2),
Old Oak High Street (P3); and
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-

North Acton (P7).

3.33 Small and medium sized catalyst uses are an integral part of town centre uses and
should be focused within the town centre hierarchy or in areas of high footfall.
3.34 Large-scale catalyst uses can play a more fundamental role in placemaking, helping
to create a destination and providing uses that serve a London-wide need as well as meeting
local needs. Large-scale uses may have a significant land-take, with subsequent impacts on
amenity and transport networks. Large-scale catalyst uses may also result in a need for
greater flexibility in development densities to continue to achieve the homes and jobs targets
identified for the OPDC area in the London Plan. Different large-scale catalyst uses will have
different impacts on their surroundings and for such uses to be acceptable these would need
to clearly demonstrate how they have successfully mitigated these impacts.
Alternative Policy Options
3.35 No reasonable alternative policy options have been identified. Creating high quality
places is underpinned by national and regional policy. Alternatives not promoting meanwhile
uses or catalyst uses are not considered reasonable as they would stifle development in the
OPDC area.
Consultation Questions
QOSP5a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, are there any other policy alternatives that could
replace the preferred policy or should be considered as alternatives?
QOSP5b: Are there any amendments or additions to the proposed place boundaries
needed to either:
Better reflect existing character and neighbourhoods?
Deliver a finer grain series of places?
QOSP5c: Are the four places identified for catalyst uses appropriate? Should other
places be identified as appropriate locations for catalyst uses?
QOSP5d: Are there other catalyst uses not included in the list that would also support
the delivery of the draft Local Plan spatial vision and objectives?
QOSP5e: Should OPDC support catalyst uses if they result in increased densities
beyond those identified in OSP4?

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4. THE PLACES
THE PLACES
Key Issues
1. OPDCs draft Local Plan includes thematic policies. These policies will be applied to
any site across the OPDC area but would not, by themselves, result in distinctive
places or neighbourhoods being delivered.
2. To set clearer policies to ensure that new development delivers a strong sense of
place, OPDC has identified ten places, which reflect the areas different, yet related,
character.
3. For each place, a vision has been developed alongside place specific policies that
set out how development will contribute to the delivery of the vision.
4. Within each of the places there may be opportunities for a series of smaller scale
neighbourhoods to emerge over time.
5. Over the life of the plan, the different places and neighbourhoods of Old Oak and
Park Royal will change and evolve. It is not possible or appropriate now to categorise
what the specific character of an area will be in 20 years. For now, it is important to
identify the key parameters that new development should seek to deliver or enhance
that will give each place the best opportunity to develop a high quality, well designed
place.
Policy Context
National
4.1
The NPPF encourages local planning authorities to allocate sites for development
and set clear policies for the expected land use and planning principles for development.
The NPPF also requires that Local Plans include policies that establish a strong sense of
place, using streetscapes and buildings to create attractive and comfortable places to live,
work and visit.
Regional
4.2
The London Plan recognises the importance of placemaking and the need to create a
strong sense of place within Londons new developments. London Plan Annex A includes
policies for the Old Oak Common and Park Royal Opportunity Areas. These provide a high
level overview of the anticipated land use and design approach to redevelopment in the
OPDC area, but do not provide detailed place-specific policies for the area.
Key Evidence
Study
OPDC Development
Capacity Study
OPDC Retail and
Leisure Needs Study
(RLNS)
OPDC Old Oak
Decentralised Energy
Strategy
OPDC Walking, cycling
and public realm
strategy

Description
A study looking at the capacity of the OPDC area
to accommodate new homes and jobs.
A study looking at the need for retail and leisure
space in the OPDC area.

Status
Draft completed

A strategy showing how a decentralised energy

network could be delivered in a phased manner in
Old Oak Common.
A strategy setting out recommendations for the
public realm, public open space and walking and
cycling infrastructure for the OPDC area.

Draft completed

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Draft completed

To be developed



OPDC Green
Infrastructure Strategy

OPDC Character Note

HE Old Oak Outline
Historic Assessment &
Addendum
OPDC Park Royal
Heritage Assessment
OPDC Views Study
OPDC Cultural
Principles

A strategy reviewing existing GI assets, future GI

requirements, and identifying opportunities for
improving function, connectivity and integration
with other infrastructure.
Sets out suggested character areas within and
around Old Oak and Park Royal.
Assessment of the historic character and
appearance of Old Oak.

To be developed

Assessment of the historic character and

appearance of Park Royal alongside identification
of local views.
Identification of local views within and around the
OPDC area.
A document showing how OPDC can contribute
to Londons position as the worlds cultural capital
and how embedding culture in development can
assist placemaking

To be developed

To be developed
Completed

To be developed
Draft completed

THE PLACES
P1: Old Oak South
P2: Old Oak North
P3: Old Oak High Street
P4: Grand Union Canal
P5: Park Royal
P6: Heart of Park Royal
P7: North Acton
P8: Scrubs Lane
P9: Old Oak West
P10: Wormwood Scrubs
Alternative policy options
4.3
Alternative policy options have not been provided for the preferred policy options as
the Old Oak and Park Royal Opportunity Area Planning Framework sets out the principles
for each of the places. However, responses to the relevant consultation questions are
welcomed.
Consultation Questions
QPa: Do you agree with the proposed places within Old Oak and Park Royal? Are
there any additional places that could be added to better reflect existing character
areas or respond to future uses?
QPb: Do you agree with the boundaries for each place? Should these be amended
and / or places added or removed? Could the boundaries be amended to better reflect
existing neighbourhoods ensuring these neighbourhoods are fully integrated with
new development?
QPc: Do the proposed policy options and proposed visions reflect the existing and
potential future character of each place? Could these be refined?
Qpd: For each of the Places, should the Local Plan state the number of homes and
amount of commercial floorspace and social infrastructure planned for each place?
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POLICY P1: OLD OAK SOUTH

EXISTING CHARACTER
4.4
The area is approximately 63 hectares in size. Its predominant land use is
operational railway infrastructure. The area is also home to two residential communities, at
Midland Terrace and Wells House Road and a designated but underused nature reserve on
the southern edge of the Grand Union Canal. It includes the shield site that is due to be
cleared for HS2 construction works. The area is bounded by the Grand Union Canal to the
north, Wormwood Scrubs to the south, Scrubs Lane to the east and Victoria Road/Old Oak
Common Lane to the west.
4.5
The Grand Union Canal is a designated Conservation Area and the open space on
the southern edge of the canal is an identified nature reserve.
4.6
Much of the developable area is in public sector ownership across Network Rail and
the Department for Transport with long leases to Transport for London (TfL), Crossrail and a
series of rail operators. High Speed 2 (HS2) will also acquire a significant amount of land
across Old Oak South through the Hybrid Bill process. There are a series of large scale rail
depots currently operating, or planned to operate, from the area including the Crossrail
depot, the Intercity Express Programme (IEP) Depot, First Great Western, and Heathrow
Express. In the north-west corner of the site sits the derelict former British Railways Hostel,
known as Oaklands House.
4.7
Walking and cycling access is very constrained across the area preventing
movement to the north/south and east/west.
VISION
4.8
Old Oak South will see a new commercial hub centred around a world-class Old Oak
Common Station that will act as a key catalyst for regeneration. This HS2, Crossrail and
Great West Coast Main Line station, along with a new London Overground station on the
West London Line, will be fully embedded into their surroundings and will provide residents,
workers and visitors with easy access to west London and the wider Old Oak and Park
Royal regeneration area.
4.9
Old Oak South will house a significant proportion of Old Oaks total new commercial
and retail space alongside opportunities for catalyst uses, along with new high density
housing all supported by a mix of open spaces and community infrastructure.
4.10 A complete new network of streets and bridges will integrate Old Oak South with its
surroundings. The primary streets of Old Oak High Street and Grand Union Street will be the
focus for town centre uses and wider movement, with Oaklands Street also acting as a key
connecting street between north and south.
4.11 Wormwood Scrubs, the Grand Union Canal and its associated nature reserve will be
celebrated features of Old Oak South and will be integral to the creation a unique sense of
place.
PREFERRED POLICY OPTION:
New development will be required to:

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Land uses
a) Demonstrate how any small, medium and / or large scale catalyst uses support
placemaking and where relevant mitigates impacts on the surrounding area;
b) Deliver a new commercial hub focused around the Old Oak Common Station;
c) Deliver a range of flexible workspace typologies for B1(a) uses in and around Old
Oak Common Station and B1 uses in other accessible locations;
d) Provide new retail and other town centres uses, including community space,
focused around Old Oak Common Station, along Old Oak High Street and along
Grand Union Street;
e) Deliver residential development across the whole of Old Oak South;
f) Support the delivery of a network of unique and connected neighbourhoods;
Density
g) Deliver highest densities around the new Old Oak Common Station;
h) Deliver high densities around Old Oak Common Lane Station;
i) Deliver a mix of densities, including high densities, at other key destinations and
routes including along Grand Union Street, Old Oak High Street, Oaklands Street
and at the Grand Union Canal;
j) Be mindful of existing residential communities at Wells House Road, Midland
Terrace/Shaftsbury Gardens, and the adjacent amenity and ecological open
spaces of Wormwood Scrubs and Grand Union Canal;
k) Provide a sensitive edge onto Wormwood Scrubs and the Grand Union Canal;
Delivery
l) Support the redevelopment of all existing infrastructure, rail and industrial uses
including the Crossrail depot, the Intercity Express Programme (IEP) Depot, where
feasible, as well as above and around stations in particular the new Old Oak
Common Station;
Transport
m) Support delivery of a new world class High Speed 2, Crossrail and Great West
Main Line interchange station (Old Oak Common Station), a new London
Overground station on the West London Line (Old Oak Common Lane Station) and
provision of new bus, taxi and cycle services that are fully integrated into their
surroundings;
n) Support delivery of a new rail link between Crossrail and the West Coast Main
Line;
Streets
o) Contribute to the delivery of a new north-south Old Oak High Street, a new eastwest Grand Union Street and associated bridges across the Grand Union Canal;
p) Deliver seamless connections through Old Oak Common Station, connecting it to
its surroundings in all directions and making the station an integral place making
feature;
q) Provide direct 24 hour pedestrian and cycle access to Wormwood Scrubs through
Old Oak Common Station and in other locations if feasible;
r) Provide a new Oaklands Street with a direct vehicle bridge over the Grand Union
Canal;
s) Improve existing streets of Old Oak Common Lane and Victoria Road ensuring
existing residential and business areas are integrated with new development;
t) Support better connections to Kensal Canalside Opportunity Area;
Social infrastructure

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u) Deliver three health centres, a community hub and two primary schools and for
these to be located to ensure they become focal points of the community;
Open spaces
v) Celebrate the unique character of Wormwood Scrubs and the Grand Union Canal
and associated nature reserve and support these in becoming accessible focal
points for the area;
w) Provide a network of connected and varied open spaces for residents, workers
and visitors including new arrival spaces at the entrances to both Old Oak
Common Station and Old Oak Common Lane Station;
x) Carefully mitigate impacts of existing rail uses and embankments.
Environment
y) Overcome current surface water flooding issues experienced to the south of the
Grand Union Canal and north of Wormwood Scrubs;
JUSTIFICATION
4.12 Old Oak South will be home to a new world class Old Oak Common Station that
deserves a world class place. Accompanied by a new London Overground station at Old
Oak Common Lane, these new stations will make Old Oak South one of the most accessible
locations on the London transport network with direct connections to central London, Euston,
the West End, Canary Wharf, Heathrow, the south east region, Birmingham and the North.
4.13 A rail connection between the West Coast Main Line and the Great West Coast Main
Line would enable improved rail connections between both rail lines. This would also provide
opportunities for Crossrail trains to run northbound towards Tring. At the time of writing this
draft Local Plan, no feasibility work has been carried out into the benefits, business case or
delivery.
4.14 The challenges associated with delivering the new London Overground Stations
should not be underestimated. At the time of writing this draft Local plan, the proposed
London Overground stations have only undergone initial feasibility work. Funding has now
been secured to further progress the design and business case for these; however, currently
there is no capital funding secured for delivery of these stations. The final arrangements for
these stations will be dependent on the outcome of this work.
4.15 In accordance with London Plan policy, the high degree of transport access supports,
in land use terms, a high-density, mixed-use approach to development. At and around the
proposed Old Oak Common Lane Station, high densities may be appropriate reflecting the
good public transport access. However, there are sensitive areas in the surroundings and
therefore development will need to strike a balance between optimising density and
responding to the existing context.
4.16 New development in Old Oak South should include commercial, hotel, retail, leisure
and a full mix of town centre uses focused around the new stations, Old Oak High Street and
Grand Union Street. There may also be opportunities for anchor or catalyst uses that would
contribute to Old Oaks role as a London destination. OSP5 provides information relating to
potential catalyst uses. Development on the fringes of Old Oak South, such as the Oaklands
House site, the Shield site and the North Pole East depot are most likely to be residentialled, with supporting local retail and social infrastructure to meet the day-to-day needs of
residents.
4.17 Providing new connections into Old Oak South will be critical to the successful
regeneration of the area. The provision of Grand Union Street - an eastern highway link,
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bridging the gap between the HS2 interchange and Hythe Road, is the single most important
highway link to provide in Old Oak, as it connects the largely residential development to the
north, to the transport hub and commercial development to the south, as well as providing
east-west through connections for other transport modes. During 2016, further work on the
design, location and deliverability of this bridge will be carried out.
4.18 Integrating new development with existing features will be key to creating a unique
sense of place. Celebrating the Grand Union Canal, Wormwood Scrubs and existing
communities will be very important in achieving this sense of place and new development
proposals will need to clearly demonstrate how it best achieves this. OPDC will work will key
partners including; landowners, applicants, the local Councils, the Wormwood Scrubs
Charitable Trust, the Canals and River Trust, local residents and interest groups to explore
how this can be achieved. Securing the delivery of social infrastructure is fundamental to
delivering successful place making. A number of social infrastructure uses are identified to
be delivered. In addition to these, Old Oak South may also be suitable for an all-through
school.
4.19 The majority of Old Oak South is expected to come forward for development post2026, when Old Oak Common Station is scheduled to open and the HS2 constructions sites
are vacated. Securing the comprehensive regeneration of Old Oak South, in a timely
manner, will require careful coordination across the public sector. The scale and complexity
in relocating and/or reconfiguring all existing infrastructure and depots cannot be
underestimated. OPDC will need to work with freeholders, leaseholders and operators to
secure a feasible programme that can best achieve both the Mayors and central
Governments requirements and aspirations for this area.
Consultation Questions
QP1a: Do you agree with the approach set out for this preferred policy option?
QP1b: Within Old Oak South should we identify a series of smaller scale
neighbourhoods that could develop their own character?
QP1c: Are there other land uses, including catalyst uses, that could be supported in
this place?
QP1d: Should the nature reserve be kept in its current location and improved, or
could it be re-provided as a series of additional new spaces across Old Oak South
with development built up to the edge of the canal?
QP1e: Do you have any other comments/observations about the proposed approach
for Old Oak South?

POLICY P2: OLD OAK NORTH

EXISTING CHARACTER
4.20 Old Oak North is approximately 43 hectares. It is home to Cargiant, the UKs largest
second-hand car dealership who occupy approximately 20 hectares. There is a significant
amount of rail infrastructure in the area, including the North London Line, West London Line,
West Coast Main Line and a number of rail freight spurs that connect these lines together.
Old Oak North is also home to Powerday and European Metal Recycling (EMR) who operate
waste recycling and processing plants. Within Old Oak North there are also a substantial
number of small and medium enterprises (SMEs), many of whom occupy Cargiant land.
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Freehold land ownership is split between Cargiant and public sector landowners including
Network Rail and the London Borough of Hammersmith and Fulham.
4.21 The area is bound by the Grand Union Canal in the south, Old Oak Lane and railway
lines to the west, Harlesden and railway lines to the north east and railway lines to the west
with Scrubs Lane beyond.
4.22 Willesden Junction Station is situated in the northern part of Old Oak North and
provides access to both the Bakerloo Line and London Overground. However, access from
this station to the core development area is poor - limited to a lightweight and narrow
pedestrian bridge over the West Coast Main Line. Harlesden Town Centre is immediately to
the north. Within the core development area there are no through east-west vehicular links.
The pedestrian environment is particularly hostile, with existing routes isolated from
surrounding uses and suffering from a lack of natural surveillance.
VISION
4.23 Old Oak North will be redeveloped in the earlier phases of the areas comprehensive
regeneration and will set the benchmark for what is to come in Old Oak South. The area will
be residential-led along with a mix of town centres and catalyst uses that will support a future
residential population.
4.24 New and improved connections into and out of Old Oak North, coupled with an
enhanced Willesden Junction Station and new London Overground station at Hythe Road,
will dramatically improve accessibility, permeability and legibility allowing Old Oak North to
be redeveloped to provide a series of new high quality connected lifetime neighbourhoods.
4.25 Old Oak North will make a significant contribution to the areas housing need. The
future population will benefit from a new network of streets, open spaces and associated
community infrastructure embedded into new buildings in accessible locations. Town centre
uses will be focused primarily along Old Oak High Street, Willesden Junction Station and
around Hythe Road Station. New employment space will cater mainly for SME and microbusinesses as part of new mixed-use buildings. Early phases will be supported by a range of
uses that activate the area including meanwhile uses and employment space for SMEs that
help support placemaking, deliver a mixed use place and act as a catalyst for wider
regeneration. This type of workspace will also provide a different offer from the large
commercial spaces in Old Oak South.
4.26 Densities in Old Oak North will vary. Sensitive areas such as along the canal will
accommodate a range of densities whilst in areas of good public transport access as well as
key destinations and focal points, there will be opportunities for higher densities.
PREFERRED POLICY OPTION:
New development will be required to:
Land uses
a) Demonstrate how any small, medium and / or large scale catalyst uses support
placemaking and where relevant mitigate impacts on the surrounding area;
b) Deliver high quality, residential-led development;
c) Provide a range of flexible workspace typologies for B1 uses;
d) Provide B1(b) and B1(c) uses at locations adjacent to transport and / or utilities
infrastructure;

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e) Provide for meanwhile and flexible open workspace that can help with early
placemaking;
f) Deliver town centre uses focused along Old Oak High Street, the Grand Union
Canal and around Hythe Road Station and Willesden Junction Station;
Density
g) Deliver high density development to the south of Willesden Junction Station and
around the new Hythe Road Overground station
h) Deliver a mix of densities, including high density, at other key destinations and
routes including along Grand Union Street, Old Oak High Street and the Grand
Union Canal;
i) Be mindful of existing residential communities;
j) Be mindful of existing heritage and ecological spaces such as the Grand Union
Canal, St. Marys Cemetery and Kensal Cemetery, and residential communities at
Old Oak Lane, Scrubs Lane and Tubbs Road;
k) Support the delivery of a network of unique and connected neighbourhoods;
Delivery
l) Support the early redevelopment of the area;
m) Safeguard the Powerday waste site (see policy EU4);
Transport
n) Facilitate delivery of an enhanced Willesden Junction Station;
o) Facilitate delivery of a new Overground station on the West London Line;
Streets
p) Provide continuous access to the northern edge of the Grand Union Canal;
q) Contribute to the delivery of Old Oak High Street;
r) Provide better connections into Harlesden Town Centre;
s) Deliver a new bridge over the West Coast Main Line connecting Willesden
Junction to the core development area;
t) Provide a new connection into Old Oak North from Scrubs Lane and enhance the
existing Hythe Road entrance;
u) Provide new and enhance existing connections over and/or under the North
London Line, West London Line and Grand Union Canal;
Social infrastructure
v) Deliver a health centre, community hub and a primary school and for these to be
located to ensure they become focal points of the community;
Open spaces
w) Celebrate the unique ecological and historic character of Grand Union Canal and
associated nature reserve, and support it in becoming an accessible focal point
for the area with appropriate cultural uses;
x) Provide a fine grain form of development around the Canal in particular and a
network of connected and varied open spaces, including spaces along the
northern edge of the canal, arrival spaces outside of Willesden Junction and Hythe
Road Stations as well as a good sized new residential park or parks;
Environment
y) Overcome current surface water flooding issues experienced to the north of the
West London Line;
z) Facilitate the delivery of an energy centre;
aa) Carefully mitigate impacts of waste facilities on new and existing residential
development; and
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bb) Carefully mitigate impacts of existing rail uses.
JUSTIFICATION
4.27 Development proposals within Old Oak North will be expected to be residential-led
contributing to the areas housing supply. Old Oak North is anticipated to form one of the
earlier phases of development and the quality of place created here will play an important
role in shaping the wider Old Oak area.
4.28 There is an opportunity to secure a range of catalyst uses including small, medium
and large scale catalyst uses that would play a role in creating a vibrant place that attracts
people to the area. OSP5 (chapter 3) provides information relating to potential catalyst uses
and could include cultural, sports, leisure, health and education uses.
4.29 Town centre uses should be focused along Old Oak High Street, Hythe Road Station,
Willesden Junction Station and along the northern edge of the Grand Union Canal (see Old
Oak High Street place).
4.30 OPDC will support proposals that deliver early meanwhile uses and low-cost SME
open workspaces that help businesses establish in the area quickly and will help to create a
buzz. This has been done successfully in other big regeneration projects such as at
Elephant and Castle and at the Olympics site.
4.31 Densities should be optimised close to the areas of highest transport access at
Willesden Junction and the new London Overground station at Hythe Road. Densities should
be lower and more sensitive in terms of their architectural treatment close to heritage assets
and existing residential areas. At and around the Willesden Junction Station, high densities
may be appropriate reflecting the good public transport access. However, there are sensitive
areas in the surroundings and therefore development will need to strike a balance between
both of these contextual elements that achieves the highest standards of design and seeks
to enhance relationships with the existing and new built environment.
4.32 The Grand Union Canal is a particularly sensitive location in the Old Oak North area.
There may be opportunities for exceptionally designed taller elements at key destinations
and focal points on the canal where these create visual interest. Development should be
informed by the areas ecological and heritage qualities and special consideration must be
given to the scale of new buildings and the use of materials along the canal edge.
4.33 The challenges associated with delivering the new London Overground Stations
should not be underestimated. At the time of writing this draft Local Plan, the proposed
London Overground stations have only undergone initial feasibility work. Funding has now
been secured to further progress the design and business case for these; however, currently
there is no capital funding secured for the delivery of these stations. The final arrangements
for these stations will be dependent on the outcome of this work.
4.34 New development provides opportunities to overcome the areas severance and
connect Old Oak North into its surroundings. Delivering better connections to Harlesden
Town Centre will be particularly critical, so that this part of London can share in the benefits
that the regeneration of the OPDC area will bring. The delivery of a new bridge over the
West Coast Mainline, linking Old Oak North to Willesden Junction Station will be necessary,
to unlock the full development potential of the area. There is an aspiration for this bridge to
be vehicular, so as to improve connectivity and public transport access into the site from the
surroundings. Creating a bus link between the heart of Old Oak and Willesden Junction
would provide benefits in terms of bus accessibility, journey times and operational efficiency.
However, it is recognised that a vehicular bridge could be challenging and further feasibility
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work should be undertaken to understand this further. At a minimum, this bridge would be a
high quality pedestrian and cycle bridge.
4.35 Willesden Junction is a major interchange for north and west London providing
Bakerloo line and London Overground services. Significant improvements to the station will
be required to cater for development related trips generated by the Old Oak development
and to act as a focus for development around Old Oak North. The station will need to offer
improved interchange, improved accessibility, better connections with buses and high quality
pedestrian and cycle links to the surrounding streets. Any proposed work in and around the
station including links over rail lines will require liaison with the Network Rail Delivery and
Operations team.
4.36 Development in Old Oak North should be supported by adequate open space. This
should include a new park, which could be formed of one larger space or a series of good
sized but smaller spaces across the area. With either approach, this space or spaces should
provide for a range of leisure and recreation activities to meet the needs of a varied
population. There should also be a series of new open spaces provided along the Grand
Union Canal. These could be a mix of hard and soft spaces and should help celebrate the
canal as a focal point in Old Oak. New arrival spaces will also be required at both Willesden
Junction and Hythe Road within Old Oak North the High Street will also play an upfront role
in providing key open space and a focal point of social interaction. Further information is
provided in policy P3.
4.37 Securing the delivery of social infrastructure is fundamental to delivering successful
place making. A number of social infrastructure uses are identified to be delivered. In
addition to these, Old Oak North may also be suitable for an all-through school.
4.38 There are significant surface water flooding issues to the north of the West London
Line and development proposals in this area will need to identify ways to address this.
Consideration should be given first and foremost to the utilisation of SuDS to minimise
pooling.
4.39 OPDCs Decentralised Energy Strategy identifies the need for an energy centre in
Old Oak North, to serve the needs of the earlier phases of development. This could be linked
to the Powerday waste facility to generate energy from waste. As development phases come
forward, this facility could subsequently be expanded to meet wider needs. Further work on
energy supply will be carried out during 2016 and they will better inform the approach that
should be taken onsite. More information is available on this approach in the Environment
and Utilities Chapter.
4.40 Air quality and noise issues are generated by Powerday and from rail uses. New
development will need to clearly demonstrate how design has successfully mitigated these
issues. This will be critical in ensuring a high quality residential environment.
Consultation Questions
QP2a: Do you agree with the approach set out for this preferred policy option?
QP2b: Within Old Oak North should we identify a series of smaller scale
neighbourhoods that could develop their own character?
QP2c: Are there other land uses, including catalyst uses, that could be supported in
this place?
QP2d: Should the new park be provided as one large space or as a series of linked
new spaces across Old Oak North?
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QP2e: Should development provide a continuous walking and cycling route along the
northern edge of the canal?
QP2f: Do you have any other comments/observations about the proposed approach
for Old Oak North?

POLICY P3: OLD OAK HIGH STREET

EXISTING CHARACTER
4.41 The proposed Old Oak High Street is approximately 1 km in length and runs across
Old Oak North and Old Oak South. Starting at Old Oak Lane, existing land uses and
infrastructure along its length include Willesden Junction Station, the West Coast Main Line,
the European Metal Recycling (EMR) plant, light industrial units, railway lines servicing the
London Overground, Cargiant, the Grand Union Canal, the canalside nature reserve, a
Crossrail depot, railway operational land, Great Western Main Line and the Intercity Express
Programme (IEP) Depot before meeting Wormwood Scrubs in the south.
4.42 The route of the High Street covers private sector and public sector land ownership
and varies significantly in terms of its topography, starting at approximately 40 metres above
ordnance datum (AOD) at Willesden Junction and falling to 20 metres AOD at Wormwood
Scrubs.
VISION
4.43 The new high street will be a destination for residents, workers and visitors. A focal
point for both existing and future communities and a place where Londoners will want to visit
and spend time. The high street will provide a new artery through the heart of Old Oak,
linking Harlesden in the north to Old Oak Common Station, Wormwood Scrubs and beyond
to the south.
4.44 The high street and Old Oak Common Station will be designated as a new major
town centre, providing a wide variety of town centre uses and supporting services. The High
Street and around the station will host a wide variety of attractions and town centre uses that
will draw people to the OPDC area from afar and will make the high street a key destination
within this new part of London.
4.45 The character of the high street will change along its length. It will be commercially
focused in Old Oak South, providing services for the large number of employees, and will
provide a mix of uses, including catalyst uses, and spaces in Old Oak North to support the
areas future residential population.
4.46 The high street will be designed to the highest quality, with an exceptional public
realm, incorporating the highest quality materials and green infrastructure. Whilst the
character of the High Street may change along its length, but buildings fronting the High
Street will be of an exemplary architectural quality and will celebrate key features and
destinations along its length. The variation in levels along the High Street will create unique
features and spaces that will play a defining role in shaping Old Oaks sense of place.
PREFERRED POLICY OPTION:
New development will be required to:
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Land uses
a) Provide a significant quantum of A-class uses as well as a range of catalyst
uses including culture, sports, leisure, health and education uses, visitor
accommodation and social infrastructure;
b) Focus primary frontages along the High Street and around public transport
hubs;
c) Focus secondary frontages along Grand Union Street and the northern edge of
the Grand Union Canal;
d) Demonstrate how any small, medium and / or large scale catalyst uses support
placemaking and where relevant mitigates impacts on surrounding area;
e) Deliver uses that support three distinct character areas:
i.
Old Oak Common Station and surroundings where the focus should
be on providing a mix of catalyst uses, comparison retail, larger format
retail and uses to support those working in Old Oak South and
interchanging in the station;
ii.
The Grand Union Canal where the focus should be on providing
sports, culture and leisure uses and eating and drinking
establishments; and
iii.
North of the canal where the focus should be on providing a mix of
catalyst uses and typical high street uses such as convenience retail
and social and community facilities.
f) Provide residential uses on upper floors;
Density
g) Recognise the High Street as a key destination with opportunities for high
densities along its route, responding to sensitive locations;
Delivery
h) Support early delivery of the High Street;
Streets
i) Provide legible connections to and from transport interchanges;
j) Incorporate generous street widths that provides a high quality public realm,
that is attractive for pedestrians and cyclists along its entire length;
k) Create interest from the change in levels;
l) Provide exemplary architecture that marks key destinations;
Open spaces
m) Support the delivery of green infrastructure along its entire length;
n) Support delivery of public open spaces at public transport hubs, by the canal,
at Wormwood Scrubs, at other key destination points and integrated along its
full length.
JUSTIFICATION
4.47 Old Oak High Street will be a key artery within Old Oak, providing direct and legible
connections between key transport and other destinations. It will join north to south. It will be
a community focal point. As a consequence, the high street is anticipated to have a high
footfall and is considered to be the most appropriate location to focus town centre uses. In
recognition this, the draft Local Plan proposes that the High Street is designated as a new
major town centre (see policy TC2). At over 1km, the high street is long and in recognition
of this and the changing character along its length, there will be opportunities for the
predominant land use to change in response to this.
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4.48 New development should achieve the highest quality design that will contribute to
delivering an excellent and accessible public realm. The High Street should be, at a
minimum, a through connection for pedestrians and cyclists with exemplar public realm to
promote its use by these two modes. It may also be necessary for all, or parts, of the street
to be vehicular, including public transport, servicing and private vehicle use. However,
further transport and design work is needed to assess this in more detail. This would be
encouraged where it would add to the streets sense of activity and does not detract from the
environment for pedestrians and cyclists.
4.49 The High Street forms part of the green grid. It is therefore expected that street
widths are generous and incorporate the highest standards of design for the public realm.
Along its length, open spaces and public squares should be provided to contribute to the
open space network. It may also be feasible for open and civic spaces to be provided
contiguously or continuously along its entire length to support the incorporation of green
infrastructure including Sustainable Urban Drainage Systems (SuDS).
4.50 Building heights and massing on the high street should vary, respond to local
character and context and should not create a wall of massing. Any development proposals
will need to be sensitive to its surroundings such as Wormwood Scrubs, the Grand Union
Canal, Kensal Cemetery and nearby existing residential areas.
Consultation Questions
QP3a: Do you agree with the approach set out for this preferred policy option?
QP3b: Are the three distinct characters we have identified for Old Oak High Street
right?
QP3c: Are there other land uses that should be supported in this place?
QP3d: Are there any other land uses we should be identifying as appropriate for Old
Oak High Street?
QP3e: Do you have any other comments/observations about the proposed approach
for Old Oak High Street?

POLICY P4: GRAND UNION CANAL

EXISTING CHARACTER
4.51 The Grand Union Canal within Old Oak and Park Royal is approximately 4.3 km long
with a continuous towpath along its southern edge. It currently provides the only consistent
east - west walking and cycling route through the area and provides a direct connection to
central London. It is designated as a cycle Quietway, a site of Metropolitan Importance for
Nature Conservation and a Conservation Area within Hammersmith and Fulham.
4.52 Today, the uses fronting onto the canal are industrial in nature providing limited
passive surveillance on to the canal and limited access points. These elements have a
negative impact on its use for walking, cycling and recreation.
4.53 The canal itself is home to a community of residential moorings and is currently not
extensively used for transport or freight movement. Landownership falls within the public and

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private sectors with the Canal and River Trust owning a substantial portion of the existing
towpath.
VISION
4.54 The Grand Union Canal will be one of the defining features of both Old Oak and Park
Royal and will be a key place where people will visit, play and spend time.
4.55 The Grand Union Canal will be central to creating a new part of London in Old Oak
and enhancing Park Royal as a thriving industrial area. Within Old Oak, new development
along the canal will transform the character of the area. New development will reflect the
areas heritage and help to create a fine grain built environment. High densities will be
provided in certain locations such as key destinations and focal points, specifically at the
junction with Old Oak High Street.
4.56 There will be a continuous walking and cycling routes on both sides in Old Oak and
on the southern side in Park Royal. It will provide a safe and convenient walking and cycling
route enabling people to access the length of Old Oak, Park Royal and beyond.
4.57 Development adjacent to the canal will provide high quality active frontages
alongside providing level changes to deliver views and access points to the canal along both
the north and south edges. New bridge crossings will support easier north / south movement
while the canal itself will be promoted and used for the transport of people and freight.
4.58 Sitting beside the Grand Union Canal, a string of waterside spaces will complement
the canals historic character providing a mix of spaces for events, relaxation, socialising and
the night time economy along busier stretches. Its ecological role will be enhanced and used
to support the delivery of the green infrastructure network.
PREFERRED POLICY OPTION:
New development will be required to:
Land uses
a) deliver a mix of town centre uses with active frontages and activities at ground
floor level within the Old Oak town centre. This should include a mix of
cultural, sports, leisure, creative, eating and drinking uses;
b) deliver commercial uses, and where possible residential with front doors on to
the canal, providing good overlooking and passive surveillance at other
locations;
c) deliver housing, and employment uses in accessible locations, at ground floor
level elsewhere along its length in Old Oak;
d) deliver industrial uses and ancillary uses with good overlooking and passive
surveillance at ground floor level in Park Royal;
e) support the delivery of residential and visitor moorings in appropriate
locations that do not adversely impact on the regeneration of the wider area or
the navigational function of the canal;
Density
f) recognise the Grand Union Canals designation as a Conservation Area and an
important ecological asset, and as such as a sensitive location. A mix of
densities will be appropriate along the canal including lower and medium
densities but with opportunities for some taller elements at key destinations
where they generate a moment of interest;
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g) deliver a fine grain development along the canal edge,
h) explore the potential to create a variety of character along the canal edge;
Heritage
i) conserve and / or enhance the Grand Union Canal and its setting as a
Conservation Area;
Transport
j) support the delivery of new passenger and freight transport facilities in
appropriate locations;
k) utilise the Grand Union Canal for passenger and freight transport and leisure
uses, taking into account any impact on biodiversity and drainage functions;
Streets
l) contribute to the retention and improvement of the towpath on the southern
side of the canal as a walking route and cycling QuietWay;
m) contribute to and / or deliver a continuous new walking and cycling route along
the northern canal edge within Old Oak;
n) support the delivery of towpath lighting which doesnt negatively impact on
local biodiversity;
o) support the delivery of new bridges over the canal;
p) ensure that existing communities within Park Royal can access and use the
canal to connect into Old Oak;
Open spaces
q) deliver and / or contribute to the delivery of new and improved canalside public
open spaces including Grand Union Square;
r) support the use of canal side spaces for events and activities;
s) explore the opportunity to deliver new waterspaces including basins within Old
Oak;
t) improve the design, treatment and access to the nature reserve within Old Oak;
Environment
u) deliver new and enhanced existing green and civic spaces that help to improve
this important green infrastructure corridor;
v) overcome current surface water flooding issues experienced along the canals
length.
JUSTIFICATION
4.59 The Grand Union Canal is one of the defining features of Old Oak and Park Royal
and provides significant opportunities to shape the regeneration of Old Oak and the
enhancement of Park Royal. Its role and function will change along its length, reflecting the
diverse range of uses and activities from the mixed use character of Old Oak to the industrial
character of Park Royal. Drawing from examples at Battlebridge Basin (LB Islington),
Brindleyplace (Birmingham), Kings Cross (LB Camden) and Hackney Wick (LB Hackney)
these functions will help inform the development and improvement of character areas along
its length. Moorings can also provide a role in activating the area and providing elements of
low cost housing.
4.60 The Grand Union Canal is recognised as a sensitive location reflecting its
designation as a Conservation Area within Old Oak. In light of this, the scale and density of
development will be expected to more restrained than elsewhere, although there will be
opportunities for taller elements at key destinations such as Grand Union Square where they
help to create moments of interest.
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4.61 To support greater use of the canal, active frontages should be focused around key
destinations on the canal edge, particularly along its northern edge, with town centre uses at
key destinations to provide passive surveillance. Improved walking and cycling infrastructure
along both sides of the canal will create a more inviting linear route linking new public open
spaces and water based activities. To support access to the canal and north and south
movement, development will need to coordinate the delivery of new routes and support the
delivery of new bridge crossings. In delivering these elements engagement with
stakeholders including the Canal and River Trust should be undertaken.
4.62 The canal is also a vital asset in securing sustainable transport patterns for
construction, waste and passenger transport. The expansion and intensification of Park
Royal will contribute to increasing the potential for water transport that will require new and
improved wharf facilities and therefore working with Transport for London and water freight
companies to maximise these potential opportunities will be important.
4.63 Development sites close to the canalside provide excellent opportunities for a range
of canalside public open spaces. These spaces provide opportunities for social interaction,
relaxation, event space and informal sports. These spaces provide a key element in the
green grid. If deliverable, new waterspaces could also be incorporated within new
development to strengthen the character of the canal and further bring elements of water
into the regeneration area.
4.64 The designation of the canal as a Nature Conservation Area will also require
development to deliver new green infrastructure to this important green corridor that forms
an integral part of OPDCs green infrastructure network.
Consultation Questions
QP4a: Do you agree with the approach set out for this preferred policy option?
QP4b: Along the Grand Union Canal should the Local Plan identify a series of smaller
scale neighbourhoods that could develop their own character?
QP4c: Are there other land uses that should be supported in this place?
QP4c: Do you have any other comments/observations about the proposed approach
for Grand Union Canal?
QP4d: Could development along the canal edge achieve higher densities than
suggested in the policy whilst still being designed to protect and / or enhance the
areas conservation area designation?
POLICY P5: PARK ROYAL
EXISTING CHARACTER
4.65 Park Royal is one of Europes largest and most successful industrial estates
providing vital services for the capital and further afield. The industrial estate is comprised of
a variety of industrial and warehousing typologies and is protected by the London Plan
Strategic Industrial Location (SIL) designation. There are approximately 1,500 business units
employing an estimated 36,000 people.

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4.66 A Gypsies and Travellers site is located in the east of the area. At the western edge,
the former Twyford Tip site benefits from an implemented planning permission. Park Royal
also includes the following locations outside of the SIL designation:

First Central office, housing and public open space located in the north west of
Park Royal;
Wesley Estate and playing fields existing housing and public open space located in
the east of Park Royal;
Acton cemetery public open space; and
Park Royal neighbourhood centre Central Middlesex Hospital, specialist housing,
town centre uses and non-industrial employment uses located in the centre of Park
Royal.

4.67 The area is structured on a street network that reflects its varied and continually
evolving pattern of growth and redevelopment. It suffers from high levels of road congestion
generated by the areas industrial functions, movement network and reliance on private
vehicular transport to get to work. The public realm is dominated in many places by parking
and poor quality public realm with limited active frontages.
4.68 There are existing issues relating to utilities infrastructure that will continue to impact
on the functioning of the area if not addressed in the short-term.
4.69 Land ownership is complex and largely in private ownership with the exception of
Central Middlesex Hospital which is owned by the London North West Healthcare NHS
Trust.
VISION
4.70 Park Royal will continue to grow, evolve and intensify to accommodate 10,000
additional jobs and to strengthen its position as a global leading location for industrial and
economic innovation that actively supports Londons economy.
4.71 Supported by resilient and innovative physical and green infrastructure, the area will
continue to be home to an array of diverse industries and a strong business community,
where innovation and start-up businesses can develop and thrive.
4.72 Transport improvements and the use of emerging transport modes, will support
businesses in efficiently delivering services and goods while new and improved business
services will support the functioning of the area.
4.73 The design of industrial buildings will likely have changed, responding to the need for
making optimum use of existing land, as values rise and new technologies support structural
change.
4.74 The residential pockets and open spaces will be better connected by safe and
inviting routes to allow existing and future residents in these areas to access the range of
new services available in Old Oak.
PREFERRED POLICY OPTION:
New development will be required to:
Land uses
a) deliver broad industrial type uses and within SIL;
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b) support shared business facilities and services;
c) support the relocation of existing businesses from Old Oak;
d) deliver workspace for small and micro businesses that require relatively lower
amounts of floorspace near to stations;
e) deliver mixed use development on the First Central site including non-industrial
employment and housing that provides walking, cycling and public transport
access to Park Royal London Underground Station;
Density
f) intensify the use of sites within SIL by requiring proposals to demonstrate how
they are maximising the use of sites, including the provision of smaller units, to
support greater industrial employment densities;
g) deliver housing densities on the First Central site that are mindful of the
surrounding context;
Heritage
h) conserve and / or enhance the Brent Viaduct and any proposed designated
heritage assets and their settings;
Delivery
i) safeguard the Twyford Waste Transfer Station site (see policy EU4);
j) contribute to addressing utilities infrastructure issues;
Transport
k) support improved frequency, capacity and connectivity in the local bus network to
stations, Old Oak, the Park Royal Neighbourhood Centre and across the area to
reduce the reliance on commuting by private vehicles;
l) Support improvements to the highway network to address congestion on local
and strategic roads;
m) Encourage the use of the canal for transport and freight movement;
n) Support the important role that servicing, freight and delivery vehicles play for
local businesses;
Streets
o) support the delivery of cycling and walking infrastructure, including parking and
improved routes to Old Oak, the Grand Union Canal, stations and other key
destinations outside of Park Royal;
p) deliver improved walking and cycling routes from the Wesley Estate to the Grand
Union Canal and beyond to Old Oak;
q) contribute to addressing traffic congestion generated by on-street parking and
freight movement;
r) contribute to addressing severance caused by the A40 and A406;
s) contribute to improving the public realm and street greening to support industrial
functions and the character of the Wesley Estate;
t) utilise a coordinated palette of high quality durable materials and street furniture
within the public realm;
Open spaces
u) celebrate the unique character of the Grand Union Canal and the towpath to
support it in becoming an accessible focal point for the area;
v) Provide a network of new and improved connected and varied public open spaces,
including spaces along the canal, Wesley Play Fields, First Central and across the
industrial area;
Environment
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w) enhance existing biodiversity assets along railway corridors, within the First
Central Site, the Grand Union Canal, existing public open spaces and at the
junction of Abbey Road and Premier Park Road;
x) Overcome current surface water flooding issues experienced across Park Royal
and specifically within areas adjacent to the A406.
JUSTIFICATION
4.75 To support the functioning of the industrial areas of Park Royal, only uses defined as
broad industrial type uses will be supported within SIL. These are defined in the London
Plan.
4.76 Policies for employment uses for both Park Royal and the Park Royal Centre are
provided in the Employment Chapter. These provides guidance for:

4.77

supporting the delivery of affordable, temporary and open workspaces;

protecting and expanding the Park Royal Strategic Industrial Location designation;
and
intensifying the use of land to deliver more workspace.
Proposed new sites to be included in SIL are shown in figure xx.

4.78 Park Royal has a rich industrial heritage which should also be reflected in the
character of development. OPDC is developing a Heritage and Views Study for Old Oak and
Park Royal to inform the designation of locally significant heritage assets specifically within
Park Royal. OPDC will work with Historic England in implementing the outputs of the Study
to inform the next version of the draft Local Plan.
4.79 The West London Waste Plan allocates Twyford Waste Transfer Station as a waste
transfer station and having the potential for redevelopment. Policy EU4 continues to
safeguard the site in accordance with the West London Waste Plan.
4.80 Park Royal currently experiences capacity and delivery issues in relation to utilities
and digital communications infrastructure. To support OPDCs aspirations to address these
issues, proposals will be supported where they seek to address existing and future capacity
issues and where they demonstrate positive engagement with utilities providers and
stakeholders.
4.81 First Centrals location near to Park Royal London Underground Station and outside
of the SIL designation enables it to include housing subject to the mitigation of any impact on
the functioning of the SIL. Housing will be supported where it enables the delivery of
significant access to public transport, provides spaces for small and micro businesses and
supports improved connections to Park Royal Centre.
4.82 The public realm of industrial areas should support its functioning through the use of
durable and robust materials while reflecting the character to support the creation of a sense
of place. Improvements to the public realm should seek to improve safety and the perception
of safety alongside wellbeing, cycling and public transport with the aim of reducing the over
reliance on private vehicles for commuting. This will help to release space across the area to
accommodate the growing servicing needs of businesses in the area The Wesley Playing
Fields offer a valuable green space within the north of Park Royal and should be improved
where appropriate. Specifically, the creation of an improved walking and cycling route to the
Grand Union Canal should be explored to improve local accessibility. Development should

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also contribute to the delivery of smaller public open spaces across the industrial area to
provide locations for residents and employees to deliver a high quality environment.
4.83 Park Royal currently suffers from traffic congestion caused by a range of factors
including use of private vehicles for personal transport, on-street parking and highways
design. The A40 and A406 strategic roads also create barriers that prevent easy north and
south movement for walking and cycling which need to be addressed to help connect
adjacent communities and enable access to services and employment.
4.84 It is envisaged that further detailed guidance for Park Royal will be provided within a
Park Royal Supplementary Planning Document.
Consultation Questions
QP5a: Do you agree with the approach set out for this preferred policy option?
QP5b: Within Park Royal should the Local Plan identify a series of smaller scale
places that could develop their own character? If so, where might there be areas
within Park Royal that have their own character?
QP5c: Are there other land uses that should be supported in this place?
QP5d: Should the Local Plan seek to retain existing industrial workspaces that are
suitable for micro and small enterprises where viable to ensure the provision of a mix
of varied industrial workspaces?
QP5e: Do you agree with the proposed expansions to the SIL within Park Royal?
QP5f: Do you have any other comments/observations about the proposed approach
for Park Royal?

POLICY P6: PARK ROYAL CENTRE

EXISTING CHARACTER
4.85 Park Royal Centre sits at the heart of Park Royal and is surrounded by the Strategic
Industrial Location (SIL) designation. The southern portion is currently designated as a
neighbourhood centre by the London Borough of Ealing. The area currently lacks a defined
character and its environment is dominated by the road network focused on the junction,
which suffers from traffic congestion.
4.86 These streets are framed by a range of inactive building frontages and parking that
creates a poor quality public realm. The existing services are dispersed within the area
which weakens its role as a centre for business services. The majority of the area comprises
the ASDA supermarket and the Central Middlesex Hospital. There are a range of local
services that provides a much needed facilities for local residents and businesses.
VISION
4.87 Park Royal Centre will be enhanced to provide a range of local services and
amenities to support the Park Royal area, including shops, hotels and other business
services. There is an opportunity for it to be an identifiable centre and a focal point for local
businesses that offers local services for businesses and employees. The public realm will be
improved and benefit from new public open spaces alongside active street frontages.
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PREFERRED POLICY OPTION

New development will be required to:
Land uses
a)
b)
c)
d)

deliver broad industrial type uses within existing SIL;

deliver affordable open workspaces for micro, small and medium businesses;
deliver shared services that support business functions of wider Park Royal;
contribute to the delivery of approximately 5,000 sqm of A class uses that are
focused on convenience retail and services in a range of sizes that that support
the local business and existing residential and medical communities;
e) deliver small scale walk-to edge of centre uses along Acton Lane, Park Royal
Road, Abbey Road and Coronation Road;
f) support the functioning of the Central Middlesex Hospital;
Density
g) intensify the use of sites by requiring proposals to demonstrate how they are
optimising the use of sites with appropriate land uses to support greater
employment densities and delivery of town centre uses;
h) improve legibility to the surrounding businesses and destinations including
stations, the Grand Union Canal and public open spaces;
Transport
i) support improved frequency, capacity and connectivity in the local bus network to
stations, Old Oak and the wider area;
j) support improvements to the highway network to address congestion on Acton
Lane, Park Royal Road, Abbey Road and Coronation Road;
Streets
k) Create a sense of place with improved walking and cycling usage with welldefined streets and spaces;
l) deliver active frontages;
m) contribute to and / or deliver high quality durable public realm;
Open spaces
n) contribute to and / or deliver new public open spaces near to the junction of the
four main streets;
Environment
o) Overcome current surface water flooding issues experienced along Acton Lane,
Abbey Road and Coronation Road.
JUSTIFICATION
4.88 Park Royal Centre is surrounded by, and includes portions of, sites designated as
Strategic Industrial Location.
4.89 Policies for employment uses for both Park Royal and the Park Royal Centre are
provided in the Employment Chapter. These provides guidance for:

supporting the delivery of affordable, temporary and open workspaces;

protecting and expanding the Park Royal Strategic Industrial Location designation;
and
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4.90

intensifying the use of land for delivering more workspace.

Proposed new sites to be included in SIL are shown in figure xx.

4.91 OPDC is amending the designation of the neighbourhood centre to define the role
and function of the centre in light the wider regeneration of Old Oak and Park Royal.
4.92 The Park Royal Centre should provide facilities to support the wider Park Royal. This
is likely to result in a quantitative need for an additional gross 5,000sqm of A-class
floorspace in Park Royal Centre. Currently, the centre includes a large ASDA superstore and
a number of smaller services including banks, sandwich shops and cafes. Within the
designated centre, proposals will be supported that further enhance the range of services
provided that supports those living and working in Park Royal. Specifically for the business
community this may include elements of the evening and night time economy. A range of
town centre uses will be supported in the centre, including hotels and business services
where a demand is demonstrated. Edge of centre uses will be supported where there is an
identified need and should be focused along the main thoroughfares into the centre - Acton
Lane, Park Royal Road and Abbey Road. Proposals that have a negative impact on the
functioning of the SIL will be resisted.
4.93 Intensification may include increasing building height and massing that will help to
improve legibility within Park Royal.
4.94 There is likely to be a growing demand for flexible, affordable open workspaces
designed to support SME and micro businesses which will help to bring more people to the
centre and drive the demand for additional business services. Alongside these nontraditional types of workspace, there will be an opportunity for the centre to deliver shared
business support facilities such as meeting spaces, conference facilities and business
orientated eating and drinking uses.
4.95 Park Royal Centre currently lacks a defined character. Its environment is dominated
by the road network and framed by a range of inactive building frontages and parking that
creates a poor quality public realm. Proposals that better frame the centre, provide active
frontages and enhance the public realm will be supported.
4.96 In seeking to improve and create a sense of place in the centre, there is an
opportunity to deliver new public open space that is well integrated within the wider public
realm and whose functions responds to the surrounding character.
4.97 The four mains streets that meet in the centre suffer from traffic congestion. As such,
uses that do not generate high levels of private vehicle commuting will be supported. To
support this, OPDC will work with stakeholders to deliver new bus and emerging transport
mode services. Through new development and improvements to the highway network, these
have the potential to address this congestion and support the bus network in conjunction
with highway improvements across Park Royal.
Consultation Questions
QP6a: Do you agree with the approach set out for this preferred policy option?
QP6b: Park Royal Centre may not be an appropriate location for new housing given
the surrounding SIL designation and the potential impact new housing could have on
the functioning of the SIL. Should the Local Plan be specific in prohibiting new
housing within this area?
QP6c: Are there other land uses that should be supported in this place?
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QP6d: Do you agree with the proposed expansions to the SIL within the Park Royal
Centre?
QP6e: Do you have any other comments/observations about the proposed approach
for Park Royal?

POLICY P7: NORTH ACTON

EXISTING CONTEXT
4.98 The area is approximately 33 hectares in size and includes areas south of North
Acton Central Line Station and the site immediately north of the Central Line, the referred to
as the sword site. The sword site currently has a mix of industrial and warehousing uses
and is due to be cleared as part of High Speed 2 construction works.
4.99 North Acton Cemetery is immediately to the west with access provided from Chase
Road and Park Royal Road. The A40 bounds the area to the south with busy road junctions
at Savoy Circus and where the A40 meets Victoria Road and Wales Farm Road. Beyond this
is West Acton, an established residential area comprised of interwar housing. To the east is
a collection of interwar and late twentieth century housing.
4.100 The regeneration of this area is already underway with the London Borough of Ealing
having led this regeneration for the past ten years. Existing and planned developments
include residential, significant amounts of student housing and retail uses which are
expected to be joined by the development of employment uses and hotels either side of
Portal Way. A new public square is currently being delivered by the London Borough of
Ealing immediately south of North Acton station.
4.101 The design and layout of the existing road gyratory and public realm are currently
uncoordinated and does not support deliver a high quality walking and cycling movement
network.
4.102 West of Victoria Road is the Victoria Industrial Estate and Perfume Factory site. The
latter is expected to be redeveloped as a residential-led mixed use development in the near
future.
VISION
4.103 Future development at North Acton will continue to progress in a comparable manner
to the recent regeneration in this area, providing substantial numbers of new homes and jobs
and reinforcing North Actons new designation as a neighbourhood town centre.
4.104 New and improved connections to Old Oak Common Station and the core
development area will ensure that North Acton is integrated into the wider regeneration area.
New development will deliver a mixture of new public and private open spaces. North Acton
station will be upgraded to increase its capacity and access arrangements.
PREFERRED POLICY OPTION:
New development will be required to:
Land uses
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a) Demonstrate how any small, medium and / or large scale catalyst uses support
placemaking and where relevant mitigates impacts on surrounding area;
b) provide a mix of small-scale retail, leisure, community uses and eating and
drinking establishments to serve local needs, focused close to North Acton
station;
c) deliver residential uses;
d) deliver employment workspace for a range of businesses including flexible and
affordable open workspaces for SME and micro businesses;
e) support the delivery of new education uses and community infrastructure;
f) provide visitor accommodation close to North Acton station;
Density
g) be high density in areas of high public transport access; such as close to
North Acton station and on the sword site; and
h) be lower density in more sensitive locations close to existing residential areas
and areas of open space;
Delivery
i) bring forward the early development of the area;
Transport
j) seek to address issues created by the existing gyratory;
k) provide significant contributions towards and facilitates the delivery of
improvements to North Acton station;
l) provide improvements to the public realm and walking and cycling network,
and in particular on the one-way system along Victoria Road and Wales Farm
Road;
Streets
m) provide active frontages in areas close to North Acton Station and along main
streets;
n) facilitate new and / or improved walking and cycling connections across the
A40 to West Acton;
o) support the delivery of Grand Union Street, connecting North Acton to the Old
Oak area;
Social infrastructure
p) Contribute to the delivery of a health centre;
Open spaces
q) Contribute to and / or deliver a new public civic square to the north and south
of North Acton station;
r) support the delivery of new high quality public, communal and private open
space;
JUSTIFICATION
4.105 North Acton has experienced major redevelopment in recent years and current
indications show that this pace of regeneration and renewal is likely to continue with
opportunities for growth across the wider area.
4.106 In the last 5 years an additional 2,000 homes and 1,200 student homes have been
built in the area and these proposals have been supported by ancillary town centre uses
including convenience retail, eating and drinking establishments and leisure facilities. North
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Acton will see continued growth during the Local Plan period. OPDC is developing evidence
base to further explore what the capacity of North Acton to accommodate new homes and
jobs might be.
4.107 It is proposed to designate North Acton as a Neighbourhood Centre to provide a
range of town centre uses to meet local need. Town centre uses should be focused on
serving the local needs of the population in North Acton, providing convenience retail, eating
and drinking establishments and catalyst culture, sports and leisure facilities. Further
information relating to catalyst uses is found in OSP5 (chapter 3).
4.108 As North Actons population grows, so will the level of ancillary services and town
centre uses it requires. The existing and future population is likely to give rise to a
quantitative need for approximately 5,000sqm of gross A-class floorspace. North Acton
Neighbourhood Centre will be capable of accommodating some of this growth but it will be
necessary for new edge of centre sites to bring forward town centre uses once the capacity
of sites in the existing centre have been exhausted. Edge of centre town centre uses should
be focused in areas anticipating high levels of footfall, in particular, along routes connecting
North Acton to the Old Oak area.
4.109 North Acton has two existing hotels and is a popular location for visitors to stay.
Proposals for additional visitor accommodation will be supported in areas of high public
transport accessibility and where the proposals do not result in increased pressure on the
highway network (see policies TC6 and T6). Residential uses on upper floors will also be
supported in the centre to add vibrancy and vitality to the centre.
4.110 North Acton currently suffers from a poor quality public realm. New eating and
drinking establishments from recent schemes in North Acton have started to improve the
public realm and add more vibrancy and vitality to the areas streets. Proposals for town
centre uses should continue to improve this vitality and vibrancy, by providing active uses at
ground floor levels and where feasible, providing outdoor activities that activate the public
realm. New and improved walking and cycling connections to West Acton are needed to help
integrate development with the wider area.
4.111 Proposals should provide a range of flexible workspace typologies in North Acton for
B1 uses which do not negatively impact on residential amenity and deliver active frontages.
North Acton has the potential to deliver new flexible and affordable workspace for a range of
employment uses to support the creation of new jobs and to contribute to the sense of place
and activation in the local area.
4.112 North Acton station improvements should include step free access, a new access
from the north, improved entrances and ticket hall, a new footbridge, new stairs and lift
access to accommodate the predicted increase in passenger numbers. A study is underway
looking into potential options for improvement and the potential for over station development.
This study can be found as a supporting evidence document to this draft Local Plan.
4.113 North Acton currently lacks public open space. A new civic square is currently being
delivered south of North Acton Station and there is an expectation that this may be amended
in light of improvements to the station alongside delivering an additional square to the north.
New development will need to deliver high quality new public, communal and private open
space and will also need to demonstrate how it is contributing to a joined up network of
public open spaces.
4.114 Securing the delivery of social infrastructure is fundamental to delivering successful
place making. A health centre is identified to be delivered. In addition to this, North Acton
may also be suitable for an all-through school.
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4.115 In recent years there has been significant amounts of new student accommodation
built and/or permitted with additional proposals currently in the process. Within North Acton,
it will be important to secure a broader mix of residential types. Given the amounts of student
accommodation delivered, this may represent an over concentration.
Consultation Questions
QP7a: Do you agree with the approach set out for this preferred policy option?
QP7b: Are there other land uses that should be supported in this place?
QP7c: Policy H10(B) in the Housing Chapter states that proposals for student
accommodation will not be supported where it would result in an over concentration.
Do you consider that North Acton currently has an over concentration of student
accommodation? Could there be benefits in restricting additional student
accommodation here to deliver a mixed and balanced community?
QP7d: Do you have any other comments/observations about the proposed approach
for North Acton?

POLICY P8: SCRUBS LANE

EXISTING CHARACTER
4.116 Scrubs Lane is approximately 1.6km long. It crosses from north to south the West
Coast Main Line, the Grand Union Canal and the Great Western Main Line. It is a key
connector road between Harlesden and White City. Heavily used by vehicles, the street
provides a poor walking and cycling experience.
4.117 To the north of the canal, Scrubs Lane is fronted by employment uses and car
parking with the former Cumberland Park Factory (currently proposed to be a Conservation
Area in light of the buildings special historic interest) leading onto residential Victorian
terraces. The former Cumberland Park Factory provides the opportunity to inform new
developments character on Scrubs Lane. To the south, there are a mix of heavier industrial
uses, including a waste management facility and a tyre factory on the north edge of the
Grand Union Canal with industrial and rail sheds immediately to the south.
4.118 The sole eastern access point into Old Oak North is located opposite the former
Cumberland Park Factory.
4.119 The area north of the canal is bounded by St. Marys Cemetery and Conservation
Area to the east, railway lines servicing the London Overground to the west and the Grand
Union Canal Conservation Area to the south.
4.120 To the south of the canal, the North Pole Depot, Mitre Bridge Industrial Park and
Little Wormwood Scrubs sit to the east of the road with Wormwood Scrubs on the western
side for the remainder of the road.
VISION
4.121 Scrubs Lane will be transformed into a pleasant street, respectful of surrounding
heritage assets with a high quality public realm. New residential-led development, sitting
alongside the retained heritage buildings of the former Cumberland Park Factory will offer a
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mix of employment and community spaces to provide workspaces for current and future
businesses. New development will provide high levels of overlooking onto the street with
passive surveillance and active frontages at lower levels. This will include commercial space,
access to residential and small amounts of retail and community use.
4.122 New and improved connections into Old Oak North, Wormwood Scrubs, Little
Wormwood Scrubs, St. Marys Cemetery to Grand Union Canal and Kensal Canalside will
improve the areas connectivity and accessibility.
4.123 Development will be designed to respond to heritage assets, their setting and
existing residential communities. New buildings on the eastern edge of Scrubs Lane will
mindful for the surrounding heritage context, responding sensitively in their design and
management.
PREFERRED POLICY OPTION
New development will be required to:
Land uses
a) deliver a range of flexible workspace typologies for:
i.
B1 uses as part of new mixed use developments with housing on upper
floors;
ii.
B1 uses within the Cumberland Park Factory for micro and SMEs; and
iii.
B1(b) and B1(c) uses with housing on upper floors at locations adjacent
to railways servicing the London Overground and the West Coast Main
Line.
b) deliver a mix of housing including well designed access to residential above
ground floors;
c) deliver small amounts of local convenience retail and community uses;
Density
d) recognise the areas adjacent to St. Marys Conservation Area, Wormwood
Scrubs, Little Wormwood Scrubs and the Grand Union Canal Conservation
Area as sensitive locations suitable for lower and medium densities;
e) recognise the areas north of the canal and on the western side of Scrubs Lane
as having opportunities for high and medium densities;
f) recognise that there will be opportunities for taller elements on Scrubs Lane
where they achieve highest standards of design, are mindful of the
surrounding context and deliver a coordinated approach to placemaking;
Heritage
g) conserve and / or enhance the proposed Cumberland Park Factory and
existing St. Marys Cemetery, Kensal Green Cemetery and Grand Union Canal
Conservation Areas and their setting;
Streets
h) contribute to and / or deliver new and improved walking and cycling routes to
the Grand Union Canal, St. Marys Cemetery, Wormwood Scrubs, Little
Wormwood Scrubs and the North Pole depot;
i) contribute to and / or deliver two new vehicular routes into Old Oak North;
j) contribute to and / or deliver new and improved high quality coordinated public
realm and street greening;
k) support highways improvements,
l) deliver a continuous cycle route along the length of Scrubs Lane;

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m) support any required improvements to the Mitre Bridge and West London Line
Bridge;
n) improve access to Wormwood Scrubs and Little Wormwood Scrubs from
Scrubs Lane;
Environment
o) Overcome current surface water flooding issues experienced to the north of
the Grand Union Canal.
JUSTIFICATION
4.124 Development along Scrubs Lane should contribute to the creation a mixed-used area
informed by surrounding heritage assets. The continued use of Cumberland Park Factory for
micro, small and medium enterprises (SME) will be supported. Other locations along Scrubs
Lane will be suitable for a mix of employment, housing and other uses including small
amounts of retail and community uses. For locations adjacent to railway infrastructure,
research and development and light industry uses could provide a useful buffer to mitigate
impacts on residential amenity. Opportunities for delivering affordable open workspace for
innovative SMEs, with stakeholders such as Imperial College, will be supported and will play
a role in informing the sense of place. In the early years, lower level units may need to be
flexibly designed to mitigate the existing environment.
4.125 Scrubs Lane is within the setting of St. Marys Conservation Area and other
designated heritage assets within Kensal Green Cemetery and includes an element of the
Grand Union Canal Conservation Area. Alongside this draft Local Plan, OPDC is consulting
on the proposed designation of a Conservation Area for the former Cumberland Park
Factory (69 to 91 Scrubs Lane). These properties are currently used for a range of
employment uses and have the potential to continue to provide employment floorspace in
buildings that positively contribute to local placemaking through their heritage value. In light
of these existing and proposed heritage assets and their setting, development should
respond sensitively in scale and density while recognising that sites west of Scrubs Lane
should also respond to the changing scale and context within Old Oak to the west. Public
realm improvements should also reflect the historic character and special interest of these
assets.
4.126 Scrubs Lane is currently a harsh environment generated by traffic and a lack of
enclosure created by incomplete street frontages. A significant amount of traffic is generated
by the waste sites located on Scrubs Lane and in Old Oak North. Following the regeneration
of Old Oak, these activities will no longer negatively impact on the areas environment. To
support the delivery of active frontages, development should deliver front doors for housing
facing onto streets.
4.127 Securing a high quality street that provides legible and well-designed public realm
needs to be coordinated with the White City Forum to ensure improvements to Scrubs Lane
will link effectively with emerging proposals for Wood Lane to the south of the A40. Securing
this as a well-designed connection with additional bus capacity will help to connect both
Opportunity Areas.
4.128 To the south of Grand Union Canal, new development should provide a new or
improved access to North Pole East that should also enable a connection to Kensal
Canalside Opportunity Area alongside improved access for pedestrians and cyclists into
both Wormwood Scrubs and Little Wormwood Scrubs.
Consultation Questions
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QP8a: Do you agree with the approach set out for this preferred policy option?
QP8b: Within Scrubs Lane should the Local Plan identify a series of smaller scale
neighbourhoods that could develop their own character?
QP8c: Are there other land uses that should be supported in this place?
QP8d: Do you have any other comments/observations about the proposed approach
for Scrubs Lane
POLICY P9: OLD OAK WEST
EXISTING CHARACTER
4.129 Old Oak West comprises areas along Old Oak Lane, Victoria Road and industrial
areas to the west, to the north and south of the Grand Union Canal. It is approximately 23
hectares comprised of industrial uses, student housing and established residential areas of
the Old Oak Lane Conservation Area, Midland Terrace and Shaftesbury Gardens. The
industrial areas north and south of the canal are due to be cleared for High Speed 2
construction works. Access to the canal is restricted, with improvements delivered through
the recent student housing development.
4.130 The area is bounded by the West Coast Main Line to the north, with railways serving
the London Overground to the east and Park Royal industrial estate to the west.
4.131 The current public realm along Old Oak Lane is dominated by vehicular transport
providing a poor walking and cycling experience. High Speed 2 works are likely to result in
large numbers of HGV movement that needs to be carefully planned and where possible
improved upon. Land is in a mix of private and public ownership.
VISION
4.132 Old Oak West will be a diverse area reflecting its location between Old Oak and Park
Royal. This place will be centred on an improved and busy street environment of Old Oak
Lane and Victoria Road. A new industrial innovation area located on the HS2 work sites
adjacent to the Grand Union Canal could act as a buffer between existing residential areas
in the Island Triangle, as well as future mixed use development at Old Oak and with the
heavier existing industrial uses within Park Royal.
4.133 Existing residential areas will benefit from improved access to the wider area, public
realm improvements and improvements to amenity. The HS2 construction sites will provide a
space for industrial innovation that integrates with Old Oak and Harlesden. Other locations
will provide opportunities for new housing development. New and improved connections to
Old Oak and the Grand Union Canal will be provided.
PREFERRED POLICY OPTION:
New development would be required to:
Land use
a) deliver broad industrial type uses on the HS2 construction sites appropriate for
SIL, such as an Industrial Business Park, once no longer required for HS2
construction;

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b) deliver employment and commercial uses with active frontages outside of existing
residential areas along Victoria Road and Old Oak Lane;
c) not have adverse negative impacts on the amenity of existing residential
communities;
d) support residential uses in areas outside of the SIL designation where it supports
the functioning of industrial uses within the SIL;
Density
e) intensify the use of sites within SIL by requiring proposals to demonstrate how
they are maximising the use of sites, including the provision of smaller units, to
support greater industrial employment densities;
f) deliver housing densities that are mindful of their surrounding context;
Heritage
g) conserve and / or enhance Old Oak Lane and the Grand Union Canal Conservation
Areas and their settings;
Transport
h) seek to minimise impacts of construction traffic on the street network for existing
residents and businesses;
i) support the potential to use the High Speed 2 works sites as temporary
consolidation centre to support the construction of Old Oak;
j) explore the potential to deliver a longer term consolidation centre on the HS2
construction sites to assist with the transportation of construction materials and
waste for the wider area;
Streets
k) support Old Oak Lanes function as an important north-south connection
connecting Harlesden and North Acton;
l) contribute to and /or deliver a vehicular bridge over the Grand Union Canal to link
the HS2 construction sites;
m) contribute to and / or deliver public realm and highways improvements,
specifically along Old Oak Lane and Victoria Road and to Willesden Junction
Station;
n) support the delivery of new vehicle connections to Old Oak, Park Royal and
Harlesden;
o) support the delivery of new walking and cycling routes to the Grand Union Canal
and Old Oak;
Environment
p) enhance existing biodiversity assets along the Grand Union Canal;
q) address risk of potential surface water flooding on Old Oak Lane, Goodhall Street,
Channel Gate Road and Stephenson Street.
JUSTIFICATION
4.134 The location of Old Oak West will enable it to develop a diverse range of
complementary uses that help to integrate Old Oak, Park Royal, North Acton and Harlesden.
4.135 The High Speed 2 (HS2) construction sites are designated as a Strategic Industrial
Location (SIL) with uses currently considered to accord with the Preferred Industrial Location
(PIL) SIL sub-category. The pressing demand today for industrial land in Park Royal
suggests that the HS2 construction sites adjacent to the canal should remain as SIL and be
designated as Preferred Industrial Land (PIL). However, given the timeframes, a more
intensive form of SIL development, in line with Industrial Business Park sub-category (IBP)
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to support the Innovation Economy could be considered in how these sites become
available in the run up to 2026 to reflect the opportunities generated by the development of
Old Oak. This would also help create a buffer between mixed use regeneration in Old Oak
and the PIL uses in Park Royal. The Innovation Economy refers to the economic sectors
associated with entrepreneurship and innovation. This work should take place in future
versions of the Local Plan.
4.136 A west London example of IBP SIL is Chiswick Park. IBP uses will help to support
the economic growth of both Old Oak and Park Royal while benefiting the amenity of
adjacent existing residential areas.
4.137 Any proposals within and adjacent to existing Conservation Areas will need to be
sensitive in scale and respond in their character to these heritage assets and their settings.
4.138 In developing the HS2 construction sites as IBP SIL, new north-south routes across
the canal should be required to improve local accessibility and help to manage traffic
congestion within the wider area.
4.139 To further help address existing and potential future congestion, the potential for
delivering consolidation centres for coordinating transport of construction material and waste
will be an important element to minimise impacts on the road network and amenity of
existing communities. The location of the north construction site adjacent to the West Coast
Main Line provides a key long-term opportunity for sustainable freight and/or waste transport
by rail.
4.140 Old Oak Lane and Victoria Road will continue to be a key north-south route for the
wider area, connecting Harlesden, Old Oak, Park Royal, North Acton and the A40 in the
south. To support improvements to the public realm and built environment along these
streets, active frontages alongside street greening will be supported. At Willesden Junction,
there will be substantial improvements to connectivity allowing for better access from Old
Oak Lane.
4.141 To the south of the West Coast Main Line, development of the Savoir Beds site may
provide opportunities to provide pedestrian/cycle and vehicular access into Old Oak through
the Powerday site, although there are substantial levels to overcome in order to achieve this.
4.142 OPDC will continue to work with Historic England to identify any additional heritage
assets along this route.
CONSULTATION QUESTIONS
QP9a: Do you agree with the approach set out for this preferred policy option?
QP9b: Within Old Oak West should the Local Plan identify a series of smaller scale
neighbourhoods that could develop their own character?
QP9c: Are there other land uses that should be supported in this place?
QP9d: Should the Local Plan require the redelivery of existing industrial workspaces
on the HS2 construction sites which are suitable for micro and small enterprises and
viable?
QP9e: Do you have any other comments/observations about the proposed approach
for Old Oak West?
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POLICY P10: WORMWOOD SCRUBS
4.143 Covering almost 68 hectares, Wormwood Scrubs is the largest open space in the
London Borough of Hammersmith & Fulham and is a green lung that provides people and
wildlife with the opportunity to enjoy green open space. The Wormwood Scrubs open space
is managed by the Wormwood Scrubs Charitable Trust. It is protected by the Wormwood
Scrubs Act 1879, the Commons Act 2006 and as Metropolitan Open Land in the London
Plan, which affords the Scrubs the same level of protection as Metropolitan Green Belt. This
protection will continue. The Ministry of Defence also have rights to access and use the
Scrubs.
4.144 The areas north boundary is the IEP depot with the Old Oak core development area
to the north. The Linford Christie Stadium, HM Prison Wormwood Scrubs and Hammersmith
Hospital bound the area to the south with White City and Shepherds Bush both to the south
of these.
4.145 Portions of Wormwood Scrubs are designated as Local Nature Reserves and Sites of
Borough Importance within the Sites of Importance for Nature Conservation hierarchy. Over
half of the Scrubs comprises a mix of young and established woodland, scrub, grassland
and tall herbaceous vegetation, which gives the Scrubs a sense of wildness that is a unique
characteristic, in particular given is proximity to central London. There is a combination of
diverse habitats across Wormwood Scrubs that support a diverse range of native plants,
breeding birds and insects, including species not usually found in more formal parks and
open spaces. The site also supports a large population of common lizards and attracts a
wide variety of migrant birds in spring and autumn. There are a number of legally protected
animals, plants and fungi resident on the Scrubs.
VISION
4.146 Wormwood Scrubs will continue to be a cherished public open space and important
ecological asset. New sensitive connections to the north and carefully considered
improvements will bring Old Oak and White City together and make the Scrubs more
accessible to all Londoners. These would be carried out in agreement with the Wormwood
Scrubs Charitable Trust, the London Borough of Hammersmith and Fulham and in
discussion with the local community.
PREFERRED POLICY OPTION
OPDC will work with stakeholders and agree any proposals with the Wormwood
Scrubs Charitable Trust and London Borough of Hammersmith and Fulham to protect
and/or enhance Wormwood Scrubs by:
a) sustaining the existing Local Nature Reserve and sites of borough importance
for nature conservation so that there is no net loss;
b) supporting Wormwood Scrubs as a public open space for exercise and
recreation for all Londoners;
c) improving access to and from Old Oak, Little Wormwood Scrubs, North
Kensington, Old Oak Common Estate and other areas to the south;
d) securing resources for its long-term management and maintenance;
e) addressing current surface water flooding issues experienced along its edge
and in locations in the eastern and western areas; and
f) carrying out sensitive enhancements.
JUSTIFICATION

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4.147 The existing valuable biodiversity assets within the Local Nature Reserve and Sites
of Borough Importance for Nature Conservation will be protected reflecting their relevant
levels of importance.
4.148 Walking and cycling access to Wormwood Scrubs is currently restricted from its
northern edges. The Wormwood Scrubs Act 1879 identifies that the area should be
maintained and where appropriate, enhanced as an area for exercise and recreation for the
inhabitants of the metropolis. As such, any development to the north of the area should
deliver coordinated sensitive new walking and cycling connections to the Scrubs to help
connect communities.
4.149 Retaining Wormwood Scrubs as a public open space that is more wild than tamed,
will inform how the regeneration of Old Oak relates to the Scrubs. Given the scale of
development planned in Old Oak, it is recognised that there will be an increase in users and
in the interest of coherent planning and to ensure that local people have access to the
Scrubs, there is a need to consider the potential impacts on Wormwood Scrubs of these new
users.
4.150 OPDC will work closely with stakeholders, including the Wormwood Scrubs
Charitable Trust, London Borough of Hammersmith and Fulham, local residents and interest
groups, including the Friends of Wormwood Scrubs in developing guidance and exploring
potential sensitive improvements for the Scrubs. Any enhancements would need to be
consented by the Wormwood Scrubs Charitable Trust. There are existing drainage and
surface water flooding issues which should be addressed to support the functioning and
enjoyment of the Scrubs as a public open space and which could also fulfil a more strategic
water management role (see Policy EU3, chapter 12).
Consultation Questions
QP10a: Do you agree with the approach set out for this preferred policy option?
QP10b: Do you have any other comments/observations about the proposed approach
for sustaining and enhancing Wormwood Scrubs?
QP10c: Should Wormwood Scrubs be made more accessible for all Londoners? How
could this be done?

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5. SUSTAINABLE DEVELOPMENT
Policy SD1: Sustainable Development
Evidence base
Study
Integrated Impact
Assessment

Description
Ensures the contents of the draft Local Plan
consider, support and enhance:
the component environmental, social and
economic elements of sustainability;
equality for all; and
physical, mental and emotional health and
well-being.
Ensure the contents of the draft Local Plan are
screened for any impact on Natura 2000 sites.

Status
Draft completed

Key issues
1. If planning policies and development decisions do not contribute to delivering the three
elements of sustainability, Old Oak and Park Royal will not be able to deliver long-term
sustainable neighbourhoods and thriving communities.
Policy Framework
National
5.1
The NPPF sets out the three elements of sustainable development that informs the
need for the planning system to perform a number of economic, social and environmental
roles which should not be taken in isolation, because they are mutually dependent.
Regional
5.2
The London Plan sets out a range of policies for realising Londons sustainable
development with regard to economic, social and environmental sustainability.
Preferred Policy Option:
a) When considering development proposals, OPDC will take a positive approach
that reflects the presumption in favour of sustainable development contained
in the National Planning Policy Framework (NPPF). It will always work
proactively with applicants jointly to find solutions which mean that proposals
can be approved wherever possible, and to secure development that improves
the economic, social and environmental conditions in the area;
b) Planning applications that accord with the policies in this Local Plan, the
London Plan, the West London Waste Plan and, where relevant, with policies in
neighbourhood plans will be approved without delay, unless material
considerations indicate otherwise;
c) Where there are no policies relevant to the application or relevant policies are
out of date at the time of making the decision, then permission will be granted
unless material considerations indicate otherwise taking into account
whether:
i) Any adverse impacts of granting permission would significantly and
demonstrably outweigh the benefits, when assessed against the policies in
the NPPF taken as a whole; or

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ii) Specific policies in the NPPF indicate that development should be
restricted.
Justification
5.3
The United Nations World Commission on Environment and Developments (WCED)
report Our Common Future (published in 1987) defines sustainable development as
development that meets the needs of the present without compromising the ability of future
generations to meet their own needs.
5.4
Achieving sustainable development in Old Oak and Park Royal means delivering
development that complies with the NPPF and the relevant policies set out in this Local Plan
and the London Plan (and, where relevant, with policies in neighbourhood plans) as a whole.
As such, OPDC will work with partners to deliver this fundamental requirement to ensure Old
Oak and Park Royal delivers long-term sustainable communities and neighbourhoods.
Alternative Policy Options
5.5
Achieving sustainable development is a requirement of the National Planning Policy
Framework (NPPF). To ensure the draft Local Plan is consistent with the NPPF, alternative
policy options are not considered to be appropriate.
Consultation Questions
QSD1a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, are there any other policy alternatives that could
replace the preferred policy or should be considered as alternatives?

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6. DESIGN
Design
This chapter contains policies addressing the following policy themes:
D1: Strategic Policy for design
D2: Streets and public realm
D3: Public open space
D4: New buildings
D5: Existing buildings
D6: Heritage
D7: Amenity
D8: Inclusive design
Consultation Question
QTCa: Are there any other town centre use policy themes that you think OPDCs Local
Plan should be addressing?

Evidence base
Study
OPDC Industrial Land
Review (ILR)

OPDC Development
Capacity Study
OPDC Character Note

OPDC Walking, cycling

and public realm
strategy

OPDC Green
Infrastructure Strategy

OPDC Smart Strategy

Interim Report

HE Old Oak Outline

Historic Assessment &
Addendum
OPDC Park Royal
Heritage Assessment

Scope
Assesses the current and future
supply and demand for industrial
land within Old Oak and Park
Royal.
A study looking at the capacity of
the OPDC area to accommodate
new homes and jobs.
Sets out suggested character
areas within and around Old Oak
and Park Royal.
A strategy setting out
recommendations for the public
realm, public open space and
walking and cycling infrastructure
for the OPDC area.
A strategy reviewing existing GI
assets, future GI requirements,
and identifying opportunities for
improving function, connectivity
and integration with other
infrastructure.
Sets out key challenges,
opportunities and
recommendations in relation to
emerging smart technology.
Assessment of the historic
character and appearance of Old
Oak.
Assessment of the historic
character and appearance of
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Status
Draft completed

Draft completed

To be developed

To be developed

To be developed

Draft completed

Completed

To be developed

OPDC Views Study

Park Royal alongside

identification of local views.
Identification of local views within
and around the OPDC area

To be developed

Policy D1: Strategic Policy for design

Key Issues
1. Creating a series of new connected places informed by existing positive elements of
character to create a sense of place, such as the Grand Union Canal, is of critical
importance.
2. It is important that new development achieves the highest standards of design and
placemaking.
Policy Framework
National
6.1
The National Planning Policy Framework (NPPF) states that planning authorities
should:
develop policies based on an understanding and evaluation of its defining
characteristics; and
develop policies to provide guidance for establishing a strong sense of place, that
respond to the local character and history, while not preventing or discouraging
innovation.
Regional
6.2
The London Plan recognises the importance of placemaking. This sets out a series of
design related policies, which provide comprehensive guidance for delivering Lifetime
Neighbourhoods and for development to help reinforce or enhance the character, legibility,
permeability and accessibility of neighbourhoods. The London Plan also provides guidance
for architecture and building design alongside guidance for development to build on the
positive elements of character and have regard to the form, function, structure, scale, mass
and orientation of a place.
6.3
The Mayors Old Oak and Park Royal OAPF principle D5 provides guidance for
placemaking alongside a series of place-specific visions and objectives.
Preferred Policy Option:
Proposals will be supported where they demonstrate the delivery of exemplar world
class architectural and landscape design quality that:
a) responds to and enhances positive elements of existing local character and
context; and
b) contributes to creating new character areas for places and neighbourhoods for
locations within Old Oak, where appropriate.
Justification
6.4
In delivering exemplar world class design and successful placemaking, development
should consider its relationship to the surrounding context, specifically by positively
responding to local views, its relationship with existing and proposed surrounding
development and spaces and ensuring it contributes to the creation of a welcoming and
outward looking environment.
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6.5
By recognising existing positive elements of the local character and context to inform
existing and evolving character areas, a sense of place for different areas can be nurtured.
The size and scale of development within Old Oak and the contrasting characters of Park
Royal and Wormwood Scrubs will enable a series of distinctive neighbourhoods to emerge
that exhibit specific characters that have been informed by existing character and by new
exceptionally designed places with mix of uses and activities. Where appropriate, there will
be opportunities for development to help inform the development of new character areas,
specifically within Old Oak.
6.6
Alongside character, context is a critical element in creating a connected and
coherent set of places. Context is defined by the GLA Character & Context SPG as the way
in which places, sites and spaces inter-relate with one another whether physically,
functionally or visually, or the way in which they are experienced sequentially and
understood. As such proposals should provide relevant information in demonstrating how it
is seeking to respond to the existing and envisaged local context.
6.7
The OPDC Place Review Group has been established to advise on the production of
planning policy documents and development proposals. Applicants will be encouraged to
present proposals to the group for consideration.
6.8
OPDC is developing a Character Study which will be used to inform the next version
of the draft Local Plan.
Alternative Policy Options
6.9
Alternative policy options are not considered to be appropriate in light of the
comprehensive and detailed regional guidance provided by the London Plan and Old Oak
and Park Royal Opportunity Area Planning Framework.
Consultation Questions
QD1a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy?
QD1b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
QD1c: What areas should be defined as neighbourhoods within Old Oak?

Policy D2: Streets and public realm

Key Issues
1. High density development must be supported by a high quality, flexible public realm that
fulfils a range of needs and delivers successful and distinctive places and
neighbourhoods.
Policy Framework
National
6.10 The NPPF identifies that:
development should establish a strong sense of place, using streetscapes and
buildings to create attractive and comfortable places to live, work and visit.
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policies for managing advertisements should be efficient, effective and simple and
should only manage their impact on buildings or on their surroundings and in the
interests of amenity and public safety.
development should deliver places which promote clear and legible pedestrian routes
that encourage the active and use of public areas.

6.11 The National Planning Policy Guidance provides detailed guidance for managing
advertisements to supplement the Town and Country Planning (Control of Advertisements)
(England) Regulations 2007.
Regional
6.12 The London Plan provides guidance for streets and public realm. This sets out a
series of comprehensive design related policies including:
extensive and detailed guidance for delivering secure, accessible, inclusive,
connected, legible public realm that relates to the local context including heritage.
This requires the public realm to incorporate the highest quality design, landscaping,
planting, street furniture and surfaces. Specifically, development is required to
support the legibility of the public realm and it should have clearly defined purposes
and an uncluttered appearance. Opportunities for high quality public art and greening
are supported.
guidance to deliver a safe and secure environment in London that is resilient to
emergencies and supports opportunities for designing out crime.
guidance for the delivery of child play space and informal recreation.
6.13 The Mayors Old Oak and Park Royal OAPF principle D1 and OO2 provides
guidance for delivering new and improve streets and public realm.
Preferred Policy Option:
a) OPDC will work with stakeholders to deliver an exemplarily designed, welcoming,
safe, resilient, flexible, inclusive and sustainable public realm network that
facilitates the use and enjoyment of spaces while responding to local character
and integrating with surrounding areas.
b) Proposals will be required to:
i.
contribute to, or improve, the network of streets as set out in the Places
Chapter;
ii.
contribute to connecting places together and breaking down severance;
iii.
contribute to improving the quality of existing and creating new public
realm;
iv.
deliver public realm and street furniture that responds to and / or
contributes to the delivery of new and improved local character areas;
v.
be supported by a clear and robust public realm management and
maintenance strategy;
vi.
support wayfinding, in particular to key destinations;
vii.
enable the coordinated design, delivery and management of utilities
infrastructure and emerging technology; and
viii.
demonstrate engagement with the Mayors Office for Policing and Crime,
the local Metropolitan Police Crime Prevention Design Advisor and other
relevant emergency services.
c) Proposals for advertisements will be required to have a:
i.
positive impact on associated buildings and surroundings; and
ii.
neutral or positive contribution to amenity and public safety.
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Justification
6.14 The quality and functioning of the public realm is critical in fostering successful
places. The public realm provides an important location for social interaction and movement.
Further guidance relating to this policy will be provided within the forthcoming OPDC Public
Realm SPD.
6.15 The use of appropriate robust materials and the quality of detailed design of the
public realm will play a key role in strengthening local identities. To support this,
management and maintenance strategies should be provided.
6.16 Street frontages are key in helping buildings frame the public realm and providing a
sense of enclosure. The frequency of their frontages along streets can inform the character
of the area with regular entrances positioned to provide ease of use.
6.17 To enable the effective management of the public realm and management of utilities
infrastructure (including emerging technology) the public realm should be designed to
facilitate easy access to subsurface utility infrastructure.
6.18 Emerging and future technology may enable the public realm to be used and
managed more efficiently and this should be encouraged through flexible design and the use
of technology, as appropriate. This may include the use of sensors to help understand how
spaces are used and can be better organised to support local communities.
6.19 Advertisements can come in a range of formats. They can include digital, illuminated
and large-scale shrouds which could potentially have a negative impact on amenity and
public safety if not managed and designed appropriately to address these impacts.
6.20 Integrating security and resilience for emergency requirements are important but the
impact on wider context and character should also be considered. Early engagement with
the Mayors Office for Policing and Crime, the local Metropolitan Police Crime Prevention
Design Advisor and other relevant emergency services will be encouraged.
6.21

The OPDC Public Realm Strategy will inform the next version of the draft Local Plan.

Alternative Policy Options

6.22 In light of the strong national and regional guidance and the requirement of the
London Plan to deliver optimum development densities supported by high quality public
realm, alternative policy options were not considered to be appropriate.
Consultation Questions
QD2a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy?
QD2b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
QD2c: Are there other key routes that should be added to the public realm network?

Policy D3: Open space

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Key Issues
1. Sufficient amounts of high quality open space that delivers a range of functions needs to
be provided within Old Oak and Park Royal to support the area and to promote the
health and well-being of existing and new residents and workers.
2. There are existing open spaces that should be sensitively enhanced, where agreed.
Policy Framework
National
6.23 The NPPF identifies that:
access to high quality open spaces and opportunities for sport and recreation can
make an important contribution to the health and well-being of communities.
policies are required to be based on assessments of the need for open space and
opportunities for provision which identify quantitative or qualitative deficiencies in
open space.
open space is protected unless it is considered to be surplus, is better replaced or
the development is for alternative sports and recreation provision.
Regional
6.24 The London Plan provides guidance for open spaces. This sets out policies including:
benchmark standards for child play space for a range of ages.
requiring that the strongest protection for Metropolitan Open Land to prevent
inappropriate development except in very special circumstances.
the Mayors support for new public open space to address areas of deficiency and
resist the loss of protected open spaces unless better quality provision is made
locally.
6.25 The Mayors All London Green Grid SPG provides supplementary guidance to the
London Plan and considers the delivery of green infrastructure across London. The Mayors
Housing SPG provides guidance for the design of communal open space alongside the
design and size of private open space. The Mayors Play and Informal Recreation SPG
provides guidance for child play space.
6.26 The Mayors Old Oak and Park Royal OAPF principle OO3 provides guidance for the
location of new public open spaces including Grand Union Square, Old Oak Square, station
squares, small open spaces and towpath linear spaces.
Preferred Policy Option:
a) OPDC will work with stakeholders to create a network of public open spaces by:
i.
safeguarding and / or enhancing existing public open spaces; and
ii.
creating and connecting new public open spaces to meet identified need.
b) Proposals will be required to:
i.
deliver, improve and / or contribute to the delivery of new public open
spaces identified in the Places Chapter;
ii.
deliver public and communal open spaces that are supported by a clear
and robust management and maintenance strategy;
iii.
deliver temporary public open spaces that contribute to the vitality,
character and activation of an area and supports the delivery of permanent
development;
iv.
enhance existing public open space; and

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v.

deliver private and communal open space to support the needs of

residents.

Justification
6.27 Old Oak and Park Royal currently have limited provision of public open space. To
meet the needs of existing and future residents, workers and visitors, new spaces need to be
provided and existing open spaces protected and / or enhanced in consultation with relevant
stakeholders. New public open spaces have been identified within the Places Chapter.
6.28 OPDC will work with stakeholders to explore whether onsite public open space
should be delivered on major development sites in addition to the public open spaces
identified in the Places Chapter. These should be coordinated with the surrounding provision
of existing and proposed public, communal and private open spaces to deliver a coherent
and connected open space network. Further information will be provided in the forthcoming
OPDC Public Realm SPD.
6.29 Enhancement of existing public and communal open space will be considered in
relation to its size, function, quality and character.
Consultation Questions
QD3a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, should the proposed Local Plan adopt the
alternative policy options as the preferred option?
QD3b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
QD3c: Should the proposed policy consider prioritising the delivery of public open
space provision ahead of private open space provision?
Policy D4: New Buildings
Key Issues
1. New housing, employment uses, town centre uses and social infrastructure should to be
delivered at high densities to:
take advantage of the access to future excellent public transport accessibility;
create a thriving new part of London comprised of a series of neighbourhoods;
and
contribute to addressing Londons housing needs.
2. New industrial workspaces need to be delivered at higher densities than the existing
industrial typologies to:
support further intensification of Park Royal; and
support economic growth in the local and London economies.
3. Building at high density will require exceptional design standards and high quality
materials to:
achieve a sense of place; and
achieve high quality local environments for occupants.
4. In the London Plan, Old Oak and Park Royal are identified as locations where tall
buildings are appropriate. Tall buildings can play a positive role in creating a sense of
place, but should be designed to the highest standards and located in the right places to
mitigate negative impacts on surrounding areas.
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Policy Framework
National
6.30 The NPPF identifies that:
good design is indivisible from good planning, and should contribute positively to
making places better for people;
decisions should aim to ensure that development optimises the potential of the site to
accommodate development and is visually attractive as a result of good architecture
and appropriate landscaping;
policies should not attempt to impose architectural styles or particular tastes and they
should not stifle innovation, originality or initiative; and
policies should promote or reinforce local distinctiveness.
6.31 NPPG requires that development should give careful consideration to details and
materials. Specifically, it requires that materials should be practical, durable, affordable and
attractive.
Regional
6.32 The London Plan provides guidance for design. This sets out policies including:
extensive and detailed guidance on architecture of new buildings and their
relationship with their surroundings. Specifically it provides guidance in relation to
delivering the highest architectural quality, scale, details and materials, climate
change mitigation and adaptation, relationship with the street and indoor/outdoor
spaces and flexibility. It also provides guidance for designing out crime and resilience
to emergencies.
specific criteria for tall and large buildings, directing them to Opportunity Areas. Tall
buildings are defined in the London Plan as those that are substantially taller than
their surroundings, cause a significant change to the skyline or are larger than the
threshold sizes set for the referral of planning applications to the Mayor.
specific guidance for the quality and design of housing and is supplemented by the
Mayors Housing SPG.
6.33 The Old Oak and Park Royal OAPF principle OO4 provides guidance for the
indicative arrangement of density across Old Oak.
Preferred Policy Option:
Design
a) OPDC will work with partners and stakeholders to promote the delivery of
world-class exemplarily designed and sustainable new buildings.
Density
b) Proposals will be required to:
i.
deliver densities in accordance with those identified in OSP4, the
employment policies and the Places Chapter, that contribute to
delivering high quality environments for all;
ii.
demonstrate successful delivery of social infrastructure, other relevant
uses and building servicing within a high density context;
Tall buildings
c) Proposals for tall buildings will be required to:
i.
accord with OSP4;
ii.
contribute to the delivery of a visually engaging and coherent skyline;
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iii.
iv.
v.

accord with relevant guidance for RAF Northolt safeguarding zones.

achieve the highest standards of design; and
be mindful of their surrounding context.

Local views
d) Proposals will be required to demonstrate how they provide positive
contributions to the character and composition of local views.
Materials
e) Proposals will be required to comprise details and materials that:
i.
are robust and durable;
ii.
complement positive elements of the existing character; and
iii.
positively contribute to the development of a new coherent character
and series of places.
Justification
6.34 The delivery of world class sustainable architecture that responds to existing and
emerging character and context, while exploring the potential to deliver a new local
character, is fundamental to the successful regeneration of Old Oak and Park Royal.
6.35 The potential for optimising development will likely require the delivery of high density
development for housing, employment uses and social infrastructure. Elements of this may
require the integration of primary schools and health services into the envelopes of high
density developments which will require innovative design and management approaches. In
delivering high density housing, proposals should consider how variants of perimeter block
typologies can optimise the density of development.
5.36 Servicing of buildings, particularly for mixed use buildings, can have a specific impact
on building design and the public realm. Where appropriate, proposals should demonstrate
how coordination of servicing facilities will be delivered.
6.37 As set out in OSP4, high density development can include tall buildings, as long as
such proposals accord with locational guidance, achieve the highest standards of design,
are mindful of their surrounding context, delivers a moment of interest and accord with the
requirements set out in national guidance, the London Plan and the draft preferred policy
options in this draft Local Plan.
6.38 The delivery of buildings will impact on the character of surrounding areas and
should enhance the skyline. Any proposals of 91.4m above ground level should consult the
Defence Infrastructure Organisation.
6.39 Local views from within and outside Old Oak and Park Royal can help positively
shape the local skyline, provide visual interest and contribute to delivering high levels of
amenity while informing the local character and identity of the area. Specific consideration
will be given to how the massing and elevational treatments of development contributes to
views. These views are those taken from existing residential communities, existing town
centres, along the Grand Union Canal, public open spaces and heritage assets (including
conservation areas). OPDC will be developing these in further detail to inform the next
version of the draft Local Plan in consultation with the community and stakeholders. In
demonstrating how views accord with the proposed policy option, proposals should include
verified daytime, evening and night-time views that consider tree coverage.
6.40 Details and materials that complement not only positive elements of existing
character but also inform new evolving character, while considering maintenance
requirements, will play a key role in delivering successful and resilient places.
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6.41 An important element of creating a high quality place is ensuring that development is
resilient to terrorism, specifically for development in busy areas such as town centres,
catalyst uses and stations. Development proposals should have regard to the appropriate
guidance published by the National Counter Terrorism Security Office, Centre for the
Protection of National Infrastructure and liaise with the Counter Terrorism Security Advisors.
Alternative Policy Options
6.42 In light of the detailed national and regional guidance, specific alternative policies
were not considered to be appropriate.
Consultation Questions
QD4a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy?
QD4b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
QD4c: Are there any additional elements to the proposed policy option for tall
buildings and London Plan policies which should be considered?
QD4d: Are there any other locations for high density development and / or taller
buildings?
QD4e: Are there any locations where taller buildings may not be appropriate?
QD4f: Where should key views by identified from? What should they be focused on?
Policy D5: Alterations & extensions
Key Issues
1. Alterations to existing buildings can negatively impact the character of an area if not
managed appropriately.
Policy Framework
National
6.43 A significant amount of different types of alterations are allowed by legislation known
as permitted development rights.
Regional
6.44 The London Plan provides limited specific guidance for managing alterations and
shop fronts that is not managed by other general policies.
Preferred Policy Option:
a) Proposals for alterations and extensions will be required to:
i.
respect and / or improve the architectural quality of the existing building
and the character of its setting;
ii.
be appropriate to the scale, form, height and mass of the existing building
and any surrounding buildings;
iii.
relate sympathetically to any other sensitive sites that will be affected; and
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iv.

have neutral or positive impact on local views.

b) Proposals for replacement shopfronts or alterations to existing shopfronts will be

required to:
i.
relate sympathetically to the upper parts of the building and the part of the
shopfront to be retained in terms of the design and materials;
ii.
not result in the loss or partial loss of shopfronts which are of architectural
interest; and
iii.
provide open and active frontages to the public realm.
Justification
6.45 Alterations and extensions can affect the character of a building and its surrounding
area. If they are not designed appropriately, both major and minor works have the potential
to undermine the contribution of an existing building to its immediate surroundings or the
pattern of development in a wider area. Proposals to alter existing buildings must therefore
ensure proposed extensions or alterations relate sympathetically to their context and achieve
a high standard of design. Proposals should demonstrate how elements considered to be of
positive value to local character have been included and / or reflected in their design.
6.46 In buildings where the windows are a valuable architectural feature of a property or
group of properties, replacement windows should seek to match the original in terms of their
materials, design, size, method of opening and section.
6.47 The addition of building services equipment to existing buildings should seek to
utilise internal spaces such as basements before other locations are considered.
6.48 Shopfronts have an important role in placemaking because they are the most
significant interface between commercial buildings and users of the public realm. This
importance will be exaggerated at Old Oak due to the planned scale of development and the
need to create a high quality pedestrian environment.
6.49 Shopfronts, including specific architectural features, considered to be of architectural
or historic interest should be preserved and enhanced if they are considered to provide a
valuable contribution to local character and distinctiveness. New buildings that include
commercial or other ground floor uses that provide access to the public should demonstrate
how the design of the shopfront relates to the architecture of the building and creates a
rhythm to the building street frontage. Design should also carefully consider the location,
materials and robustness of alarm boxes, canopy boxes and security cameras to avoid
undermining the appearance of new developments.
6.50 Solid and perforated roller shutters can have a negative impact on the public realm.
Where roller shutters are considered necessary, internal perforated shutters should be
located within the shop unit.
Alternative Policy Options
1. Guidance is not provided for alterations, extensions and shopfronts.
6.51 The benefit of this approach would be the development of a streamlined local
planning framework. The disadvantage would be that individual and an accumulation of
unmanaged amendments to existing buildings could result in negative impacts on the local
character and context.
Consultation Questions
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QD5a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, should the proposed Local Plan adopt one of the
alternative policy options as the preferred option?
QD5b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
Policy D6: Heritage
Key Issues
1. It is important that regeneration and intensification recognises the positive role that
heritage and the historic environment can play in helping to shape the character of
development.
2. Proposed uses within or for designated heritage assets may not be consistent with the
assets significance.
Policy Framework
National
6.52 The NPPF identifies that local planning authorities should set out a positive strategy
for the conservation and enjoyment of the historic environment that considers:
the desirability of sustaining and enhancing the significance of heritage assets;
putting them to viable uses consistent with their conservation and the wider social,
cultural, economic and environmental benefits;
the desirability of new development making a positive contribution to local character
and distinctiveness;
undesignated heritage assets; and
opportunities for heritage to contribute to the character of a place.
Regional
6.53 The London Plan provides guidance for design in Chapter 7. This sets out policies
including:
comprehensive and detailed guidance for heritage assets and archaeology.
Specifically it identifies that development should identify, value, conserve, restore, reuse and incorporate heritage assets, where appropriate. It also requires development
to conserve their significance and make provision for the protection of archaeological
resources, landscapes and significant resources.
guidance for heritage-led regeneration and seeks regeneration schemes to make use
of heritage assets to stimulate environmental, economic and community
regeneration.
Preferred Policy Option:
a) OPDC will work with Historic England and stakeholders to:
i.
identify, conserve, enhance and improve access to the historic
environment, heritage assets and their settings where appropriate;
ii.
ensure heritage assets contribute to improving and creating a sense of
place; and
iii.
address Heritage at Risk.
b) Proposals will be required to conserve and / or enhance the significance of
heritage assets to contribute to successful placemaking.
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Justification
6.54 Heritage assets and their settings play a critical role in helping to inform placemaking
and generating social, economic and environmental benefits for Old Oak and Park Royal. As
such their architectural or historic special interest should be conserved and enhanced.
6.55 In 2015, Historic England published the Old Oak Outline Historic Area Assessment to
inform the development of planning policy for Old Oak and the designation of local assets.
Alongside this draft Local Plan, OPDC is also consulting on the designation of the proposed
Cumberland Park Factory Conservation Area. The two existing designated heritage assets
within the OPDC area are the Grand Union Canal Conservation Area and the Grade II Listed
Brent Viaduct.
6.56 OPDC will be developing a Park Royal Heritage Assessment and a Views Study to
inform the next version of the draft Local Plan which will also consider potential heritage
assets within Park Royal. OPDC will use this information alongside the Old Oak Outline
Historic Area Assessment to work with Historic England and stakeholders in exploring the
designation of other heritage assets including the potential development of a Local List.
6.57 Although OPDC is not responsible for the adjacent St. Marys and Kensal Green
Cemetery Conservation Areas, they contain a number of heritage assets which are identified
by Historic England to be at risk. OPDC will work with Historic England and other
stakeholders to remove these from the Heritage at Risk Register.
6.58 By supporting proposals which seek to promote the significance of heritage assets
through beneficial reuse, assets can help to inform wider placemaking and deliver a wide
range of economic benefits. The proposed designation of the Cumberland Park Factory
Conservation Area aims to facilitate this aspiration and continue the legacy of employment
uses and economic innovation within Old Oak.
Alternative Policy Options
6.59 In light of the strong national and regional guidance provided for managing heritage,
providing alternative policy options is not considered to be appropriate.
Consultation Questions
QD6a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy?
QD6b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
QD6c: Do you have an opinion on the designation of the proposed Cumberland
Factory Conservation Area?
Policy D7: Building user amenity
Key Issues
1. Building a new part of London requires the provision of high quality amenity for building
users. However, building at higher densities can have an impact on the quality of the
environment for building users in and around sites if not carefully managed.
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Policy Framework
National
6.60 The NPPF identifies that planning should always seek to ensure a good standard of
amenity for all existing and future occupants of land and buildings as a core planning
principle.
6.61 The NPPG identifies that the scale of buildings should take account of local climatic
conditions, including daylight and sunlight, wind, temperature and frost pockets.
Regional
6.62 The London Plan provides guidance for amenity. This sets out policies including:
guidance requiring that buildings and structures should not cause unacceptable harm
to the amenity of surrounding land and buildings with a specific reference to housing.
It references the elements of amenity to be privacy, overshadowing, wind and
microclimate.
specific guidance in relation to tall buildings not adversely affecting their surroundings
also in terms of microclimate, wind turbulence, overshadowing, noise and reflected
glare.
Preferred Policy Option:
a) OPDC will work with stakeholders to ensure that development delivers a high level
of amenity and high quality environment for building users in and around Old Oak
and Park Royal; and
b) Proposals will be required to demonstrate that they achieve appropriate levels of:
i.
privacy for workspaces and habitable rooms; and
ii.
non-reflected daylight and sunlight.
Justification
6.63 New development and all density levels will need to deliver a high standard of
amenity in terms of privacy, overshadowing, air quality, noise and light pollution,
daylight/sunlight, wind and microclimate for future building users and neighbours.
6.64 During construction and operational phases, OPDC will work with stakeholders to
minimise negative impacts on local communities.
5.65 Appropriate levels of privacy and daylight / sunlight are relevant to the types of use of
buildings associated activities. For residential uses, this is important for habitable rooms and
private open spaces. To support the amenity of building users, proposals demonstrating
levels of daylight / sunlight should provide information relating to non-reflected light in
accordance with relevant site layout planning for daylight and sunlight guidance.
6.66 To minimise the visual and acoustic impact of plant and services equipment, this
should always be integrated into new buildings with appropriate capacity for future
equipment incorporated into the design. External equipment should be sensitively sited to
minimise any visual impact, including consideration of long distance views, whilst allowing
for necessary noise mitigation.
6.67 Proposed policy options for managing air quality and noise are provided in the
Environment and Utilities Chapter.
Alternative Policy Options
1. London Plan policies are used to manage amenity
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6.68 The benefit of this option would be the use of a London-wide standardised approach
and the provision of a streamlined Local Plan. The disadvantage would be the inability for
OPDC to manage specific amenity issues in relation to higher density development.
Consultation Questions
QD7a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, should the proposed Local Plan adopt one of the
alternative policy options as the preferred option?
QD7b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
QD7c: Should policies allow a greater acceptable impact on residential uses in light of
the high densities being delivered?

Policy D8: Inclusive design

Key Issues
1. A number of existing destinations within Old Oak and Park Royal have restricted access
including the Grand Union Canal.
2. Infrastructure and impermeable land uses across the area present barriers to movement
that need to be addressed.
Policy Framework
National
6.69 The NPPF identifies that local planning authorities need to plan positively for the
achievement of inclusive design for all developments, including buildings, public and private
spaces and that planning policies and development should create safe and accessible
environments.
6.70 Building Regulations Part M provides legislation in relation to the access to and use
of buildings. This sets out requirements for accessibility for general housing, accessible and
adaptable housing and wheelchair user dwellings.
Regional
6.71 The London Plan provides guidance for inclusive design. This sets out policies
including:
detailed guidance for delivering Lifetime Neighbourhoods, requiring development to
maximise the opportunity for community diversity, inclusion and cohesion.
detailed guidance for delivering inclusive environments. Specifically it requires all
new development to achieve the highest standards of accessible and inclusive
design by according with a series of criteria based policies.
requiring development delivers 10% of new housing to be designed to be wheelchair
accessible, or easily adaptable for residents who are wheelchair users. The policy
also requires all new housing to be built to Lifetime Homes Standards.
6.72 The Accessible London SPG provides further guidance on the implementation of
London Plan to deliver the Mayors aspirations for delivering an accessible environment in
London, with particular emphasis on the access needs of disabled and older people.
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6.73 The Housing SPG provides additional specific guidance for wheelchair housing to
Building Regulations Part M to ensure new homes are designed to allow sufficient flexibility
to adapt to residents changing needs and circumstances.
Preferred Policy Option:
a) OPDC will work with stakeholders to promote and deliver an exemplarily
inclusive and accessible designed environment for Old Oak, Park Royal and
Wormwood Scrubs.
b) Proposals will be required to meet the highest standards of accessible and
inclusive design by:
i.
delivering accessible design solutions that contribute to addressing
existing barriers;
ii.
seeking to exceed latest guidance on accessible and inclusive design;
and
iii.
engaging with relevant stakeholders to inform proposals at the earliest
opportunity.
Justification
6.74 Inclusive design is defined by the NPPF as designing the built environment,
including buildings and their surrounding spaces, to ensure that they can be accessed and
used by everyone.
6.75 In promoting the delivery of the highest quality inclusive and accessible
environments, OPDC seeks to enable the creation of a series of Lifetime Neighbourhoods
that meet the needs of all sections of the community, including disabled and older people.
With this in mind, the OPDC Place Review Group has specific expert representation in
accessible and inclusive design. OPDC will work with a range of stakeholders to achieve this
aspiration including local access groups represented on the London Access Forum.
6.76 The existing network of transport infrastructure currently has a negative impact on
people accessing areas within Old Oak and on-street congestion, alongside a poor quality
physical environment, restricts easy movement within Park Royal. New development will
play a new role in addressing these barriers to deliver inclusive and welcoming
environments.
6.77 Proposals which demonstrate how they will exceed the existing latest guidance for
inclusive design for housing, commercial uses (including shop fronts), infrastructure, public
realm, public open spaces (including child play space) will be supported. The use of
Accessibility Management Plans (see Policy TC6) for hotel proposals will be considered on a
case-by-case basis. Proposals which demonstrate engagement with relevant access groups
at the earliest opportunity will be supported.
Alternative Policy Options
6.78 In light of the strong national and regional guidance provided for delivering inclusive
and accessible environments, providing alternative policy options is not considered to be
appropriate.
Consultation Questions
QD8a: Do you agree with the preferred policy option? If so, what might you change
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about the preferred policy?
QD8b: Are there any other policy alternatives you consider are appropriate?

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7. HOUSING
This chapter contains policies addressing the following policy themes:
H1: Strategic Policy for Housing
H2: Housing Supply
H3: Housing Mix
H4: Affordable Housing
H5: Existing Housing
H6: Housing in the Private Rented Sector
H7: Houses with shared facilities
H8: Specialist housing for older people and/or vulnerable people
H9: Gypsy and Traveller Accommodation
H10: Student Housing
Consultation Question
QHa: Are there any other housing policy themes that you think OPDCs Local Plan
should be addressing?

Evidence Base
Study

Scope

Status

OPDC Strategic
Housing Market
Assessment
(SHMA)

The Strategic Housing Market Assessment (SHMA)

identifies the objective housing need across tenures for
the OPDC area and a wider catchment covering the
London Boroughs of Brent, Ealing and Hammersmith
and Fulham.

Draft
completed

OPDC Gypsy and

Traveller
Accommodation
Needs
Assessment
(GTANA)

The Gypsy and Travellers Accommodation Needs

Assessment will identify the specific housing needs of
the Gypsy and Travellers community.

Draft in
developmen
t

OPDC Affordable
Housing Viability
Assessment

The study tests the viability of affordable housing

across Old Oak and Park Royal.

To be
developed

OPDC
Development
Capacity Study
(DCS)

A study looking at the capacity of the OPDC area to

accommodate new homes and jobs.

Draft
completed

Policy H1: Strategic Policy for Housing

Key Issues
1. The delivery of new homes to meet housing needs is a critical issue facing the UK.
2. Central government has:
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a. introduced reforms to the planning framework to speed up delivery of new
homes. The draft Housing and Planning Bill (2015) proposes measures to
boost housing supply and home ownership
b. set a target to deliver an additional one million homes by 2020, including
200,000 Starter Homes.
3. Old Oak and Park Royal has a key role in delivering much needed new housing
within London.
Policy Context
National
7.1
The National Planning Policy Framework (NPPF) states that local planning
authorities should:
objectively assess the housing needs for market and affordable housing;
identify key sites critical to the delivery of its housing strategy, (over the next five, ten
and where appropriate, fifteen years); and
demonstrate expected rates of housing delivery.
Regional
7.2
Housing Policies in the London Plan (2015) recognise Londons pressing need for
new housing. The Plan;
identifies a London-wide housing need for between 49,000 62,000 new homes per
year between 2015-2036
sets annual average housing supply targets for London boroughs on the basis of an
annual average supply of 49,000 new homes
states that the supply of new housing should comprise a range of housing types,
sizes, tenures and include a percentage of (wheelchair) accessible homes.
Preferred Policy Option:
a) OPDC will work to ensure the area plays a crucial role in delivering a range of
high quality housing that addresses Londons housing requirements. This will
be achieved through encouraging:
i.
the delivery of new housing, where it accords with other policies in this
Local Plan;
ii.
a mix of housing types and tenures to meet a wide variety of needs; and
iii.
developments to be flexible and adaptable to accommodate future need,
innovation and smart technologies.
Justification
7.3
The OPDC area covers two of Londons Opportunity Areas (Old Oak and Park Royal)
which are identified in the London Plan as having capacity to provide a minimum 25,500 new
homes. The area will help play a critical role in meeting Londons strategic housing need
and in meeting local need. To support this, OPDC will actively promote the development of
land for housing, where development proposals accord with other policies in this draft Local
Plan.
7.4
Given the scale of new homes that could be delivered in the area, OPDC has set up
a housing advisory group of experts to help it develop its policies and strategies and plan for
and deliver a wide range of housing types and tenures. This will include affordable housing,
starter homes, low cost market housing, private rented sector (PRS) and open market
housing. There is also an opportunity to plan and deliver a range of housing products aimed
at specific groups, such as students or older people.
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7.5
It is imperative that OPDC delivers a lasting legacy of high quality housing by
providing Lifetime Neighbourhoods. Housing design, both internally and externally and
across all housing tenures and types, will be expected to be exemplary. It will need to
incorporate the highest standards of modern design and flexibility that can accommodate
smart and innovative technologies from the outset. As well as this, it will need to cater for a
wide variety of needs promoting consideration of aspects such as natural lighting, ventilation
and the efficient use of space. High-quality housing is a key determinant of good health and
well-being. OPDC will encourage developers to consider positively impacting on mental and
physical health through the quality of their new housing provision.
Alternative Policy options
7.6
No suitable policy alternative has been identified as an alternative would not be
consistent with the NPPF or in general conformity with the London Plan.
Consultation Questions
QH1a: Do you agree with the preferred policy option? If not, what might you change
about the preferred policy?
QH1b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
Policy H2: Housing Supply
Key Issues
1. Londons population is projected to grow to over 11 million by 2050 and will need a
supply of new housing to accommodate it.
2. OPDC will play an important role in meeting the need for new housing identified in
the London Plan - a requirement for 49,000 new homes per annum across London
by delivering a minimum of 25,500 new homes.
3. OPDCs Local Plan policy will need to demonstrate what proportion of the 25,500
target is feasible to deliver within the plan period over the next 20 years, considering
issues such as site availability, deliverability and market needs.
Policy Context
National
7.7
To significantly boost the supply of housing, the NPPF states that local planning
authorities should:
- meet the full objectively assessed needs for market and affordable housing and
identify key sites for the delivery of housing:
- identify and update annually a supply of specific deliverable sites sufficient to
provide five years-worth of housing;
- identify a supply of specific, developable sites or broad locations for growth, for
years 6-10 and where possible, for years 11-15 and for market and affordable
housing, illustrate the expected rate of housing delivery through a housing
trajectory for the plan period.
Regional
7.8
The London Plan (2015) identifies Londons housing need and provides detail on
meeting this need though increasing housing supply. The potential for the area to
accommodate a minimum 25,500 new homes is set out in annex one of the London Plan.
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Preferred Policy Option:
OPDC will support delivery of new homes during the Plan period (2017-2037). This
new housing will be achieved through:
a. Setting an annual housing target;
b. Promoting the development of sites identified within the Development Capacity
Study (DCS);
c. Promoting development opportunities on windfall sites, where these accord
with other Local Plan policies;
d. Working with the London Boroughs of Brent, Ealing and Hammersmith and
Fulham to bring vacant dwellings back into use;
e. Supporting housing conversions and changes of use to residential where this
accords with other Local Plan policies; and
f. Monitoring delivery and publishing information on the rate of housing starts
and completions and the trajectory of deliverable and developable housing
supply.
Justification
7.9
London is a global city experiencing a period of rapid population growth. This,
coupled with a slow rate of housing delivery has resulted in a widening gap between housing
supply and demand. The 2011 census shows that Londons population is growing faster and
in ways previously not forecast leading to Londons Strategic Housing Market Assessment
identifying a housing requirement of between 49,000 and 62,000 new homes per year.
Figure XX shows the projected population for the three authorities covered in the OPDC
area.
Figure XX: Population projections for London Boroughs of Brent, Ealing and Hammersmith
and Fulham

7.10 The NPPF requires local planning authorities to ensure that their Local Plan meets
the full, and objectively assessed, needs for market and affordable housing in the housing
market area.

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7.11 Based on the areas current population of 7,000 people and 2,800 households and
following national and regional guidance for preparing a Strategic Housing Market
Assessments, OPDCs work identifies an objectively assessed housing need for the OPDC
area of 1,200 homes, of which 564 as affordable housing, over the plan period up to 2037.
7.12 However, as Londons single largest regeneration scheme and recognising that
existing guidance for producing a SHMA is based on a standard local planning authority and
not one created through a Mayoral Development Corporation, the OODC area can deliver
new homes far in excess of this objectively assessed housing need and so needs to look
wider than just its immediate boundary.
7.13 In realising its wider strategic role and in supporting west Londons housing needs,
the combined area of the London Boroughs of Brent, Ealing and Hammersmith & Fulham
has therefore been identified in OPDCs draft SHMA. This is considered to be a more
appropriate housing market area for OPDC. In adopting this approach, a much wider
demographic base is included in the population projections and the draft SHMA identifies a
housing need for 96,000 homes over the plan period for this combined area across these
three boroughs. Delivery of new homes across Old Oak and Park Royal will go some way to
meeting that demand.
7.14 The draft DCS identifies the indicative phasing for the areas to be brought forward for
residential development (subject to known constraints). The table below provides further
details on the first five-year supply of housing (deliverability) as well as sites for development
(years 6-20).
Years
0-5
6-20
20+

Development Phase
2017 - 2021
2021 - 2037
2037+ (post plan period)

Delivery Phase
1
2
3

Unit Delivery
To be confirmed
To be confirmed
To be confirmed

7.15 Figure XX sets out the delivery phases for housing development. Many of these
areas cannot be brought forward in advance of 2026, as they rely on the opening of the Old
Oak Common station and/or are reliant on the release of land required up until or after this
date.
Figure XX: Development phasing (from DCS)
7.16 Further work is being progressed to identify other areas likely to come forward and
contribute to OPDCs first five-year housing supply (deliverability), OPDC will also identify an
annual delivery target following this further work. Further details will be provided in the next
iteration of the Local Plan.
7.17 There may also be other windfall sites that have not yet been identified in the DCS.
They may make a contribution to the supply of new housing. As part of this consultation we
are inviting suggestions for additional sites that could help contribute towards meeting
Londons growing housing need through a call for sites.
7.18 Changes of use to residential and housing conversions can also contribute to the
overall housing supply. Changes of use will be supported where they accord with other draft
Local Plan policies. The appropriateness of housing conversions is covered in Policy H5.
7.19 Monitoring new housing delivery will be vital to achieving the broader objectives and
OPDC will report on the number of new homes started and completed in its Authority

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Monitoring Report (AMR). The AMR will also contain a housing trajectory which will show
annual updated information on OPDCs 0-5 year, 6-10 year and 11-15 year housing supply.
Alternative Policy options
1 Seek to deliver a higher number of new homes within the Local Plan period
7.20 This option is unlikely to be achievable as there are significant infrastructure and
delivery issues that would need to be overcome to free up all sites for development within
the plan period. Further information on site availability is set out in the DCS.
Consultation Questions
QH2a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, should the proposed Local Plan adopt the
alternative policy option as the preferred option?
QH2b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
QH2c: Do you agree with the approach OPDC is taking to its objectively assessed
housing need?
QH2d: Do you agree with sites identified for the first 5 years in figure XX?
QH2e: Are there sites, that have not been identified as providing the first five year
supply, that you consider can be brought forward to deliver housing in the first five
years of the plan period (2017-2021)?

Housing Supply - Call for sites

7.21 OPDCs draft Development Capacity Study identifies land that OPDC is currently
aware of that can be developed for housing. It identifies the potential phasing showing when
they may come forward for delivery, based on currently available information.
7.22 As well as areas identified in the DCS for development, OPDC are as part of this
consultation inviting suggestions for additional sites that could support development through
a call for sites. This will assist OPDC to meet its obligations under the NPPF and assist in
implementing the presumption in favour of sustainable development when planning
decisions are taken.
Consultation Questions
QH2f: Are there any sites excluding those already identified in OPDCs DCS or sites
designated as Strategic Industrial Location (SIL) (see page XXX) that you would like to
see identified as a site capable of contributing towards OPDCs overall housing
supply?
QH2g: Are there specific strategic sites within Old Oak and Park Royal that site
specific policies and allocations should be made for?

Policy H3 Housing Mix

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Key Issues
1. Different households require different types and sizes of housing. A wide choice of
housing broadens the appeal of an area to new residents as well as meets the areas
housing need. Within Old Oak and Park Royal an appropriate mix of housing across
all types and tenures is needed to create balanced and sustainable communities.
2. Delivering a mix of family and non-family sized housing will be important.
3. There will be a challenge in securing appropriate levels of well-designed family
accommodation as part of high density development if not carefully planned and
located.
Policy Context
National
7.23 The NPPF requires local planning authorities to plan for the delivery of a wide choice
and mix of housing based on evidence. In doing so, local planning authorities will need to
identify the size, type, tenure and range of housing that is required including the mix of
housing in particular locations and meeting affordable housing needs on site.
Regional
7.24 The London Plan states that Londoners should have a genuine choice of homes they
can afford and which meet their requirements for different sizes and types. The provision of
affordable family-sized housing has been specifically identified as a strategic need in
London.
Preferred Policy Option
a) Proposals for new housing developments should deliver a mix of dwelling types
and sizes to meet strategic and local need and support the creation of mixed,
balanced and sustainable neighbourhoods taking into consideration:
i. The housing mix identified in OPDCs draft Strategic Housing Market
Assessment (SHMA);
ii. The affordable housing component of developments should aim to achieve
the following housing mix:
Household
type
%

1 bed flat

2-bed flat

3-bed flat

4-bed flat

22%

24%

36%

17%

iii. The market housing component of developments should aim to achieve a

mix of unit sizes and in particular, family sized housing;
iv. The local character and ability of the site to accommodate a mix of housing
types and sizes; and
v. The design of proposals for new homes to be of the highest quality
delivering Lifetime Neighbourhoods and provide 90% of units as Building
Regulation M4(2) accessible and adaptable dwellings and 10% of new
housing as Building Regulation M4(3) wheelchair user dwellings across all
tenures.
Justification
7.25 OPDCs draft Strategic Housing Market Assessment (SHMA) provides evidence of
local need. When considering proposals for new residential developments, the proposed
scheme will be expected to take into account the current SHMA and any other relevant local

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data. Due regard should be given to the most up to date version of the SHMA to determine
the relevant mix.
7.26 The SHMA identifies that the greatest demand is predicted for family sized dwellings
across both market and affordable housing. Affordable housing should meet the need
identified in the above preferred policy option. For market housing, OPDCs draft SHMA
identifies a need for a range of unit sizes and in particular family sized housing. OPDC will
encourage early engagement from developers to discuss how market housing provision can
help OPDC to meet this need.
7.27 While developments are expected to reflect the identified dwelling mix, rigid
application of these may not be appropriate in every case and development proposals are
expected to take into account, site viability, location, and other constraints.
7.28 Family sized housing (which the London Plan identifies as having 3 or more
bedrooms) is better located on the lower floors of high-density development where it affords
better access to courtyards and outside space. In general, OPDC will expect family sized
units to be located on lower floors but recognises that certain locations such as town centres
or sites adjoining infrastructure may not be suitable for family sized units on the lower floors.
Where family sized units are included in schemes in these locations, they will need to be
carefully designed.
7.29 There is a need to ensure that new housing is designed to be readily adaptable and
that it will meet the differing and changing needs of households, particularly as the UKs
population is growing older. There is also a significant need in London and in the local area
for accessible housing across all tenures. To support these demographics and needs
changes, OPDC will require that 90 percent of new homes are designed to be accessible
and adaptable (Building Regulation M4(2)) and that 10 percent of new homes are fully
equipped or adaptable for wheelchair users (Building Regulations M4(3)).
Alternative Policy options
1 Allow a proportion of new housing to not comply with London Plan space
standards or Building Regulations M4(2) and M4(3)
7.30 An alternative option would be to allow a proportion of new homes to not comply with
London Plan space requirements or Building Regulations M4(2) or M4(3). This option could
deliver a more flexible range of unit types, which could offer opportunities for lower cost
market housing. However, these new homes would not be designed to meet lifetime needs
and would therefore only be appropriate for those people wanting smaller units and in areas
of high densities where smaller household units would be more appropriate.
Consultation Questions
QH3a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, should the proposed Local Plan adopt the
alternative policy option as the preferred option?
QH3b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
QH3c: Do you agree with the identified size mix for affordable housing that should be
delivered?
QH3d: Should OPDC consider identifying a proportion of housing that does not meet
the London Plan space requirements or Building Regulations M4(2) and M4(3)?
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Policy H4: Affordable Housing

Key Issues
1. There is a significant London-wide and local need for affordable housing and an
aspiration for Old Oak and Park Royal to contribute to the delivery of these affordable
homes.
2. Securing the required levels of affordable housing onsite will be a challenge in the
context of infrastructure requirements and viability.
3. Understanding of the long-term implications of the changes to affordable housing
(both its definition and funding arrangements) introduced through the Housing and
Planning Bill will continue to evolve as the Bill makes its passage through
parliament. Through its Local Plan, OPDC will be required to respond to changes
once the Bill is enacted.
Policy Context
National
7.31 The NPPF defines affordable housing as social rented, affordable rented and
intermediate housing, provided to eligible households whose needs are not met by the
market. To comply with this definition affordable housing should:
be provided to households whose needs are not met by the market;
to be provided to eligible households, where eligibility takes into account local
incomes and house prices; and
remain at an affordable price for future eligible households unless the subsidy is
recycled for alternative housing provision.
7.32 The NPPF also defines intermediate housing as that which is provided at a cost
which is above the income level at which social or affordable rented housing is required and
below the entry level for purchasing a home at lower quartile prices on the open market.
7.33 The governments recently announced Starter Homes initiative is the latest addition
to the affordable housing product range. The draft Housing and Planning Bill states that
proposals for new developments will be required to provide Starter Homes.
Regional
7.34 London Plan policies relating to affordable housing identify a target of at least 17,000
more affordable homes per year from sites with a capacity for 10 or more homes. These
policies also specify that 60% of affordable homes in London should be affordable or social
rented, and the remaining 40% should be for intermediate sale or rent.
Policy Options
7.35 There are two key factors that need to be considered when setting an affordable
housing policy:
1. What is the objectively assessed housing need i.e. what is the evidence of need for
different types of housing in the area and in London as a whole and,
2. How viable is it to deliver affordable housing based on viability assessments.
7.36 OPDC is still developing its evidence base and until the evidence is available it is not
possible to set an affordable housing policy target. OPDC will set out an evidence based
policy in the next iteration of the draft Local Plan following the completion of further evidence
work.
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7.37 While the affordable housing policy evidence and detail will develop over time, OPDC
considers that a set of clear policy principles should apply to any future affordable housing
policy. These are to:
1. Optimise affordable housing provision from developments on each site;
1. Require applicants to sign-up to the Mayoral Concordat, to market new homes in
London and the UK at the same time as abroad;
2. Secure a mix of affordable housing for a range of household income levels;
3. Achieve tenure blind developments;
4. Achieve a mix of tenures across all developments; and
5. Agree an approach for establishing nominations rights to the affordable rented
housing.
Affordable Housing policy options
7.38 As OPDCs evidence on need and viability continues to emerge, OPDC has been
considering four broad approaches that it could take when setting an affordable housing
policy for the area. OPDC invites views and comments on which of these potential policy
approaches to develop further.
Option 1 Fixing the percentage
7.39 A single OPDC wide figure is fixed for the level of affordable housing. The Mayors
draft Housing SPG supports this approach in Opportunity Areas. This fixed rate would be
subject to a regular review of viability by OPDC and this figure would need to be amended to
keep track of market changes. OPDC may also need to consider abnormal costs on specific
sites in extreme circumstances and where clearly demonstrated and justified. Comments are
invited on whether or not this option should have a review mechanism (please see questions
below). The table below sets out the strengths and weaknesses of this option.

Strengths
Helps provide certainty to developers
and land owners about the affordable
housing requirements and helps
prevent land price rises based on hope
value.
Gives a single definite target and
delivers policy compliant levels of
affordable housing over the life of a
large scheme.
Easy to define any external subsidy
required to deliver this policy
requirement.
Clear definition of obligations where
land is sold.
No need to negotiate on commuted
sums as part of negotiations
Reduces lengthy and costly
negotiations with applicants as there
would be no need for any detailed
viability assessments.

Weaknesses
The fixed AH level is dependent on the
quality of OPDC initial viability work
including estimated costs for abnormals
and infrastructure.
May require a high density to meet
identified housing needs.
Little flexibility to respond to rapid
changes in market conditions.
Could end up with less affordable
housing if market performs strongly and
if there is no review mechanism.
Not an approach that has been tried or
tested anywhere before.
The fixed percentage may have to be
set at a low rate due to initial viability.
Would require robust and regular
viability analysis by OPDC to ensure
conformity with national and regional
policies.

Option 2 Product dependent range

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7.40 A percentage range is set for each product type, recognising that some affordable
housing products are more costly to deliver than others or are more suited to different types
of developments. The table below sets out the strengths and weaknesses of this option.

Strengths
Innovative.
Clear minimum/maximum range
for negotiations.
Move away from a hard target.
Flexible enough to reflect different
development types, site
economics or local priorities.

Weaknesses
Complex to negotiate and monitor.
May not provide a mixed and
balanced sustainable community
as it could promote developments
providing only one affordable
tenure type.

Option 3 Viability tested percentage

7.41 This is the approach currently favoured by local planning authorities. A percentage
target is set but this target is still subject to viability and each individual scheme would be
viability tested to see how much affordable housing it could deliver. The table below sets out
the benefits and disbenefits of this option.
Strengths
Approach currently adopted by
local planning authorities.
This option has a proven track
record of being accepted by
Secretary of State.
Transparency reliance on
published and verifiable data
through developers viability
assessments.
Responsive to market
conditions but also to needs
as tenure and product types
could flex.
Responsive to site-specific
conditions.

Weaknesses
Does not control land price rises in
the same way as Option 1.
Could result in the level of affordable
housing secured being below the
policy target.
Time consuming and will require
costly and protracted negotiations.
No incentive for
developers/applicants to exceed set
target.
Can have sites where no or little
affordable housing is viable.

Option 4 Negotiate a target on site-specific basis

7.42 This seeks the maximum reasonable amount of affordable housing without specifying
a percentage target for each development to achieve. A review of relevant economic data at
the outset will enable an allocation of affordable housing on the site to be determined.
Strengths
No upper thresholds and could
secure high levels of affordable
housing on certain sites beyond the
levels in the London Plan.
Is a site specific approach.
A strong audit trail.
Does not require upfront or
comprehensive viability analysis.

Weaknesses
Does not provide certainty on the level
of affordable housing that will be
secured through a development.
Will not be in compliance with the
London Plan or NPPF.
Is not aspirational.
Requires long and costly negotiations
on each site.
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Relies on verifiable data.

Consultation Questions
QH4a: Do you agree with the affordable housing policy principles that would apply to
any of the four affordable housing options?
QH4b: Which of the four options do you prefer for securing affordable housing?
QH4c: Are there any strengths and weaknesses to the four options that should be
included?
QH4c: Are there any other options we should be considering as a preferred option to
the four identified?
QH4c: Should option 1 include a review mechanism?
Policy H5: Existing Housing
Key Issues
1. There are approximately 2,800 existing homes. While this is a relatively low number
given the size of the area, OPDC recognises the importance of the existing housing
as providing a suitable supply of homes for the established communities.
2. Long-term empty homes not only impact negatively on their immediate environment,
they also remove the potential to use a home in an area.
3. Empty homes are an issue that should be addressed.
Policy Context
National
7.43 The NPPF states that local planning authorities should identify and bring back into
use empty residential housing and buildings in line with local housing and empty homes
strategies. Where appropriate, it may use its compulsory purchase powers to achieve this. It
states that where there is an additional identified need for housing, planning applications for
conversions from commercial to residential use should normally be approved.
Regional
7.44 Policies in the London Plan specifically protect residential dwellings and seek to
prevent the loss of existing housing numbers, including affordable housing numbers, unless
the housing is replaced at existing or higher densities with at least an equivalent floorspace.
Preferred Policy Option
OPDC will seek to optimise the use of existing the housing stock and land through:
a. Resisting the net loss of existing housing units or floorspace through change
of use or redevelopment, except in areas of Strategic Industrial Location (SIL)
or where it is being reprovided at a higher density;
b. Work with the London Boroughs of Brent, Ealing and Hammersmith & Fulham
and other stakeholders to bring vacant residential properties back into use
(including where appropriate the use of empty dwelling management orders or
compulsory purchase powers);
c. Permit conversions of existing dwellings to two or more dwellings where:
i. at least one family sized unit is provided through each conversion with
access to amenity space;

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ii. residential conversions maintain the amenity of neighbours, the general
character of the surrounding area and do not result in cumulative stress
on services; and
iii. The proposal would not result in adverse impacts on parking and/or
other local amenities.
Justification
7.45 OPDC will refuse proposals that would result in the net loss of existing levels of
housing, except in the areas identified as Strategic Industrial Location (SIL). However,
OPDC will allow the loss of existing housing where it is to be replaced by new housing at
equivalent or higher density.
7.46 Empty homes can undermine housing supply and negatively impact on adjacent
residents and the surrounding area. The longer a dwelling remains empty the more
dilapidated it is likely to become. Once back in use, these dwellings will contribute towards
the overall supply of new homes. OPDC will work with the local authorities, landowners and
other stakeholders to bring vacant residential buildings back into use. This could include,
where necessary, using empty dwelling management orders or compulsory purchase
powers (see Delivery and Implementation chapter).
7.47 The OPDC areas existing housing stock is limited but conversions can make a
valuable contribution towards delivering new homes and increase the availability of smaller
homes. However, the potential cumulative stress from conversions of larger dwellings to
smaller homes on both the supply of family sized homes and on on-street parking provision,
waste collection and other social amenities needs to be weighed against the wider economic
benefits from such conversions and the resultant overall growth in the number of new
homes. OPDC will consider these on a case by case basis.
Alternative Policy options
1. Take a more flexible approach to the loss of existing stock
7.48 This allows for the loss of existing residential stock for non-residential uses. This may
enable greater deliverability of sites; however, proposals resulting in the loss of existing
housing without it being replaced could undermine the overall housing supply.
2. Allow the conversion of smaller family sized units and not require a proportion of
these to be replaces as family homes.
7.49 Allowing conversions of smaller family sized units without requiring their replacement
would increase the overall number of new housing supplied, but it will result in a loss of
family sized accommodation.
Consultation Questions
QH5a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, should the proposed Local Plan adopt one of the
alternative policy options as the preferred option?
QH5b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
Policy H6 - Housing in the Private Rented Sector (PRS)
Key Issues
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1. The private rented sector (PRS) accounts for approximately 25% of Londons
housing market. The sector helps meet demand for short and long-term housing as
well as providing accommodation for households unable to afford to buy their own
home or access affordable rented housing.
2. OPDC should consider how PRS can play a role in supporting the overall supply of
housing within its area whilst creating a mixed and balanced community.
Policy context
National
7.50 The government has promoted growth of a new development sector building homes
specifically for private rent.
Regional
7.51 In providing for a choice of housing, the London Plan provides positive and practical
support to sustain the PRS contribution towards increased housing delivery and meeting
housing need.
Preferred Policy Option
OPDC will require new purpose built private rented accommodation, in appropriate
locations, to:
a) Meet local and Londons strategic private rented housing needs;
b) Provide an affordable housing contribution;
c) Provide PRS for a defined period with a review mechanism or in perpetuity;
and
d) Incorporate high standards of design and provide a management strategy,
committing to high standards of ongoing management of the premises.
Justification
7.52 OPDCs draft Strategic Housing Market Assessment identifies the Private Rented
Sector (PRS) as making up approximately 30% of the housing tenure across the OPDCs
host boroughs (Brent, Ealing and Hammersmith and Fulham). The private rented sector
(PRS) plays an important role in providing homes for those choosing not to, or unable to, buy
homes or access affordable housing. It is also an important component in delivering a choice
of housing and can play an important role in early delivery and placemaking.
7.53 Historically, private rented homes have often been regarded as badly maintained
properties suffering from overcrowding, hazards, poor facilities and insecure tenancies.
However, in recent years institutional companies and investors have started to provide largescale purpose built PRS accommodation, such as at the Olympic Village in Stratford. This
accommodation is generally of a much higher standard than the majority of traditional rented
accommodation.
7.54 New PRS will need to provide affordable housing. Based on the viability analysis
there may be an opportunity to consider the type of affordable PRS product this could
include a proportion as discounted market rent. OPDC will secure a proportion of PRS
homes at below market rates for a specified period or in perpetuity, through covenants,
section 106 or other legal agreements, and in line with the affordable housing policy.
7.55 Where discounted market rent is secured as the affordable component of a PRS
scheme, we will encourage developers to offer deposit savings options for these tenants
whereby the tenant pays into a savings scheme with contributions also provided by the
developer. This would enable tenants to save towards a deposit for future homeownership.
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7.56 OPDC will encourage the retention of private rented units in perpetuity. Where, this is
not the case and PRS schemes are agreed for a defined period, then a review mechanism
will be triggered at the point at which the PRS units in a scheme convert to market sale. This
review will consider the affordable housing requirements at that time and commuted sums
for affordable housing would be made to the local planning authority.
Alternative Policy option
1 - Make it mandatory for PRS proposals to sign up to London Rental Scheme (LRS)
7.57 Having landlords sign up to the voluntary London Rental Standard (LRS) can help to
ensure a high quality standard of PRS and positively impact on the amenity of neighbouring
residents. Making it a mandatory requirement for all PRS proposals to either have in place
arrangements/agreements to professionally manage stock will mean an increase in
associated costs and could result in some smaller schemes not being delivered.
Consultation Questions
QH6a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, should the proposed Local Plan adopt the
alternative policy option as the preferred option?
QH6b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
QH6c: Should OPDC seek to have covenanted requirements for all purpose built PRS
development to be signatories of the LRS?
Policy H7 Housing with shared facilities
Key Issues
1. A house with shared facilities or a house in multiple occupation (HMO) generally
refers to a flat or house that is the main resident for three or more occupiers forming
two or more households and who share a kitchen, bathroom or toilet.
2. Hostels generally cater for a specific group or groups of occupiers, for example, long
or short-term vulnerable residents and homeless persons. Hostels may provide some
meals or welfare arrangement to the occupiers and have on site management. They
may be provided on a temporary basis, such as winter shelters for the homeless, and
by different public bodies or charities.
3. HMOs and hostels contribute to the overall supply of housing and have an important
role in helping to meet an areas housing need.
4. They can also adversely impact, especially in high concentration, on the amenity of
neighbouring properties if not properly managed and controlled.
Policy Context
National
7.58 The NPPF states that local planning authorities should deliver a wide choice of high
quality homes and shared houses, either purpose built or otherwise, are an important part of
the housing stock. Amendments, in 2010, to the Use Classes Order and the General
Permitted Development Order introduced a new class of residential development C4:
Houses in Multiple Occupation (commonly referred to as small HMOS. The Sui Generis
HMOs, which existed under the previous legislation, are now commonly referred to as large
HMOs and consist of more than six occupants.
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Regional
7.59 The London Plan recognises the strategically important role of HMOs in meeting
distinct needs and reducing pressure on other elements of the housing stock.
Preferred Policy Option
Proposals for new purpose built shared housing or for the net loss of the existing
shared housing will be considered against the following criteria:
a. Whether meets identified local need for shared housing;
b. Whether it complies with any relevant standards, including quality;
c. Whether it is located in areas with a high public transport access level and
facilities and services such as shops, social infrastructure etc.; and
d. Whether it gives rise to unacceptable impacts on amenity.
Justification
7.60 Shared housing can play an important role in providing accommodation and meeting
the housing need of individuals unable to access self-contained affordable or market rented
housing.
7.61 Where HMOs are not carefully managed and if there is an overconcentration of
HMOs in a location, they can negatively impact on the amenity of that location. Where
evidence suggests this to be the case, OPDC will consider proposals to either improve the
accommodations standard or accept its loss to an alternative housing use.
7.62 New HMOs or hostels should be located in areas that can absorb the more intensive
occupancy rates by individuals living as separate households and sharing a property. In
addition, proposals for HMOs or hostels need to be accompanied by information setting out
how arrangements will effectively manage the scheme.
Alternative Policy options
1. Encourage the conversion or loss of shared housing without replacing it.
7.63 This approach would be more responsive to market needs, but encouraging the loss
of shared housing would remove this form of housing from the overall affordable housing
supply. This may result in greater pressure on other forms of affordable housing.
Consultation Questions
QH7a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, should the proposed Local Plan adopt the
alternative policy option as the preferred option?
QH7b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
Policy H8 Specialist housing for older people and/or vulnerable people
Key Issues
1. There is an increasing need for specialist housing for older people and vulnerable
people.
2. The scale of regeneration in the OPDC area provides opportunities to meet this
need.

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3. Providing these types of specialist housing in new high density buildings will require
careful planning, design and location to ensure future residents needs are accounted
for and they are integrated into the new development.
Policy Context
National
7.64 The NPPF identifies the need for local planning authorities to plan for a wide choice
of housing, including housing for older people.
Regional
7.65 Policies in the London Plan require specific account to be taken of the housing needs
of older persons in the design of developments and when assessing older peoples housing
needs. Local planning authorities are required to identify and develop plans and strategies
for other supported housing needs. In doing so, the long and short-term supported housing
needs of vulnerable and disadvantaged groups should be assessed.
Preferred Policy Option
a) OPDC will require an appropriate supply of specialist care and supported
needs housing for older people and/or vulnerable people to live as
independently as possible.
b) OPDC will require proposals to be:
i.
suitable for the intended occupiers in terms of the standard of facilities,
the level of independence, the provision of support or care and be
accompanied by relevant management policies;
ii.
of an appropriate mix of sizes to meet needs;
iii.
of a high design quality, including inclusive design and provision of
adequate internal and external space; and
iv.
accessible to public transport, shops, services, community facilities and
social networks appropriate to the needs of the intended occupiers.
c) In the case of market-led development aimed at older people and/or vulnerable
people, particularly where self-contained units are included, contributions to
the supply of affordable specialist housing will be required.
Justification
7.66 The London Strategic Housing Market Assessment 2013 identified a net strategic
requirement for between 3,600 and 4,200 new older persons housing units per year between
2015 and 2025. OPDCs draft SHMA identifies that specialist housing needs from the local
area (Brent, Ealing and Hammersmith and Fulham) will increase by more than 400 persons
per annum over the 20 year period.
7.67 OPDC will support proposals for specialist housing where it contributes to the mix of
an area and is delivered through partnerships (arrangements between developer and
support service provider) and will have arrangements in place for the long-term management
of the development/scheme.
7.68 OPDC will support proposals that enable older people to live in their homes for as
long as they want and to then move to supported living when they require greater support to
remain independent. Proposals for new older people housing will need to be available at a
range of costs to suit a range of financial circumstances. As such developments should
contain a proportion of affordable units for older people.
Alternative Policy options

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7.69 No alternative policy option is considered since the proposed policy is consistent with
national and regional policy to deliver a wide choice of good quality homes that meet the
housing needs of older people and vulnerable people. The NPPF requires local planning
authorities to plan for a mix of housing and this policy is in line with this national planning
policy.
Consultation Questions
QH8a: Do you agree with the preferred policy option? If not, what might you change
about the preferred policy?
QH8b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
Policy H9 - Gypsy and Traveller Accommodation
Key Issues
1. OPDC needs to ensure that it has effective plans to meet the distinct accommodation
needs of gypsies and travellers.
2. The authorised site in the London Borough of Ealing falls within OPDCs boundaries
and the pitches on it meet the needs of the existing community.
3. OPDC will need to plan for the existing pitches located at this site and consider
whether there is any additional need for pitches in the OPDC area.
Policy Context
National
7.70 Planning policy for traveller sites (August 2015) states that local planning authorities
should:
make their own assessment of need (in respect of traveller sites);
work jointly with other local planning authorities to develop plans through
identifying land for sites;
plan for sites over a reasonable timescale;
reduce unauthorised developments and encampments and make
enforcement more effective;
ensure that access to education, health, welfare and employment is facilitated
by the provision of suitable accommodation; and
have due regard to the protection of local amenity and local environment.
Regional
7.71 The London Plan states that local planning authorities should identify and address
the accommodation requirements of gypsies and travellers (including travelling show
people).
Preferred Policy Option
a. OPDC will give careful consideration to the needs of gypsies and travellers and
work with the London Boroughs of Brent, Ealing and Hammersmith & Fulham to
secure a sufficient supply of plots/pitches to meet the needs of existing and future
gypsy and traveller households (including travelling show people);
b. Where OPDCs Gypsy and Traveller Accommodation Needs Assessment study
determines a need for provision of pitches on an additional site OPDC will work
with the London Boroughs of Brent, Ealing and Hammersmith & Fulham to identify
a suitable site. Any new sites, pitches and/or plots for travellers should:
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i.
ii.
iii.

Be accessible to transport (including safe access to/from the main road

network), services and facilities, and be capable of being supported by
the local social infrastructure;
Be capable of connecting to the utilities infrastructure; and
Support the health and wellbeing of the occupiers of the site by
providing appropriate facilities, layout and design quality.

Justification
7.72 There is currently one authorised site in the London Borough of Ealing, which falls
within OPDCs area. OPDC has commissioned a Gypsy and Traveller Accommodation
Needs Assessment (GTANA) in order to provide it with an evidence base. The assessment
will identify the need for pitch provision during the plan period and inform the development of
a strategy to meet the identified need. As this work is in progress, outputs from it will inform
the next iteration of the draft Local Plan gypsy and traveller accommodation policy.
7.73 Historical data shows a sufficient level of churn at the existing site, which should
enable this site to continue to meet any need arising in the short/medium term. Where
evidence of additional need emerges, OPDC will work with the three local boroughs to meet
the additional identified need and identify a suitable alternative site in line with the
requirements of this preferred policy option.
Alternative Policy options
7.74 No alternative policy option has been considered, as national policy requires local
planning authorities to meet the needs of gypsy and travellers within its area as part of its
objectively assessed need and 5-year supply.
Consultation Questions
QH9a: Do you agree with the preferred policy option? If not, what might you change
about the preferred policy?
QH9b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
Policy H10 Student Housing
Key issues
1. London is home to some of the worlds finest universities. They are important assets
for the city and the UK. Suitable and affordable student accommodation plays a
major role in the university experience. Well-designed and purpose built student
accommodation, managed effectively and in the right location not only provides a
place to live and study but also relieves pressure from the private housing market.
2. OPDC needs to work with these universities, as well as specialist student
accommodation providers to support the supply of new well-managed, purpose built
student accommodation.
Policy Context
National
7.75 The NPPF require local planning authorities to plan for a choice of housing, creating
sustainable, inclusive and mixed communities.
Regional
7.76 London Plan policies require local planning authorities to address l student
accommodation needs.
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Preferred Policy Option

a) Student housing will be supported where it:
i.
Results in no net loss of conventional housing supply, especially selfcontained homes;
ii.
Does not lead to an over-concentration of student housing in a particular
location;
iii.
Does not have an unacceptable impact on the immediate and surrounding
areas and residential amenities; and
iv.
is located in areas with high PTAL or is easily accessible by non-motorised
forms of transport.
b) Proposals must include:
i.
Management and maintenance plans demonstrating how the amenity of
neighbouring residents will be protected; and
ii.
What steps would be taken to minimise impacts on neighbouring uses
c) Where the proposal is not linked to a specified educational institution it will need
to provide the maximum reasonable amount of affordable student housing.
Justification
7.77 The Mayors Academic forum has provided projections for the growth of full time
students in London from 2011/12 to 2026/27 and the required additional purpose-built
student accommodation that this growth generates. These projections estimate that by
2026/27 Londons current student population of just over 365,000 will have increased to
between 429,391 and 487,317.
7.78 OPDC recognises the many positive benefits that universities/higher education
institutions and their students bring to London. Both enhance an areas reputation as a
dynamic and vibrant location, create a critical mass for the delivery or goods, services and
events, provide local businesses with skilled workers and seasonal workers and can aid
regeneration and investment.
7.79 To achieve mixed and balanced communities, provision of purpose built student
accommodation will be supported but it must not result in an over-concentration in any one
particular location. This will avoid issues of:
not achieving a mix and variety of housing in a location;
overconcentration of one form of dwelling type;
directly related noise and management concerns;
vacant premises at particular times of the year; and
pressure on the transport infrastructure at particular times of the year (end/start of
terms).
7.80 Proposals for student accommodation will be required to be of high quality in relation
to design and size. Student housing proposals should also make an appropriate contribution
to affordable housing, subject to viability.
7.81 Proposals for student housing should be located in or close to transport nodes so
that students can easily access public transport, workplaces and services. Developments
located close to transport nodes will also support with the movement of students especially
during the start and end of terms.

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7.82 OPDC will expect proposals to be accompanied by management plans setting out
how any impact on the surrounding area and the amenity of the neighbouring residents will
be mitigated. These plans must provide details of the management regime to be
implemented on site, from first occupation and on an ongoing basis and include details of
arrangements for move-in and move-out dates around academic terms.
Alternative Policy options
1.
Require student housing proposals to be linked to specified educational
institutions
7.83 While this may provide the required level of affordable student accommodation and
the management policies of the educational institution will ensure that the development is
appropriately managed, it may not enable the future flexible use of the accommodation.
Consultation Questions
QH10a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, should the proposed Local Plan adopt the
alternative policy option as the preferred option?
QH10b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
QH10c: should OPDC seek to restrict new development of student housing in certain
locations?

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8. EMPLOYMENT
This chapter contains policies addressing the following policy themes:
E1: Strategic Policy for employment
E2: Old Oak
E3: Park Royal
E4: Open workspaces
E5: Local access to employment and training
Consultation Question

QEa: Are there any other employment policy themes that you think OPDCs Local Plan
should be addressing?

Evidence base
Study
OPDC Industrial Land
Review
OPDC Development
Capacity Study (DCS)
GLA Creating Open
workspaces document

Scope
Assesses the current and future supply
and demand for industrial land within Old
Oak and Park Royal.
A study assessing the development
capacity of development plots within the
OPDC area
Assesses London-wide demand and
opportunities with recommendations for
local planning policy in relation to nontraditional workspaces for micro, small and
medium enterprises.

Status
Draft
completed
Draft
completed
Completed

Policy E1: Strategic Policy for employment

Key issues
1. To secure benefits generated by the huge increase in accessibility, as a result of the
arrival of a new HS2, Crossrail and Great West Coast Main Line station, there will be a
need to release Strategic Industrial Location (SIL) designation in Old Oak to support a
mixed use approach to development and optimise the delivery of a range of employment
workspace typologies. This needs to be considered against Londons and west Londons
release of industrial land which is greater than envisaged by the GLA 2011
benchmarking exercise.
Policy Framework
National
8.1 The NPPF sets out a number of requirements for Local Plans including setting a clear
economic vision and strategy that encourages sustainable economic growth which is
supported by flexible policies that meet the development needs of existing and new business
sectors.
Regional
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8.2 The London Plan seeks to maximise the benefits from new infrastructure to secure
sustainable growth and development. It supports office based employment by focusing new
development in viable locations with good public transport. It also states that how
development in and adjacent to SIL should be planned and managed to support the
continued functioning of SIL.
8.3 The London Plan alongside the Old Oak & Park Royal OAPF (2015) identify the principle
of SIL being consolidated and intensified at Park Royal to both ensure its continued
protection and accommodation of 10,000 new jobs and for non-industrial employment uses
to be provided in Old Oak to deliver approximately 55,000 new jobs.
Preferred Policy Option:
OPDC will work with stakeholders to deliver a sustainable and robust local economy
that promotes Old Oak and Park Royal as a place for enterprise and innovation and
which contributes to Londons economic growth. This will be achieved by:
a)
b)
c)

establishing Old Oak as a recognised commercial hub;

consolidating Strategic Industrial Location (SIL) at Park Royal;
supporting proposals that deliver economic growth by:
i.
contributing to delivering a range of employment uses in areas outside
of SIL to support the delivery of 55,000 new jobs; and
ii.
contributing to delivering a range of industrial uses within Park Royals
SIL and the areas intensification to accommodate 10,000 new jobs.

Justification
8.4 Old Oak and Park Royal have a long history of economic innovation and growth that has
shaped the surrounding areas and London as a whole. The area is the UKs largest and
most successful industrial location and it plays a fundamental role in supporting the
functioning of London.
8.5 The regeneration opportunities presented by the arrival of High Speed 2 and Crossrail at
Old Oak should continue to support this legacy of employment and innovation that benefits
the local area, west London and London as a whole. To support this opportunity, the London
Plan, Old Oak & Park Royal Opportunity Area Planning Framework and OPDC Development
Capacity Study (DCS) identify that Old Oak has the potential to deliver space for 55,000 new
jobs and has the potential through intensification to deliver 10,000 new jobs. To facilitate
this, land currently designated as SIL in Old Oak should be de-designated as SIL to enable
mixed use development. The main employment hub should be focused close to the new Old
Oak Common Station, which will benefit from high levels of public transport accessibility. In
other areas of Old Oak, a more varied and mixed type of employment space will be
encouraged to support micro, small and medium business growth.
8.6 Old Oak and Park Royal currently has a diverse economic profile, with 1,500 business
units employing an estimated 36,000 people. In total there is approximately 2,100,000sqm of
employment floorspace on 355 hectares of employment sites within SIL across the area. It
provides much needed employment to the surrounding areas and west London, while
supplying diverse goods and services to businesses and inhabitants across the local area,
west London and the capital.
8.7 This diverse range of sectors forms a patchwork across Old Oak and Park Royal with
some sectors having a greater presence. These are:
logistics;
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prop houses and film studios;

food manufacturing and wholesale; and
vehicle sale and repair.

8.8 Businesses occupy a range of different space typologies and sizes, from small
workshops to large warehouses.
8.9 OPDC must consider how to accommodate and support new and existing economic
sectors as they grow and develop as well as retain those which are successful. Today, it is
not possible to define exactly what future sectors may seek to locate here. However, sectors
which comprise the Innovation Economy could be a significant element of this. These
sectors include clean technology, applied sciences, life sciences, niche manufacturing,
creative industries, film and screen, circular economy and other digital and innovation
technology based industries. OPDC will support and promote measures to grow existing and
new employment clusters with employment-generating potential to enhance the areas
economic profile and performance and act as a magnet to draw further investment into the
area.
8.10 OPDC is exploring what these sectors could be and what their spatial and design
requirements are to inform the next stage of consultation on the draft Local Plan.
Alternative Policy Options
8.11 Alternative policy options are not considered to be realistic given that strategic guidance
is set out in national and regional policy frameworks.
Consultation Questions
QE1a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy?
QE1b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
QE1c: What types of employment uses should OPDC seek to attract to the area and
what are the specific requirements of these sectors?
Policy E2: Old Oak
Key issues
1. The London Plan identifies Old Oak as having the potential to accommodate 55,000
new jobs in response to new strategic transport infrastructure. The Old Oak and Park
Royal OAPF suggests that these jobs will be across a range of sectors including a
significant amount of new commercial and town centre uses. This will require the
release of Strategic Industrial Location to accommodate this growth.
2. Due to the timescales of the development, policies need to be able to accommodate
a range of potential employment sectors as demand for workspace increases.
3. Employment floorspace typologies need to be both flexible and located to support a
mixed and vibrant place.
4. There are a range of proposed uses in Old Oak that may benefit from the co-location
of non-residential floorspace, to act as a buffer and mitigate environmental impacts of
existing and future infrastructure.
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Policy Framework
National
8.12 The NPPF requires Local Plans to support existing business sectors and plan for new
or emerging sectors.
Regional
8.13 For industrial areas, the London Plan interprets this guidance to focus new office
development on viable locations with good public transport access. The London Plan
specifically identifies Old Oak as having capacity to accommodate 55,000 new jobs.
Preferred Policy Option:
Old Oak will become a mixed employment hub by requiring proposals to provide:
a) a new commercial area and a range of flexible open workspace
typologies in locations identified in the Overarching Spatial Policies and
Places Chapters; and
b) town centre uses which generate employment along the High Street, in
and around Old Oak Common Station and in other accessible locations.
Justification
8.14 The London Plan identifies Old Oak as having the potential to deliver 55,000 new jobs
in response to new strategic transport infrastructure. The Old Oak and Park Royal OAPF
suggests that these jobs will be largely commercial based along with a smaller proportion of
other town centre uses such as retail, leisure, culture and community uses. Future
employment sectors attracted to Old Oak will change over time. It is therefore important to
retain flexibility in their design and management. However, OPDC will expand on these
possible sectors in the next version of the draft Local Plan. A new commercial hub including
a significant proportion of the areas new office and commercial employment would be
focused on and around Old Oak Common Station. The station is due to open in 2026 and
sites around the station are only likely to be available for development near to this point.
8.15 Outside of the commercial hub, OPDC will strongly encourage a more varied and
flexible commercial offer as part of mixed use development. These areas can provide much
needed space for micro, small and medium enterprises, including open workspaces (see
policy E4). These spaces are typically smaller than those located within the new commercial
hub and as such can offer greater choice for businesses and encourage a more varied
economic offer.
8.16 Light industrial uses can make use of spaces not suited to other uses. There will be a
significant amount of transport infrastructure retained in Old Oak where such uses could act
as a buffer to more sensitive residential and community uses. Light industrial uses can also
contribute to local distinctiveness and a unique character of an area. Fish Island, on the
edge of the Queen Elizabeth Olympic Park provides a strong case study for the role these
spaces can play in contributing to the identity of an area.
8.17 North Acton has the potential to deliver new town centre employment floorspace that
will contribute to a sense of place and activation of the local area.
Alternative policy options
1. Support for focusing B1(a) uses in and around Old Oak Common Station is not
provided

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8.18 The benefit of this approach would be the provision of a more flexible approach to office
distribution across Old Oak. The disadvantage would be that the commercial centre around
Old Oak Common Station could become less defined leading to the location of office space
in less accessible locations.
2. Support for B1(b) and B1(c) uses in Old Oak north is not provided
8.19 The benefit of this approach would be that additional floorspace is provided for nonindustrial uses. The disadvantage would be that locations not suited to retail, office, leisure
or residential uses could remain vacant and negatively impact on the amenity of the public
realm.
Consultation Questions
QE2a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, should the proposed Local Plan adopt one of the
alternative policy options as the preferred option?
QE2b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
Policy E3: Park Royal
Key issues
1. The draft OPDC Industrial Land Review (2015) has identified that the rate of release of
industrial land in west London boroughs has been higher than the annual target
envisaged by the 2011 GLA benchmarking process. This is creating pressure on existing
industrial locations, including Park Royal, to accommodate industrial uses. The release
of SIL will place further pressures on industrial land requirements at Park Royal.
2. The impact of the transformative regeneration at Old Oak will need to be managed to
secure benefits for Park Royal and address issues created by this change.
3. The impact of the construction and future operation of development at Old Oak needs to
be carefully managed to support the operation of Park Royal.
4. The Park Royal Business Group has identified that Park Royal lacks uses which support
the industrial businesses in the estate.
Policy Framework
National
8.20 The NPPF requires Local Plans to support existing business sectors and plan for new
or emerging sectors.
Regional
8.21 For industrial areas, the London Plan policies interpret national guidance to promote,
manage and where appropriate, protect Strategic Industrial Locations (SIL). For planning
decisions it sets out a series of criteria that supports the delivery of broad industrial type
uses, SME or new emerging industrial sectors workspace or small scale walk to services
for industrial occupiers within SIL. The London Plan requires that uses in or adjacent to SIL
should not compromise the integrity and effectiveness of these locations to accommodate
industrial type activities.

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8.22 The London Plan also identifies two types of SIL. These and the broad industrial type
activities are:
SIL type
PIL Preferred Industrial
Location

IBP Industrial Business Park

Broad industrial type activities

General industrial, light industrial, storage and
distribution, waste management, recycling, some
transport related functions, utilities, wholesale markets
and other industrial related activities.
Activities that need better quality surroundings
including research and development, light industrial
and higher value general industrial, some waste
management, utility and transport functions, wholesale
markets and small scale distribution.

Preferred Policy Option:

Park Royal Strategic Industrial Locations (SIL) will be retained and where possible
enhanced by:
a) protecting existing SIL;
b) requiring proposals for uses adjacent to SIL to robustly demonstrate
how the use and design will continue to facilitate the integrity and
effectiveness of industrial activities within SIL;
c) designating the following sites as new SIL:
i. Matthew Park (B6.29);
ii. Central Park (B6.31);
iii. Corner of Acton Lane and Park Royal Road (E2.05b);
iv. Vacant land on Western Road (E3.19); and
v. The Courtyard Estate (E4.26).
d) intensifying the use of land by requiring proposals to demonstrate how
they are maximising the use of sites, including the provision of smaller
units, to support greater employment densities; and
e) supporting appropriate town centre uses in the Park Royal Centre
outside of SIL.
Justification
8.23 Park Royal forms an important function as a reservoir of industrial land in west London.
London needs such reservoirs to function efficiently and supply the population and other
businesses with goods and services, while also accommodating any future manufacturing
activity that needs to remain in the capital. With the release of industrial land occurring at a
greater rate than previously expected, OPDC will work with the GLA, west London boroughs
and other relevant stakeholders to help manage the supply of industrial land across the subregion and London.
8.24 SIL is suitable for a wide range of industrial uses, but what sets SIL in Park Royal apart
is its size and location. It is one of the few areas of Londons industrial reservoir that can
accommodate uses which can lead to land use conflicts elsewhere. This includes land for
waste, utilities and transport but also industrial activities operating 24 hours a day and
creating industrial noise. These features are one of Park Royals most important land use
assets and one of the keys to its success.

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8.25 In demonstrating how uses adjacent to SIL will not negatively impact on uses within the
SIL, proposals should define how the uses, design and layout will ensure that impacts on
building occupant amenity and the road network would be managed.
8.26 OPDC will use its planning enforcement powers to ensure the SIL can continue to
operate effectively.
8.27 To help promote the industrial role of Park Royal, ancillary uses within a multifunctional
space can play a key role in supporting existing businesses and future industrial uses. These
uses may include ancillary retail, meeting, eating and drinking spaces alongside shared
services that industrial units may not be able to accommodate but can provide a valuable
service for businesses and employees.
8.28 Applicants will be expected to demonstrate how these proposals have been optimised
to include a range of unit sizes that cater to a diverse range of industrial uses including those
requiring open workspaces. This will provide accommodation for a broad range of
businesses that require diverse unit types, sizes and rental or tenure conditions.
8.29 While the market can play a key role in determining the form and mix of industrial
property development, the decreasing levels of SIL across London means that OPDC needs
to ensure that the remaining stock of land is used as efficiently as possible. Development
proposals should set out how more intensive forms of development with more industrial
floorspace and higher plot ratios have been considered, ensuring this happens on each plot.
This process may include considering multi-storey warehousing, delivering a range of unit
typologies for open workspaces (including small units of less than 250sqm to meet London
wide demand) and demonstrating how adjacent site owners have coordinated development
proposals and/or considered the potential for sharing services. OPDC will be exploring
whether it can play a more active role in delivering this aspiration.
8.30 New sites proposed for inclusion within SIL have been subject to a thorough analysis to
consider their appropriateness to be included within SIL. For each site this analysis is set out
below. Further information on this is included in the draft Industrial Land Review.
Site
Matthew Park
(B6.29)

Central Park
(B6.31)

Corner of Acton
Lane and Park
Royal Road
(E2.05b)
Vacant land on
Western Road
(E3.19)

Reasoning for designation

1 Currently in industrial use;
2 Abutting existing industrial uses (site B6.31) recommended to be
designated as a SIL;
3 Located adjacent to SIL designation to the north and east; and
4 Addressing incomplete SIL designation. Industrial warehousing
designated as a SIL but supporting loading area not currently
designated.
1 Currently in industrial use;
2 Abutting existing industrial uses (site B6.29) recommended to be
designated as a SIL;
3 Located adjacent to SIL designation to the south east; and
4 Addressing incomplete SIL designation. Only a portion of industrial
warehousing and loading areas on site designated as a SIL.
1 Abutting existing SIL designation to the east, south and west.

1
2

Currently in industrial use with walk to uses serving the business

community facing Acton Way and Park Royal Road; and
Abutting existing SIL designation to the east and south.
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The Courtyard
Estate (E4.26)

Currently in industrial use and located adjacent to SIL designation

to the east.

8.31 It is envisaged that further detailed guidance for Park Royal will be provided within a
Park Royal Supplementary Planning Document.
8.32 The Park Royal Centre will play an important role as a neighbourhood town centre in
delivering uses which support the functioning of the wider Park Royal area and in delivering
open workspace typologies. Further information is provided in preferred policy option P6.
Alternative policy options
1. SIL boundary is not extended
8.33 The benefit of this approach would be sites could deliver non-industrial uses which
support the functioning of SIL. However, not designating sites considered to be appropriate
for SIL could be considered as a lost opportunity to help support the continued success of
Park Royal.
2. Additional land in Park Royal is released, such as the High Speed 2
construction work sites north and south of the canal, to accommodate other
forms of development
8.34 The benefit of this approach would be that additional development capacity is delivered.
The disadvantage is that further pressure on industrial land capacity is created and it would
threaten the future success of Park Royal.
Consultation Questions
QE3a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, should the proposed Local Plan adopt one of the
alternative policy options as the preferred option?
QE3b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
QE3c: Are there different parts of Park Royal that you consider could accommodate
different types of uses appropriate to SIL that reflects local character?

Policy E4: Open workspaces

Key issues
1. The London Enterprise Panel recognises that SMEs contain much of Londons future
innovation, enterprise and growth but it is becoming increasingly hard to find
business premises at affordable rates. The draft OPDC Industrial Land Review also
concludes that industrial workspace developers tend to build speculative units that
are targeted at medium and larger businesses rather than micro or small businesses.
As such, a key issue is that the delivery of appropriate floorspace for SMEs is
necessary but difficult to secure.
2. The management, design, flexibility and affordability of these spaces can present a
challenge to traditional employment space developers.

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3. There are a range of difference economic sectors comprising micro, small and
medium enterprises that could play a very positive role in contributing to economic
growth and placemaking. These are broad ranging and include digital, creative,
cultural, life sciences, applied sciences, clean, green and low carbon technology and
the circular economy. OPDC will need to develop a strategy for how to attract and
support these growing sectors to locate to Old Oak and Park Royal.
Policy Framework
National
8.35 The NPPF requires Local Plans to support existing business sectors and plan for new
or emerging sectors.
Regional
8.36 London Plan interprets this guidance by identifying the need to ensure the availability
of sufficient and suitable workspaces in terms of type, size and cost, supporting
infrastructure and suitable environments for larger employers and small and medium
enterprises, including the voluntary and community sectors.
8.37 London Plan policy on new and emerging economic sectors highlights the need to
support the evolution of Londons science, technology, media and telecommunications
sector, promote clusters such as Tech City and Med City ensuring the availability of suitable
workspaces.
Preferred Policy Option:
Proposals for open workspace typologies will be supported by:
a) protecting and/or enhancing existing viable open workspace typologies where
they make maximum use of their site and contribute to the wider regeneration
of the OPDC area;
b) requiring proposals for major commercial development to deliver affordable
workspace;
c) supporting proposals for open workspaces typologies where they are
demonstrated to be:
i. appropriately located and designed;
ii. viable for nurturing and stimulating entrepreneurial activity, in
particular in future growth sectors;
iii. informed by the business needs of open workspace providers and
the requirements of relevant small business sectors;
iv. appropriately managed by a registered workspace provider, or
supported by a Management Scheme, and agreed through Section
106 agreements; and
v. not resulting in a net loss of employment land or floorspace;
d) exploring mechanisms to deliver open workspaces in accordance with OPDC
regeneration priorities.
Proposals for temporary employment floorspace will be encouraged where it:
e) contributes to the vitality, character and activation of an area;

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f) contributes to establishing and/or growing business sector clusters that
make a positive contribution to the economic and social regeneration of the
area;
g) provides open workspace typologies; and
h) demonstrates how it would complement the longer term comprehensive
regeneration of the area.
Justification
8.38 The GLAs Creating Open Workspaces document (2015) shows how Open
workspaces to be designed and managed to support small, medium and micro enterprises.
These typologies are usually flexible, with shared facilities and low-cost or managed
workspaces and can include office space with flexible rental terms, co-working spaces,
incubator spaces, accelerator spaces, creative/artist spaces and makerspaces. They tend to
be flexible and affordable and are ideally managed by an appropriate workspace provider.
Other low threshold enterprise space can have similar characteristics and provide some of
the benefits of open workspaces for small businesses, as identified in the GLA
Accommodating Growth in Town Centres (2014) report. Existing examples can be seen at
Birminghams Custard Factory in Digbeth, Impact Hub in Westminster and Acme Studios in
Southwark. Lease agreements between developers, workspace providers and tenants are
key to the successful delivery of effective workspaces.
8.39 Affordable workspaces will be required to meet need for workspaces for a range of
growth sectors provided at sub-market levels. As such, any proposals for major commercial
development should demonstrate how they will deliver viable and sustainable affordable
workspace.
8.40 OPDC will be exploring what spatial, design and management requirements are
needed to be delivered in the Local Plan open workspace typologies. This will be undertaken
as part of the evidence base to inform development of OPDCs Socio-economic
Regeneration Strategy and other Local Plan evidence base to inform the next draft of the
Local Plan.
8.41 99% of the business units in the OPDC area are micro, small and medium sized,
employing 76% of the workforce. 56% of these are micro with less than 10 people; they
make up only 10% of the workforce. Businesses occupy a range of different space
typologies and sizes, from small workshops to large warehouses. As such, where existing
workspaces meet with the criteria in Policy E4c) it is proposed that they should be protected.
8.42 To support continued economic innovation and diversity in Old Oak and Park Royal,
innovative design, delivery and management of open workspaces for start-up businesses
needs to be supported in the regeneration of the area. Existing open workspace typologies
will be supported where they positively contribute to the wider regeneration of the area and
are demonstrated to be viable. Proposals for these typologies will be supported and/or
informed by the business needs and design requirements of relevant workspace providers.
8.43 Temporary employment uses, otherwise known as meanwhile or pop-up uses, can play
a key role in helping to generate a sense of place and activation of an area during the
transformation phases and enabling new entrepreneurs to test their business ideas. Kings
Cross has seen the use of a diverse range of temporary uses successfully drawing people
into the area and generating interest before development is completed. These uses include
the Kings Cross Pond and the Floating Cinema alongside numerous events. Temporary
uses may be in the form of open workspace or traditional typologies. Existing examples
include Pop Brixton and the forthcoming Peckham Levels.
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8.44 Within Old Oak, the long-term development timescales provide the opportunity for
temporary employment uses to be located within the area and provide critical space for
emerging sectors, specifically those generated by higher education establishments.
Consideration will need to be given to the potential impact of these uses on the wider
regeneration of the area and the impact on existing uses and residents. Major proposals
should be accompanied by a meanwhile strategy to demonstrate how they accord with policy
requirements (see Policy OSP5, chapter 3).
Alternative policy options
1. Delivery of onsite open workspace is required for residential and/or commercial
proposals.
8.45 To help further ensure that open workspace typologies for small, medium and micro
enterprises, this option would require all proposals for residential and/or employment
proposals to deliver onsite open workspace. The advantage of this option would be to
provide a large quantum and range of employment workspace and support a diverse local
economy. The disadvantage would be that low quality spaces may be produced and would
be burdensome for smaller developments. Provision of such spaces without an appropriate
market needs assessment may result in high vacancy rates which may have a negative
impact on placemaking and perceptions of community safety.
2. Delivery of small-scale workspaces is supported with coordinated delivery of
rented small-scale residential units outside of the SIL.
8.46 To support the delivery and operation of small-scale workspaces, these spaces could
be linked with the use of rented small-scale residential units for occupiers within Old Oak.
This would be secured through S106 agreements and other management arrangements.
The advantage of this option would be that development would support start-up businesses
to be established and would support the delivery of a range of housing typologies meeting
potential need. The disadvantage would be the risk that if one of the employment or housing
units is vacant, the related joined unit would also be vacant and increase overall vacancy
rates.
Consultation Questions
QE4a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, should the proposed Local Plan adopt one of the
alternative policy options as the preferred option?
QE4b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
QE4c: Are there any other open workspace typologies that the policy should
consider?
QE4d: Should existing open workspace typologies be protected?
QE4e: Where should open workspaces be located?
QE4f: What are the requirements for the development to deliver open workspaces?
QE4g: Should policies seek the provision of affordable workspace for all new
development?
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Policy E5: Local access to employment and training

Key issue
1. Some of the areas to the north and south of the OPDC area are shown to be in the 10%
most deprived locations in the country. OPDC needs to work with partners to ensure that
local people, especially those in deprived locations, are able to access opportunities to
improve their skills, training, qualifications and gain employment generated by the
regeneration of Old Oak and Park Royal.
Policy Framework
National
8.47 The NPPF sets out a commitment to secure economic growth in order to create jobs
and prosperity.
Regional
8.48 London Plan policies support this aspiration with the Mayor committing to ensuring
equal life chances for all Londoners alongside seeking to co-ordinate initiatives to improve
employment opportunities and remove barriers to employment and progression.
Preferred Policy Option:
a) OPDC will maximise access to employment, skills training, apprenticeships
and pre-employment support that responds to changing labour market
conditions and employer demand by:
i.

ii.

promoting the benefits of responsible business by giving developers

and employers information and tools to recruit a local talent pool and
source local firms to fulfil their business needs; and
working with partners and relevant stakeholders to deliver a
coordinated, demand-led training and employment offer and effective
pathways for local people into sustainable jobs and higher paid work.

b) Development proposals will be required to include a Local Employment and

Training Agreement setting out how they will meet OPDCs socio-economic
regeneration priorities.
Justification
8.49 Getting more local people into sustained employment is key to the successful
regeneration of Old Oak and Park Royal, so maximising access to local employment and
training is a key priority for OPDC. OPDC intends to play an active role in implementing and
coordinating initiatives to secure employment, training and apprenticeships through its own
activities, through development proposals, and through partnership working with the
boroughs and employment and skills providers.
8.50 Some of the areas to the north and south of the OPDC area are shown to be in the 10%
most deprived locations within the country, with local communities experiencing high levels
of worklessness and children in poverty. Employment uses and associated education and
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training opportunities can play a fundamental role in addressing socio-economic deprivation
and poverty. Having a job is also a key determinant of health and well-being. As such, it will
be important that local employment and training opportunities are maximised to ensure that
they support community development and help to contribute to a robust local economy.
8.51 In order to ensure that this new part of London becomes a well-connected and inclusive
part of the city that is linked into surrounding neighbourhoods, it will be vital that change is
planned so that local people (including existing and future residents and businesses) will be
able to benefit from the opportunities that will come forward. OPDC will support a range of
jobs, skills, apprenticeship and enterprise interventions that will equip local people to be able
to compete in the economy of the future, that add value to existing provision in the three
boroughs and that contribute to wider west London sub-regional provision.
8.52 An informed and skilled local community can provide the local labour force that existing
and new employers need to help grow their businesses. There is an opportunity to enable
local residents to secure work closer to where they live which in turn will generate wealth
and contribute to the development of a robust and sustainable local economy.
8.53 To ensure proposals for major developments are meeting OPDCs socio-economic
regeneration priorities, the Local Employment and Training Agreement should set out
development employment forecasts, proposed targets for employing a local labour force;
demonstrating how they will proactively seek to employ women, Black and Minority Ethnic
(BAME) groups, Disabled people and ex-offenders; provide apprenticeship and skills training
opportunities; and include a commitment to advertise construction and end use job
vacancies locally in local labour and business schemes and job centres; and pay employees
the living wage.
8.54 In delivering its own regeneration priorities, OPDC is currently envisaging undertaking
the following:
Brokering training, apprenticeship and jobs with employers, contractors, public,
private and third sectors to link local young people and adults into training and
sustainable jobs;
Working with schools, the further education (FE) and higher education (HE) sector,
and businesses to deliver a high quality educational offer that responds to employers
needs, raises young peoples aspirations and provides them with the knowledge and
skills that they will need to compete effectively within a world city, whatever their
chosen career; and
Using its procurement of works and services to promote local employment, training
and apprenticeships and encourage supplier diversity and SME involvement in
supply chains.
8.55 OPDC will work with partners and stakeholders, including:
HS2, other transport bodies and their supply chains and end use employers to share
labour forecasting data on construction and end-use requirements to help plan for
local employment and skills offers;
developing with partners, demand-led, localised employment and training initiatives,
including brokerage schemes so that employers are able to benefit from a local
workforce that is appropriately trained and local people have access to job, training
and apprenticeship vacancies.

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8.56 Alongside the draft Local Plan, OPDC will also prepare a Section 106 Supplementary
Planning Document that will set out the mechanisms to be implemented to secure
employment, training and apprenticeships for local people.
Alternative policy options
8.57 Securing access to employment, skills training, apprenticeships and pre-employment
support is considered to be a priority for OPDC and is supported by local stakeholders. As
such, an alternative policy is not considered to be appropriate.
Consultation Questions
QE5a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, are there any other policy alternatives that could
replace the preferred policy or should be considered as alternatives?

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9. TOWN CENTRE USES

Town centre uses
9.1 This chapter contains policies addressing the following policy themes:
TC1: Strategic Policy for town centre uses
TC2: Town centre hierarchy
TC3: Vibrancy
TC4: Retail and eating and drinking establishment needs
TC5: Culture, sports and leisure facilities
TC6: Visitor accommodation
TC7: Hours of operation for night time economy uses
Consultation Question
QTCa: Are there any other town centre use policy themes that you think OPDCs Local
Plan should be addressing?

Evidence Base
Study
OPDC Retail and
Leisure Needs Study
(RLNS)

OPDC Cultural
Principles

Description
A study looking at the quantitative need for
retail and leisure space in the OPDC area
generated by those living, working and
visiting the area. The study also includes
qualitative recommendations to deliver vital
and vibrant town centres.
A document showing how OPDC can
contribute to Londons position as the worlds
cultural capital and how embedding culture in
development can assist placemaking.

Status
Draft completed

Draft completed

Policy TC1: Strategic Policy for town centre uses

Key issues
1. The new population will need to have access to town centre uses and services to
serve their needs.
2. The Old Oak and Park Royal area itself is poorly served by town centre uses, but the
wider hinterland is well served through a network of town centres, such as
Harlesden, Ealing and Shepherds Bush.
3. Provision will need to complement existing neighbouring centres and their ability to
grow in future.
4. Town centre uses can play a critical role in placemaking, adding vibrancy to buildings
and the public realm and helping to attract people to live, work and visit the area.
5. Town centre uses can also add to the economic prosperity of an area, helping to
provide a range of employment opportunities over a wide range of sectors and skill
levels.
Policy Context

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National
9.2 The NPPF promotes the role that town centre uses can play in supporting the needs of
those living, working and visiting an area and that town centres should sit as the heart of
communities.
Regional
9.3 The London Plan promotes the importance of providing adequate retail, visitor
accommodation and culture, sports and leisure uses to accommodate Londons growing
needs and the role that these facilities can play in promoting economic prosperity and
maintaining Londons status as one of the worlds greatest cities.
Preferred Policy Option:
OPDC will support proposals for town centre uses that:
a) Provide locally and strategically significant culture, sports and leisure
facilities, that act as catalysts for regeneration and help strengthen Londons
position as the worlds cultural capital;
b) Provide a range of A-class uses that serve the needs of existing and new
residents, employees and visitors in terms of their location, scale and phasing;
c) Create a network of new town centres that are the focus for town centre uses
and which complement Londons wider network of centres;
d) Add to the activation and vibrancy of the area and help to create a sense of
place;
e) Promote social and economic regeneration and healthy lifestyles; and
f) Deliver best practice in terms of implementing innovative technology, design
and management of spaces to support long term sustainability.
Justification
9.4 A key role of OPDC is to coordinate and drive forward the regeneration and
transformation of the area. As part of this, there is a need for a range of life choices to be
provided for existing and future people living, working and visiting Old Oak and Park Royal.
Town centre uses will play a critical role in achieving this, providing new employment and
services and adding vibrancy and activity.
9.5 The OPDC Cultural Principles document sets out how OPDC could play a significant role
in Londons cultural offer by delivering new cultural destinations. This could include a mix of
culture, sports and leisure uses to serve the needs of existing and new residents, the
surrounding neighbourhoods and strategically across London and the south-east.
9.6 Small and large-scale culture, sports and leisure uses, which could act as catalysts for
regeneration should be supported by visitor accommodation as well as a range of retail uses
and eating and drinking establishments to serve the needs of those living, working and
visiting the area. Town centre uses will be focused within a series of new designated town
and local centres (see policy TC2). To support these centres, employment and residential
uses will also be supported as part of the mix of uses, which can help to increase footfall and
add to vibrancy and vitality.
9.7 New town centre uses will also play a critical role in overcoming the socio-economic
deprivation experienced in and around the OPDC area by providing a range of new
opportunities for employment and training across a breadth of sectors.
9.8 Through their spatial distribution and function, town centre uses can also promote
healthy lifestyles and OPDCs role as a Healthy New Town.
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9.9 The enhancement of existing centres and provision of new town centres provides
opportunities to demonstrate how new technology can be successfully integrated to support
flexibility and ongoing changes in the retail and leisure sector.
Alternative Policy Options:
9.10 There are no alternative options considered appropriate as this would not accord with
OPDCs draft Retail and Leisure Needs Study (RLNS) or the London Plan, which requires a
mix of uses as part of major development proposals.
Consultation Questions
QTC1a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, are there any other policy alternatives that could
replace the preferred policy or should be considered as alternatives?
Policy TC2: Town Centre Hierarchy
Key issues
1. The only existing centre in the OPDC area is the neighbourhood centre in the middle
of Park Royal, designated in LB Ealings Core Strategy.
2. To support the needs of new employees, residents and visitors to the area, a new
network of town centres needs to be designated.
3. The centres should be of a sufficient size to meet needs, promote sustainability and
assist with placemaking.
4. It is recognised that a new centre at Old Oak will impact on west London, but this
new centre will need to be planned and sized so as to complement the existing
hierarchy.
Policy Context
National
9.11 The NPPF requires local authorities to:
- positively plan for town centres, promoting competitiveness and setting out policies
for the management and growth of centres over the plan period;
- define a network and hierarchy of centres that is resilient to anticipated future
economic changes;
- set policies for the consideration of town centre uses which cannot be
accommodated within designated town centres; and
- apply a sequential approach requiring applications for main town centre uses to be
located in town centres, then in edge of centre locations and only if suitable sites are
not available should out of centre sites be considered.
Regional
9.12 The London Plan promotes the designation of new town centres, giving priority to areas
with a need for regeneration and better access to services, facilities and employment, which
is true for both Old Oak and Park Royal which are identified as Opportunity Areas and parts
of which are also identified as areas of regeneration.
Preferred Policy Option:
a) OPDC will support development that delivers the following town centre
hierarchy:

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i.

Old Oak High Street a potential new Major Centre within Old Oak (see
Policy P3);
ii.
North Acton - a potential new Neighbourhood Centre close to North
Acton Station (see Policy P7); and
iii.
Park Royal a Neighbourhood Centre in the middle of the Park Royal
Industrial Estate (see Policy P6).
b) Existing edge or out of centre town centre uses will be protected where they
meet local needs;
c) Proposals for new town centre uses on the edge of or outside of town centres
may be appropriate but only where a sequential approach has been taken to
site identification, looking firstly within centres and secondly on the edge of
centres and where they;
i.
Address identified deficiencies in need;
ii.
Reduce the need to travel by car and do not have an adverse impact on
the operation of the road network;
iii.
Support placemaking;
iv.
Do not impact on the functioning of Strategic Industrial Locations; and
v.
Do not have an adverse impact on, and support the role and function of,
designated centres.
d) OPDC will require developers to submit an impact assessment for schemes:
i. providing over 5,000sqm of town centre uses in Old Oak High Street;
and
ii. providing over 2,500sqm of town centre uses gross elsewhere (and
including both the North Acton and Park Royal centres).
[Figure XX: Map showing Town Centres]
9.13 OPDCs draft Retail and Leisure Needs Study (RLNS) identifies that a new Major
Centre should be designated in the Old Oak area. This recognises that:
- the significant new population that will be created in the area - 50,000 new residents,
55,000 employees and 250,000 people interchanging (embarking or disembarking)
each day within Old Oak Common Station. The draft RLNS identifies that this would
generate a quantitative need for 62,500sqm of A-class uses alone within Old Oak
High Street upon the developments completion.
- the fantastic public transport accessibility that will be afforded to the area, making Old
Oak a highly sustainable location for town centre uses, reducing the need for people
in the surrounding area to travel to these uses by private vehicle; and
- a new major town centre in Old Oak would have significant benefits to placemaking
in the area, providing opportunities for the provision of a range of culture, sports and
leisure facilities which as well as meeting local need, could make a significant
contribution to strategic provision and help to promote London as the worlds cultural
capital, as set out in the Mayors Cultural Strategy.
9.14 The draft Retail and Leisure Needs Study (RLNS) has tested the impact that the
designation of Old Oak High Street as a major centre would have on the surrounding retail
hierarchy. This shows that negative impacts are likely to be minimal and that most if not all
centres are likely to significantly benefit from the additional expenditure brought to the area
by the new residents, employees and visitors. OPDC will be working with the local
authorities to explore ways in which existing town centres such as Harlesden, Shepherds
Bush and Ealing can be well positioned to capture the benefits of this new expenditure.
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9.15 In recent years, development in North Acton has delivered over 2,000 homes and an
additional 1,000 student homes with current and future schemes anticipated to deliver an
additional 2,000+ homes within the plan period as well as a substantial quantum of new jobs,
particularly to the north of North Acton station in the Park Royal Industrial Estate. To support
this growing population and to provide a range of town centre uses within easy reach of
residents and employees, the preferred policy option proposes that North Acton is
designated as a new Neighbourhood Centre. OPDCs draft RLNS suggests that this centre
should accommodate approximately an additional 5,000sqm of A-class floorspace.
9.16 The centre of Park Royal was identified as a Neighbourhood Centre in Ealings Core
Strategy (2010). The continuation of this designation recognises the important role that this
centre plays in acting as a service centre for employees in the Park Royal Industrial Estate.
The intensification and growth of the Park Royal Industrial Estate will provide opportunities
for OPDC to review the boundary of this centre through future iterations of the draft Local
Plan.
9.17 Outside of these centres, there are a number of existing town centre uses, including a
number of eating and drinking establishments, convenience stores and culture, sports and
leisure uses. These uses will continue to be protected where these facilities are providing
local facilities to residents and employees and where there are no comparable alternative
facilities in the vicinity.
9.18 Retail and other town centre uses should be focused within the designated town
centres. However, in accordance with the sequential test, if there are no suitable sites within
these designated centres there may be the potential for town centre uses in edge of centre
or out of centre locations. This would be supported where it addresses a specific deficiency
in need, such as in areas further away from the designated centres or where they provide
local convenience retail that reduces the need to travel. Such provision should also
demonstrate how it supports placemaking, such as by providing improved legibility or by
providing active uses in areas of high footfall. Applicants would also need to demonstrate
that the proposals form and function would not detract from the designated centres both
within the OPDC area and within the wider hinterland.
9.19 The designation of the new town centre hierarchy would negate the need for a
sequential test for developments within that centre under paragraph 24 of the NPPF.
However, as no centres with the exception of Park Royal are currently established, OPDCs
draft RLNS recommends that retail impact assessments are required until such time as the
proposed centres are designated, in order to ensure that uses will have a complementary
impact on existing and new town centres. In accordance with the draft RLNS, OPDC will
require applicants proposing in excess of 5,000sqm gross additional town centre use space
in Old Oak High Street and 2,500sqm gross additional town centre use space elsewhere to
submit an impact assessment. In accordance with the NPPF, this should consider the impact
of the proposal on existing, committed and planned investment in nearby centres within its
catchment and the impact of the proposal on the vitality and viability of nearby centres.
Alternative Policy Options:
1. Identify Old Oak High Street as a Metropolitan Centre.
9.20 This option would provide the opportunity to increase the scale of town centre uses in
the Old Oak area. This option would have benefits in terms of making Old Oak an attractive
destination and could have benefits for placemaking by attracting higher footfall. However,
this option could impact on the vitality and viability of the surrounding town centre hierarchy.
It may also dilute investment in other centres and could also impact on a wider catchment
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and a greater number of town centres in west London. The greater quantum of retail on Old
Oak High Street could also make it more difficult to let space.
9.21 Examples of other metropolitan town centres in London are Ealing, Shepherds Bush
and Kingston.
2. Two centres are designated in Old Oak - a District Centre to the north of the
canal and a Neighbourhood Centre around Old Oak Common Station.
9.22 This option would limit the quantum of town centre uses to look to minimise impacts on
nearby town centres such as Harlesden, Ealing and Shepherds Bush. However, this
approach would not provide sufficient floorspace to cater for the needs arising from
development. The London Plan explains that typically District Centres contain 10,00050,000sqm retail, leisure and service floorspace and that Neighbourhood Centres, would by
virtue, be at either the lower end of this range or below 10,000sqm. The Retail and Leisure
Needs Study identifies a quantitative need for 62,500sqm of A-class floorspace alone in Old
Oak (of which 52,500sqm would be within the draft Local Plan period) and consequently,
designating a District Centre and Neighbourhood Centre would be likely to only provide
sufficient floorspace to provide for retail needs and would not allow for the provision of a
significant quantum of culture, sports or leisure uses within these centres. The approach of
designating a Neighbourhood Centre around the Old Oak Common Station would also fail to
capture the catalytic impact that the station could have on the immediate area and wider
hinterland. The Old Oak Common Station is estimated to have approximately 250,000
passengers a day interchanging (embarking or disembarking). There is a significant
opportunity for the land uses around the Old Oak Common Station to attract these
passengers who are interchanging into the surrounding hinterland and to help activate the
place and capture economic benefits for the area and its hinterland and this opportunity
would be limited through the designation of a Neighbourhood Centre here, rather than a
Major Centre.
9.23 Examples of other District Centres in the area are Harlesden, Hanwell and Portobello
Road and examples of other neighbourhood centres in the area are East Acton, Kensal
Rise and Perivale.
3. Two centres are designated in Old Oak - a District Centre to the south of the
canal around Old Oak Common Station and a Neighbourhood Centre to the
north of the canal.
9.24 As with option 2 above, this option would seek to limit the quantum of town centre uses
to minimise impacts on nearby town centres. As above, it is unlikely that a district and
neighbourhood centre would provide sufficient floorspace to cater for the needs of
development and certainly would not provide a policy framework for the establishment of
strategic culture, sports and leisure uses in the area.
9.25 The designation of a district centre to the south of the Grand Union Canal would better
capture the scale of need for town centre uses arising from the population living, working
and visiting the area than in option 2. However, to the north of the canal, the designation of a
Neighbourhood Centre would not be capable of providing sufficient town centre uses to meet
the areas need. This could be met to a certain degree by the District Centre at Old Oak
Common Station and the District Centre at Harlesden, but there would also be a risk that
premises in this area would struggle and the limited quantum of town centre uses may
impact on placemaking.

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4. Park Royal is not identified as a Neighbourhood Centre and a different
approach is taken to town centre uses in the area.
9.26 The town centre uses in the centre of Park Royal, in particular the ASDA supermarket,
generate significant volumes of traffic which have an impact on the ability of Park Royal to
function as an industrial estate. An approach to minimise this impact might be to dedesignate the centre and allow for its gradual erosion to other uses such as employment and
residential including local walk to services. However, this approach could also result in
worse impacts on the highway network if the town centre uses are dispersed requiring
employees and residents to travel further for their services. It would also see the loss of well
used existing local services over time.
Consultation Questions
QTC2a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, should the proposed Local Plan adopt one of the
alternative policy options as the preferred option?
QTC2b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
Policy TC3: Vibrancy
Key Issues
1. Town centre uses play an important role in placemaking, by attracting people to an
area and helping to enliven it.
2. This will be particularly important at Old Oak where comprehensive regeneration will
support the creation of a new part of London without a clearly defined character.
3. The policy should look to secure a mix of retailers over a wide range of uses and
types, including independent retailers, who can add diversity to a shopping centre
and play an important role in supporting the local economy.
4. The policy should also look to control uses that may have a negative impact (through
over-concentration of one use type) on placemaking.
Policy Context
National
9.27 The NPPF requires local planning authorities to:
- recognise town centres as the heart of their communities and pursue policies to
support their viability and vitality;
- promote competitive town centres that provide customer choice and a diverse retail
offer and which reflect the individuality of town centres; and
- retain and enhance existing markets and, where appropriate, re introduce or create
new ones, ensuring that markets remain attractive and competitive;
Regional
9.28 The London Plan supports proposals that sustain and enhance the viability of a town
centre, promote healthy living, support and enhance the competitiveness, quality and
diversity of town centre uses and that contribute towards enhancing the public realm.
Preferred Policy Option:

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To promote the role that town centre uses can play in shaping high quality places in
Old Oak and Park Royal and ensure that designated centres are vibrant and viable,
OPDC will:
a) Support the role town centre uses can play in delivering high quality places by
encouraging proposals that:
i.
Provide for outdoor uses such as eating and drinking uses with outdoor
seating, event space and street markets where viable and where they do
not detract from residential amenity. Any proposals for street markets
would need to be accompanied by a management plan;
ii.
Deliver and maintain high quality accessible shopfronts; and
iii.
Deliver and maintain high quality overlooked public realm.
b) Encourage the provision of meanwhile uses in early development phases (see
OSP5);
c) Support innovation and flexibility so that uses can expand and/or change
between use classes subject to demand and appropriate
permissions/agreements;
d) Require proposals for A-Class uses (retail and food and drinking
establishments) to provide a mix of unit sizes, including at least 10% of
floorspace for units of 80sqm or less to support independent retailers.
Applicants should actively market these units within the local communities;
e) Require proposals:
i.
Providing over 2,500sqm of A-class floorspace to submit a Retail Vision
Statement; and
ii.
Providing over 2,500sqm of town centre use floorspace to submit a
Cultural Action Plan.
f) Support the creation of a healthy new part of London by supporting uses that
have a positive impact on health and well-being and restricting planning
applications for:
i.
betting shops, pay-day loan shops and games arcades; and
ii.
takeaways (Class A5 uses), particularly where they are in close
proximity to primary and secondary schools.
Justification
9.29 Town centre uses within the OPDC area, particularly in Old Oak, will help to play a
critical role in the approach to placemaking. An important way of achieving this is through
activating and overlooking the public realm, by providing outdoor uses such as event space,
outdoor seating associated with eating and drinking establishments and through the
provision of street markets. Any proposals for street markets would need to be accompanied
by a management plan that identifies its hours of operation and storage arrangements when
not in use, types of traders, servicing and transport impacts.
9.30 The quality of buildings fronting onto the public realm will be of equal importance to
ensuring that town centres create vibrancy and activity. Proposals must ensure that
shopfronts and other active frontages are accessible and are designed to the highest quality,
considering how proportions, materials and detailing relates to and complement their
surroundings, exploring opportunities for variety, innovative design and local distinctiveness.
9.31 In Old Oak in particular, it will be important to create a place as early as possible in the
development phases. Meanwhile or temporary town centre uses could play an important role
in achieving this and OSP5 encourages major development proposals to submit a
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meanwhile strategy demonstrating how their proposals will actively promote and deliver
meanwhile uses in early development phases.
9.32 Given the scale of development envisaged within the OPDC area and the timescales
over which this development is programmed for delivery, it will be important for proposals to
9.33 be designed to be sufficiently flexible to allow for changing market conditions and
accommodate emerging retail typologies. In particular at the lower levels of buildings. OPDC
will encourage proposals that allow for flexibility in their size, for example by providing for
expansion through the future creation of mezzanines or the subdivision/amalgamation of
units. OPDC will also support proposals that, through their design, consider the ability for
units to readily change use class.
9.34 Within town centres, it is important to have a variety of retailers in order to create
vibrancy and ensure the long term vitality of the centre. To support this, OPDC will expect
retail proposals to provide for a range of unit sizes for A-class floorspace and secure at least
10% floorspace for units of 80sqm or less (defined in the London Small Shops Study 2010),
which will also help support the establishment of SMEs and independent retailers in the
OPDC area, who tend to operate in smaller units.
9.35 For major applications providing over 2,500sqm of A-class uses (which is the threshold
for OPDCs requirement for a Retail Impact Assessment in Policy TC2), OPDC will require
applicants to submit a Retail Vision Statement. This should set out in more detail what the
applicants expectations are in terms of the type of retailers and eating and drinking
establishments. The Vision Statement should also identify what the long term management
arrangements are for the proposed units and what opportunities this might provide for the
longer term management of the centre, in a similar way to how the Howard de Waldon
Estate has managed Marylebone High Street.
9.36 OPDCs Cultural Principles document identifies that OPDC can help play an important
role in continuing Londons position as the globes cultural capital. To support this, proposals
providing in excess of 2,500sqm of town centre use floorspace will need to submit a Cultural
Action Plan that sets out how their scheme will contribute to the cultural offer in Old Oak and
Park Royal as support OPDCs realisation of its cultural vision.
9.37 The Health on the High Street report published by The Royal Society for Health in
2015 provides a range of sources of evidence about the negative health impact of betting
shops, payday loan shops and fast food takeaways and the positive health impacts of health
services, pharmacists, leisure centres/health clubs, libraries, museums and art centres and
pubs and bars. There has been a growing concern in recent years about the proliferation
and over-concentration of betting shops, pay-day loan shops and amusement arcades and
their impacts on mental health and the vibrancy and vitality of town centres. In 2015
Government re-classified betting shops and pay-day loan shops within a separate use class
(amusement arcades are already within a separate use class). There has also been a
growing concern about the growth in fast food takeaways (Class A5 uses) and their impact
on health, in particular, regarding the proximity of takeaways to schools and the impact that
this has on childhood obesity. Evidence shows that the type of food on sale nearest to
schools influences the diet of schoolchildren and that the availability of unhealthy foodstuffs
makes healthier choices less likely. As a Healthy New Town, OPDC will restrict proposals
for new takeaways in close proximity of school entrances and will promote the loss of
existing takeaways within these areas. In addition, OPDC will resist proposals that would
result in the clustering of A5 uses to the detriment of the character and function or vitality
and viability of a centre. As a Healthy New Town OPDC, in consultation with NHS England,
will work closely with stakeholders to promote and support uses that have a positive impact
on health and well-being. It will also resist proposals for new, and encourage the loss of
existing, facilities that have a detrimental impact on health and well-being.
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Alternative Policy Options

1. Take a more flexible approach to betting shops, pay-day loan shops and
takeaways
9.38 This option would not look to resist these uses and would instead consider proposals
for such uses on their merits, having regard to their impact on amenity, transport and other
Local Plan considerations. The benefits to this approach would be that it would be more
responsive to market demands. However, the option would have significant negatives as it
could result in the proliferation of these uses and would not promote OPDCs role as a
healthy new part of London.
Consultation Questions
QTC3a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, should the proposed Local Plan adopt the
alternative policy option as the preferred option?
QTC3b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
QTC3c: How should we manage the potential over-concentration of betting shops,
pay-day loan shops games arcades and take-aways?
Policy TC4: A-Class (Retail and eating and drinking establishment) Needs
Key Issues
1. It is important that an appropriate quantum of A-class uses are provided to support
the needs of those living, working and visiting Old Oak and Park Royal.
2. If there is not enough A-class floorspace, people will be required to travel further for
their needs, putting increased pressures on the transport network and undermining
the placemaking benefits that A-class floorspace could bring to the OPDC area.
3. Conversely, if too much A-class floorspace is provided, units could remain vacant or
the uses could start to draw significant levels of trade away from the surrounding
retail hierarchy and have a detrimental impact on their vitality and viability.
4. It will be important to achieve the right balance and consider how OPDC can be
flexible and respond to future changing market conditions and local need.
Policy Context
National
9.39 The NPPF sets out an expectation that local planning authorities assess the
quantitative need for town centre uses including A-class uses and that sites should be
identified to meet this need.
Regional
9.40 The London Plan requires local planning authorities to identify future levels of retail and
other commercial floorspace need.
Preferred Policy Option:

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a) A-class uses (retail and eating and drinking establishments) should serve the
needs of the development and complement nearby centres. This will be
achieved by requiring developers to:
i.
Accord with the quantitative need identified below:

A1
A1 service and A2
A3-A5
Total*

Local Plan period (2037)

33,000 sqm
17,500 sqm
12,000 sqm
62,500 sqm

*including floorspace within Old Oak Common Station

ii.
Submit a masterplan showing how their proposals fits within a wider
comprehensive approach and how their retail provision interacts with
provision in neighbouring schemes;
iii.
Demonstrate through robust justification and evidence that the
proposals would not adversely affect the vitality and viability of nearby
centres where proposals would exceed the quantitative need; and
iv.
Submit a Town Centre Enhancement Strategy where proposals are
likely to have an impact on nearby centres;
b) In the Local Plan period, A-class uses should be broadly distributed across the
town centre hierarchy as follows:
i.
Approximately 52,500sqm in Old Oak High Street Town Centre;
ii.
Approximately 5,000sqm in North Acton Neighbourhood Centre; and
iii.
Approximately 5,000sqm in Park Royal Neighbourhood Centre.
Justification
9.41 The new population that will be living, working, visiting and travelling through the OPDC
area will need to be served by an appropriate quantum of retail. There retail quantum will be
vital in making a new place and creating activity and vibrancy. However, the area
surrounding OPDC is currently well served by retail and it is important that the vitality and
viability of these centres are not undermined by this new retail provision. This is particularly
the case with Harlesden Town Centre in the London Borough of Brent, which is the closest
town centre to OPDC and which is the most susceptible to impacts as a result of proposals
for retail in OPDC.
9.42 The Old Oak and Park Royal Retail and Leisure Needs Study (RLNS) has tested the
appropriate overall quantum and phasing of retail in OPDC. The study assumes that
approximately 75% of convenience expenditure and 15-25% of comparison expenditure from
the population will be retained in the area (with 25% and 75-85% respectively being spent in
the surrounding hinterland). The RLNS recommends that OPDC adopt a 25% retention
figure for comparison expenditure in recognition of the potential designation of a new major
town centre at Old Oak High Street. The study confirms that this quantum of retail would:
- Deliver the necessary placemaking benefits for the OPDC area;
- Provide an appropriate quantum of retail to provide for the needs of the development,
including those living, working, visiting and travelling through OPDC; and
- Not have a significant detrimental impact and may have a beneficial impact on
neighbouring town centres.
9.43 For larger retail proposals, OPDC will require applicants to submit a Town Centre
Enhancement Strategy that would need to recommend how nearby town centres might be
impacted by a proposal and also set out how interventions in town centres could maximise
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benefits and avoid risks. The RLNS identifies that this will be of particular relevance to
Harlesden, which the study identifies at the town centre with the most to lose or gain as a
result of retail provision in OPDC.
9.44 The RLNS sets out the broad spatial distribution of retail and other A-class uses, which
identifies that the majority of this floorspace should be provided within the Old Oak High
Street Major Centre. This recognises the substantial uplift in new homes and jobs is likely to
occur in the Old Oak area. However, the study also identifies potential growth in both North
Acton and Park Royal, which will both see increases in new homes and jobs across the plan
period.
Alternative Policy Options:
1. Identify OPDC as a more significant retail destination with a higher quantum of
retail over and above that required to serve the needs of the development.
9.45 This option would have potential benefits in terms of placemaking, by creating a greater
retail draw and providing more opportunities for active uses. However, this option could
impact on the vitality and viability of surrounding retail centres and as a consequence, this
policy approach has not been identified as the preferred option.
Consultation Questions
QTC4a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, should the proposed Local Plan adopt one of the
alternative policy options as the preferred option?
QTC4b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
Policy TC5: Culture, sports and leisure facilities
Key Issues
1. Culture, sports and leisure facilities make an important contribution to placemaking,
could be important catalyst uses and could help to define and shape the place and
add to vibrancy and activity by attracting visitors to an area.
2. The Mayors Cultural Strategy promotes London as the global centre for culture and
as Londons largest and well connected regeneration area.
3. The OPDC area and particularly Old Oak can play a leading role in maintaining
Londons pre-eminence for culture, sports and leisure.
Policy Context
National
9.46 The NPPF sets out an expectation that local planning authorities assess the
quantitative need for town centre uses including culture, sport and leisure uses and that sites
should be identified to meet this need.
Regional
9.47 The London Plan requires local planning authorities to assess the quantitative need for
town centre uses, including culture, sports and leisure. The plan and the Mayors Sports
Legacy Plan aim to increase participation in, and tackle inequality of access to, sport and
physical activity in London, particularly amongst groups/areas with low levels of participation.
Preferred Policy Option:
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Proposals for culture, sports and leisure facilities will be required to:
a) Support the creation of a cultural, sporting and leisure destination at Old Oak,
serving both a local and a London-wide catchment;
b) Help support placemaking and/or act as a catalyst for regeneration;
c) Not give rise to unacceptable impacts on amenity and transport; and
d) Provide affordable access for local communities.
9.48 The Mayors Cultural Strategy promotes London as the worlds cultural capital and how
this role can help widen the reach of and access to culture, support education skills and
careers and enhance the physical environment. As Londons largest regeneration project,
OPDC can play a central role in delivering new cultural facilities to help consolidate Londons
position as a global leader for culture. OPDC has produced a Cultural Principles document
which outlines how this could be supported. OPDC will be supportive of the provision of new
facilities, where they demonstrably address either a local or strategic need and do not give
rise to an unacceptable impact on the amenity of existing and future residents, businesses or
on the transport network.
9.49 Culture, sports and leisure uses can play an integral role in the place-shaping strategy
for Old Oak and Park Royal, particularly as part of the early development phases. The scale
of the Old Oak area in particular, provides opportunities for a range of large and small-scale
culture, sports and leisure uses that could become a focus or a catalyst for regeneration in a
similar way to the Central St Martins University of Arts at Kings Cross (see OSP 5, Chapter
3). OPDC will work with landowners and providers to achieve this.
9.50 Culture, sports and leisure facilities will be expected to cater for a range of incomes,
particularly those in low incomes who are often excluded from access to such facilities or
whose choice is often limited. This will be especially important for access to sports facilities.
There is a direct correlation between income deprivation and obesity; as a healthy new part
of London, OPDC is keen to ensure that there is access for all to new sports facilities for
local communities. OPDC will seek to secure a proportion of affordable sports and leisure
provision as part of any planning agreement, in the form of discounted membership fees and
discounted non-membership access fees.
Alternative Policy Options
1. Set a quantum threshold for culture, sports and leisure uses.
9.51 This option would identify an indicative floorspace figure for non A-class town centre
uses such as for leisure, sports and culture. It would provide a clearer indication of the
acceptable quantum of floorspace for other town centre uses, providing greater certainty to
stakeholders. However, this approach would constrain the ability for these sorts of uses to
aid with placemaking and could potential prevent a major cultural, sports or leisure use from
locating the area that could act as a catalyst for regeneration and provide a strategic cultural
or leisure destination.
Consultation Questions
QTC5a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, should the proposed Local Plan adopt one of the
alternative policy options as the preferred option?
QTC5b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
QTC5c: What culture, sports and leisure uses do you think OPDC should look to
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attract to the OPDC area?
Policy TC6: Visitor accommodation
Key Issues
1. London has a growing need for visitor accommodation and particularly business
hotels and convention centres.
2. Hotels are well suited to areas of high public transport access and therefore, parts of
the OPDC area and particularly the Old Oak area would be appropriate locations to
consider promoting visitor accommodation.
3. There is and will be a growing demand for hotel spaces for people visiting Park Royal
businesses.
Policy Context
National
9.52 The NPPF states that local planning authorities should ensure that the needs for main
town centre uses such as hotels are met in full and are not compromised by limited site
availability.
Regional
9.53 The London Plan promotes the provision of additional visitor infrastructure and
promotes a London-wide target to deliver an additional 40,000 hotel bedrooms by 2036 and
that in particular, new business hotel space and convention centres should be provided.
Preferred Policy Option:
OPDC will contribute to Londons visitor infrastructure and Londons overall need for
an additional 40,000 high quality hotel bedspaces by 2036 by:
a) Supporting proposals for visitor accommodation within OPDCs designated
town centres and/or within area of high public transport accessibility;
b) Requiring proposals to provide at least 10% of hotel bedrooms as
wheelchair accessible and submit Accessibility Management Plans;
c) Providing a range of types of visitor accommodation over a range of
affordabilities;
d) Promoting the provision of business hotels and multi-functional convention
facilities; and
e) Promoting high quality design and protecting the amenity of nearby
residents.
9.54 The London Plan establishes a London-wide need for an additional 40,000 hotel
bedrooms by 2036. Due to its high public transport accessibility and proximity to destinations
such as the West End, Heathrow and first point of call for trains coming from the north, the
OPDC area is likely to be an attractive location to meet this need. Visitor accommodation
within the OPDC area should be focused within designated centres and in areas of high
public transport access to minimise impact on residential amenity and to minimise the need
for car parking and hence reduce the impact on the transport network.
9.55 Applicants will be required to provide at least 10% accessible hotel bedspaces and will
be required to submit an Accessibility Management Plan committing to providing an
enhanced level of customer care to disabled guests and, at the same time, optimise the use
of the accessible rooms.
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9.56 OPDC will welcome proposals over a wide range of affordabilities, from high end 5*
hotels down to value and budget hotels in order that a wide variety of tourists will be
attracted to the area and to London. There is a particular need in London for high quality
business visitor accommodation and the Old Oak area will be particularly well suited to
providing for this need with good connections to Heathrow, Gatwick, Central London and the
north of England.
9.57 Business accommodation should include provision for conference facilities and in large
hotels, convention centre facilities, for which there is currently an under-supply in west
London. Providing high quality facilities is essential as the quality of hotel accommodation
often shapes visitors perceptions of the capital and encourages recommendations and/or
repeat visits. OPDC will encourage developers to join national quality assurances such as
VisitEnglands National Quality Assessment Scheme. OPDC will also require developers to
demonstrate that proposals do not have a detrimental impact on the amenity of neighbours,
particularly residents and will require developers to submit management schemes
demonstrating how potential impacts will be minimised and mitigated against.
9.58 It should be noted that this preferred policy option does not provide guidance for
emerging sharing economy models for delivering visitor accommodation.
Alternative Policy Options:
9.59 No reasonable alternative policy options have been identified, as alternatives would not
be consistent with the NPPF or in general conformity with the London Plan.
Consultation Questions
QTC6a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, are there any other policy alternatives that could
replace the preferred policy or should be considered as alternatives?
Policy TC7: Hours of operation for evening night time economy uses
Key Issues
1. Night-time economy uses play an important role in adding to vibrancy of an area.
However, if not carefully designed and located they can result in disturbance to
residents, in particular in high density areas.
2. A policy is necessary to set in place controls on the hours of operation of such uses
so that there is a limit to the hours of operation without express permission for later
opening hours.
Policy Context
National
9.60 The NPPF requires local authorities to recognise town centres as the heart of their
communities and pursue policies to support their viability and vitality.
Regional
9.61 The London Plan requires local planning authorities in their Local Plans to minimise the
impact of night time economy uses on other land uses. The approach should take into
account the cumulative effects of night time uses and saturation levels beyond which would
result in unacceptable impacts on the environmental standards befitting a world city and
quality of life for local residents.
Preferred Policy Option:
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a) Planning permissions for eating and drinking establishments and culture, sports
and entertainment uses, either as the main or as the ancillary use, will be the
subject of conditions controlling hours of operation to minimise their impact on
residential amenity;
b) There will be a presumption that:
i.
Within designated centres premises should close by 00:00; and
ii.
Outside of designated centres premises should close by 23:00.
c) Proposals for extended opening hours beyond the limits outlined under b) would
need to demonstrate that:
i.
there would be no detrimental harm to the amenity of neighbours resulting
from the facility itself or from those travelling to and from the facility; and
ii.
the proposal would not result in harmful cumulative impacts in association
with other late licensed properties.
9.62 OPDC supports the role that eating and drinking establishments and culture, sports and
leisure uses can play in contributing to the vibrancy and vitality of the OPDC area alongside
adding activity to the public realm and supporting the local economy. However, it is important
in the late evening and during the night that the impact of these uses on the amenity of
neighbours, particularly residents, is controlled. OPDC will condition planning permissions to
minimise this impact. Proposals for late licenses will be assessed in terms of the uses impact
on residential amenity and will consider issues such as noise within the premises, smells,
light pollution and the impact of those going to and from the facility, considering issues such
as traffic and car parking and anti-social behaviour.
9.63 Residential uses surrounding town centre locations where there is potential for late
night activities should carefully consider the locations of habitable rooms and in particular
bedrooms. They should also clearly demonstrate how noise attenuation measures have
been included and designed to the highest standards. This approach is necessary to ensure
both a vibrant night-time economy and high quality residential environment.
Alternative Policy Options:
9.64 No reasonable alternative policy options have been identified, as not controlling hours
of operation would cause an unacceptable impact on amenity.
Consultation Questions
QTC7a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, are there any other policy alternatives that could
replace the preferred policy or should be considered as alternatives?

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10. SOCIAL INFRASTRUCTURE

10.1 This chapter contains policies addressing the following policy themes:
SI1: Strategic Policy for social infrastructure
SI2: Educational
SI3: Health
SI4: Community facilities
SI5: Public houses
Consultation Question
QSIa: Are there any other social infrastructure policy themes that you think OPDCs
Local Plan should be addressing?

Evidence base
Study
OPDC Old Oak and Park
Royal Development
Infrastructure Funding
Study (DIFS)
OPDC Development
Capacity Study (DCS)

Scope
Assessment of the infrastructure
needed to support the scale of
development planned in the OPDC
area.
A study assessing the development
capacity of development plots within
the OPDC area.

Status
Completed

Draft completed

Policy SI1: Strategic Policy for Community Uses

Key Issues
1. The future population in the OPDC area will need to be supported by adequate
provision of social infrastructure to meet the populations needs.
2. The scale of development in Old Oak and Park Royal provides substantial
opportunities to upgrade existing facilities and to provide smart technology
demonstrating best-practice in terms of the provision of social infrastructure.
Policy Framework
National
10.2 The NPPF requires local planning authorities to ensure an integrated approach to
considering the location of community facilities and services. Local planning authorities are
required to work with other authorities and providers to assess the quality and capacity of
infrastructure for health, social care and education and its ability to meet forecast demands.
Regional
10.3 The London Plan notes that adequate provision for social infrastructure is particularly
important in areas of major new development. The policy requires local planning authorities
to provide a framework for collaborative engagement with social infrastructure providers and
community organisations and ensure that adequate social infrastructure provision is made to
support new developments.
Preferred Policy Option:
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OPDC will:
a) Safeguard existing social infrastructure subject to a continued need;
b) Secure enhancements to existing and provide new social infrastructure to
support the needs of the new population living and working in the OPDC area;
c) Require high quality and inclusive design of social infrastructure;
d) Promote the innovative delivery of social infrastructure;
e) Promote the co-location and multi-functionality of social infrastructure; and
f) Work with stakeholders to consider funding arrangements for the ongoing
maintenance costs of social infrastructure.
Justification
10.4 There are a number of existing social infrastructure facilities in the OPDC area. OPDC
will seek to protect this social infrastructure space as part of any development proposals.
This could include the re-provision of the space within a new scheme, but any new space
should be of an equal or better standard in terms of its access and quality of service.
10.5 The Old Oak and Park Royal Development Infrastructure Funding Study (DIFS)
identifies that the OPDC area will require a broad range of new social infrastructure facilities
(including education, health, emergency services and community facilities) to support the
areas future residents and employees. Table XX in the Delivery Chapter outlines the type,
quantum and phasing of social infrastructure. The exact need arising from each individual
development will be generated by calculating the anticipated population and child yield,
based on home sizes and tenures.
10.6 Social infrastructure facilities are locations where neighbouring residents get the
opportunity to meet one another and can play a vital role in creating a sense of community.
OPDC will work with relevant stakeholders/partners to expand existing social infrastructure
both within and outside the OPDC area and where appropriate within earlier development
phases. This will help to knit together the new community with existing communities
surrounding the OPDC area. This approach could also be a more cost effective way of
providing infrastructure. The potential for the expansion of existing infrastructure will be
contingent on further discussions with service providers and it is recognised that many of the
surrounding facilities will not be capable of expansion. Within later phases, it is anticipated
that social infrastructure will need to be provided on-site. OPDC will work with developers
and service providers to coordinate the delivery of this on-site infrastructure, which may be
funded and delivered in a number of different ways, including through planning agreements
and Community Infrastructure Levy (CIL).
10.7 Enhancements to existing and provision of new community use infrastructure should be
designed to the highest quality. New community uses should aim to achieve best practice
design standards which help to establish these new facilities as focal points within the
development. When designing community uses, developers should consider the needs of all
members of the community and particularly the protected characteristics in the Equality Act
2010. In delivering services, OPDC will work with stakeholders to promote and explore the
use of contemporary and innovative technology to benefit service users and providers.
10.8 Space is at a premium in London and getting the most efficient use of public buildings,
must be a primary consideration. In the design of social infrastructure, particular
consideration should be given to the promotion of the multi-functionality and use of buildings.
10.9 OPDC will work closely with service providers and the local authorities to ensure that
when new or expanded facilities are being secured; there is adequate certainty and security

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around the ongoing maintenance costs in order that the facilities remain viable in the longer
term; and do not place an undue burden on service providers funding streams.
Alternative Policy Options
1. Require new social infrastructure to be provided solely on-site rather than
looking to expand surrounding existing facilities.
10.10 This approach would help with placemaking, by delivering a range of community
facilities on-site in earlier development phases. This approach may also have benefits on the
transport network as new residents would not have to travel as far to access community
uses. However, this option would not help to knit the residents and employees on early sites
with the existing community and may leave these sites feeling isolated in early years.
Consultation Questions
QSI1a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, should the proposed Local Plan adopt the
alternative policy option as the preferred option?
QSI1b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
Policy SI2: Education
Key Issues
1. Funding for schools is based on a per-pupil rate and covers a schools maintenance
costs and some limited capital expenditure.
2. There are other funding pots available for capital expenditure, such as the Targeted
Basic Need Programme, but this does not account for increases in child yield
resulting from development.
3. There is therefore a need for OPDC to secure funding to cover the capital costs of
providing new education provision to meet the needs of the new population.
4. Given the scale of development in the area, there is also an opportunity to promote
the OPDC area as an appropriate location for higher education institutions and
recognise the potential benefits this might have as a catalyst for the regeneration of
the area and the wider economy.
Policy Context
National
10.11 The NPPF states that planning policies should aim for a balance of land uses within
their area so that people can be encouraged to minimise journey lengths for education. The
NPPF requires local planning authorities to take a proactive, positive and collaborative
approach to meeting school place requirements, and to development that will widen choice
in education. In particular, the NPPF states that local planning authorities should give great
weight to the need to create, expand or alter schools and work with schools promoters to
identify and resolve key planning issues before applications are submitted.
Regional
10.12 The London Plan states that borough strategies should provide the framework:
- for the regular assessment of the need for childcare, school, higher and further
education institutions and community learning facilities at the local and sub-regional
levels; and
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-

to secure sites for future provision recognising local needs and the particular
requirements of the education sector.

10.13 The policy also states that boroughs should support and maintain Londons
international reputation as a centre of excellence in higher education.
Preferred Policy Option:
OPDC will:
a) Require proposals to provide adequate educational provision to meet the
needs of development;
b) Work with surrounding local authorities to identify sites for school expansion
in the short/medium term;
c) Allocate sites for the provision of a new all-through school (ages 3-18) and
work with landowners and developers to secure sites for primary schools and
nurseries; and
d) Support the establishment and growth of higher education institutions in the
OPDC area.
[Figure XX: showing area of search for all-through school]
10.14 The Development Infrastructure Funding Study (DIFS) identifies that there will be a
significant need for additional educational facilities resulting from development. Proposals
will be assessed against the local authorities child yield calculators to determine what
educational requirements will be necessary to adequately mitigate against the impacts of
development on the local authorities educational services.
10.15 The DIFS identifies that in the earlier phases of development there may be the
potential to expand existing educational facilities in the surrounding hinterland to meet this
need. This could be a more cost effective way of providing facilities and could also help to
knit the new community into existing communities. OPDC will undertake further discussions
with education providers to understand the potential for the expansion of existing facilities. If
this is not feasible, education facilities will need to be provided on-site and this will certainly
be the case in the medium/long-term given the scale of development anticipated in the area.
The DIFS identifies the need for on-site primary and nursery provision and an all-through
school. Primary and nursery schools generally have smaller footprints and in larger
schemes, can be incorporated into the schemes design. However, if proposals come
forward in a piecemeal fashion OPDC will allocate sites for the delivery of new facilities. The
all-through school will require a substantial land-take. Figure XX identifies an area of search
for the provision of this all-through school, based on phasing assumptions. We are inviting
stakeholders to suggest a preferred location for this facility through their consultation
responses on this Local Plan.
10.16 London is one of the worlds global centres for education. It is home to a wide number
of universities and colleges including the world renowned Imperial College London and
University College London universities, both of which are ranked in the top 10 of the QS
World University Rankings 2015. In recent years, there has also been a growth in London of
universities establishing satellite hubs in London to capitalise on Londons world city status,
such as the Newcastle University and the University of Sunderland, who have both recently
opened London campuses. The development potential in the OPDC area provides
significant opportunities to meet this growing need for higher education space. These higher
education institutions could act as a catalyst for the regeneration of the OPDC area (see
OSP 5, Chapter 3), by helping to create a sense of place in early phases, in a similar way to
the recently completed Central St Martins - University of Arts at Kings Cross.

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Alternative Policy options
1. Do not promote the OPDC area as a location for higher education uses
10.17 Instead of promoting higher educational uses to the area, this approach would instead
take a more flexible approach and proposals would be assessed on a case by case basis.
This approach would not preclude the provision of higher educational uses in the OPDC
area. However, as Londons largest development site, OPDC thinks it is right to identify the
potential for the OPDC area to accommodate higher educational uses and the positive role it
could play in supporting regeneration.
Consultation Questions
QSI2a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, should the proposed Local Plan adopt the
alternative policy option as the preferred option?
QSI2b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
QSI2c: What site or sites within the OPDC area to do you think should be identified for
an all-through school?
Policy SI3: Health
Key Issues
1. As a Healthy New Town, OPDC should be designed to encourage healthy living and
well-being from the out-set.
2. There is a need to ensure that development in Old Oak and Park Royal is supported
by adequate health infrastructure.
3. OPDC will need to secure facilities to meet the needs arising from development.
4. Any facilities will need to be easily accessible for all residents.
5. There may be opportunities for health uses to be co-located with other community
spaces.
6. Planning for the provision of healthcare is challenging given the upcoming changes
to process and funding of healthcare across the country and there is therefore a need
for flexibility.
Policy Context
National
10.18 The NPPF requires local planning authorities to secure accessible local services that
reflect the communitys needs and support its health, social and cultural well-being. The
NPPF requires local planning authority Local Plans to include strategic policies to deliver the
provision of health.
Regional
10.19 The London Plan states that borough strategies should identify and address specific
social care issues facing the area and work with service providers to, assess the need for
facilities and secure sites and building for the provision of health facilities to meet future
needs. The policy also requires boroughs to promote the continued role and enhancement of
London as a national and international centre of medical excellence and specialised
facilities.
Preferred Policy Option:
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OPDC will:
a) Support the delivery of a Healthy New Town to encourage healthy living and
innovation in health;
b) Require proposals to provide adequate health provision to meet the needs of
development;
c) Ensure that new health facilities are easily accessible to all users, flexibly
designed and potentially co-located within other community uses; and
d) Support the establishment and growth of national and international health
institutions in the OPDC area.
10.20 OPDC has been designated as a Healthy New Town by the NHS. It is critical that this
new part of London is designed to encourage healthy living. To support this, OPDC will
require that new development in the OPDC area delivers best practice in promoting health
and well-being including through the design of the built environment.
10.21 OPDC will ensure that the new population in Old Oak has access to a range of health
uses to meet their needs. OPDC will work with developers and service providers to ensure
development proposals deliver adequate health provision, including health centres with
space for GPs, social care facilities, dentists, pharmacies and opticians.
10.22 OPDC will look to secure the provision of health services on-site as early as possible
in order that facilities are easily accessible for members of the new community. Facilities
should be located in designated town centres and close to areas of high public transport
access, which would be easily accessible and visible for members of the public. There will
also be opportunities to co-locate health provision with other uses, such as with community
facilities or sports and leisure centres, to deliver efficiencies in space and maintenance
costs.
10.23 The OPDC area is home to Central Middlesex Hospital and Hammersmith Hospital is
also to the immediate south of the OPDC area. The scale of development planned in the
OPDC area provides opportunities for these facilities and others across London to expand to
further medical science and help strengthen Londons position as one of the worlds centres
for medical excellence. Health institutions could act as a catalyst for the regeneration of the
OPDC area, by helping to create an early sense of place (see OSP 5, Chapter 3).
Alternative Policy options
10.24 No reasonable alternative policy options have been identified, as it is considered that
an alternative approach to that outlined in the preferred policy option would not be in
conformity with the NPPF, London Plan or draft supporting evidence base.
Consultation Questions
QSI3a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, are there any other policy alternatives that could
replace the preferred policy or should be considered as alternatives?
Policy SI4: Community facilities
Key Issues
1. There is a need to ensure that development in Old Oak and Park Royal is supported
by adequate community facilities, such as libraries, places of worship, halls for hire,
youth space and training and meeting space.
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2. Community facilities could be key hubs of activity within town centres and in areas of
high public transport access and could help with placemaking.
Policy Context
National
10.25 The NPPF requires local planning authorities to plan positively for the provision and
use of shared space, community facilities and other local services to enhance the
sustainability of communities and residential environments.
Regional
10.26 The London Plan promotes the protection and enhancement of social infrastructure
and the need for local planning authorities to secure sites for future provision or
reorganisation of provision.
Preferred Policy Option:
OPDC will secure a range of new high quality community facilities that:
a) support the needs of the new population;
b) Provide for a diverse range of community uses, such as library space, places
of worship, halls for hire, youth space, adult learning and training space,
community cafs, flexible office and meeting space for use by residents and
voluntary sectors;
c) are located at key destination points within the OPDC area, close to
destinations of high footfall and high public transport access;
d) are of a high design quality, promoting inclusivity; and
e) are co-located where feasible with other community or town centre uses.
Justification
10.27 Good quality community facilities can have a significant bearing on the quality of life
and health and well-being of a community, by encouraging social interaction, promoting
learning and by providing support services for those living, working and visiting an area.
10.28 Given the scale of development envisaged in the OPDC area there will be a need for,
and opportunities to provide, a range of community facilities. OPDC will work with service
providers and developers to ensure that a range of community facilities are provided to
support the needs of the area.
10.29 Community facilities will play an important role in placemaking in the OPDC area,
helping to create hubs of activity and focal points for neighbourhoods. Facilities should be
located within prominent and highly visible positions in the development, in areas of high
footfall and or high public transport access. Community facilities should also be delivered to
a high design quality with opportunities for architectural distinctiveness to distinguish
community facilities from their surroundings so that they act as destination points. This
approach has been successfully delivered in other regeneration projects in London such as
at Peckham Library. Community facilities should be designed to be fully inclusive. Particular
consideration should be given to the needs of people with a protected characteristic as
defined in the Equality Act 2010. In order to save costs and attract as many people as
possible to community facilities and other public services, opportunities for the collocation of
community facilities with other social infrastructure or town centre uses should be explored.
Alternative Policy options

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10.30 No reasonable alternative policy options have been identified, as it is considered that
an alternative approach to that outlined in the preferred policy option would not be in
conformity with the NPPF, London Plan or draft supporting evidence base.
Consultation Questions
QSI4a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, are there any other policy alternatives that could
replace the preferred policy or should be considered as alternatives?
Policy SI5: Pubs
Key Issues
1. Pubs are an important community use, providing a place to meet, socialise and be
entertained.
2. In recent years, London has seen an increase in the number of planning applications
to convert pubs to alternative land uses.
3. There has been a growing concern about this at the national, regional and local level
and more and more Local Plans are now looking to safeguard pubs as community
uses.
4. OPDC has three public houses within its boundary and consideration should be given
to whether OPDC should look to safeguard these pubs as community uses.
Policy Context
National
10.31 The NPPF does not say anything explicit on the protection of pubs. However, in 2015,
the government introduced changes to the planning use class order to take away powers for
permitted development rights where pubs have been listed as assets of community value.
Regional
10.32 The London Plan states that local planning authorities should develop policies to
prevent the loss of valued local community assets, including public houses, justified by
robust evidence.
Preferred Policy Option:
OPDC will protect pubs unless it can be demonstrated that for at least 12 months:
a) the pub is no longer a viable business, demonstrated through accounts data;
and
b) the property has been appropriately marketed for a continuous period and no
suitable offer has been made.
10.33 In recent years, there has been growing concern about the loss of public houses in the
UK. In April 2015, Government changed the permitted development rights to provide a
greater level of protection to pubs listed as Assets of Community Value (ACV). Developers
must also now submit a written request to the local authority to determine whether the
building has been the subject of an ACV nomination prior to carrying out any development
that has the benefit of permitted development rights and no development can be carried out
or a period of 56 days following the date of the request to the local authority.
10.34 Within the OPDC are there are currently three public houses. These are:
- The Castle in North Acton;
- The Fishermans Arms on Old Oak Lane; and
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-

The Grand Junction Arms on Acton Lane.

10.35 At the time of the production of this Local Plan, none of the three public houses are
listed as ACVs.
10.36 OPDC considers that pubs can act as hubs for community life, which is important for
mental health and wellbeing. They provide a social space and promote community cohesion,
provide economic benefits by providing jobs, supporting local food suppliers, bringing activity
to high streets and can also provide heritage value. As a Healthy New Town OPDC
proposes that the Local Plan looks to protect its public houses, subject to their continuing
viability. For any proposal to be considered acceptable, OPDC will require applicants to
submit detailed accounts data for at least the past year and also that the proprietor has
appropriately marketed the property as a public house at a reasonable rate and has not had
a suitable offer.
Alternative Policy Options
1. OPDC takes a more flexible approach to the loss of public houses and does
not set out stringent requirements for information on accounts and marketing
of the property.
10.37 This approach would have potential advantages of it allowing for the optimisation of
development on sites occupied by public houses. This approach may however result in the
loss of pubs that provide a valued community facility and has therefore not been identified as
the preferred policy option.
Consultation Questions
QSI5a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, should the proposed Local Plan adopt the
alternative policy option as the preferred option?
QSI5b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?

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11. TRANSPORT
Transport
11.1

This chapter contains policies addressing the following policy themes:

T1: Strategic Policy for Transport

T2: Walking
T3: Cycling
T4: Rail
T5: Buses
T6: Roads and streets
T7: Parking
T8: Freight, servicing and deliveries
T9: Construction
T10: Transport Assessments and Travel Plans
Consultation Question
QTa: Are there any other transport policy themes that you think OPDCs Local Plan
should be addressing?

Evidence Base
Study
OPDC Old Oak
Strategic
Transport Study
OPDC Park Royal
Transport
Strategy (PRTS)
OPDC Walking,
cycling and
public realm
strategy
TfL North Acton
study

Scope
A strategic assessment of the existing transport
provision in Old Oak, the impact of the planned future
growth and identification of the transport interventions
required to mitigate those impacts.
A strategic assessment of the existing transport
provision in Park Royal, the impact of the planned
future growth and identification of the transport
interventions required to mitigate those impacts.
A strategy setting out recommendations for the public
realm, public open space and walking and cycling
infrastructure for the OPDC area.
This study investigates the options for enhancing the
capacity and accessibility of North Acton station and
options for improving the permeability of the site.

Status
Completed

Draft
completed

To be
developed

Draft
completed

T1: Strategic Policy for Transport

Key Issues
1. The key transport challenges across the development area include a congested
strategic and local road network, limited access to public transport services and poor
pedestrian and cycle environments mainly due to severance and limited provision of
infrastructure.
2. The provision of the HS2/ Crossrail/ National Rail station will transform accessibility
of this part of west London and will provide an opportunity to rethink transport
provision in the OPDC area.

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3. There is an inherent need to fully integrate new transport infrastructure into the
regeneration area to ensure that development potential can be optimised around
these new and improved accessible transport hubs.
4. Coupled with the significant general background growth and the increase in travel
demand resulting from the new HS2, National Rail and Crossrail station, the
additional homes and jobs created within the development area will add to the
existing travel demand, both at the strategic and local level.
5. It is vital that high quality, safe and accessible transport infrastructure is provided to
facilitate the planned growth and better connect the development area with its
surroundings and other areas of London.
6. Changes to public transport accessibility identified in this draft Local Plan may
require changes to the spatial distribution of density in figure XX. See policy OSP4.
Policy Context
National
11.2. The NPPF emphasises the important role that transport policies have to play in
facilitating sustainable development and in contributing to wider sustainability and health
objectives and notes that the transport system needs to be balanced in favour of sustainable
transport methods that are efficient, safe and accessible and that have a low impact on the
environment.
Regional
11.3. The Mayors London Plan (2015) states the Mayors commitment to improving the
environment by encouraging more sustainable means of transport, through a cycling
revolution, improving conditions for walking and enhancing public transport.
Preferred Policy Option:
OPDC will support proposals that:
a) Deliver a state of the art, safe and accessible transport system, by providing
infrastructure that connects communities and helps facilitate growth in and
around the Old Oak and Park Royal area;
b) Ensure new transport infrastructure is fully embedded into the area and that
Old Oak and Park Royal is fully integrated with its surrounding areas.
c) Prioritise sustainable transport modes and support modal shift from private
cars; and
d) Implement and safeguard future innovative and smart technologies that
maximise the efficiency and interoperability of the transport network.
Justification
11.4. Old Oak Common HS2 station presents a once in a lifetime opportunity to catalyse
the comprehensive regeneration and deliver a step change in public transport access across
Old Oak and Park Royal. Providing quality connections to this transport super-hub through
the delivery of state of the art transport infrastructure will be a key aspect in the success of
the OPDC area.
11.5. There is and will be a large number of people working, living and moving within the
area and to support this it is vital to relieve pressure on the road network and connect key
origins and destinations with sustainable transport modes. Proposals should prioritise
pedestrians and cyclists as the most important travel modes, followed by public transport
and then, as appropriate, the private vehicle. This approach will support a shift towards
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sustainable transport modes by changing people's behaviour and attitude towards car use. It
is recognised that businesses in Park Royal will require vehicle movement by road,
particularly for servicing and deliveries and this should continue to be supported but also
carefully planned so as to mitigate potential negative impacts from increased traffic. There
are opportunities to optimise the number of journeys on more sustainable modes in
particular for employees travelling to work which will in turn free up capacity for essential
freight movements and deliveries.
Figure XX: Prioritisation of road users: [pedestrians-cyclists-public transport-private vehicles]
11.6. Encouraging transport improvements that are both sustainable and technologically
innovative will deliver enormous quality of life benefits and deliver a step change in the
appeal of walking and cycling as healthy, active travel options. OPDC is striving to become
an exemplar NHS Healthy New Town and to gain WHO Healthy City status. Provision of
healthy street environments that encourage walking, cycling and public transport use must
be sought.
11.7. The scale of development at Old Oak and Park Royal offers an opportunity to deliver
transport improvements that are at the vanguard of sustainability and innovation. Whilst
advances in technology can have wide-ranging impacts, some major advances in transport
are already being developed; including automated vehicles (trains, buses, cars, taxis)
improved accuracy of passenger information, the proliferation of wearable technology,
drones, ticketless technology and sensors to detect traffic congestion and cycling and
vehicular parking availability. Smart transport solutions should be identified at an early stage
and, where possible, safeguarded for future implementation.
Alternative Policy Options
1. Giving priority to car travel
11.8. This policy option would support proposals which prioritise cars above more
sustainable modes, which may benefit some businesses and residents. However, by
facilitating the use of private vehicles, congestion, noise and emissions would increase and
fewer people would make journeys by foot, bike or public transport impacting on health and
well-being.
Consultation Questions
QT1a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, should the proposed Local Plan adopt the
alternative policy option as the preferred option?
QT1b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
Policy T2: Walking
Key issues
1. Walking is the most sustainable form of transport and encouraging increased walking
will have many advantages including economic and health benefits, more connected
neighbourhoods and fewer road traffic injuries. Through an increase in footfall, the
vitality of an area is likely to increase and subsequently bring benefits to local
businesses.
2. The propensity to walk is influenced not only by distance but also by the quality of the
walking experience. The existing pedestrian environment within the development
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area is poor. There is limited permeability and a lack of lighting and active frontages,
which creates an unwelcoming streetscape, a perception of poor personal security
and a fear of crime, particularly after dark.
Policy Context
National
11.9. The NPPF states the requirement for planning principles to actively manage patterns
of growth to make the fullest possible use of public transport, walking and cycling. It
indicates that where practical key facilities such as primary schools and local shops should
be located within walking distance of most properties.
Regional
11.10. The London Plan indicates the requirement for transport proposals to bring about a
significant increase in walking in London through emphasis on the pedestrian and street
environment, promoting simplified streetscapes, decluttering and access for all users. In
addition, TfLs Health Action Plan identifies the need for a whole street approach to make
streets more inviting for walking and cycling and better for health.
Figure XX: Diagram of indicators of a healthy street environment. Ref: TfL Health Action
Plan (2014)
Preferred Policy Option:
Development proposals will be required to:
a) Provide high quality, safe, direct and accessible walking networks;
b) Support healthy lifestyles;
c) Provide new and enhance existing walking infrastructure;
d) Maximise active frontages and promote a fine grain development that creates
an interesting and varied streetscape;
e) Connect to existing and planned pedestrian links in the wider area; and,
f) Support and provide infrastructure for the Legible London scheme.
Figure XX: Map of existing walking routes and new walking connections.
Justification
11.11. Redevelopment presents an opportunity to enhance existing and provide new
pedestrian environments across Old Oak and Park Royal. High quality pedestrian walking
routes to Old Oak Common Station from all areas will be vital to ensure residents, workers
and businesses can benefit from this new transport superhub. By providing a street network
that is safe, attractive and easy to navigate, people will be encouraged to walk more, which
will have social, economic, environmental and health benefits and support the viability of the
development area.
11.12. Walking provision should be safe, well lit, direct, comfortable, coherent and attractive
and should integrate well with the street environment and desire lines, minimising conflict
between different users.
11.13. Legible London signage should be implemented throughout the area to provide clear,
comprehensive and consistent wayfinding information and enable pedestrians to complete
more journeys on foot. New connections and wayfinding to both existing and proposed
strategic walking routes and to key destinations such as Harlesden, Park Royal and North
Acton should also be provided.

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11.14. To minimise severance and encourage permeable movement in Old Oak, it is
important to provide a number of new links under or over existing barriers. Where possible
the early delivery of these elements will help set a precedent for a shift towards sustainable
transport modes.
Alternative Policy Options
11.15. No reasonable alternative policy options have been identified, as it is considered that
an alternative approach to that outlined in the preferred policy option would not be consistent
with the NPPF, in general conformity with the London Plan or supporting evidence base to
the Local Plan (Old Oak Strategic Transport Study, PRTS), or deliver the required pedestrian
improvements.
Consultation Questions
QT2a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, are there any other policy alternatives that could
replace the preferred policy or should be considered as alternatives?
QT2b: Do you agree with the proposed walking connections set out in figure XX? If
not, do you have any alternative suggestions?
Policy T3: Cycling
Key Issues
1. After walking, cycling is the next most sustainable transport mode.
2. Cycling on Londons main roads has risen by 173 per cent since 2001.
3. The expected growth of cycling up to 2026 is estimated to deliver 250m in economic
health benefits annually.
4. The development area has a number of physical barriers to cycling including the rail
lines, canals, roads (including the A40 and A406) and a lack of through routes. There
is currently a lack of cycling infrastructure and wayfinding, which encourages a
greater number of people to use their private cars.
Policy context
National
11.16. The NPPF states the requirement for planning principles to actively manage patterns
of growth to make the fullest possible use of public transport, walking and cycling.
Regional
11.17. The London Plan indicates a target for cycling in London to account for at least 5% of
modal share by 2026 and the Mayor of Londons Cycling Vision sets out a target to double
cycling over the next 10 years (March 2013).
Preferred Policy Option:
Development proposals should:
a) Provide state of the art cycling infrastructure;
b) Provide new and enhance and provide links to existing, cycle connections to
ensure they are safe, convenient and direct, but not to the detriment of
pedestrians;
c) Implement signage to improve cycle wayfinding and legibility;
d) Promote and help to deliver cycle hire schemes within the OPDC area;
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e) Promote safety and security measures for cyclists; and
f) Require secure, integrated, convenient and accessible cycle parking facilities
that at least meet the standards set out in the London Plan.
Figure XX: Map of existing cycling routes and new cycling connections.
Justification
11.18. The Mayors Vision for Cycling and the London Cycling Design Standards,
encourage a bold approach to making better, more attractive streets and spaces for
pedestrians and cyclists. Higher levels of cycling can be achieved through the delivery of
infrastructure that is safe, direct, comfortable, coherent, attractive and adaptable, whilst
ensuring consideration is given to the impact of cycling infrastructure on pedestrians.
11.19. In Old Oak, redevelopment provides an opportunity to push the boundary and
provide state of the art cycling infrastructure that can benefit everyone who lives and works
in the area. Adoption of best practice from the mini-Holland projects should be the norm, with
connections to existing and proposed commuter routes such as the proposed East-West
cycle superhighway and to Quietways, such as along the Grand Union Canal.
11.20. The Park Royal Transport Strategy (PRTS) shows that the vast majority of
employees live within 8km of Park Royal with a significant concentration within 5km or less.
This distance is well within cycling distance subject to the appropriate infrastructure and
safety measures being in place. It is important to realise a shift towards cycle usage for
commuters through good design of cycle routes, connections to existing and proposed cycle
networks and better cycle infrastructure.
11.21. Interventions are also needed to reduce severance across the A40 and A406 and
improve wayfinding in order to improve cycle connectivity to and from Old Oak and Park
Royal from surrounding areas and nearby local centres such as Harlesden, White City,
Queens Park and Ladbroke Grove.
11.22. Investments in end-of-journey cycle facilities in the form of secure cycle parking,
lockers and showers are also vital across Old Oak and Park Royal. Major employers,
businesses and landowners should invest in this infrastructure, recognising its value and
importance to their businesses, tenants and employees. OPDC will work with businesses to
develop training and guidance and improve awareness of the benefits of cycling to
employees, to encourage more cycling.
11.23. Cycle parking should cater for future demand, in line with the quantitative and
qualitative requirements set out in the London Cycling Design Standards (2014), providing
numbers in excess of London Plan minimum standards. This will include private cycle
parking for residents and employees as well as generous provision for visitors and high
quality facilities at public transport interchanges. The necessary spatial and design
requirements will need to be factored in from the outset and should not impede pedestrian
movement. Cycle wayfinding signage will be required to improve the legibility and navigation
to, from and through the area.
11.24. A future extension of Cycle Hire into Old Oak and Park Royal would represent a
logical expansion westwards. Subject to further analysis, a network of docking stations could
be designed across the new development areas from the outset and built at the appropriate
timings. Funding for the docking stations should be sought from contributions from
developers as there are currently no plans by TfL to extend the network in this area. OPDC
will also support proposals for infrastructure for other cycle hire schemes.

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Alternative Policy Options
11.25. No reasonable alternative policy options have been identified, as it is considered that
an alternative approach to that outlined in the preferred policy option would not be in
conformity with the NPPF, London Plan or supporting evidence base to the Local Plan (Old
Oak Strategic Transport Study, PRTS), or deliver the required cycling improvements.
Consultation Questions
QT3a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, are there any other policy alternatives that could
replace the preferred policy or should be considered as alternatives?
QT3b: Do you agree with the proposed cycling connections? If not, do you have any
alternative suggestions?
Policy T4: Rail
Key issues
1. The new HS2, Crossrail and National Rail station at Old Oak Common will be a key
driver for regeneration in the area.
2. When built out the core area at Old Oak will be served by approximately ten different
rail services and over 200 trains per hour at peak times.
3. The Old Oak area is currently served by Willesden Junction and North Acton
stations, providing London Overground, Bakerloo and Central line services. Park
Royal is served by North Acton, Park Royal, Hanger Lane and Stonebridge Park
stations providing Central, Bakerloo, Piccadilly Line and London Overground
services.
4. The stations are on the periphery of both areas and access to them by foot or by
cycle is currently limited due to the lack of safe and appropriate routes.
5. Existing stations are well used with some crowding at North Acton and Willesden
Junction which is predicted to increase without station improvements.
6. By 2030, it is predicted that existing services running through the area will be at
capacity, without upgrades.
Policy context
National
11.26. The NPPF states the requirement for planning principles to actively manage patterns
of growth to make the fullest possible use of public transport, walking and cycling.
Regional
11.27. The London Plan indicates the importance of improving public transport to increase
its appeal relative to the private car. By improving accessibility and capacity within the south
east of England and beyond, London will maintain its attractiveness as a place to work, visit
and do business.
Preferred Policy Option:
Development proposals will be supported where they:
a) Facilitate the delivery of:
i.
a state of the art rail station at Old Oak Common with the highest quality
architecture that provides interchange between HS2, Crossrail and
National Rail services;
ii.
two new London Overground stations and supporting infrastructure
including high quality links to the HS2/ Crossrail station;
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iii.

substantial capacity improvements to existing London Underground

and Overground stations, particularly Willesden Junction and North
Acton;
iv.
an exceptionally designed intermodal interchange;
v.
links between stations that facilitate the safe, efficient and sustainable
movement of passengers;
vi.
improved services on existing infrastructure;
vii.
a rail connection between the Great Western Mainline (GWML) and the
West Coast Mainline (WCML);
b) Ensure that the impact on existing rail infrastructure is minimised during
construction;
c) Enable new rail routes to improve connections to the OPDC area; and
d) Enable future proofing of station design and services to enable smart
technology to be implemented.
Figure XX: Map of existing and proposed rail connections
Justification
11.28. The new Old Oak Common Station and surrounding interchange will be a key driver
for regeneration in the area and will be the focus of future transport connections. It will
provide better connections to west London and the rest of the UK. The station is being
designed to accommodate 250,000 passengers a day, which is comparable in capacity to
Waterloo station.
11.29. This could be further supported by a potential link from Crossrail to the West Coast
Main Line (WCML), which could provide additional connections from north-west London and
Hertfordshire including, potentially, Wembley Central. This would also provide opportunities
for Crossrail trains to run northbound towards Tring. At the time of writing this plan no
feasibility work has been carried out into the benefits, business case or delivery.
11.30. Two new London Overground stations will also be built at Old Oak Common Lane
and Hythe Road. The new London Overground stations will provide excellent local and
subregional connections and will support development by extending the catchment area for
new commercial activities bringing 250,000 additional people and 150,000 additional jobs
within an hours journey of Old Oak. OPDC will ensure the delivery of high quality links
between the London Overground stations and the Old Oak Common HS2/ Crossrail and
National Rail station. The challenges associated with delivering these stations should not be
underestimated. At the time of writing this draft Local Plan the proposed London Overground
stations are at initial feasibility stage only. Funding has now been secured to further progress
the design and business case for these. However, currently there is no capital funding
secured for the delivery of these stations. The final arrangements for these stations will be
dependent on the outcome of this work.
11.31. The Park Royal Transport Strategy identifies the need to improve the public realm,
accessibility and permeability of stations in Park Royal in order to encourage a higher rail
mode share.
11.32. All of the stations within the area will need to incorporate a legible, safe and
accessible transport interchange between different modes of travel and particularly between
public transport, pedestrians and cyclists. High quality walking and cycling routes between
stations will also be important.
11.33. A strategic rail study will be carried out to determine how rail connections to the
OPDC area from a range of rail corridors across Central London and beyond can be
improved. This will include consideration of fare zones and rail links to airports.
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11.34. There are a range of potential smart rail innovations that could be achieved with
advances in technology, many of which are already being trialled across the world today.
These include ticketless and security technology which eliminates gate-lines in stations and
enables 360 access, intelligent robots to repair and maintain infrastructure, energy flooring
that generates electricity from footfall, virtual shopping walls, underground freight pipelines
for moving goods, real-time passenger information for seamless journey planning,
monitoring drones for predictive maintenance and improved security, intelligent robots to
unload and sort cargo and automated passenger trains. There are significant opportunities
now to embed flexibility into rail design to support smart technology in the future.
Alternative Policy Options
11.35. No reasonable alternative policy options have been identified, as it is considered that
an alternative approach to that outlined in the preferred policy option would not support the
necessary rail capacity requirements, nor be consistent with the NPPF, London Plan or
supporting evidence base to the draft Local Plan.
Consultation Questions
QT4a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, are there any other policy alternatives that could
replace the preferred policy or should be considered as alternatives?
QT4b: Do you have any suggestions of additional rail connections to the OPDC area
that should be provided?
Policy T5: Buses
Key issues
1. Five bus routes serve Old Oak and 15 bus routes serve Park Royal with frequencies
of between approximately 6-15 minutes.
2. The bus routes provide links to surrounding areas including; Acton, Harlesden,
Hammersmith, Shepherds Bush, White City and local London Underground/ National
Rail stations.
3. Today there are a number of parcels of land in both Old Oak and Park Royal which
are inaccessible to the bus network because they are outside the recommended
400m walk distance to bus stops.
4. Buses are well used particularly to access Willesden Junction and North Acton
stations and to access local services such as the Asda supermarket located in Park
Royal Centre.
5. Bus journey time reliability in the area is affected by congestion on the local and
strategic road network. It will be important to ensure bus journey time reliability is
improved and then protected from development impacts in the future.
6. There is a need to deliver a comprehensive new bus network to serve new
developments at Old Oak and to improve services within Park Royal.
Policy context
National
11.36. The NPPF states the requirement for planning principles to actively manage patterns
of growth to make the fullest possible use of public transport, walking and cycling.

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Regional
11.37. The London Plan indicates the importance of buses in London and therefore, how
important it is to deliver improved journeys for bus passengers which will lead to increased
bus use.
Preferred Policy Option:
Proposals should deliver/contribute to:
a) Increases in bus frequencies on existing routes and new and extended bus
routes;
b) Infrastructure to improve bus journey time reliability including bus priority
measures;
c) New and improved bus stops, including access to real-time travel information
at bus stops; and,
d) Clear and legible signage for bus users.
Figure XX: Map showing existing bus routes and indicative future routes.
Justification
11.38. Good provision of bus services and bus infrastructure is a key contributor to a high
public transport modal share and reduces the impact of developments on the surrounding
road network. Bus services will be particularly important in the early phases of development
before the new rail stations are delivered.
11.39. A review of the bus network in the Old Oak and Park Royal areas will be carried out
in conjunction with TfL London Buses. Increased bus services and frequencies would
provide improved connections to homes, office and retail destinations in Old Oak and Park
Royal reducing dependence on the private car.
11.40. Connections to new rail stations should take priority to capitalise on new transport
services. There is also a need to secure improved bus connections between Old Oak and
Park Royal to ensure that the existing community can take advantage of the benefits the
new interchange at Old Oak Common would bring to the area.
11.41. New bus routes should provide direct links from other parts of London on corridors
not served directly by rail or underground services and ensure that surrounding residential
areas benefit from the new opportunities brought by development.
11.42. All new roads to be used by buses must allow appropriate highway clearance for the
largest double deck vehicles and be built to an adoptable standard with sufficient widths.
Infrastructure should include bus priority measures such as priority at junctions, bus gates
and bus only links as well as suitably located bus stops, stands and welfare provision for
drivers.
11.43. London's green bus fleet is the largest in the world, combining the roll out of new
hybrid buses, the early introduction of new Euro VI buses and the retrofit programme,
leading to significant improvements in emissions throughout London. As infrastructure
improves, more routes will be served by electric buses and supporting infrastructure should
be considered from the outset in the design of transport infrastructure in the OPDC area.
Alternative Policy

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11.44. No reasonable alternative policy options have been identified, as it is considered that
an alternative approach to that outlined in the preferred policy option would not support the
necessary bus improvements required.
Consultation Questions
QT5a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, are there any other policy alternatives that could
replace the preferred policy or should be considered as alternatives?
QT5b: Do you have any suggestions for how the bus network could be developed in
the future to serve the OPDC area ?
Policy T6: Roads and Streets
Key Issues
1. The regeneration area is within close proximity to a number of key strategic road
corridors including the A40 and A406. These corridors experience significant
congestion.
2. The local road network is limited and in many cases does not meet current highway
design standards due to narrow lanes and poor sight lines. The limited local road
network already forces local traffic to use the strategic network unnecessarily, while the
extent and usefulness of bus routes is also impeded by the limited road network close to
and within the OPDC area.
3. As with walking and cycling, the rail lines and the Grand Union Canal restrict
vehicular movements.
4. Localised congestion is also an issue with most roads and junctions operating at or
close to capacity.
5. Congestion at key junctions and on links providing access to strategic routes is a
barrier to business growth.
6. New bridges providing new links to join up areas severed by the rail lines and the
Grand Union Canal may be required.
Policy context
National
11.45. The National Planning Policy Framework indicates a need to establish a strong
sense of place, using streetscapes and buildings to create attractive and comfortable places
to live, work and visit.
Regional
11.46. The Mayor supports the need for improvements to Londons road network where it is
required to improve or extend existing capacity and provide new links. Congestion is
estimated to cost the economy 4 billion a year and stalled traffic in London has been found
to lead to 8% more CO2, 6% more particulates (PM10) and 9% more nitrogen dioxide (NO2)
emissions than free-flowing traffic.
Preferred Policy Option:
Development proposals should:
a) Provide a range of new streets that help overcome severance and optimise
connectivity;
b) Enhance existing streets and junctions to mitigate the impacts of development
on the surrounding local and strategic road network;

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c) Deliver high quality streets with robust and coordinated materials that
integrate effectively with the wider public realm;
d) Ensure that streets give priority to pedestrians, cyclists and buses; and
e) Promote effective and integrated management of streets to future-proof for
innovations in technology.
Figure XX: Map of existing road network and new connections that need to be provided
Justification
11.47. The road network within Old Oak and Park Royal should better serve local
communities, contribute positively to the urban realm and facilitate improved pedestrian,
cycle and bus connections.
11.48. The Roads Task Force (RTF) Street Types classification, adopted by TfL, recognises
that different roads have different "moving" and "living" functions and therefore require
different approaches. RTF Street Types will be used to identify the movement and place
functions of the existing and future network of streets across Old Oak and Park Royal.
Figure XX: Street types matrix
11.49. In Old Oak, measures to prioritise bus movements, provide segregated facilities for
cyclists and create pedestrian priority areas will be supported. In Park Royal, the road
network will need to support the movement of freight to facilitate business growth. This will
need to be carefully planned alongside the need to improve bus movements, pedestrians
and cyclists and deliver a healthy street environment. Any through routes used by general
traffic should be designed to avoid rat-running including traffic calming and controlled
crossing facilities. 20 mile per hour speed limits will be explored. Managing vehicle
movement and speed should be achieved through good design, rather than merely signage.
All new and improved roads must be built to adoptable standards and any decision to adopt
streets would need to be made in collaboration with the relevant local councils.
11.50. The strategic road network, particularly the A40 and A406, is vital to the successful
operation of Park Royal and will be in the future to Old Oak, both during construction and
once the area is developed. OPDC will work with TfL and relevant local councils to realise
improvements to the A40 junctions and corridor.
11.51. It will be important that the amount of traffic generated during construction and
development activity is limited to what the strategic road network including the A40 and A406
can handle without having a negative impact on the strategic function of these routes. OPDC
will be developing a Construction and Logistics strategy, which will help to inform, plan for
and minimise the impact of construction and development activity.
11.52. It will also be important to improve the connectivity across the A40 for pedestrians,
buses and cyclists. A study of the A40 junctions close to the development area (Savoy
Circus, Gypsy Corner, Hanger Lane), is being carried out to understand the cumulative
impact of growth at Old Oak and Park Royal and to identify potential long-term solutions,
including tunnelling options.
Alternative Policy Options
11.53. No alternative policy options have been identified that meet the requirements of the
guidance set out in the Local Plan and the aspirations for the development area.
Consultation Questions
QT6a: Do you agree with the preferred policy option? If so, what might you change
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about the preferred policy? If not, are there any other policy alternatives that could
replace the preferred policy or should be considered as alternatives?
Policy T7: Car Parking
Key issues
1. Managing car parking plays an important role in controlling the number of cars
generated from a development and minimising the developments impact on the
surrounding highway network.
2. The modelling work completed for the Old Oak Strategic Transport Study indicates
that the road network would not be able to accommodate additional development
related traffic unless parking was restricted to very low levels across the Old Oak
development area.
3. Today the Park Royal estate has around 12,000 off-street parking spaces. The mode
share is 53% by car (including driver and passengers) with average vehicle
occupancy of 1.06. On-street parking is largely uncontrolled and causes obstructions
to freight traffic, buses, cyclists and pedestrians. This needs a thorough review and
sensitive regulation.
Policy context
National
11.54. The NPPF requires local authorities to consider accessibility, availability of public
transport, car ownership levels and the importance of reducing emissions when setting
parking standards.
Regional
11.55. All developments in areas of good public transport accessibility should aim for
significantly less than 1 space per unit. It also states that developments must ensure that 1
in 5 spaces provide an electric charging point to encourage the uptake of electric vehicles.
Preferred Policy Option:
OPDC will ensure the development area is an exemplar of low carbon development
and will promote a modal shift towards more sustainable modes by:
a) In Old Oak:
i.
Limiting car parking to 0.2 spaces per unit for residential developments;
ii.
Promotion of car free development close to public transport hubs; and
iii.
Securing zero car parking for non-residential developments, except for blue
badge holders.
b) In Park Royal:
i.
Limiting car parking to 0.2 spaces per unit for residential developments; and
ii.
Allowing limited car parking for non-residential development taking into
account access to public transport and operational or business needs.
c) When providing car parking, proposals should:
i.
incorporate electric charging points for electric vehicles at all new parking
spaces;
ii.
include and promote provision for car club vehicles and car sharing;
iii.
be sensitively designed; and

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iv.

not take precedence over other street level users or the incorporation of open
space, public realm or open space.

d) Proposals should provide suitable facilities to cater for anticipated demand for
taxis and coaches.
Justification:
11.56. Low levels of car parking will be essential to ensure that traffic congestion does not
reach unacceptable levels. Where justified, some car parking will be provided to meet the
essential needs of development. However, this will need to be carefully planned and
managed to ensure that there are suitable places for disabled people, car clubs and electric
cars and to facilitate the successful operation of the Park Royal industrial estate. Where
possible car parking should be located underground.
11.57. This approach is justified by the very high level of public transport accessibility
resulting from the planned and proposed public transport investment. The need for access to
a car can be met in part by dedicated car club spaces together with parking for disabled
people. Spaces designated for blue badge holders should be located on firm level ground
and as close as feasible to the accessible entrance to the building.
11.58. OPDC will work with the local highway authorities, businesses and local groups to
achieve a co-ordinated approach to the potential implementation of Controlled Parking
Zones (CPZs) across the area to protect residents living close to stations and high streets
and to discourage journeys made by car, which could be made by more sustainable
transport modes. Car club vehicles spread across the site will provide access to a car when
needed for specific journeys and car club bays will need to be designed into the new
development areas at the outset.
11.59. There is likely to be a strong demand for taxis and private hire vehicles (PHVs)
generated by the HS2/ Crossrail/ National Rail interchange. The interchange will be
designed with fully accessible taxi ranks and facilities for PHVs. It will be important to
carefully manage onward journeys from stations to avoid large numbers of people using
taxis and PHVs instead of walking, cycling or using the bus network. Where specific
development types will attract a large number of visitors, facilities for coach parking and pick
up and drop off areas will need to be provided.
Alternative Policy Options
1.

Setting less stringent car parking standards.

11.60 This policy option would offer greater choice. However, transport modelling outputs
indicate this is likely to place unacceptable impacts on the surrounding road network,
discourage a mode shift towards the use of more sustainable transport modes and increase
emissions. As such this policy goes against OPDCs aspirations and the transport policies
detailed in this draft Local Plan.
2.

Car free no residential car parking. Only blue badge.

11.61 This policy option would enable a modal shift towards the use of more sustainable
transport modes and would reduce traffic flow and congestion. However a low amount of car
parking spaces is considered necessary to meet the essential needs of development,
particularly ensuring that there are suitable places for disabled people, car clubs and electric
cars. A car free policy option would also negatively impact businesses that rely on private
vehicles, particularly in Park Royal.

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Consultation Questions
QT7a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, should the proposed Local Plan adopt one of the
alternative policy options as the preferred option?
QT7b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
Policy T8: Freight, Servicing and deliveries:
Key Issues
1. Light freight journeys are responsible for 80% of freight miles on Londons roads. TfL
estimates that by 2030 this will grow by 43%. The growth in e-commerce and
personal deliveries is a major contributor.
2. Freight activity is a significant feature of the development area due to the needs of
the Park Royal industrial estate, the proximity to Heathrow Airport and the strategic
road network (A40 and A406) providing links to Central London.
3. The significant HGV activity in the development area can have negative impacts on
the environment in terms of noise and air quality and causes congestion, particularly
on Scrubs Lane.
4. The volume of freight and servicing movements also raises challenges in terms of
maintenance and management of the road network and the safety and environment
for other road users.
5. Coordination of HGV activity across the development area will be important in order
to mitigate those impacts.
6. There is also rail freight activity within the wider Park Royal area utilising the Great
Western Main Line and West Coast Main Line routes (including at various sites
around Willesden such as the Euro Freight Terminal) which handle inbound flows of
aggregates and cement and outbound flows of waste, mail and, until recently, scrap
metal.
7. Currently there is unrealised potential for water borne freight on the Grand Union
Canal with a wharf facility located on the Powerday site.
Policy Context
National
11.62 The NPPF indicates that planning authorities should work with neighbouring
authorities and transport providers to develop strategies for the provision of infrastructure
necessary to support sustainable development, including rail freight interchanges.
Regional
11.63 London plan policy indicates a need to ensure deliveries are efficient and highlight
the use of consolidation centres, not just for construction purposes, but also for deliveries.
Preferred Policy Option:
OPDC will require proposals to:
a) Secure Delivery and Servicing Plans (DSPs) through planning agreements;
b) Identify potential sites for consolidation centre(s) and lorry holding areas;
c) Require off-street servicing facilities within new developments, ensuring
this does not impact on the public realm;
d) Encourage the provision of facilities for home deliveries within residential
developments;
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e) Provide opportunities for click and collect sites;
f) Identify more efficient and sustainable ways of delivering goods including
encouraging the use of cargo bikes;
g) Ensure that the operators of all freight vehicles operating in the area have
attained the Gold Fleet Operator Recognition Scheme (FORS) accreditation
so that they have made proven efforts to reduce emissions; and
h) Implement and safeguard for future innovative and smart technologies in
relation to freight that maximise the efficiency and interoperability of the
transport network.
Justification
11.64 Servicing and delivery requirements in Old Oak and Park Royal need to minimise the
impact on the surrounding road network. In new developments, off street solutions for
servicing should be adopted, where possible, utilising different ground levels including
basement and void areas within multi storey structures. Street frontage servicing should be
minimised and restricted to small individual units located on lightly trafficked streets which
can be serviced by small delivery vehicles. A number of sites within the OPDC area have
good access to the canal and rail lines. Opportunities to use rail and water transport for
freight should be explored.
11.65 A Delivery and Servicing Plan (DSP) will manage deliveries to reduce the number of
trips, particularly during peak hours and identify safe and legal loading locations and ensure
the use of delivery companies who can demonstrate their commitment to best practice such
as FORS members. The DSP will help to identify more efficient ways of delivering goods,
including:
- Delivery booking systems which could be implemented to ensure that deliveries are
managed according to the capacity of the loading facilities available;
- Moving deliveries outside of peak or normal working hours. This approach was
successfully used during the London 2012 Olympic Games;
- Suggest alternative routings to avoid congestion;
- Encourage the adoption of low emission vehicle options (buying or leasing); and
- Promote white labelling and encourage collaboration amongst companies.
11.66 A consolidation centre would help to minimise vehicle journeys, while also improving
delivery reliability and efficiency. This would reduce the number of journeys needed and
minimise disruption for the recipient. The preferred policy option for Policy P9 (Chapter 4)
identifies the potential to use the High Speed 2 works sites as temporary consolidation
centre to support the construction of Old Oak and explore the potential to use the northern
High Speed 2 works site as a longer term rail freight consolidation centre. The potential for a
consolidation centre in west London is also being explored through Westrans West London
Freight Study.
11.67 OPDC is inviting stakeholders (see question QT8d below) to suggest other potential
sites in the OPDC area that could accommodate a freight consolidation centre or lorry
holding area, which would be used to minimise HGV movements within the OPDC area and
potentially also the surrounding area and help have positive benefits for the highway network
and the environment.
11.68 FORS is an overarching scheme that encompasses all aspects of safety, fuel
efficiency, economical operations and vehicle emissions. FORS accreditation encourages
freight operators to become safer, greener and more efficient and has been achieved by
operators across London. The highest standards should be applied in the Old Oak and Park
Royal area.
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Alternative Policy Options

1. No controls over deliveries and servicing.
11.69 This policy option may have some attraction for businesses. However, if no
measures were put in place to control servicing and deliveries, HGVs and LGVs flow would
increase drastically, exacerbating the congestion issues in the development area, as well as
having noise and environmental impacts, affecting the public realm and using up road space.
2. Ban deliveries and servicing by larger vehicles.
11.70 This policy option would provide benefits to the public realm, pedestrians and cyclists
and would reduce the congestion sometimes caused by HGVs. However, banning larger
vehicles completely would negatively impact businesses.
Consultation Questions
QT8a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, should the proposed Local Plan adopt one of the
alternative policy options as the preferred option?
QT8b16: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
QT8c: Do you think the HS2 work sites could be a suitable location for a freight
consolidation centre?
QT8d: Are there any other potential sites within the OPDC area that you would
suggest could operate as a freight consolidation centre?
Policy T9: Construction
Key Issues
1. There will be a number of concurrent construction projects associated with delivering
the HS2 and Crossrail proposals as well as the developments proposed across the
area.
2. Construction traffic will increase the volume of HGVs and other construction vehicles
on the local and strategic road network. This will need careful planning, coordination
and management to minimise its traffic and environmental impacts and to ensure that
its as safe as possible, particularly for cyclists and pedestrians.
3. A Construction Logistics Strategy will be developed by TfL and OPDC to ensure a
coordinated approach, which will minimise the disruption to surrounding residents
and business.
Policy Context
National
11.71 The National Planning Policy Framework does not include any specific policies
relating to construction.
Regional
11.72 The congestion and environmental impacts from freight activity should be minimised
and innovative approaches to manage Londons freight needs should be explored.
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Preferred Policy Option:

Development proposals should:
a) Provide for measures to reduce freight and construction trips, by:
i.
Securing a Construction Logistics Plan and Construction Code of
Practice from major developments;
ii.
Promoting the use of freight and construction consolidation centres;
b) Make maximum use of rail and water transport for construction and freight;
and
c) Co-ordinate and phase construction projects to enable the transport impacts to
be effectively mitigated.
Justification
11.73 Redevelopment in Old Oak alongside major infrastructure projects will generate a
large amount of construction vehicle movements, exporting waste and importing materials
over a number of decades. The amount of construction activity planned for the area provides
an opportunity for sustainable transport solutions to be adopted. The freight consolidation
centre described in policy T8 could be used to reduce the number of construction vehicles
required and the number of construction vehicle movements on the road network. Maximum
re-use and recycling of waste and construction materials within the area will reduce transport
demands. For residual movements, there is potential for bulk construction materials and/or
waste to be transported by rail and canal although issues of local environmental impact and
commercial viability will need to be addressed.
11.74 To coordinate construction transport across the development area, OPDC will require
Construction Codes of Practice and Construction Logistics Plans to be submitted by
developers. These will need to be aligned to the overarching Construction Logistics Strategy
that OPDC and TfL will prepare, which will set in place the area wide requirements for
construction transport.
Alternative Policy Options
1.

There is no control or co-ordination of construction transport

11.75 This would enable individual projects to programme construction works without any
co-ordination with other projects. However, given the number of construction projects, a lack
of coordination would lead to very high volumes of construction vehicles on the road network
which would also have noise and environmental disbenefits.
2. All freight has to be moved by rail or water
11.76 This policy option would reduce the impacts of construction on the road network and
therefore provides noise and environmental benefits. However, there are a number of
reasons why this policy option may not be practical, including the high costs associated with
using only rail and water freight, the lack of capacity for rail and water to take on all of the
construction activity and the need for local transfer from the railhead or wharf.
Consultation Questions
QT9a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, should the proposed Local Plan adopt one of the
alternative policy options as the preferred option?
QT9b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
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Policy T10: Transport Assessments and Travel Plans

Key Issues
11.77 Major developments are likely to generate high levels of movement and have an
effect on the operation of the transport network. As such it is essential that developments
access requirements are planned and their impacts mitigated.
Policy Context
National
11.78 The NPPF states that all developments that generate significant amounts of
movement should be supported by a Transport Statement or Transport Assessment which
assesses the extent to which the development will support opportunities for sustainable
travel, provide safe access for all users and limit its impact on the existing transport system.
Regional
11.79 Any planning application which is referable to the Mayor is accompanied by a
Transport Assessment. It is expected that any Transport Assessment is carried out in
accordance with the TfL Transport Assessment Best Practice Guidance, published in 2014.
Preferred Policy option:
a) Transport assessments and travel plans should be provided for planning
applications exceeding the thresholds in, and produced in accordance with,
the relevant TfL guidance.
b) Construction logistics plans and delivery and servicing plans should be
secured in line with the London Freight Plan and should be co-ordinated with
travel plans.
Justification
11.80 The Transport Assessment will need to assess the transport impact of the
development and ensure that measures to reduce and manage a developments transport
impact are identified and planned. The Travel Plan will provide a long-term strategy to
deliver sustainable transport objectives through an action plan that is regularly reviewed. The
Travel Plan should set objectives and monitoring requirements along with the measures,
management plan and funding details required to meet those objectives. The Travel Plan
should be secured by a planning obligation and include ongoing management. All proposals
for new or significantly expanded schools or other education or institutional uses should be
accompanied by a Travel Plan.
11.81 All development proposals will be assessed for their contribution to traffic generation
and their impact on congestion, particularly on bus routes and on the primary route network,
and against the existing and potential availability of public transport and its capacity to meet
increased demand.
11.82 Proposals for development may come forward which fall below the thresholds for
referring applications to the Mayor of London, but may have a significant effect on highway
or public transport capacity. In these cases, a Transport Assessment may also be sought.
Effective and early pre-application discussions will help to identify whether such a
requirement is likely and will be particularly encouraged where a proposal may fall just below
the relevant thresholds.
Alternative Policy Options

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1.

Requiring a transport assessment for all developments.

11.83 This policy option would enable more scrutiny over developments to ensure they
comply with best practice. In addition it would enable more control over the cumulative
impact of developments on the transport network. However, very small-scale developments
are likely to have a minimal impact on the transport network. Early engagement through the
pre-application advice stage will help to identify any transport planning issues associated
with the development.
2.

Increasing the threshold for schemes that require a transport assessment.

11.84 If the threshold was increased developments could be planned without assessing the
impact of the development on the transport system. This could lead to access issues, a
congested road network and insufficient public transport infrastructure to cope with the
demands of the new development.
Consultation Questions
QT10a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, should the proposed Local Plan adopt one of the
alternative policy options as the preferred option?
QT10b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?

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12. ENVIRONMENT AND UTILITIES
Environment and Utilities
This chapter contains policies addressing the following policy themes:
EU1: Strategic policy for the environment and utilities
EU2: Smart
EU3: Water
EU4: Waste management
EU5: Circular Economy and resource efficiency
EU6: Decentralised Energy
EU7: Digital communications infrastructure
EU8: Green Infrastructure & biodiversity
EU9: Extraction of minerals
EU10: Air Quality
EU11: Noise
EU12: Land contamination
Consultation Question
QSIa: Are there any other social infrastructure policy themes that you think OPDCs
Local Plan should be addressing?

Evidence Base
Study
OPDC Draft Smart
Strategy Interim
Report
OPDC Integrated
Water
Management
Strategy
OPDC Old Oak
Decentralised
Energy Strategy
OPDC Waste
Strategy

OPDC Air Quality

Study

OPDC Green
Infrastructure
Strategy
OPDC Walking,

Description
Sets out key challenges, opportunities and
recommendations in relation to emerging smart
technology.
Review of water infrastructure requirements for water
demand, drainage, and flood risk (including OPDCs
SFRA) and options and costs for integrated water
management.
Review of the potential for a heat network to supply
the Old Oak Common Opportunity Area with
competitive low to zero carbon heat.
A strategy outlining OPDCs approach to waste
apportionment, to accord with the requirements of
paragraph 5.80 of the London Plan (2015), which
requires mayoral development corporations to
cooperate with local authorities to ensure their waste
apportionment requirements are met.
Review of the existing and anticipated air quality
issues across the construction and built-out phases of
development and recommendations for mitigation and
measures to ensure the highest possible air quality for
future residents and workers.
A strategy reviewing existing GI assets, future GI
requirements, and identifying opportunities for
improving function, connectivity and integration with
other infrastructure.
A strategy setting out recommendations for the public
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Status
Draft
completed
Draft
completed

Draft
completed
Draft
completed

Draft
completed

To be
developed

To be



cycling and public
realm strategy

realm, public open space and walking and cycling

infrastructure for the OPDC area.

developed

Policy EU1: Strategic policy for the environment and utilities

Key Issues
1. OPDC is in a position to work with developers and other stakeholders, to push the
boundaries in best practice sustainable development and co-ordinated infrastructure
planning and delivery. In doing so, there is an opportunity to exceed Mayoral targets
for sustainable development and environmental performance and to support
Londons transition to the circular and low/zero carbon economy.
2. There is potential for OPDC to enhance the natural environment integrating it with
new development and infrastructure to improve resilience to the effects of climate
change and helping to optimise the efficient use and re-use of previously developed
land.
Policy Framework
National
12.1 The NPPF sets out a number of core principles achieving sustainable development,
including;
- support for the transition to a low carbon future in a changing climate, taking account
of flooding and encouraging the re-use of existing and renewable resources;
- contributing to conserving and enhancing the natural environment and minimising
pollution to land, air, and water; and
- promoting healthy communities, taking account of strategies to improve health, social
and cultural wellbeing.
Regional
12.2 The London Plan outlines Londons challenges in responding to a changing climate,
ensuring that there is infrastructure to support growth and focussing on providing the highest
quality of life. The Mayors objective is that the city becomes a world leader in improving the
environment.
Preferred Policy Option:
OPDC will support proposals that:
a) Promote environmentally sustainable development that utilises the highest
standards of design, delivery and operation;
b) Deliver best practice in utilising innovation and the application of emerging
technologies;
c) Maximise their contribution to a healthy and safe environment for people
and for nature;
d) Increases the areas resilience to the effects of a changing climate and
minimises carbon emissions;
e) Contribute to the achievement of environmental standards set by OPDC
(see Table XX); and
f) Support delivery of coordinated and area-wide utilities infrastructure.
Table XX. Environmental sustainability targets for development in the OPDC area
Topic Area
Reduce greenhouse gas

Current targets in London Plan/Mayoral Strategies

- Reduce CO2 emissions by 60 per cent from 1990
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emissions
Local energy supply

Waste reduction and

recycling

Green Infrastructure

Water Management

Air Quality

Digital Communications

Circular economy

levels by 2025, and 80% by 2050

All new homes to be zero carbon by 2020
Reduce Londons waste management to save one
mega tonne of CO2 equivalent per year by 2031
Application of the Energy (and cooling) Hierarchy in
the London Plan.
Supply 25 per cent of Londons energy locally,
including the use of decentralised energy networks.
Work towards zero biodegradable/recyclable waste
to landfill by 2026.
90% reuse re-cycling/re-purposing of construction
materials.
Recycling 70% of commercial/industrial waste by
2020.
Recycling of 50% of municipal waste by 2020, and
60% by 2031.
1% reduction in municipal waste per capita per
annum.
increase tree coverage by at least 10%.
all major buildings to include a green, solar or cool
roof and a minimum of 50% of the built environment
footprint to include urban greening measures.
Achieve net gains for nature.
Minimising use of mains water.
Use SuDS to achieve run-off rate equivalent to a
greenfield.
Water efficiency of 105 litres per household per day
to match higher requirements of Building
Regulations.
Meet EU values for air pollutants.
Seek to achieve Air Quality Neutrality.
Apply Ultra Low Emissions Zone standards to NonRoad Mobile Machinery as given in Mayoral SPG on
The Control of Dust and Emissions.
To deliver a world-class network.
Embed Smart solutions.
Support job creation linked to re-manufacturing,
repair, reuse, and recycling.
Consider the application of the GLAs Responsible
Procurement Policy to the OPDC area.

Justification
12.3 OPDC is in a position to push the boundaries of UK best practice in development and
infrastructure and has an objective to be recognised as a leader in sustainability. The
preferred policy option reflects this and aims to deliver a place shaped by innovation that
showcases exemplar sustainable regeneration. Table XX above identifies existing
environmental targets in the London Plan, and in Mayoral strategies which OPDC will be
looking to benchmark itself against when setting its own environmental targets which will be
included in the next draft Local Plan. As part of the next stage of work, OPDC will assess to
what extent these targets can be met or exceeded thereby giving rise to a set of areaspecific standards and targets.

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12.4

Achieving these targets will require:

collaboration between OPDC, developers, infrastructure providers and other
stakeholders, taking advantage of the scale of development and the opportunities
this presents;
an integrated approach to the design, delivery and operation of development and
infrastructure;
taking advantage of the highest standards of design, innovation and the latest
technologies; and
better integration of the built and the natural environment.

12.5 In Old Oak there is a particular opportunity to create a new sustainable community.
Within Park Royal there are opportunities to tackle current issues of pollution, surface water
drainage and digital connectivity. Across both, there is a need to address resilience to
climate change. As part of OPDCs environmental target and performance-setting OPDC will
explore the opportunity to achieve a low or zero carbon development, including the delivery
of low-carbon networks, de-centralised energy supply and district-wide systems for
sustainable drainage and for waste.
Alternative Policy Options
12.6 No alternative policy options have been identified, as alternatives would not be
consistent with the NPPF or in general conformity with the London Plan.
Consultation Questions
QEU1a: Do you agree with the preferred policy option? If not, what might you change
about the preferred policy?
QEU1b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
QEU1c: Do you agree with those area identified above for setting environmental and
sustainability performance targets for the development and infrastructure?
Policy EU2: Smart Old Oak & Park Royal
Key Issues
1. Londons continuing growth alongside the transformative scale of regeneration at Old
Oak and Park Royal creates significant opportunities to integrate smart city
technology solutions and approaches.
2. Smart city technology is a rapidly changing field and OPDC should seek to
encourage flexibility and adaptability.
3. Digital information and data needs to be open and able to be shared and used to
support innovation in the design, implementation and operation of development and
efficient delivery of services post-development.
Policy Framework
National
12.7 The NPPF identifies that advanced, high quality communications infrastructure is
essential for sustainable economic growth and that high speed broadband technology and
other communications networks also play a vital role in supporting the delivery of local
community facilities and services.
Regional
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12.8 The London Plan recognises that smart city technology plays a role in supporting the
delivery of a number of policy areas including economic growth, smoothing traffic flow and
energy generation.
Preferred Policy Option:
a) OPDC will work with partners and stakeholders to position Old Oak and Park
Royal as a world-leading location for the exploration, exploitation and
implementation of smart city technology, approaches and systems.
b) OPDC will require proposals to provide interoperable open and usable data to
inform OPDC activities and processes.
Justification
12.9 A smart Old Oak and Park Royal will be a place where innovation and technology is
explored and harnessed to create opportunities and address challenges / barriers.
12.10 The transformative change proposed across Old Oak and Park Royal and the
timescales involved requires that OPDC considers how the area will function over the
ensuing decades and what role smart city technology and approaches will have.
12.11 Smart City technology and practices are not an end in themselves. They present a
huge opportunity (as enabling elements) to address a diverse range of challenges. The use
of new and innovative technologies may, for example, reduce the need to travel and / or
encourage the use of low /zero emissions modes of transport, thus enhancing the areas
resilience to climate change by reducing greenhouse gas emissions.
12.12 OPDC is developing a Smart Strategy with input from a range of industry experts. It
seeks to identify opportunities and challenges to embed Smart City approaches, concepts,
technologies, and systems from the outset across Old Oak and Park Royal.
12.13 The Smart London Board and other stakeholders, including the GLA, #HyperCatCity,
Future Cities Catapult, Imperial College, University College London and Londons tech
communities will have a key role in helping OPDC to establish Old Oak and Park Royal as a
demonstrator and scale-up location for smart city technology and approaches.
12.14 OPDC will work with partners and stakeholders to position Old Oak and Park Royal
as a world-leading location for the exploration, exploitation, evaluation and implementation of
smart city technology, approaches, concepts and systems to help:
i.
plan, deliver and manage development;
ii.
improve the quality of life of local people and Londoners;
iii.
create and capture economic, social and environmental opportunities; and
iv.
address challenges and barriers.
12.15 New development proposals will be expected to provide open, usable and interoperable data, including appropriate digital Building Information Management (BIM) models.
This will help OPDC achieve its aspiration to deliver an open and secure digital environment.
Specifically, this will aid OPDC to plan, deliver and manage development while creating
business opportunities, including application (app.) development for a range of technologies
and services during development and for the communities that live, work and visit there.
12.16 Data provided to OPDC will be kept in a secure environment and where appropriate
will be used to help inform and shape the development of the emerging OPDC digital model.
Alternative Policy Options
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1. That the provision of inter-operable, open and usable data is not specifically
required.
12.17 The benefit to this approach would be that applicants are able to provide information
in the format of their choice. The disadvantage is that this would inhibit OPDC in creating an
open digital environment to inform the development management process and wider
activities.
Consultation Questions
QEU2a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, should the proposed Local Plan adopt the
alternative policy option as the preferred option?
QEU2b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
QEU2c: Are there any other challenges and opportunities in addition to those stated
in the draft Smart Strategy that smart city technology could address?
QEU2d: Should the Local Plan and OPDC provide stronger requirements for
proposals to provide relevant interoperable and open data?
Policy EU3 Integrated Water Management
Key issues
1. The areas sewer network is old and has insufficient capacity in places to serve
the planned growth and regeneration for the purposes of foul-water and surface
water drainage.
2. There is a need to manage the increasing demand for clean potable water
resulting from new development and population growth, to reduce the deficit in
water supply-demand balance and improve water security in London.
3. There is a need to manage flood risk from the River Brent and from localised
surface water flooding.
4. There is a need to protect the water environment and waterways from the risks of
contamination and improve the ecological condition of the waterways.
5. As the OPDC area is regenerated, area-wide and site-specific solutions will be
needed.
Policy Context
National
12.18 The NPPF requires local planning authorities to adopt proactive strategies to mitigate
and adapt to climate change over the longer term, with Local Plans taking full account of
flood risk, water supply and demand and wastewater considerations.
Regional
12.19 London Plan policies set the context for sustainably managing water, including:
managing flood risks; sustainable drainage; ensuring the adequacy of water quality and
wastewater infrastructure; and managing water supply-demand. Further information is set
out in the Mayors Water Strategy and Climate Change Adaptation Strategy.
Preferred Policy Option
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Development proposals will be required to:

a) demonstrate a collaborative approach to working with OPDC and its
development partners to implement and manage area-wide water
infrastructure options identified in the Integrated Water Management Study
(IWMS) that address surface and waste-water disposal capacity issues and
sustainable management of water supply and that connect or contribute
towards a local rain/grey/storm water management system;
b) minimise water consumption by seeking to get as close to neutrality in water
use and consumption as possible and achieve the water management
standards that will be set through this Local Plan;
c) use sustainable drainage techniques to achieve at least greenfield rates of
surface water run-off;
d) implement the flood risk management measures identified in the relevant
boroughs Surface Water Management Plans and protect existing flood
management assets;
e) due to the limited capacity of the combined sewer serving the Counters Creek
catchment, demonstrate that the scheme would result in the release of
network capacity, or includes the provision of capacity improvements
sufficient to meet its needs without adversely impacting on existing
development, or compromising the ability of other developers to meet the
future needs of development planned for in the Local Plan;
f) in the Park Royal area, support the actions identified in the Thames River
Basin Management Plan for the River Brent; and
g) include measures to protect and improve the water environment, water quality
and ecological value of the Grand Union Canal and other watercourses.
Justification
12.20 In setting environmental standards, OPDC wishes to be recognised as a leader in
sustainability and delivering sustainable, resilient development. To achieve this it will be
necessary to ensure adequate water supply, surface water and foul drainage and sewerage
treatment capacity to serve both existing and new development, and to sustainably manage
the risks of flooding onsite and within the wider drainage catchment.
12.21 There is insufficient current capacity in the combined sewer network served via the
Counters Creek catchment to receive anything more than the black-water flows from
development in the OPDC area. This provides a technical imperative for development to
achieve run-off rates equivalent to a green field.
12.22 OPDCs preferred approach is therefore for the area to aim to be as close to water
neutral as is feasible. Water neutrality is where the demand for water from development is
no greater after it is built than it was before. OPDCs aim to move development towards
neutrality will require exemplary design and operation and may require developers to
consider off-setting the impacts of their development by making existing homes and
buildings in the area more water efficient, beyond the requirements of the London Plan.
12.23 OPDC wants to realise the sustainability and cost benefits from an integrated
approach to water management. The supporting draft Integrated Water Management
Strategy (IWMS) identifies innovative and strategic options to reduce the risks of flooding for
the development area as well as delivering the wider drainage network whilst minimising the
demand on stressed water resources. Development proposals will be expected to support
and deliver the preferred options recommended by the IWMS, subject to the outcome of
public consultation, which will be incorporated in the next draft Local Plan. The IWMS
should be read in conjunction with this policy and justification.
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12.24 The IWMS has identified six scenarios of intervention options to deliver the
challenging aspirations of limiting surface water run-off from the area to achieve a rate
equivalent to a green field and of managing water in a sustainable way, set out in Table XX
below. None of the interventions by themselves would deliver the necessary outcomes. To
meet our aspirations, interventions are required to be delivered in combination. The issue is
which scenario of interventions is preferable views are sought through the consultation
question below (see QEU3b).

Scenario 5

Scenario 6

Strategic

Scenario 4

Intervention
level:
Strategic and
/or Site?

Scenario 3

Storm water attenuation

provided through strategic
SuDS network for the public
realm.
Strategic wastewater
recycling provided area-wide
with a single treatment
location and a system to
meet non-potable water
demand.
Storm water recycling
provided area-wide with a
single treatment location and
a system to meet non-potable
water demand.
Greywater recycling provided
at site level to meet nonpotable demand.
Storm water attenuation
provided by source control
SuDS at site level.
Storm water attenuation
provided mostly through
above-ground storage to be
dispersed through the
opportunity areas or provided
at a single central storage
location which would need to
be identified.
Remaining Storm water
attenuation provided mostly
at development scale through
on site and underground
storage.

Graphic to
be inserted

Scenario 2

Intervention

Scenario 1

Table XX: Summary of IWMS water management interventions and scenarios

Strategic

Strategic

Site

Site

Strategic /
Site

Strategic /
Site

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12.25 Two interventions are needed cross all scenarios, these being;
Strategic Sustainable Drainage Systems (SuDS)
Source control SuDS, eg. green roofs and permeable paving on sites.

12.26 The remaining interventions in the scenarios are grouped into complimentary ranges
of measures.
12.27 Three scenarios identify options to retain storm water on-site and/or in underground
storage tanks. This approach would manage run-off rates. However, the widespread use of
underground water storage in several locations may have impacts on land take, would
require maintenance, and would provide limited added value in terms of health and wellbeing, amenity and to biodiversity compared to over-ground water management measures.
12.28 Three scenarios focus on the option for centralised surface water collection and
storage using above ground balancing/retention ponds or wetlands. This approach has been
used in the Queen Elizabeth II Park in Stratford and can have wider environmental and
ecological benefits such as providing an enhanced public realm, amenity and recreation,
health and well-being, biodiversity and reductions to the urban heat island effect. The system
would require a mixture of on and off-site space, the extent of which would depend on the
degree that other options can disperse surface/storm water around the area. Such features
could include the use of ponds/wetlands/swales. Land would need to be found for off-site
provision.
12.29 Flood risk within Old Oak and Park Royal is generally low, albeit with some localised
higher risk areas around the River Brent, and from localised surface water flooding. These
risks will need mitigation, and surface water run-off from the OPDC area will require
alternative and sustainable means of management.
12.30 The London Boroughs of Brent, Ealing and Hammersmith and Fulham, as Lead
Local Flood Authorities have Surface Water Management Plans (SWMPs) in place. A
SWMP is prepared by the boroughs in their role as Lead Local Flood Authority. It is a study
to understand the flood risk that arises from local flooding, defined by the Flood and Water
Management Act 2010 as flooding from surface runoff, groundwater, and ordinary
watercourses. The boroughs identify actions which they and others must take to mitigate and
manage flood risks. Such actions where relevant to the OPDC area have been accounted for
in the IWMS and are mainly in regard to the need to mitigate localised areas of surface and
storm water flooding, and flooding from sewers.
12.31 Major development will be expected to alleviate localised surface water drainage
problems. A site specific flood risk assessment may be required to ensure that the
development will remain safe and will not increase flood risk to others.
12.32 Locally, smaller-scale projects that help to separate foul and surface water drainage
will also be important to help mitigate the poor water quality status of the River Brent, and
poor water quality of the Grand Union Canal, helping to meet the requirements of the EU
Water Framework Directive (2000/60/EC) and the objectives and actions of the Thames
River Basin Management Plan 2015.
12.33 The opportunities for integrating the delivery of other forms of infrastructure, notably
green infrastructure, with water infrastructure will also be needed to realise wider benefits to
people and nature, improve climate resilience and secure cost efficiencies.
Alternative Policy Options
12.34 No reasonable alternative policy options have been identified, as an alternative would
be to not achieve greenfield run-off rates, or exemplary standards of water efficiency. This
would have an unacceptable impact on the sewer network within and downstream of OPDC
and on the demand for water resources.
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Consultation Questions
QEU3a: Do you agree with the preferred policy option? If not, what might you change
about the preferred policy?
QEU3b: What are your views on the individual scenarios and interventions identified
as necessary to sustainably manage water? Please refer to the IWMS for additional
information if required.
QEU3c: Where might water features be located outside the core development area to
help water management?
Policy EU4 Waste Management
Key Issues
1. As well as being a Local Planning Authority (LPA), OPDC is a Waste Planning
Authority (WPA).
2. OPDC is therefore responsible for waste development planning applications and has
a statutory duty to prepare a local waste plan, either individually or as part of a joint
plan.
3. Although OPDC does not have a waste apportionment target in the current London
Plan, the London Plan requires Mayoral Development Corporations to work with
boroughs to ensure that borough apportionments are met.
4. There are existing waste facilities that need to be either re-located, retained or reorientated.
Policy Context
National
12.35 The NPPF states that Councils should set out the strategic priorities for their area in
the Local Plan, which includes delivering waste management infrastructure.
12.36 The National Planning Policy for Waste (NPPW) provides further detailed policy on
waste and the National Planning Practice Guidance (NPPG) on Waste states that WPAs
should have regard to the apportionments set out in the London Plan when developing their
policies. The Local Waste Plan will need to be in general conformity with the London Plan
Regional
12.37 The London Plan apportions waste arisings to each London Borough for them each
to allocate sufficient land to deal with the apportioned amount of waste per year. This is to
work towards net self-sufficiency of waste management in London by 2026.
12.38 Paragraph 5.80 requires that where a Mayoral Development Corporation (MDC)
exists or is established within a Borough the MDC will co-operate with the Borough to ensure
that the Boroughs apportionment requirements are met. OPDCs approach to waste site
management must therefore accord with this policy requirement across its area.
Preferred Policy Option
OPDC will:
a) continue to safeguard existing waste and recycling sites in Park Royal in
accordance with the West London Waste Plan;
b) safeguard the Powerday (Old Oak Sidings) waste site in Old Oak; and
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c) work with other waste operators in Old Oak to coordinate their relocation to
other suitable and accessible sites.
Justification
12.39 For the part of the OPDC area covered by the London Boroughs of Brent and Ealing,
OPDC has been working jointly with these boroughs to prepare the West London Waste
Plan (WLWP), which was adopted by OPDC in July 2015 as a Development Plan Document
and part of OPDCs Local Plan. The plan identifies two specific sites within Park Royal (see
figure xx) that should be safeguarded for waste:
- Twyford Waste Transfer Station; and
- Quattro, Victoria Road.
12.40 OPDC will work closely with the London Boroughs of Ealing and Brent and other
WLWP authorities to safeguard these waste sites.
12.41 The part of the OPDC area in the London Borough of Hammersmith and Fulham is
not covered by the West London Waste Plan. Hammersmith and Fulham is part of the
Western Riverside Waste Authority (WRWA), which also covers the London Boroughs of
Lambeth and Wandsworth and Royal Borough of Kensington and Chelsea. Within the
Hammersmith and Fulham part of the OPDC area there are currently five waste sites (see
Figure XX), which are:
- European Metal Recycling;
- Powerday;
- Capital Waste Ltd;
- UK Tyre Exporters; and
- ODonovans Waste Disposal Ltd.
Figure XX: OPDC waste sites
12.42 OPDC has produced a Waste Strategy as a supporting study to this draft Local Plan
which outlines how these sites contribute to Hammersmith and Fulham Councils
apportionment and in accordance with the London Plan, how OPDC can co-operate with the
Council to ensure that the Councils apportionment requirements are met. The Waste
Strategy identifies that the Powerday waste site is capable of meeting Hammersmith and
Fulhams apportionment (both in terms of tonnage capacity and land) for the London Plan
period up to 2036 and this draft Local Plan therefore proposes that this site is safeguarded.
12.43 The Waste Strategy identifies that Powerday currently exports its products overseas;
however, the draft Local Plan promotes the use of waste as a resource on-site through
processes such as energy from waste and / or the re-use of spoil for construction (see
Policies EU5 and EU6). This could see these materials being re-used within the OPDC area
in future, helping to transition the OPDC area to a circular economy.
12.44 Within Old Oak, it will be necessary to relocate other identified waste sites to
accommodate new development and realise the homes and jobs targets set for the area in
the London Plan. OPDC is keen to ensure that existing waste management activities in Old
Oak continue to operate in the OPDC area where possible, whilst ensuring that this would
not adversely impact on local communities, heritage assets or the natural environment, and
will work with waste providers to explore ways in which sites could be relocated. Any
relocation deemed necessary will be done in line with London Plan waste policy.
Alternative Policy Options:

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1. Safeguard all waste sites in Old Oak.
12.45 This approach would ensure that borough apportionment targets are exceeded, but
would prevent development from being brought forward within the Old Oak North place and
would undermine the delivery of homes and jobs in the OPDC area.
Consultation Questions
QEU4a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, should the proposed Local Plan adopt the
alternative policy option as the preferred option?
QEU4b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
Policy EU5: Circular economy and resource efficiency
Key Issues
1. OPDC aspires to enable a more competitive, resource efficient circular economy,
across a range of economic sectors, including waste.
2. The scale of new development and regeneration proposed at Old Oak and Park
Royal, both in its construction and operation, provides challenges and opportunities
to minimise the use of natural resources and waste and to maximise the re-cycling
and economic re-use of these resources.
3. Existing and new development will need to consider how it can increase its
contribution to reducing waste, to the more efficient use of natural resources, and to
provide resilience to the effects of a changing climate.
Policy Context
National
12.46 The NPPF does not deal with waste matters directly, but refers to the Waste
Management Plan for England. This plan sets out:
- the Governments ambition to work towards a more sustainable and efficient
approach to resource use and management;
- to get the most environmental benefit by increased recycling of resources and
recovery of energy from residual waste; and
- the Waste Hierarchy, which identifies disposal as the least desirable option and
waste reduction and then reuse as the most desirable options.
12.47 The National Planning Policy for Waste (NPPW) provides further detailed policy on
waste.
Regional
12.48 The London Plan sets out the Mayors policies for Londons waste net selfsufficiency, waste capacity, construction-related waste, hazardous waste and aggregates.
The Mayors policies encourage a collaborative approach to working between stakeholders
to implement the waste hierarchy embedded in EU and national waste plans, and to enable
resource recovery. The Plan sets out the Mayors aims for Londons waste net selfsufficiency, achieved by minimising waste, setting targets for waste recycling, re-use, and
composting, and reducing waste export outside the capital.
Preferred Policy Option
Development proposals, in promoting a circular economy, will be required to:
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a) demonstrate how they have as far as possible designed out waste and
ensured the efficient use of building materials through:
i.
lean design, minimising the use of primary materials and the
production of excess or waste material during construction;
ii.
maximising the use of secondary materials and the opportunities for
reuse, remanufacture or recycling of materials; and
iii.
considering the end-of-operational life use of materials, or if not
viable, on-site energy recovery from waste;
b) make adequate provision for convenient domestic and commercial waste
storage and for collection within the development that allows for a range of
future collection options;
c) investigate the potential for the movement of waste and recyclable
materials during construction by sustainable means of transport, including
by rail, and the Grand Union Canal; and
d) promote other on-site waste management and communal composting.
Justification
12.49 A circular economy (CE) is one that keeps products, components and materials at
their highest use and value at all times. It is an alternative to the current linear economy,
where we make, use and then dispose of products, components and materials. By adopting
a circular economy approach OPDC can help London unite business interests with the citys
wider development needs, and assist London to remain globally competitive.
12.50 EU and national policy sets out a Waste Hierarchy, which identifies disposal as the
least desirable option, and waste reduction and then reuse as the most desirable options.
The London Plan reinforces the Waste Hierarchy, setting out the Mayors policy for Londons
waste net self-sufficiency through managing as much of Londons waste as is practicable
within London, and for this to equate to 100 per cent by 2026 (within the lifetime of this Local
Plan). OPDC aims to support this objective and Londons transition to a circular economy,
including turning Londons used materials and waste into an economic opportunity.
12.51 Our aim is to promote a local economy which is waste-free, and resilient and
remanufacture-able by design to ensure products and materials are kept at their highest
utility for as long as possible This approach together with waste recycling and reprocessing
offer clear benefits for the local economy, the environment and our resilience to climate
change including, the creation of green jobs in the area make new products, contribute to
local energy requirements, reduce carbon emissions and avoid the use of virgin materials
and associated adverse environmental impacts.
12.52 The scale of construction can be expected to result in significant amounts of
construction waste and excavated material. OPDCs expectation is that this material will be
re-cycled and re-processed, and re-used onsite, wherever practicable. Applicants will be
expected to demonstrate how they support this aspiration.
12.53 The use of recycled materials and waste minimisation in construction can offset the
requirement for energy intensive production of primary materials. The scale of regeneration
within OPDC may support the capability for producing heat from waste for local district
heating schemes, thus further contributing to OPDCs aims for decentralised energy and
local energy generation, and help us move towards a low carbon economy.
12.54 CE thinking is evolving especially in the area of built environment. OPDC will review
further, which elements of the circular economy would be most beneficial for Old Oak Park
Royal. New development at Old Oak and Park Royal affords the opportunity to explore how
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existing waste facilities can be incorporated in to solutions for the treatment, re-processing
and transfer of the areas waste, and potentially provide for local energy needs. The
Powerday waste site for example could be refurbished over time to contribute to districtscale energy generation from waste (refer also to Policies EU4 and EU6).
12.55 OPDC will, in making planning decisions, require new development proposals to
demonstrate how they have adopted the Waste Hierarchy and CE principles in their design
for construction and operation stages and how they will enable their residents and users to
minimise waste and maximise reuse, recycling and composting.
12.56 The provisions made within new development should not simply seek to meet the
requirements of existing waste collection and management practices, but should also
provide sufficient on-site space for waste storage and access, to allow for future practices
and innovation. These include exploring the provision of separate collection of general
waste, recyclable materials and other waste streams.
12.57 Communal composting facilities should be operated in association with proposals for
urban food growing and green infrastructure.
Alternative Policy Options:
12.58 No reasonable alternative policy options have been identified as they would not
accord with national policy or be in general conformity with the London Plan.
Consultation Questions
QXX: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, are there any other policy alternatives that could
replace the preferred policy or should be considered as alternatives?
Policy EU6: Decentralised Energy
Key issues
1. Large-scale regeneration at Old Oak and intensification in Park Royal will place
increasing demands on the energy network. The current network is not capable
of accommodating future energy requirements and this will need to be addressed
to enable timely delivery.
2. Integrated delivery of a decentralised energy network at the scale that could be
achieved at Old Oak presents a significant opportunity for sustainability.
Policy Context
National
12.59 The NPPF, supplemented by guidance on renewable and low carbon energy in the
National Planning Practice Guidance, supports the move to a low carbon future, setting out
local planning authorities and communities roles in supporting greenhouse gas reduction,
energy efficiency, decentralised energy supply, reducing energy consumption and increasing
the supply and use of renewable and low carbon energy.
Regional
12.60 London Plan polices set out aims for residential buildings to be zero carbon from
2016, and non-residential buildings from 2019. Mayoral expectations are for 25% of
Londons heat and power generation to be from local decentralised energy by 2025.
Preferred Policy Option:
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OPDC will support and facilitate:

a) provision of energy supply infrastructure that enables development (electricity
and gas);
b) the provision of infrastructure to deliver a decentralised energy;
c) proposals which contribute to the delivery of a decentralised energy subject
to:
i.
providing evidence that appropriate management mechanisms will be
put in place to ensure that end customers are protected in respect of the
price of energy provided; and
ii.
ensuring that heat losses from the network are minimised; and.
Proposals for major developments will be required to:
d) demonstrate a collaborative approach to working with OPDC and its
development partners to contribute to the supply and capacity of the
decentralised energy network unless it can be demonstrated that this is not
technically feasible or economically viable;
e) be designed to enable connection to the decentralised energy network, where
there is no connection to a decentralised energy network yet available, and/or
where CCHP or CHP would not be technically feasible or financially viable;
f) demonstrate that provision is included to accommodate routes and land for
energy centres and utilities networks; and
g) submit an Energy Statement.
Justification
12.61 Major re-development at Old Oak and Park Royal provides significant potential to
contribute to the Mayors target for reducing Londons carbon dioxide emissions, through a
co-ordinated and best practice approach to energy provision.
12.62 OPDC has produced a draft Old Oak Decentralised Energy Strategy, which shows
how a decentralised energy network could be delivered to supply low or zero carbon heat.
Further work will be carried out over the coming years, but initial findings show that this
would be done on a phased basis, with initial energy production plant accommodated within
three energy centre buildings, and potentially later consolidated into a single energy centre
in the early 2030s, subject to development phasing. Proposals would be expected to align
their own energy strategies in accordance with the strategic approach and safeguard land for
energy centres, routes and infrastructure for new networks or extensions to any existing
networks and to connect with these networks.
The areas waste sites could contribute over time to the provision of energy from waste, and
so contribute to district-scale energy generation (refer also to Policy EU5).
12.63 Development will be expected to maximise its contribution to the delivery of, and
connection to, the area network. Where this is not currently feasible, development should to
be designed to be adaptable to enable future connection to the network.
12.64 Energy Statements should demonstrate that opportunities to connect to existing heat
and energy networks and/or to construct and connect to new energy networks have been
maximised through provision of localised network connections and CCHP or CHP
infrastructure within buildings where it is feasible and viable to do so. They should address
energy efficiency and renewables, aiming to minimise carbon dioxide emissions to the fullest
extent possible by application of the Energy Hierarchy

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12.65 OPDC will support development that minimises its need for mechanical heating and
cooling, and its requirements for power by incorporating energy efficiency measures in
buildings, and by careful consideration of the site layout and design.
12.66 Opportunities will be expected to be taken by developers for co-delivery of energy
supply with other utilities, and other infrastructure.
12.67 OPDC recognises the relationship between decentralised energy generation and the
potential effects on local air quality, noise and light pollution on local communities, heritage
assets and the natural environment. Proposals will be expected to demonstrate how they
have minimised any negative impacts and be designed to be resilient to the risks of flooding.
Alternative Policy Options
1. To delete the policy reference to major development, so that the policy
requirements apply to all development.
12.68 This would put the onus on all developments to contribute to the de-centralised
energy network. This option would deliver greater sustainability but could be difficult and
costly to deliver, creating greater uncertainty of delivery and impact on the viability of smaller
schemes
Consultation Questions
QEU6a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, should the proposed Local Plan adopt the
alternative policy option as the preferred option?
QEU6b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
Policy EU7: Digital communications
Key Issues
1. The majority of Old Oak and Park Royal have poor digital communications infrastructure
and lacks access to next generation broadband or superfast broadband services.
2. Current digital communication infrastructure within Old Oak will not be sufficient to meet
the envisaged rising demand for data capacity.
3. Current digital communications infrastructure within Park Royal is considered to
negatively impact on the functioning of businesses within the estate.
4. To optimise development, support economic growth and provide high quality, efficient
and agile services, new digital communications infrastructure needs to be provided within
Old Oak and Park Royal.
5. Digital communications infrastructure will need to be flexible to accommodate
technological change and evolution.
Policy Context
National
12.69 The NPPF identifies that advance, high quality communications infrastructure is
essential for sustainable economic growth and that high speed broadband technology and
other communications networks also play a vital role in providing local community facilities
and services. Local Plans are required to support the expansion of electronic
communications networks while seeking that new equipment is sympathetically designed
and camouflaged where appropriate.
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Regional
12.70 London Plan policies provide guidance to encourage a connected economy by
facilitating the provision and delivery of the information and communications technology
infrastructure.
Preferred Policy Option:
a) OPDC will work with partners and infrastructure providers to deliver exemplar
digital communications infrastructure by:
i.
promoting the delivery of digital communications infrastructure;
ii.
exploring innovative delivery and management models; and
iii.
integrating contemporary technology and seeking to accommodate
future technologies to address challenges and create opportunities.
b) Development proposals will be required to demonstrate how they will support
and integrate the delivery of technology and communication infrastructure.
Justification
12.71 Digital communications infrastructure refers to a range of contemporary and future
technologies and transmission media which currently include transmission lines (including
copper, cable, fibre), terrestrial wireless (including fixed, mobile (such as 4G and 5G) and
Wi-Fi) and satellites.
12.72 Next generation access or superfast broadband is defined by OFCOM as providing a
download speed that is greater than 24 Mbps. This speed is commonly considered to be the
maximum speed that can be supported by copper based networks. As such next generation
access requires different technologies to deliver this speed.
12.73 Ultrafast broadband is defined by the Department of Culture and Media as providing
a download speed of at least 100 Mbps.
12.74 To support OPDCs aspirations to be an exemplar in innovation, OPDC will work with
a range of public, private and community sector stakeholders to deliver a world-class digital
communications infrastructure network that meets the needs of existing and future residents,
businesses, visitors and service providers.
12.75 The UKs digital economy grew over seven times faster than the economy as a whole
between 2008 and 2013 with growth expected to continue. SMEs also consider that access
to digital communications infrastructure is a critical element to their current and future
economic success.
12.76 The demand for data capacity is also expected to rise with the emergence of new
services, applications and devices being developed to meet a variety of demands alongside
other services that have yet to be even considered. These expected new demands will relate
to:

Video services;
Cloud services;
Health services;
Education services; and
Smart City, utilities networks and Internet of Things requirements.

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12.77 In light of the above, OPDC considers digital communications infrastructure to be
fundamental to the long-term success of Old Oak and Park Royal.
Alternative Policy Options
1. OPDC does not specifically seek to integrate contemporary technology and
accommodate future technologies to address challenges and create opportunities.
12.78 The benefit of this approach would be that existing technologies and systems are
implemented at less risk to stakeholders. The disadvantage would be that existing
challenges arent addressed and new opportunities arent created or captured.
Consultation Questions
QEU7a: Do you agree with the preferred policy option? If so, what might you change
about the preferred policy? If not, should the proposed Local Plan adopt one of the
alternative policy options as the preferred option?
QEU7b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
QEU7c: Please identify any specific areas within Old Oak and Park Royal that currently
have issues with access to internet services. Are there any other issues relating to
access to internet services?

Policy EU8: Green Infrastructure & biodiversity

Key issues
1. The area is highly urbanised and affected by issues, such as poor air quality, higher
temperatures, lack of green space and noise from traffic and commercial uses
2. The areas existing network of green spaces is limited in extent and functionality by
fragmentation that is reinforced by major railway and road corridors and poor
connection to its surroundings.
3. OPDCs existing green spaces require protection and / or enhancement. These
include a hierarchy of sites of importance for nature conservation (SINCs) across the
OPDC area.
4. The planned regeneration will increase urban density and grey infrastructure, but
also provides an opportunity to create new green infrastructure that can provide a
range of services.
Policy Context
National
12.79 The NPPF identifies sustainable development as the purpose of the planning system
and conserving and enhancing the natural environment as a core planning principle. It also
states that local plans should plan positively for the creation, protection, enhancement and
management of networks of biodiversity and green infrastructure, including moving from a
net loss of biodiversity to achieving gains for nature.
Regional
12.80 London Plan policies set out Mayoral objectives for a multi- functional network of
green and open spaces (i.e. green infrastructure), requires Londons boroughs to set out a
strategic approach by producing green infrastructure strategies, and sets out the Mayors
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proactive approach to the protection, enhancement, creation, promotion, and manage of
biodiversity and features such as trees, woodlands and waterways.
Preferred Policy Option:
Development will be required to:
a) protect and/or enhance and create multi-functional green and water spaces
and ensure they are connected by street greening and other green links;
b) demonstrate how green infrastructure has been:
i.
integrated with utilities infrastructure; and
ii.
planned, designed and managed to contribute to and be integrated with,
the wider green infrastructure network;
c) take account of the proximity of SINCs, and the habitat and species targets in
relevant Biodiversity Action Plans (BAPs);
d) be accompanied by an Ecological Statement for major applications;
e) have particular regard to the measures for the protection and enhancement of
ecology and biodiversity in Wormwood Scrubs and for the Grand Union Canal.
[Figure XX: Map showing OPDC existing GI network]
Justification
12.81 Green infrastructure (GI) is the network of green spaces and waterways and features
such as street trees and green roofs, that is planned, designed and managed to deliver a
range of benefits, including recreation and amenity, healthy living, mitigating flooding,
improving air quality, cooling the urban environment, encouraging walking and cycling and
enhancing biodiversity and ecological resilience.
12.82 OPDC recognises that significant new development, especially at Old Oak will
provide opportunities for working with developers and stakeholders to provide new GI,
secure improved connections, to and within the GI network and to protect and /or enhance
these assets. OPDC is developing a GI Strategy which will accompany the next draft of the
Local Plan and will demonstrate how the areas GI network can be enhanced.
12.83 Developers will be expected to incorporate a GI approach from early in the design
process through to considering management arrangements. Early adoption of a GI approach
in development proposals will enable cost-effective, more efficient and more resilient
infrastructure solutions to be considered by individual developers and by developers working
in co-operation with each other. Incorporating a GI approach will also contribute to the ability
of development to respond to the effects of a changing climate over the long-term.
12.84 Green infrastructure assets should be connected through the delivery of street
greening. This may include soft landscaping, retaining existing trees and planting new trees
to encourage healthy, active and walk-able neighbourhoods incorporating green features
(such as green roofs and walls, etc.) into buildings, and greening our streets and public
realm will also help provide a liveable and healthy environment for people and nature.
Regeneration also presents opportunities to realise the role of GI in enabling space for
utilities and other infrastructure.
12.85 There are opportunities for the co-delivery of GI with other utilities such as SuDS,
and district-wide systems for energy and for waste, in addition to providing routes for walking
and cycling, which will have sustainability and potential cost benefits.

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12.86 Londons most important wildlife sites are recognised by the Mayor and London
borough councils as Sites of Importance for Nature Conservation (SINCs). There is a
hierarchy of SINCs in the area from the most significant of Metropolitan Importance, such as
the Grand Union Canal, to those of Borough Importance, such as Wormwood Scrubs and to
those of Local Importance, such as green corridors associated with the areas railways and
with roads which intersect the area.
Alternative Policy Options
12.87 No alternative policy options have been identified as an alternative approach would
be to not have proactive policies for the delivery of new and enhance existing GI and this
would not be consistent with the NPPF or in general conformity with the London Plan.
Consultation Questions
QEU8a: Do you agree with the preferred policy option? If not, what might you change
about the preferred policy?
QEU8b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
QEU8c: Are there any other biodiversity assets that should be identified?
QEU8d: Are there any biodiversity designations which could be amended and / or
removed?
Policy EU9: Extraction of minerals
Key Issues
1. It is unknown whether there is potential for this activity in the plan area or if the
geology is suitable.
2. Unconventional oil and gas resources may provide opportunities to contribute to
meeting growing energy demands from development within OPDC and in wider
London, if this represents sustainable development.
Policy Context
National
12.88 The NPPF and the associated Technical Guidance addresses facilitating the
sustainable use of minerals and states that in addressing local plans, local planning
authorities should identify and include polices for the extraction of minerals and set out
environmental criteria against which to assess applications for development.
Regional
12.89 The London Plan does not contain any policies that directly relate to oil and gas
exploration.
Preferred Policy Option
Applications for mineral extraction, including the exploration, appraisal and operation
of unconventional oil and gas resources, will be considered against the following
criteria:

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a) Protection of nearby residents and businesses from the effects of the
operations;
b) The operations design, including its sensitivity to the character of the urban
landscape and to features of national, London, and local importance;
c) Site access, traffic generation and the routing of heavy vehicles;
d) Safeguarding of water supplies and the water environment, the safe and
sustainable disposal of waste water and flood risk management including
surface water;
e) The effects on public rights of way, open spaces or outdoor recreation;
f) The control and mitigation of greenhouse gas emissions and dust during
construction and operation;
g) The efficient use of resources (such as construction materials or water);
h) The contribution of the operation to the development of heat and energy
recovery or low carbon technologies;
i) Site restoration, and effective after-use following development; and
j) the safeguarding of biodiversity, and sites of interest for nature conservation.
Justification
12.90 Mineral extraction is any process that involves isolating minerals from natural sources
such as rock or soil. Minerals are essential to support sustainable economic growth and our
quality of life. Minerals Planning Authorities such as OPDC are required by government to
identify and include policies for the extraction of minerals. The sustainable use of the UKs
own mineral resources is a key focus of national policy in securing energy supply.
Consequently, this is an important issue for London and for the Old Oak and Park Royal
area, as its communities and economy grow, supported by more sustainable, de-centralised,
local sources of energy supply.
12.91 The OPDC area is not currently covered by Department of Energy & Climate Change
(DECC) licences allowing companies to search for minerals, including unconventional oil and
gas. It is unknown whether there is potential for this activity in the OPDC area or if the
geology is suitable. Nonetheless, should future exploration demonstrate the presence of oil
and gas resources, these may provide opportunities to contribute to meeting growing energy
demands from development planned both within OPDCs boundaries and in wider London, if
this represents sustainable development.
12.92 OPDC will consult with the relevant boroughs in regard to any proposals for minerals
extraction. Outside the planning system, licences for exploration are dealt with by the Oil and
Gas Authority as an executive agency of DECC, again working with their regulatory partners.
Alternative Policy Options
12.93 No reasonable alternative policy options have been identified. The NPPF requires
Local authorities to address minerals extraction.
Consultation Questions
QEU9a: Do you agree with the preferred policy option? If not, what might you change
about the preferred policy?
QEU9b: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
Policy EU10: Air Quality

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Key Issues
1. The London Boroughs of Ealing, Brent and Hammersmith and Fulham experience
significant air pollution, directly attributable to emissions from road traffic, as in many
parts of London.
2. The Old Oak and Park Royal area is particularly affected. The nature of industrial
uses and the strategic road network in the area both give rise to air pollution.
3. The three local authorities have designated Air Quality Management Areas across
the whole of the Old Oak and Park Royal for Nitrogen Dioxide (NO2) and particulate
matter (PM10). They are each preparing Air Quality Management Plans covering the
area.
Policy Context
National
12.94 The NPPF requires planning to contribute to and enhance the natural and local
environment by preventing development contributing to being put at risk by air pollution.
Planning policies should sustain compliance to EU and national objectives for pollutants,
taking into account Air Quality Management Areas and cumulative impacts and that
decisions need to be consistent with local Air Quality Action Plans.
Regional
12.95 London Plan policies state that local plans should seek reductions in the levels of
pollutants having regard to the Mayors Air Quality Strategy and take into account their own
air quality assessments and action plans, particularly where Air Quality Management Areas
have been designated.
Preferred Policy Option
Development will be required to demonstrate through an air quality assessment how
it:
a) implements the recommendations of the Old Oak and Park Royal Air Quality
Study (summarised in Table XX below);
b) has regard to the relevant boroughs Air Quality Management Plans and the
mitigation measures identified therein;
c) considers air quality impacts during construction and operation with the aim of
being air quality neutral, with mechanisms for how this will be monitored over
time; and
d) seeks to minimise air quality impacts from surrounding uses.
Justification
12.96 Air quality has a significant role to play in the health and wellbeing of occupants. The
OPDC area is particularly affected by poor air quality, thanks to its high levels of traffic and
industrial uses. The London Boroughs of Brent, Ealing and Hammersmith and Fulham have
each identified incidences of poor air quality in OPDC are and have designated Air Quality
Management Areas covering the entire OPDC area for Nitrogen Dioxide (NO2) and
particulate matter (PM10).
12.97 As a result of these air quality issues, OPDC has published its own draft Air Quality
Study (AQS) to inform the draft Local Plan. It identifies area-wide measures to support
improvement in the areas air quality which are listed in Table XX below. Where relevant
these recommendations have also been incorporated in other preferred policy options in this
draft Local Plan.

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12.98 OPDC will need to work with others on the implementation of the measures
necessary to address poor air quality as some measures require broader changes in
practice and behaviour. The matter is not confined to one planning authority area and
development is often governed by separate regulatory regimes and legislation such as
building regulations and environmental permitting.
Table XX: Summary of the draft Air Quality Study (AQS) recommendations
Policy Area
Transport

Energy

Waste
Overall
Emissions

Design / Public
Realm

Construction
and logistics

Policy action / mitigation measure

- Minimise demand for travel by private motor vehicles and
encourage transport by shared, low and zero emission modes.
- Provide no more than 1 car parking space per 5 residential units
and ensure sufficient provision of electric charging points.
- Encourage the uptake of Low and Zero Emission Vehicles by
providing vehicle re-fuelling / charging infrastructure.
- Design local roads to restrict vehicle speeds to 20mph.
- CHP / biomass should meet the highest emissions standards
detailed in the Mayor of Londons Supplementary Planning
Guidance (SPG) on Sustainable Design and Construction.
- Development design should be optimised to ensure adequate
dispersion of emissions from discharging stacks and vents.
- All new waste treatment and handling facilities will require to be
fully enclosed.
- Minimise air pollution making new developments air quality
neutral in accordance with the Mayor SPG on Sustainable Design
and Construction.
- Proposals should not increase the area of exceedance of EU
established health-based standards and objectives for NO2 and
PM10. Where new developments are introduced into area where
the standards and objectives are exceeded, developments should
be designed to minimise and mitigate against increased exposure
to poor air quality.
- Developers should produce an air quality assessment with the
planning application. The AQS provides further recommendations
on matters for inclusion within the air quality assessment.
- Development and building design should not inhibit the effective
dispersion of pollution. In particular, bus and taxi facilities should
be designed to avoid the build-up of pollution.
- Developments should provide adequate, appropriate and well
located green space and infrastructure.
- Minimise emissions from freight, delivery and servicing during the
demolition and construction phase.
- Follow the guidance set out in the Mayors SPG on The Control of
Dust and Emissions during Construction and Demolition to assess
the impact on air quality during construction and to inform
mitigation.
- Renewable, mains or battery powered plant items should be used
for Non-Road Mobile Machinery (NRMM) on construction sites.
- All demolition and construction sites should be monitored for the
generation of air pollution. PM10 monitoring should be carried out
at medium and high risk sites.

Alternative Policy Options:

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12.99 No alternative policy options have been identified as alternatives would be to not
have policies promoting improvements to air quality and this would not be consistent with the
NPPF or in general conformity with the London Plan.
Consultation Questions
QEU10a: Do you agree with the preferred policy option? If not, what might you
change about the preferred policy?
QEU10b: Are there any other policy alternatives that could replace the preferred
policy or should be considered as alternatives?
Policy EU11: Noise
Key issues
1. The existing road and rail transport network and the predominance of industrial uses
and heavy traffic associated with them means that the area suffers from significant
ambient and background noise levels.
2. To a lesser extent, there is ambient noise from air traffic associated with the areas
proximity to Heathrow airport and flight-paths.
3. Noise can impact on the quality of life and the natural environment. It will be
important to carefully plan for this through development.
Policy Context
National
12.100 The NPPF states that planning policies and decisions should aim to avoid noise from
giving rise to significant adverse impacts on health and quality of life as a result of new
development, mitigate and reduce to a minimum other adverse impacts on health and quality
of life arising from noise from new development, including through the use of conditions and
identify and protect areas of tranquility which have remained relatively undisturbed by noise
and are prized for their recreational and amenity value for this reason.
Regional
12.101 London Plan polices set out the Mayors approach to the management and reduction
of noise to improve health and the quality of life and to support the spatial planning
objectives of the Mayors published Ambient Noise Strategy.
Preferred Policy Option
Development proposals should submit a noise assessment that demonstrates:
a) how design has minimised adverse noise impacts from both surrounding and
internal uses on future occupants. In high density development noise
attenuation measures will be of particular importance; and
b) where development is proposed close to existing noise generators such as
waste sites, cultural facilities, strategic roads or uses within Strategic
Industrial Locations (SIL), how it will ensure the continued effective operation
of those uses;
Justification
12.102 Noise is an inherent part of everyday life. It contributes to the character of different
places High levels can have a considerable effect on human health, productivity, quality of
life and amenity, and on wildlife.
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12.103 The impact of noise is a material planning consideration in the determination of

planning applications. Given the significant amount of regeneration and new development
planned there is the potential for conflict between noise sensitive and noise generating
developments. New development in the OPDC area may create more noise, but there may
be opportunities to consider improvements to the acoustic environment.
12.104 Where a proposed development has the potential to negatively impact on a noise
sensitive development or new noise sensitive development is proposed near major sources
of noise, OPDC will require major development proposals to include a noise assessment to
investigate noise levels and determine the effectiveness of proposed mitigation measures.
OPDC will apply agent of change principles when considering the impact of noise, i.e. if
there is an existing use that generates noise, such as a cultural facility or an industrial use,
the onus will be on the new development to adequately mitigate against the impacts of this
noise. When assessing proposals, OPDC will have regard to relevant noise exposure
standards and internal noise standards which apply to particular uses.
Alternative Policy Options:
12.105 No alternative policy options have been identified as alternatives would be to not
have policies mitigating the impacts of noise and this would not be consistent with the NPPF
or in general conformity with the London Plan.
Consultation Questions
QXX: Do you agree with the preferred policy option? If not, what might you change
about the preferred policy?
QXX: Are there any other policy alternatives that could replace the preferred policy
or should be considered as alternatives?
Policy EU12: Land contamination
Key Issues
1. The OPDC area is 650ha of brownfield land with a long industrial history, alongside
significant corridors of transport infrastructure.
2. Past uses are likely to have left a legacy of contamination within the ground. If not
dealt with appropriately, it has the potential to affect human health and natural
habitat, including the water environment and groundwater.
3. Remediation or clean up may be required for large development.
Policy Context
National
12.106 The NPPF requires that local planning authorities, though Local Plans and planning
decisions, ensure that a site is suitable for its use, having regard to ground conditions,
including previous activity pollution and, remediation proposals. After remediation under
planning, as a minimum, land should not be capable of being determined as contaminated.
Regional
12.107 London Plan Polices Identify the need for local planning authorities to encourage
remediation and to set out policy to deal with contamination and prevent its spread and reactivation.

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Preferred Policy Option
OPDC will:
a) assess development proposals in relation to the suitability of the proposed use
for the conditions on that site;
b) require applications for new development to be supported by:
i.
a site investigation;
ii.
an assessment to establish the nature, extent, and risk presented by
contamination; and
iii.
remediation proposals, to be agreed before planning permission is
granted;
c) expect, as a preferred approach, the treatment of contamination to take place
on-site; and
d) require developers to complete the implementation of agreed measures to
assess and abate any risks to human health or the wider environment, prior to
the first occupation and use of the development, or as otherwise agreed by
planning conditions.
e) Require development proposals to set out practicable and effective measures
to manage the risks from contamination and decontamination by treating,
containing or controlling any contamination so as not to:
i.
expose the occupiers of the development and neighbouring land uses
including, in the case of housing, the users of open spaces and gardens
to an unacceptable risk;
ii.
threaten the structural integrity of any building built, or to be built, on or
adjoining the site;
iii.
lead to the contamination of any watercourse, water body or aquifer; or
iv.
cause the contamination of adjoining land or allow such contamination
to continue.
Justification
12.108 The OPDC area contains a significant amount of brownfield land with a long
industrial history. Much of this land is expected to be contaminated and remediation or clean
up may be required on development sites. Given the scale of regeneration planned, OPDC
wants to ensure the impacts of these past and future land uses do not affect the health of
people and the environment.
12.109 Land contamination and remediation is the subject of planning and other regulatory
regimes. A key to the successful redevelopment of brownfield land is therefore early and
continual engagement between developers, planners and regulators. OPDC will expect
developers to work with OPDC, the relevant London Boroughs and the Environment Agency
in assessing the risks and the management of contamination, in assessing the suitability of
the proposed use for the conditions on that site, and in agreeing any necessary steps for
remediation.
12.110 Regulatory advice and guidance is available to identify the principal matters which
both the Planning Authority and environmental regulator look to be undertaken when
approaching redevelopment and land contamination. The Environment Agency documents
Model Procedures and The Guiding Principles are particularly useful as they highlight the
main stages in the process, best practice and refer to further guidance.
12.111 Where land is known or found to be contaminated, or where a sensitive use is
proposed or exists, developers will be expected to assess their proposals using the seven
stage process below:

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1. Preliminary Risk Assessment: Comprising a desktop study including details of past
and present uses at the site and the surrounding area to identify any potential sources of
contamination, potential risks and sensitive receptors. A conceptual site model should be
produced to demonstrate where any pathway connects any of these sources to the
sensitive receptors.
2. Site Investigation Scheme. Based upon stage one, setting out how the site investigation
will be carried out, how the sources of pollution identified in the conceptual site model will
be targeted and to determine the existence of the pathway to the identified receptors.
3. Site Investigation. To be undertaken using current guidance and methods.
4. Risk Assessment. Based upon site investigations, to determine the degree and nature
of any contamination on the site and the risks posed by any contamination to human
health, controlled waters and the wider environment.
5. Remediation Strategy. A detailed method statement for required remediation works
identified through stage four, with the aim of breaking any pollutant linkages. The Strategy
should support waste minimisation and maximising resource use by promoting the
sustainable remediation and re-use of contaminated soils.
6. Verification. A report which validates and verifies that all of the works outlined in stage
five have been undertaken as agreed.
7. On-going monitoring. If during development, contamination not previously identified is
found to be present at the site, the local authority should be immediately informed and no
further development should be carried out until a report indicating the nature of the
contamination and how it is to be dealt with is agreed in writing.
12.112 Sending contaminated soils to landfill is no longer considered to be sustainable, or
economic. Sustainable, economic and local alternatives are required. At OPDC the
opportunity exists to promote strategic and sustainable risk based approaches to land
assessment and remediation based upon current best practice and guidance.
12.113 In some cases, the polluted layers in a site may contain rubble, rubbish and coarse
waste materials. Often, on-site recycling and re-use of debris and treated material is
possible and can reduce demand for primary aggregate resources, the need to transport
material off-site and reduce the potential risks from pollution. This will be encouraged
wherever possible.
Alternative Policy Options
12.114 No reasonable alternative policy options have been identified. There are no options
but to require the decontamination and remediation of brownfield land to ensure its
suitability for future uses.
Consultation Questions
QEU12a: Do you agree with the preferred policy option? If not, what might you change
about the preferred policy?
QEU12b: Are there any other policy alternatives that could replace the preferred
policy or should be considered as alternatives?

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13. DELIVERY AND IMPLEMENTATION

Introduction
13.1 Given the scale of the proposed development and the range and number of
stakeholders that are already and will be involved, ensuring that there are adequate
mechanisms to secure and monitor delivery are essential to the success of the Local Plan.
This chapter sets out what infrastructure is needed to support development and the
mechanisms that OPDC has at its disposal to secure the delivery of infrastructure,
redevelopment, regeneration and the creation of a high quality place.
Infrastructure provision
Context
13.2 This Local Plan seeks to deliver a high quality new part of London. To support this,
there will be a need to deliver:
- Infrastructure to support the needs of the new population, including transport,
education, health, community space, open space and utilities;
- Affordable housing, to meet housing needs and promote the areas as a mixed,
balanced and inclusive community;
- A very high standard of placemaking and integration with the surrounding area; and
- A mix of land uses that can help create a vibrant new destination, by providing a
range of uses and catalyst uses that will attract people to the area.
13.3 OPDC has produced an indicative masterplan that shows how this new place could
be laid out and the infrastructure needed to support this. Early work is showing that not all of
this infrastructure can be funded through contributions from private development alone. To
help with this, OPDC is undertaking a number of work-streams to further inform the Delivery
and Implementation Chapter in the next draft of the Local Plan, which will need to be kept
under regular review to keep on top of changing market conditions. These work-streams
include:
- looking at infrastructure prioritisation and phasing. In this chapter we pose a series of
questions to help us make an informed decision on what infrastructure is needed and
of this, which are the critical pieces needed to support a new population;
- testing a number of different development scenarios and investigating how much
funding there is available to fund infrastructure and affordable housing;
- identifying our affordable housing need, through our Strategic Housing Market
Assessment (SHMA); and
- exploring other funding options available to OPDC to help fund necessary
infrastructure.
13.4 The section below provides further detail on what infrastructure we think we need to
make a high quality place and ways in which this could be funded, delivered and phased.
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Identifying infrastructure needs

13.5 OPDC has been working with the GLA, TfL and the London Boroughs of Brent,
Ealing and Hammersmith & Fulham to produce an indicative masterplan for the area, as set
out in Chapter XX of the Local Plan. To assess the viability and deliverability of this
masterplan, OPDC and the GLA produced a Development Infrastructure Funding Study
(DIFS), which was prepared in consultation with the three boroughs and other stakeholders
in 2014-15.
13.6 The DIFS identified the required infrastructure necessary to support the indicative
masterplan and needs of the population and the phasing and costs of this infrastructure. The
assumptions on phasing have now been further refined as part of OPDCs Development
Capacity Study (DCS). Figure XX presents the indicative phasing plan in the DCS.
13.7 The indicative phasing is largely informed by the delivery of the Old Oak Common
Station, which is expected to open in 2026. Some sites are capable of being brought forward
in advance of the station whereas other sites are contingent on its opening. Given the length
of time over which this project could be delivered it is anticipated that the exact phasing
would vary; however, what is set out is considered to be a pragmatic programme based on
current knowledge of development interests and infrastructure delivery. The programme will
need to maintain flexibility and be regularly updated.
13.8 OPDC has undertaken a number of additional studies in support of this Local Plan
which have identified additional infrastructure requirements in the OPDC area such as the
Park Royal Transport Strategy (PRTS) and the Integrated Water Management Strategy
(IWMS). OPDC is also developing its Socio-economic Regeneration Strategy which will
identify additional infrastructure requirements in the OPDC area to promote sustainable
economic growth, and maximise the benefits to local residents and businesses from the new
opportunities that will come forward from the development.
13.9 Table XX below identifies the infrastructure required to support development,
alongside the indicative phasing of these infrastructure items and the relevance policies in
this Local Plan that will secure their delivery. This infrastructure table is largely based in the
DIFS but also includes other infrastructure items identified as part of OPDCs draft evidence
base.
Funding and delivering infrastructure
13.10 To support the needs of the new population and deliver a high quality place,
appropriate mechanisms need to be put in place to secure the delivery of infrastructure.
OPDCs DIFS has investigated potential mechanisms for funding this infrastructure, which
are considered in more detail below. The early work as part of the DIFS identifies a
substantial funding gap between the amount of infrastructure needed and the ability of
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private development to pay for all of this infrastructure. As a result, OPDC will consider a
wide range of options to support the delivery of infrastructure.
Funding through development
13.11 Development within the OPDC area, if not supported by adequate infrastructure,
would give rise to pressures on existing infrastructure and services and therefore may be
unacceptable. Development should make appropriate contributions towards new
infrastructure and improvements to existing infrastructure. The NPPF requires planning
authorities to properly consider development viability when considering infrastructure
delivery. If development is not viable, it will not proceed and this would impact on the
provision of new homes and on new jobs to support the economy. Figure XX provides a
diagrammatical indication of how infrastructure funding from development works and how
local planning authorities ensure that development makes an appropriate contribution
towards supporting infrastructure.
13.12 There are generally four ways that infrastructure can be funded from development:
1. On-site development costs
13.13 These are works carried out on a site as part of the construction of the development.
They tend to include (but not be limited to) items such as internal roads, public realm, open
space and street greening.
2. Community Infrastructure Levy
13.14 The Community Infrastructure Levy (CIL) is a levy on new development of an
amount per square metre of net additional floorspace. It is usually set at a different rate for
different types of intended uses of floorspace, and can be set at different rates for different
areas. These variations in rates reflect differences in development viability and thus
profitability for different types of land use and in different places. OPDC is the CIL charging
authority for the OPDC area. The infrastructure that a CIL charging authority intends to
spend CIL income on is set out in a Regulation 123 list. This infrastructure is generally
strategic in nature and therefore benefits a wide number of users. Infrastructure in a
Regulation 123 list cannot also be funded by money raised through Section 106 (S106)
agreements, to avoid double dipping.
13.15 OPDC is in the process of setting a CIL charging schedule and plans to consult on its
1st draft during 2016, known as the Regulation 15 consultation. This will include OPDCs
draft Regulation 123 list.
13.16 The Mayor of Londons CIL is also chargeable in the OPDC area. This presently
stands at 35/m in Brent and Ealing boroughs and at 50/m Hammersmith & Fulham and
in broad terms applies to all development other than for education and health facility uses.
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3. Section 106 Agreements

13.17 Section 106 of the Town and Country Planning Act 1990 allows a consenting
authority such as OPDC to enter into legal agreements with developers to fund or deliver
certain works to make development proposals acceptable in planning terms. This might
include the amount of affordable housing which would be included in the development or an
item of infrastructure or financial contribution towards it, such as a new school, employment
and training support or increased transport network capacity.
13.18 No more than five financial contributions made under S.106 agreements can be
pooled to fund or help fund any one item or category of infrastructure.
13.19 OPDC will be producing a Supplementary Planning Document (SPD) which sets out
how S106 Planning Obligations will be used in the OPDCs area and how they will be used
alongside CIL to secure infrastructure and mitigate adverse impacts.
4. Section 278 Agreements
13.20 These are agreements made under the Highways Act 1980 for the developer to carry
out scheme-specific highway works needed to satisfactorily tie in a scheme to the road
network, or to mitigate adverse impacts which would otherwise arise in the immediate vicinity
of the site. Examples of the works covered by S.278 agreements are vehicular crossovers
and drop kerbs (standard for most developments), or more major highway works such as
traffic lights or junction improvements, where a scheme is estimated to generated a large
number of vehicular movements.
Funding through service providers, including public sector funding
13.21 New people living and working in an area means new income for service providers.
When the service provider is a governmental body (i.e. the GLA or TfL), this funding comes
from public taxes, whilst in the case of non-governmental service providers, this usually
comes via a direct payment from the customer to the service provider (i.e. gas or electrical
provision).
13.22 A service providers business plan will set out how it intends to continue to deliver its
services subject to changing market needs. In the case of the OPDC area, there will be
many service providers set to benefit from an increased market and OPDC is holding
discussions with these service providers to make them aware of the anticipated new
population coming to the area, the phased programme for delivery and the anticipated
infrastructure needs.
Funding through Borrowing

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13.23 Where neither development nor public or private service providers can meet the
anticipated costs of development, the public sector can look at borrowing monies to fund
infrastructure. A recent example of this is the planned Northern Line extension in Vauxhall
Nine Elms Battersea. Here, the GLA borrowed monies through a method called Tax
Increment Financing (TIF), which is where an authority borrows money against anticipated
future business rate income, to up-front fund the delivery of infrastructure and then repay this
over time. There are significant associated risks with this approach.
13.24 In the case of the OPDC area, early work shows a significant funding gap between
the amount of infrastructure needed and the ability of development to pay for this
infrastructure and OPDC has been in discussions with government about potential borrowing
options to help finance this gap.
Prioritising Infrastructure
13.25 The DIFS identifies a total infrastructure bill of approximately 2 billion and additional
infrastructure items emerging from other draft studies and strategies are likely to increase
this figure. The funding and delivering infrastructure section above identifies the challenges
of funding infrastructure in a project of this scale. It is therefore important that there is a clear
prioritisation of infrastructure so that there is certainty that pieces of critical infrastructure are
funded.
13.26 OPDC as part of this consultation would welcome:
a) stakeholders views on what infrastructure OPDC should seek to prioritise; and
b) if there are any pieces of infrastructure that should be added to the list.
Consultation Questions
QDIa: What do you think are the highest priority pieces of infrastructure in Table XX?
QDIb: Are there any pieces of infrastructure identified in Table XX that you dont think
are a high priority or that you think may not be necessary to support development?
QDIc: Are there any additional pieces of infrastructure not in Table XX that you think
OPDC should be identifying?
QDId: Do you think we have identified the infrastructure within the right phases (0-20
years being within this plan period and 20+ years being post this Local Plan)?

Table XX Infrastructure requirements

Ite Sho Item
m
wn
No. on
Map
?*

Phasing Relevant Local

A: 0-20 yrs Plan Policy/s
B: 20+ yrs

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Ite Sho Item
m
wn
No. on
Map
?*
1.

Phasing Relevant Local

A: 0-20 yrs Plan Policy/s
B: 20+ yrs

Key Transport Infrastructure

T1

Willesden Junction Station bridge over West

Coast Mainline (minimum capacity
pedestrian and cycle)

P2, T1, T2, T3, T5

T2

Improvements to Willesden Junction Station

P2, T1, T4

T3

Vehicular bridge over Grand Union Canal,

through Oaklands site

P1, P2, T1, T2, T3,

T5, T6, T8

T4

Northern connection between Old Oak

North & Scrubs Lane

P2, T1, T2, T3, T5,

T6, T8, T9

T5,

Southern connection between Old Oak

North & Scrubs Lane

P2, T1, T6

T6,

Eastern road link across Grand Union Canal

P1, P2, T1, T2, T3,

T5, T6, T8, T9

T7,

Pedestrian/cycle bridge to Grand Union

Canal towpath

P2, P4, T1, T2, T3

T8,

Hythe Road Overground station (West

London Line)

P2, T1, T4

T9,

Old Oak Common Overground station

(North London Line)

P1, T1, T4

T10

Improvements to North Acton station stage 1

P7, T1, T4

T10

Improvements to North Acton station stage 2

P7, T1, T4

T11

Public realm and capacity enhancements on

Old Oak Lane

P9, D2, T1, T2, T3,

T5, T6

T12

Public realm and capacity enhancements on

Scrubs Lane

P8, D2, T1, T2, T3,

T5, T6

T13

Public realm and capacity enhancements on

Victoria Road

P7, P9, D2, T1, T2,

T3, T5, T6, T8

T14

Public realm and capacity enhancements on

Old Oak Common Lane (including upgrade
of Great Western & Chiltern lines
underpasses)

P1, D2, T1, T2, T3,

T5, T6, T8

T15

Junction capacity improvement, Old Oak

Common Lane at Oaklands

T1, T2, T3, T5, T6,

T16

Connector railway between Crossrail and

West Coast Main Lines

P1, T1, T4

T17

High street bridge across Grand Union

Canal

P1, P2, P3, T1, T2,

T3, T5, T6

T18

Access from Old Oak Common Station to

Wormwood Scrubs open space

P1, T1, T2, T3

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Phasing Relevant Local

A: 0-20 yrs Plan Policy/s
B: 20+ yrs

T19

Street linking Old Oak Common Lane to

Scrubs Lane

P1, D2, T1, T2, T3,

T5, T6

T20

Junction between Scrubs Lane and new

road to Kensal Canalside Opportunity Area

P1, T1, T2, T3, T5,

T6

T21

Connection from Crossrail station to west

side of Old Oak Common Overground
station

P1, T1, T2, T3

T22

Northern entrance to North Acton station

P7, T1, T4

T23

Access to Powerday site

P2, P9, T1, T4

T24

High street crossing of West London

Overground line

P2, T1, T2, T3, T5

T25

Pedestrian/cycle link across West London

line at proposed Hythe Rd station

P2, T1, T2, T3

T26

Improved pedestrian/cycle bridge, CarGiant

site to Willesden Junction Station

P2, T1, T2, T3

T27

Park Royal Road/ Coronation Road junction

improvements

P6, T1, T2, T3, T5,

T6

T28

Abbey Road junction improvements

P5, P6, T1, T2, T3,

T5, T6

T29

Improved pedestrian access towards Park

Royal station from north

P5, T1, T2, T3

T30

A40 junction improvements (Hanger Lane

gyratory, Gypsy Corner and Savoy Circus)

P5, T1, T5, T6

T31

NA

General street improvements in Park Royal

A/B

P5, P6, T1, T2, T3,

T5, T6

T32

NA

Junction improvements in surrounding areas

A/B

T1, T2, T3, T5, T6

T33

NA

Mini-Holland standards adopted across the

OOC core area

A/B

T1, T3

T34

NA

Cycle hire; Legible London wayfinding and

signage

A/B

T1 T3

T35

NA

Bus operating revenue support for new

services and compensation during
construction

T1, T5

T36

NA

New bus routes and bus infrastructure

including bus stops, bus stands, welfare and
maintenance facilities

A/B

T1, T5

T37

NA

Transport construction mitigation

A/B

T9, EU5

3. Digital communications infrastructure

UT1

NA

Delivery of optical fibre along road network.

EU1, EU2, EU7

UT2

NA

Alternative technology, such as wireless

point to point bridges.

EU1, EU2, EU7

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Map
?*

Phasing Relevant Local

A: 0-20 yrs Plan Policy/s
B: 20+ yrs

3.

Potable water network

UW
1

4.

Waste water / sewerage network

UW
2

UW
3

5.

Waste management network

UW
4

For OPDC areas in LB Brent and Ealing,

accord with the West London Waste Plan to
safeguard waste sites.
For OPDC areas in LB Hammersmith and
Fulham, safeguard the Powerday site.

UW
5

Alternative technology, such as pneumatic

waste collection systems and anaerobic
digestion systems.

6.

Energy network

UE1

NA

UE2

EU1, EU3

Not yet determined - further work to be

undertaken by OPDC in 2016 through the
Environment & Utilities Working Group with
Thames Water.

EU1, EU3

Potential district-wide SUDS to be

investigated.

EU1, EU3, EU8

P2, EU1, EU4

Not yet determined - further work to be

undertaken by OPDC in 2016 through the
Environment & Utilities Working Group with
Thames Water.

A/B

EU1, EU4, EU5

Decentralised Energy heat network.

EU1, EU6

Grid delivered energy Electricity

EU1, EU6

UE3

Grid delivered energy Gas

EU1, EU6

7.

Urban water management

UW
1

Tokyngton and Stonebridge Flood

Alleviation Scheme

EU1, EU3

UW
2

Strategic sustainable urban drainage

systems

EU1, EU3, EU8

UW
3

NA

On-site sustainable urban drainage systems

EU1, EU3, EU8

8.

Education

SS1

One-form expansion of primary school (offsite; options to be explored)

SI1, SI2

SS2

Two-form expansion of secondary school

(off-site; options to be explored)

SI1, SI2

SS3

Two-form primary school # 1 (Old Oak

North)

P2, SI1, SI2

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Phasing Relevant Local

A: 0-20 yrs Plan Policy/s
B: 20+ yrs

SS4

2 two-form primary schools # 2 & #3 (Old

Oak South)

P1, SI1, SI2

SS5

All-through (3-19 years) four-form school

(site to be identified)

SI1, SI2

* Further work to be undertaken with councils and the EFA to understand capacity to
expand schools. If this is not possible all additional school capacity will be needed to be
provided in the OPDC area.
9.

Health

SH1

Health centre # 1 (approximately 1,200 m,

to accommodate 6 GPs, dentists,
pharmacists and opticians.

OSP3, P1, SI1, SI3

SH2

Health centre # 2 (approximately 1,200 m,

to accommodate 6 GPs, dentists,
pharmacists and opticians.

OSP3, P1, SI1, SI3

SH3

Health centre # 3 (approximately 1,200 m,

to accommodate 6 GPs, dentists,
pharmacists and opticians.

OSP3, P1, SI1, SI3

SH4

Health centre # 4 (approximately 1,200 m,

to accommodate 6 GPs, dentists,
pharmacists and opticians.

OSP3, P2, SI1, SI3

SH5

Health centre # 5 (approximately 1,200 m,

to accommodate 6 GPs, dentists,
pharmacists and opticians.

P7, SI1, SI3

* Health care provision will change reflecting the changing NHS landscape, the focus on
the wider preventative agenda and as models of health and social care are reviewed,
revised and amended. On-site health care provision will need to respond to these
requirements and may be incorporated into fewer buildings that may also be mixed use.
10.

Emergency services

SE1

425 m extension to existing police facility

#1 (location to be determined)

SI1

SE2

425 m extension to existing police facility

#2 (location to be determined)

SI1

SE3

Intensification (1,500 m) of Park Royal Fire

Station

SI1, SI13

SE4

Additional capacity at existing ambulance

stations

SI1

SE5

On-site contact point/police shop

SI1

SE6

25 m on-site CCTV monitoring suite.

SI1

11.

Green infrastructure

OS1

P1, P2, P3, P4, P5,

P6, P7, D1, D3,
EU8

New on-site green open spaces and

equipment

196

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Map
?*

Phasing Relevant Local

A: 0-20 yrs Plan Policy/s
B: 20+ yrs

OS2

Enhancing existing green open spaces

P1, P2, P4, P5,

P10, D1, D3, EU8

OS3

New on-site hard landscaped open spaces

P1, P2, P3, P4, P5,

P6, P7, P10, D1, D3

OS4

Improvements to the Grand Union Canal

towpath

P1, P2, P4, D1, D3

OS5

Sensitive enhancements to existing open

space, including Wormwood Scrubs and
Birchwood

P10, D1, D3, EU8

OS6

New path along north side of Grand Union

Canal;

P2, P4, D1, D3

OS7

Play space for under 5s within development

plots

12.

Community and sports facilities

SC1

Community hub #1 of 2,600 m, which could

be co-located with other services such as
GPs, police and primary schools, or could
be provided as a series of smaller centres

P1, SI1, SI4

SC2

Community hub #2 of 2,600 m

P2, SI1, SI4

13.

Socio-economic regeneration

SE1

NA

Local employment , training &

apprenticeship programmes

A/B

E5

SE2

NA

Local business support programmes and

supply chain initiatives

A/B

E5

SE3

NA

Local entrepreneurship and innovation

programmes

A/B

E4

SE4

NA

Affordable workspace and meanwhile uses

promoting new business start-ups and
providing support for SMEs and social
enterprises

A/B

OSP5, P7, E4, TC3

SE5

NA

Cultural participation programmes and

public art

A/B

TC5

SE6

NA

Sports participation programmes; Facilities

and programmes to promote healthy
lifestyles

A/B

TC5

SE7

NA

Schools engagement programmes

A/B

E5

A/B

D1, D3

* Shown on Map: Yes (Y) or No (N), or not applicable (NA) for policy or scheme that is nonlocation specific.
Managing and promoting development
1. Working with stakeholders
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13.27 A wide range of public and private sector stakeholders as well as existing and new
residential and business communities will each play an important role in facilitating the
delivery of this Local Plan. There are a number of policy areas within the Local Plan that
require joint working with adjacent local planning authorities and other public sector bodies.
In accordance with the Duty to Cooperate, OPDC works closely with these authorities and
bodies, liaising on policy, development management and infrastructure delivery matters.
13.28 Figure XX shows land ownership within the core development area at Old Oak.
Today, over 50% of this land is in public sector ownership and together with the HS2s
construction work sites, this could rise to over 75% within the Local Plan period. This strong
public sector interest provides opportunities for the public sector to act as a coordinator and
potential master developer. OPDC has established a Public Sector Advisory Panel (PSAP)
to draw together and co-ordinate these public sector bodies. Early work shows that this
public sector land could deliver XXX homes and XXX jobs, of which XXX homes and XXX
jobs could be within this Local Plan period (2017-37). This provides the public sector with
significant opportunities to realise the optimal value for their assets and bring significant
opportunities for investment in homes, jobs, infrastructure and other economic benefits.
13.29 Within Old Oak, there are a number of transport depots and land designated as rail
freight sites. These include:
- Intercity Express Programme (IEP) depot;
- Powerday site;
- Crossrail depot and sidings;
- European Metal Recycling (EMR); and
- North Pole East depot.
13.30 Within the Local Plan period, it is unlikely that either the IEP depot or Powerday site
will be brought forward for development, as the former is required operationally and the latter
is an important waste site that contributes towards identified London Plan waste
apportionment figures.
13.31 This Local Plan does seek to bring forward development on the Crossrail depots,
EMR site and North Pole East depot. In the case of the Crossrail depot and sidings, the
Mayor has publicly stated that he considers it critical that this site be redeveloped, either
through reconfiguration and/or relocation to coincide with the opening date of Old Oak
Common Station. OPDC has been working with Transport for London (TfL) and the
Department for Transport (DfT) to assess how this could be achieved. In the case of the
EMR site and North Pole East depot, their release for development is contingent on them
being de-designated as rail freight sites, which must go through its own separate
consultation process.
13.32 Land ownership in the Park Royal industrial estate is much more disparate than Old
Oak but OPDC has been engaging with a number of landowners in this area, as well as the
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Park Royal Business Group who represent the businesses on the estate to identify how
intensification could be achieved through gradual redevelopment over time.
2. Determining planning applications
13.33 This Local Plan will form part of OPDCs development plan and will be a material
consideration in the determination of planning applications in the OPDC area. The following
outlines the process through which planning applications may take when being considered
by OPDC.
Pre-application meetings
13.34 OPDC offers a pre-application advice service. The benefits of pre-application advice
include providing clarity about planning policies, early identification of issues specific to a
particular site. The process provides certainty at an earlier stage in the planning process. It
is geared towards a proactive and positive engagement with applicants that seeks to
improve the quality of design, and early discussions about matters such as affordable
housing and section 106 agreements.
Local information requirements for the validation of planning applications
13.35 OPDC has a local list of information that must be submitted with a planning
application. This list is published on the OPDC website (insert web address) and will be
reviewed at least once every two years. This draft Local Plan suggests additional documents
that applicants would be encouraged to submit and OPDCs Validation List will be updated to
include these as this Local Plan is progressed.
PLACE Review Group
13.36 OPDC is committed to embedding placemaking within the plan making and
development management process, and to achieving the highest standards of design in new
development. As part of this, an independent and impartial Design Review Panel called the
PLACE Review Group (OPRG) has been established to advise OPDC on planning policy
and development proposals. PLACE stands for planning, landscape architecture,
architecture, conservation and engineering. Panel members are professionals with
experience in architecture, landscape architecture, urban design, environmental
sustainability, inclusive design, development economics and delivery.OPRG reviews
proposals at pre-application stage and post-submission before they are reported to Planning
Committee.
13.37 Further information about the PLACE Review Groups purpose and the way it works
with OPDC can be found on OPDCs website.
Determination of applications
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13.38 Once a planning application has been submitted to, and validated by OPDC, it is
considered against relevant planning policy and any other material considerations. This
Local Plan, alongside NPPF, London Plan, the Old Oak and Park Royal Opportunity Area
Planning Framework (OAPF), any neighbourhood plans and Supplementary Planning
Documents will form the basis for assessing and determining planning applications.
Enforcement Powers
13.39 Where necessary, OPDC will use its planning enforcement powers to ensure that
unacceptable development built without planning permission or other consents does not
compromise the achieving of the policies set out in this Local Plan.
3. Compulsory purchase powers
13.40 Compulsory purchase is the power that enables public bodies to acquire land, or
rights over land, compulsorily in return for compensation. It is an important tool to assemble
land needed to help deliver social, environmental and economic change. OPDC or the
GLAs compulsory purchase powers were introduced by the Localism Act and the statutory
basis is set out within Section 333ZA of the GLA Act 1999.
13.41 It may be in the interests of the proper and comprehensive planning of Old Oak and
Park Royal for OPDC or the GLA to acquire land using these powers, if this would facilitate
the regeneration of the OPDC area and if this regeneration could not be achieved without
using these powers.
13.42 In exercising its CPO powers, OPDC or the GLA must have regard to the guidance in
the DCLG Circular Compulsory Purchase and the Crichel Down Rules, October 2015 that a
CPO should only be made where there is a compelling case in the public interest and that
the purposes for which an order is made sufficiently justify interfering with the human rights
of those with an interest in the land affected.
Monitoring Local Plan Effectiveness
13.43 It is important to ensure that the policies in this Local Plan deliver regeneration for the
area and tangible benefits to local communities and to Londoners. To ensure this, OPDC will
identify indicators against which it can measure the success of the strategies and policies
within this Local Plan and help to identify any potential need to review part or all of the Local
Plan. Monitoring of these indicators will be reported through OPDCs annual Authority
Monitoring Report (AMR).
13.44 OPDC will continue to undertake further work over the coming months to identify
what these indicators might be. The indicators are likely to include the environmental targets
identified in the Environment and Utilities Chapter and socio-economic targets and standards
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identified in OPDCs Socio-Economic Strategy, which OPDC plans to consult on in 2016. As
part of this Local Plan consultation, we would like to invite stakeholders to suggest things
that we should seek to monitor to help OPDC assess the effectiveness of Local Plan
policies. This could include things such as:
- new homes permitted and delivered;
- non-residential floorspace permitted and delivered;
- town centre vacancy rates;
- cycle and car parking spaces approved; and
- new trees delivered.
Consultation Questions
QDIe: What categories should OPDC look to monitor the effectiveness of the Local
Plan against?
QDIf: Do you have any thoughts on specific indicators that should OPDC monitor the
effectiveness of the Local Plan against?

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This page is intentionally left blank

Page 224

$SSHQGL[%

OLD OAK AND PARK ROYAL

DEVELOPMENT CORPORATION
REGULATION 18 DRAFT LOCAL PLAN
Integrated Impact Assessment
Draft Report

DECEMBER 2015

Page 225

CONTACTS
DAVID HOURD
Technical Director

Arcadis.

dd 01925 800753

5th Floor
401 Faraday Street
Birchwood Park
Warrington
WA3 6GA
UK

m 07872 675 607

e David.Hourd@arcadis.com

Arcadis Consulting (UK) Limited is a private limited company registered in England & Wales (registered number 02212959). Registered Office at Manning
House, 22 Carlisle Place, London, SW1P 1JA, UK. Part of the Arcadis Group of Companies along with other entities in the UK.
Copyright 2015 Arcadis. All rights reserved. arcadis.com

Page 226

VERSION CONTROL
Issue

Revision No.

Date Issued

Description of
Revision: Page
No.

Description of
Revision:
Comment

18/12/2015

Various

Draft IIA Report

for client review

David Hourd

21/12/2015

Various

Final Draft IIA

Report following
client review

David Hourd

Page 227

Reviewed by:

CONTENTS
NON-TECHNICAL SUMMARY .....................................................................I
Introduction ........................................................................................................................... i
Strategic Environmental Assessment and Sustainability Appraisal .............................. i
Health Impact Assessment .................................................................................................. i
Equalities Impact Assessment............................................................................................ i
Habitats Regulations Assessment..................................................................................... ii
Scope of the Appraisal........................................................................................................ ii
Key Sustainability Issues and Opportunities ................................................................... ii
IIA Framework for Assessment ......................................................................................... iii
Developing and Refining Options and Assessing Effects ............................................. iv
Strategic Options................................................................................................................ iv
Appraisal of Local Plan Policies and Options ................................................................. iv
Next Steps ........................................................................................................................... iv

ABBREVIATIONS ........................................................................................1
1

INTRODUCTION ................................................................................2

1.1

Purpose of the Draft IIA Report .............................................................................. 2

1.2

The Local Plan ......................................................................................................... 2

1.3

The London Plan and Opportunity Area Planning Framework........................... 3

1.4

Sustainable Development ....................................................................................... 3

1.5

Integrated Impact Assessment .............................................................................. 4

1.6

Sustainability Appraisal and Strategic Environmental Assessment ................. 4

1.7

Health Impact Assessment ..................................................................................... 5

1.8

Equalities Impact Assessment ............................................................................... 5

1.9

Habitats Regulations Assessment......................................................................... 5

1.10

Consultation ............................................................................................................. 6

1.10.1

SA Workshop ......................................................................................................... 6

1.10.2

Formal Consultation............................................................................................... 6

1.10.3

Additional Consultation .......................................................................................... 6

1.11

Structure of this Draft IIA Report ........................................................................... 6

THE IIA PROCESS.............................................................................7

2.1

Stages in the IIA Process........................................................................................ 7

Page 228

STAGE A: SETTING THE CONTEXT AND OBJECTIVES, ESTABLISHING THE

BASELINE AND DECIDING ON THE SCOPE ..........................................14

3.1

Introduction ............................................................................................................ 14

3.2

Spatial Scope ......................................................................................................... 14

3.2.1

Aspects of the Local Plan to be assessed and how ............................................ 14

3.3

Temporal Scope ..................................................................................................... 15

3.4

Technical Scope .................................................................................................... 15

3.4.1

SEA...................................................................................................................... 15

3.4.2

HIA ....................................................................................................................... 16

3.4.3

EqIA ..................................................................................................................... 16

3.4.4

HRA ..................................................................................................................... 17

3.5

Review of Relevant Plans, Programmes and Environmental Objectives ........ 17

3.5.1

Introduction .......................................................................................................... 17

3.5.2

Key Results from the Review............................................................................... 23

3.6

The Sustainability Baseline and Key Sustainability Issues .............................. 24

3.6.1

Introduction .......................................................................................................... 24

3.6.2

Methodology ........................................................................................................ 25

3.6.3

Key Sustainability Issues and Opportunities ....................................................... 26

3.6.4

Cross-boundary considerations ........................................................................... 36

3.7

The IIA Framework................................................................................................. 36

3.7.1

Background to the IIA Framework ....................................................................... 36

3.7.2

Development of the IIA Objectives ...................................................................... 36

3.8

Assessment Methodology .................................................................................... 50

STAGE B: DEVELOPING AND REFINING OPTIONS AND ASSESSING EFFECTS

52

4.1

Alternatives ............................................................................................................ 52

4.2

Appraisal of the Strategic Options ...................................................................... 52

4.3

Assessment of the Spatial Vision ........................................................................ 52

4.4

Assessment of the Strategic Objectives ............................................................. 52

4.5

Appraisal of Preferred Policies and Policy Options .......................................... 52

4.6

Mitigation ................................................................................................................ 53

4.7

Appraisal of Cumulative and Synergistic Effects............................................... 53

4.8

Appraisal of Transboundary Effects.................................................................... 53

4.9

Technical Limitations and Uncertainties............................................................. 53

Page 229

APPRAISAL OF STRATEGIC OPTIONS.........................................54

5.1

Affordable Housing Approaches ......................................................................... 54

5.1.1

6
6.1.1

Summary of Assessment..................................................................................... 54

APPRAISAL OF THE SPATIAL VISION AND OBJECTIVES .........57

Recommendations ............................................................................................... 57

APPRAISAL OF REGULATION 18 LOCAL PLAN POLICIES AND OPTIONS

7.1

The Overarching Spatial Policies......................................................................... 62

7.1.1
7.2
7.2.1
7.3
7.3.1
7.4
7.4.1
7.5
7.5.1
7.6
7.6.1
7.7
7.7.1
7.8
7.8.1
7.9

Summary of Assessment..................................................................................... 62
The Places .............................................................................................................. 62
Summary of Assessment..................................................................................... 63
Sustainable development ..................................................................................... 63
Summary of Assessment..................................................................................... 64
Design ..................................................................................................................... 64
Summary of Assessment..................................................................................... 64
Housing................................................................................................................... 64
Summary of Assessment..................................................................................... 65
Employment ........................................................................................................... 65
Summary of Assessment..................................................................................... 65
Town Centre Uses ................................................................................................. 65
Summary of Assessment..................................................................................... 66
Social Infrastructure.............................................................................................. 66
Summary of Assessment..................................................................................... 66
Transport ................................................................................................................ 67

7.9.1

Summary of Assessment..................................................................................... 67

7.10

Environment and Utilities ..................................................................................... 68

7.10.1

Summary of Assessment..................................................................................... 68

NEXT STEPS....................................................................................71

APPENDICES
(PROVIDED IN SEPARATE DOCUMENT)

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62

APPENDIX A
Scoping Workshop Attendees and Findings

APPENDIX B
Review of Plans, Programmes and Environmental Protection Objectives

APPENDIX C
Baseline Data

APPENDIX D
Initial Analysis of other relevant SA Frameworks

APPENDIX E
Consultation Responses to IIA Scoping Report

APPENDIX F
Strategic Options Assessment

APPENDIX G
Assessment of Policy Options, Preferred Policy Options and Alternative Options

Page 231

Non-Technical Summary
Introduction
As a Local Planning Authority, the OPDC has a duty to prepare a Local Plan that sets its strategy for
development within its area and the policies that will be used to direct development and determine
applications for planning permission across the entire OPDC area. The plan period will be to 2037.
When preparing the Local Plan it is a legal requirement to undertake a Sustainability Appraisal (SA) to
ensure that it is developed within the principles of sustainable development. The term Integrated Impact
Assessment (IIA) can be used to described the process of covering more than one type of impact
assessment into a single process. Integrating different types of impact assessment into a single process can
improve efficiencies in both the assessment itself, as many of the issues covered in the different forms of
assessment overlap, as well as simplifying outcomes and recommendations for policy makers. Where more
detail on certain issues is required or necessary, this can be undertaken and included within the IIA. This
approach has been adopted by the Mayor of London, who has taken an integrated approach to assessing
the impacts of his strategies, incorporating the requirements of SEA, SA, HIA, and EqIA. This IIA draws
together the following impact assessments:
x Sustainability Appraisal and Strategic Environmental Assessment;
x Health Impact Assessment;
x Equalities Impact Assessment; and
x Habitats Regulations Assessment (HRA Screening will be undertaken as a parallel process, the findings
of which will be integrated into the IIA as appropriate).
Independent consultants, Arcadis Consulting (UK) Ltd., have undertaken the IIA of the OPDC Regulation 18
Local Plan. This Non-Technical Summary provides a high-level summary of the findings of the Draft IIA.

Strategic Environmental Assessment and Sustainability Appraisal

SA is a process for assessing the social, economic and environmental impacts of a Plan as it develops and it
aims to ensure that sustainable development is at the heart of the plan-making process. It is a legal
requirement under planning law. The law states that the SA must comply with requirements of the European
Strategic Environmental Assessment Directive.
Good practice guidance proposes a number of prescribed stages in the SA process, each of which links with
stages of the plan-making process. It is important that the SA is able to feed into the plan-making process.
This involves the ongoing appraisal of the plan and makes recommendations to help steer its direction to
avoid potentially adverse consequences. This is particularly important when considering alternative strategy
options. Consultation with statutory bodies (Natural England, Historic England and Environment Agency) and
the public is also required at key stages.

Health Impact Assessment

The online National Planning Practice Guidance (NPPG) states that a health impact assessment may be a
useful tool to use where there are expected to be significant impacts. The NHS London Healthy Urban
Development Unit states that a health impact assessment (HIA) helps ensure that health and wellbeing are
being properly considered in planning policies and proposals. Consequently, we are undertaking a highlevel assessment of the possible health impacts of the Local Plan.

Equalities Impact Assessment

The Equality Act 2010 includes a public sector equality duty which requires public organisations and those
delivering public functions to show due regard to the need to:
x Eliminate unlawful discrimination, harassment, victimisation;
x Advance equality of opportunity; and
x Foster good relations between communities.

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Consequently we are undertaking a high-level assessment of the possible equalities impacts of the Local
Plan. This will be integrated into the IIA process.

Habitats Regulations Assessment

It is a legal requirement that any plan or programme likely to have a significant impact upon a European site
protected for nature conservation, which is not directly concerned with the management of the site for nature
conservation, must be subject to an Appropriate Assessment. The overarching process is referred to as
Habitats Regulations Assessment (HRA). A HRA screening exercise is currently being undertaken to
determine if they (either in isolation and/or in combination with other plans or projects) would generate an
adverse impact upon the integrity of a European protected site, in terms of its conservation objectives and
qualifying interests. This process will be documented in a Screening Report that will be submitted to Natural
England for approval. This is a parallel process to the IIA process and will be reported separately. It is noted
that the full findings will be published with the next iteration of Local Plan and the Final IIA Report.

Scope of the Appraisal

The scope of the IIA was determined through collecting information on the environmental, social and
economic characteristics of the area. This enabled key issues, opportunities and trends to be identified. A
review of other relevant environmental protection objectives and policies was also undertaken. The review of
these documents focussed upon identifying key environmental and sustainability objectives that would need
to be considered in the IIA and the Local Plan. The scope of the appraisal was documented in a Scoping
Report, issued for consultation with the statutory bodies and the public in September 2015.
Following the consultation, responses were analysed and amendments made to the scope as appropriate. A
finalised Scoping Report has been published and is available on OPDCs website.
Individual components of the Local Plan have been assessed to determine their sustainability performance
and to provide recommendations for sustainability improvements. The following elements have been
assessed:
x The Local Plans Spatial vision;
x The Local Plans Strategic Objectives; and
x The Local Plans Preferred Policies and Policy Options.
The SA process is iterative, with regular feedback occurring between the plan-makers and the SA team as
plan options and policies are developed.

Key Sustainability Issues and Opportunities

To ensure that a robust assessment of the emerging Local Plan is undertaken, it is necessary to understand
the existing conditions and characteristics of the borough, for example, population dynamics, levels of
deprivation, health, employment patterns and the condition of housing stock and its affordability. These are
detailed in the IIA Report. The lists below identifies the sustainability topics covered in the IIA. Details of the
identified issues and opportunities are provided in the IIA Report.
x Population: demographics and implications for service provision and housing.
x Education and qualifications: levels of attainment and implications of development on school places; gap
between skills and suitable job availability.
x Human health: potential implications of opportunities for health improvements for quality of life and the
economy.
x Crime: deprivation in relation to crime levels and potential opportunities for design measures.
x Water: river water quality; drainage; wastewater capacity; flood risk; and water efficiency/water sensitive
design.
x Soil and land quality: contaminated land and the need for remediation.
x Air quality: existing air quality and opportunities/implications for construction practices and changes in
land use.

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ii

x Climatic factors and energy: energy consumption and energy efficiency; and renewable/low carbon
energy.
x Biodiversity: designated and important sites and protected species; potential impacts and opportunities to
promote environmental improvements.
x Cultural Heritage: cultural heritage resource of the borough and consideration of the wider historic
landscape including non-designated heritage and archaeological resources.
x Landscape and townscape: townscape character and green areas; access to and awareness of valued
aspects and potential for improve design and legibility.
x Waste: recycling and composting rates; existing waste sites; sustainable waste management
opportunities and waste apportionment/potential displacement.
x Transportation: accessibility and connectivity; congestion; opportunities for more sustainable modes of
transport and improved connectivity.
x Noise: road and rail noise; opportunities to minimise effects.
x Local economy: local business characterisation; unemployment; infrastructure requirements and town
centres; potential for employment and training, business opportunities and infrastructure capacity.
x Deprivation and Living Environment: high levels of deprivation and potential for improvements.
x Housing: housing tenure characteristics; housing needs; gypsy and traveller accommodation needs;
opportunities for provision of a range of types and tenures.

IIA Framework for Assessment

The IIA Framework underpins the assessment methodology and comprises a series of sustainability
objectives (covering social, economic and environmental issues) that are used to test the performance of the
plan being assessed. The IIA Objectives have been developed using the review of other relevant plans,
programmes and environmental objectives, the baseline data and the key issue and opportunities. The IIA
Framework was amended following receipt of the Scoping Report consultation responses from statutory
consultees in 2015. The following Objectives for the basis of the IIA Framework. These are supported by a
series of sub-objectives, indicators and targets, which can be found in the Draft IIA Report (Table 3-4):
1 To enhance the built environment and encourage place-making
2 To optimise the efficient use of land through increased development densities and building heights, where
appropriate
3 Maximise the reuse of previously developed land and existing buildings, including the remediation of
contaminated land
4 Minimise the need to travel, improve accessibility for all users by public and non-motorised transportation
methods and mitigate impacts on the transport network
5 Improve access to well designed, well-located, market, affordable and inclusive housing of a range of
types and tenures, to meet identified local needs
6 Improve climate change adaptation and mitigation, including minimising the risk of flooding and
addressing the heat island effect
7 To minimise contributions to climate change through greater energy efficiency, generation and storage;
and to reduce reliance on natural resources including fossil fuels for transport, heating and energy
8 To minimise production of waste across all sectors in the plan area, maximise efficiencies for transporting
waste and increasing rates of re-use, recycling and recovery rates as well as composting of all green
waste
9 Improve the quality of the water environment
10 Create and enhance biodiversity and the diversity of habitats across the area and its surroundings
11 To minimise air, noise and light pollution, particularly for vulnerable groups
12 To conserve and enhance the historic environment, heritage assets and their settings
13 Increase community cohesion and reduce social exclusion to encourage a sense of community and
welfare
14 Improve safety and reduce crime and the fear of crime
15 Maximise the health and wellbeing of the population, reduce inequalities in health and promote healthy
living

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16 To improve the education and skills levels of all members of the population, particularly vulnerable groups
17 Maximise the social and economic wellbeing of the local and regional population and improve access to
employment and training
18 To encourage inward investment alongside investment within existing communities, to create sustainable
economic growth

Developing and Refining Options and Assessing Effects

Strategic Options
Government guidance advises that only realistic and relevant alternatives should be considered and they
should be sufficiently distinct to enable a meaningful comparison of their different environmental effects.
Good practice guidance recommends that the key aims and principles of the plan should be assessed
against the IIA Objectives, in order to test their compatibility and to determine whether they accord with
broad sustainability principles. The spatial strategy options were assessed ahead of the drafting of the
Regulation 18 Local Plan, as they form the basis of the approach within the area.. The assessment of the
strategic options is presented in Chapter 5 of this Draft IIA Report.
The Spatial vision for OPDC has been reviewed against the IIA Objectives, and a summary of the key
strengths, weaknesses and recommendations are presented in Chapter 6 of the IIA Report. The assessment
of the Strategic Objectives of the Local Plan against the IIA Objectives has been undertaken during the IIA
using a simple matrix based approach. Chapter 6 of the IIA Report presents the complete compatibility of the
Spatial Objectives against the IIA Objectives.

Appraisal of Local Plan Policies and Options

The Local Plan policies and policy options for development were assessed against the IIA Objectives using a
matrix based approach. This matrix allowed the identification of positive and negative impacts, as well as the
potential for cumulative effects to occur. Mitigation measures and recommendations were suggested to offset
or alleviate any predicted adverse impacts, or to enhance any opportunities that were identified.
A summary of the assessment of this is provided in Chapter 7 of the IIA Report. The complete results of the
assessment are presented in Appendix G.
In summary, the majority of predicted effects were positive. The assessment led to the prediction of major
positive effects against all of IIA Objectives.

Next Steps
This Draft IIA Report has now been issued for consultation alongside the Regulation 18 Local Plan to all key
stakeholders (including statutory consultees and the public) for comment. The Regulation 18 Local Plan
along with this accompanying IIA Report and associated appendices will be consulted on for eight weeks.
Following the close of the consultation period, OPDC will review the feedback and revise the Plan as
appropriate. The IIA Report will then be updated to reflect the assessment of these amendments or additions
prior to the Regulation 19 Local Plan being published. The IIA Report will also include aspects relating to the
SA process, such as a draft Monitoring Framework, as outlined in Table 2-1 of this report. The next
consultation on the IIA Report will be undertaken alongside the consultation on the Regulation 19 Local Plan.
If you would like to comment on this Draft IIA Report, please send comments to:
localplan@opdc.london.gov.uk
or
Local Plan Consultation
Old Oak and Park Royal Development Corporation
City Hall,
The Queen's Walk,
More London Riverside,
London
SE1 2AA

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iv

Abbreviations
AQMA

Air Quality Management Area

BAP

Biodiversity Action Plan

CIL

Community Infrastructure Levy

cSAC

Candidate Special Area of Conservation

DECC

Department of Energy and Climate Change

EqIA

Equalities Impact Assessment

GLA

Greater London Authority

HIA

Health Impact Assessment

HRA

Habitats Regulations Assessment

HUDU

NHS London Health Urban Development Unit

IIA

Integrated Impact Assessment

LNR

Local Nature Reserves

LSDC

The London Sustainable Development Commission

LSOA

Lower Super Output Area

NNR

National Nature Reserves

NPPG

National Planning Policy Guidance

NVQ

National Vocational Qualification

ONS

Office for National Statistics

OPDC

The Old Oak and Park Royal Development Corporation

OPDM

The Office of the Deputy Prime Ministers

ppha

persons per hectare

pSPA

Potential Special Protection Areas

RIGS

Regionally Important Geodiversity Sites

SA

Sustainability Appraisal

SAC

Special Area of Conservation

SAM

Scheduled Ancient Monument

SCI

Sites of Community Importance

SEA

Strategic Environmental Assessment

SHMA

Strategic Housing Market Assessment

SINC

Sites of Importance for Nature Conservation

SPA

Special Protection Area

SSSI

Site of Special Scientific Interest

WCED

World Commission on Environment and Development

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1 Introduction
1.1

Purpose of the Draft IIA Report

The Old Oak and Park Royal Development Corporation (OPDC) is currently consulting on the Regulation 18
Local Plan. This Draft IIA Report has been prepared by Arcadis Consulting UK Ltd. (formerly Hyder
Consulting (UK) Ltd.) on behalf of the OPDC, as part of the combined Sustainability Appraisal (SA) and
Strategic Environmental Assessment (SEA), incorporating Health Impact Assessment (HIA) and Equalities
Impact Assessment (EqIA) (hereinafter referred to as the Integrated Impact Assessment (IIA)) of the
emerging Local Plan. Habitats Regulations Assessment Screening will also be undertaken as a parallel
process, the findings of which will be integrated into the IIA as appropriate.
As a Local Planning Authority, the OPDC has a duty to prepare a Local Plan that sets its strategy for
development within its area and the policies that will be used to direct development and determine
applications for planning permission across the entire OPDC area.
The SA process commenced with a Scoping consultation, in September 2015. The SEA Directive requires
the authority preparing the plan to consult the Consultation Bodies on the scope and level of detail of the
Environmental Report (in this case a full Integrated Impact Assessment Report, which will ultimately
document the findings of the IIA). In addition to the Consultation Bodies, a public consultation was
undertaken. The preparation of a Scoping Report provides the most effective means of undertaking this
consultation by providing the consultees with a document upon which they can make comments.
Consultation responses as a result of this consultation have been integrated into this report and are
documented in Appendix E.
This Draft IIA Report is intended to document the assessment of the Regulation 18 Local Plan, which sets
out preferred policy direction for the OPDC area. It is noted, therefore, that the assessment of the preferred
policy options is not final, and, along with the public consultation on the Regulation 18 Local Plan which this
Draft IIA Report accompanies, seeks to inform the development of the next stage of the Local Plan, and
comprises a non-statutory stage for SA public consultation. It is noted that the version of the Regulation 18
th
Local Plan assessed is dated 15 December 2015. Any changes to the text following this date, have not
been considered.

1.2

The Local Plan

Launched on 1 April 2015, the OPDC has been established by the Mayor of London, to take on powers of
planning, regeneration, compulsory purchase orders and the ability to adopt and manage streets and space
in the area covered by the emerging Old Oak and Park Royal Opportunity Area Planning Framework
(OAPF). This new Local Planning Authority spans parts of the London Boroughs of Brent, Ealing and
Hammersmith and Fulham and therefore takes on planning powers in the areas of these authorities that it
covers. The OPDC boundary, including its relationship to its three constituent boroughs, is shown in Figure
1-1.
The OPDCs purpose is to use the once-in-a-lifetime opportunity of investment in HS2 and Crossrail, to
develop an exemplar community and new centre in north-west London, creating opportunities for local
1
people and driving innovation and growth in London and the UK .
The OPDC is a functional body of the Greater London Authority (GLA), working closely with a number of
organisations including the Mayor of London, the GLA, Transport for London, central government, the local
Boroughs of Brent, Ealing and Hammersmith & Fulham, residents in neighbouring local communities, local
organisations, businesses, landowners, developers and regeneration agencies.
As a Local Planning Authority, the OPDC has a duty to prepare a Local Plan that sets its strategy for
development within its area and the policies that will be used to direct development and determine
applications for planning permission across the entire OPDC area. The plan period will be to 2037.

https://www.london.gov.uk/priorities/planning/old-oak-park-royal

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Until the OPDC adopts its own Local Plan for the OPDC area, the Boroughs Local Plans will apply to the
areas that they cover. Figure 1-1 shows the areas covered the three constituent Local Authorities of the
London Borough of Brent; the London Borough of Ealing; and the London Borough of Hammersmith and
Fulham.

1.3

The London Plan and Opportunity Area Planning Framework

The London Plan is the overall strategic plan for London, and forms part of the development plan for the
OPDC. The London Plan sets out a fully integrated economic, environmental, transport and social framework
for the development of the capital to 2036. London boroughs Local Plans need to be in general conformity
with the London Plan, and its policies guide decisions on planning applications by councils and the Mayor.
The Opportunity Area Planning Framework for Old Oak and Park Royal provides supplementary guidance to
the London Plan to help to shape the regeneration of Old Oak and enhancement of Park Royal. This was
adopted by the Mayor of London on 4 November 2015.
Figure 1-1 OPDC Boundary

1.4

Sustainable Development

The concept of sustainable development is central to the planning system. The term sustainable
development has been used since 1987 following the publication of the World Commission on Environment
and Development (WCED) report Our Common Future (The Brundtland Report). It called for a strategic that
united development and the environment, and defined sustainable development as:
Development that meets the needs of the present without compromising the ability of future generations to
meet their own needs.
The UK Government has produced a Sustainable Development Strategy, Securing the Future (March
2005). Priority areas for immediate action are outlined as:
x Sustainable consumption and production;

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x Climate change and energy;

x Natural resource protection and environmental enhancement; and
x Sustainable communities.
To achieve forms of development that are more sustainable than previous development, proposals must
strike an acceptable balance between maximising resource and energy efficiency; minimising environmental
impacts; delivering social benefits; and supporting a healthy economy. The London Sustainable
Development Commission (LSDC) provides advice to the mayor to help make London more sustainable as it
continues to develop and grow. The priorities of LSDC are as follows:
x London Infrastructure Plan 2050: The Mayor has asked the Commission to advise on the London
Infrastructure Plan 2050. The LSDC Chair is a member of the Infrastructure Delivery Board.
x Circular Economy: The LSDC sees waste as an opportunity to create new jobs and industries. This is
why its exploring ways to support Londons move to a circular economy. In such an economy, waste is
no longer considered just rubbish, but a resource of raw materials that has value.
x Energy: The LSDC will be exploring a range of issues around energy in the capital. This includes energy
efficiency, and decentralised energy, meaning energy which is produced close to where its used. The
Commission will also look at how Londoners can overcome barriers to solar panel uptake in the capital.
Progress here could also achieve greater investment in community infrastructure projects.
x Green Economy: The LSDC has made recommendations on ways to speed up the growth of Londons
low carbon goods and services sector. It is now helping to determine how these measures might be
achieved. The LSDC is also helping to raise the capitals profile as a centre for cleantech technology
which is environmentally friendly.
Relevant national and London based guidance has been considered and adhered to as part of this IIA.
Where relevant, this has been referenced and reflected in the review of PPPs and the IIA Framework in
Chapter 6.

1.5

Integrated Impact Assessment

The term Integrated Impact Assessment (IIA) can be used to described the process of covering more than
one type of impact assessment into a single process. Integrating different types of impact assessment into a
single process can improve efficiencies in both the assessment itself, as many of the issues covered in the
different forms of assessment overlap, as well as simplifying outcomes and recommendations for policy
makers. Where more detail on certain issues is required or necessary, this can be undertaken and included
within the IIA. This approach has been adopted by the Mayor of London, who has taken an integrated
approach to assessing the impacts of his strategies, incorporating the requirements of SEA, SA, HIA, and
EqIA. This IIA draws together the following impact assessments:
x Sustainability Appraisal and Strategic Environmental Assessment;
x Health Impact Assessment;
x Equalities Impact Assessment; and
x Habitats Regulations Assessment (HRA Screening will be undertaken as a parallel process, the findings
of which will be integrated into the IIA as appropriate).
The following text provides further detail of each of the component impact assessments in turn. Section 3
provides further detail about how the assessment processes will be integrated.

1.6

Sustainability Appraisal and Strategic Environmental Assessment

SA is a process for assessing the social, economic, and environmental impacts of a plan and aims to ensure
that sustainable development is at the heart of the plan-making process.
It is a legal requirement that Local Plans are subject to SA, under the Planning and Compulsory Purchase
Act 2004. This Act stipulates that the SA must comply with the requirements of the SEA Directive which was
transposed directly into UK law through the SEA Regulations.
SEA is a systemic process for evaluating the environmental consequences of plans and programmes to
ensure that environmental issues are integrated and assessed at the earliest opportunity in the decisionmaking process. Article 1 of the SEA Directive states that the aim is to:

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Provide for a high level of protection of the environment and to contribute to the integration of environmental
considerations into the preparation and adoption of plans and programmes with a view to promoting
sustainable development.
It is possible to combine the processes of SEA and SA, as they share a number of similarities. National
Planning Policy Guidance (NPPG) promotes a combined process (i.e. a process which assesses social,
economic and environmental effects) and this is the approach that has been adopted here. Whilst there are
formalised approaches for both SA and SEA, only SEA has a legal obligation to perform certain activities.
These legal obligations have been and will continue to be adhered to throughout the Integrated Impact
Assessment for the new Local Plan. This Scoping Report includes a series of boxes which clearly identify
the specific requirements of the SEA Directive that need to be fulfilled.

1.7

Health Impact Assessment

The online National Planning Practice Guidance (NPPG)2 states that:

Local planning authorities should ensure that health and wellbeing, and health infrastructure, are considered
in local and neighbourhood plans and in planning decision makingA health impact assessment may be a
useful tool to use where there are expected to be significant impacts.
According to the NHS London Healthy Urban Development Unit:
A health impact assessment (HIA) helps ensure that health and wellbeing are being properly considered in
planning policies and proposals.
Consequently, we are undertaking a high-level assessment of the possible health impacts of the Local Plan.
As the OPDC is a pioneer for having public health expertise based within its core team, they have already
ensured that public health expertise is, and will be, provided by the Local Authorities, Transport for London,
GLA Health Team and Public Health England, as well as from OPDC Health Advisor. This will be integrated
into the IIA process. Further details on the scope of the assessment and how the processes will be
integrated can be found in Sections 2 and 3 of this report.

1.8

Equalities Impact Assessment

The Equality Act 2010 includes a public sector equality duty which requires public organisations and those
delivering public functions to show due regard to the need to:
x Eliminate unlawful discrimination, harassment, victimisation;
x Advance equality of opportunity; and
x Foster good relations between communities.
Consequently we are undertaking a high-level assessment of the possible equalities impacts of the Local
Plan. This will be integrated into the IIA process. Further details on the scope of the assessment and how the
processes will be integrated can be found in Sections 2 and 3 of this report.

1.9

Habitats Regulations Assessment

European Council Directive 92/43/EEC on the Conservation of natural habitats and of wild flora and fauna
(the Habitats Directive) requires that any plan or programme likely to have a significant impact upon a
Natura 2000 site (Special Area of Conservation (SAC) and Special Protection Area (SPA), which is not
directly concerned with the management of the site for nature conservation, must be subject to an
Appropriate Assessment. The overarching process is referred to as Habitats Regulations Assessment
(HRA). In addition it is a matter of law that candidate SACs (cSACs), Sites of Community Importance (SCI),
Ramsar sites and potential SPAs (pSPAs) are also considered in this process.

http://planningguidance.planningportal.gov.uk/blog/guidance/health-and-wellbeing/what-is-the-role-of-health-andwellbeing-in-planning/

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A HRA screening exercise is currently being undertaken to determine if they (either in isolation and/or in
combination with other plans or projects) would generate an adverse impact upon the integrity of a Natura
2000 site, in terms of its conservation objectives and qualifying interests. This process will be documented in
a Screening Report that will be submitted to Natural England for approval.
This is a parallel process to the IIA process and will be reported separately. However, its findings will be
3
relevant to the IIA and vice versa so the two processes will need to interact. The NPPG states that, the
sustainability appraisal should take account of the findings of a Habitats Regulations Assessment, if one is
undertaken. The findings of the HRA screening exercise have been considered in this Draft IIA Report
where relevant. However, it is noted that the full findings will be published with the next iteration of Local Plan
and the Final IIA Report.

1.10 Consultation
1.10.1 SA Workshop
A scoping workshop was held in July 2015 with attendees from a range of organisations including officers
from: the GLA; Transport for London (TfL); OPDC; Historic England; the London Boroughs of Brent, Ealing,
Hammersmith and Fulham and Kensington and Chelsea; Public Health England; and the Environment
Agency. The findings of this workshop have contributed to this report. Further details of the specific findings
of the workshop are provided in Appendix A.

1.10.2 Formal Consultation

In accordance with regulation 12(5) of the SEA Regulations, the Scoping Report was consulted upon for a
five week period, commencing in September 2015. The statutory SEA bodies consulted were:
x Natural England;
x Historic England; and,
x The Environment Agency.
The Scoping Report was made available for comment on OPDCs website for the general public and other
stakeholders during the consultation period, as well as being sent directly to the IIA Workshop attendees
(see Appendix A). Comments received have been integrated into this Draft IIA Report, and are documented
in Appendix E.

1.10.3 Additional Consultation

An important element of the IIA, HIA and EqIA in particular, is to engage the community throughout the
development of the Local Plan. OPDC officers have met with community groups prior to the Regulation 18
consultation and will continue to do so during and after the formal consultation period.

1.11 Structure of this Draft IIA Report

This Draft IIA Report provides a summary of the IIA process so far and documents the findings and
recommendations of the assessment. It will be used as a consultation document and issued to statutory
bodies and stakeholders for comment alongside the Regulation 18 Local Plan. It will also be made available
to the public.
It is essential that this Draft IIA Report is read alongside the OPDC Regulation 18 Draft Local Plan.

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2 The IIA Process

2.1

Stages in the IIA Process

4

The Office of the Deputy Prime Ministers (OPDM) Practical Guide as well as NPPG (March 2014), provide
guidance on conducting an SA. This will be followed for the purposes of the IIA. The five main stages in
conducting an SA are defined as:
x Stage A - setting the context and objectives, establishing the baseline and deciding on the scope;
x Stage B - developing and refining options and assessing effects;
x Stage C - preparing the Sustainability Appraisal Report;
x Stage D - consulting on the preferred option of the development plan and SA Report; and
x Stage E - monitoring significant effects of implementing the development plan.
Table 2-1 presents the key stages in the SA process. This Draft IIA Report documents the findings of Stages
A and B. However, it is noted that further assessment within Stage B of the process for refining options is
likely to be required for the next iteration of the Local Plan. The table also demonstrates how each of the SA
(including SEA), HIA, EqIA and HRA assessment processes and stages are linked to each other, as well as
to the preparation and development of the Local Plan.

ODPM (2005) A Practical Guide to the SEA Directive

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Old oak and park royal development corporation Regulation 18 DRAFT local plan

Table 2-1 Stages in the IIA Process

Local Plan
Stage
Determining
the scope of
the Local Plan
including
specifying the
opportunities
or issues the
authority wants
to solve

Sustainability Appraisal including

Strategic Environmental
Assessment
A. Setting the
Identify related
context and
plans/programmes
objectives,
establishing
the baseline
and deciding
Identify
on the scope
environmental
protection
objectives
Baseline data and
likely future trends

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Identify
sustainability issues
and opportunities

Develop objectives,
indicators and
targets
(Assessment
Framework)
Prepare SA
Scoping Report,
incorporating HRA
and HIA
Consult on the
scope of the SA
including HIA,

Habitats
Regulation
Assessment

Identify all
European sites
within and up to
20km from the
OPDC area
Contact Natural
England for details
of all European
sites (including
conservation
objectives) and
consultation
purposes
Liaise with SA team
to ensure the
Assessment
Framework covers
European sites
appropriately
HRA information
incorporated in SA
Scoping Report
Consultation as
part of SA Scoping
Report consultation

Health Impact
Assessment

Equalities Impact
Assessment

Identify health related

plans/programmes (as
part of SA) linked into
local Joint Strategic
Needs Assessments
Derivation of health related themes

Review of relevant
policies and
strategies

Where covered
in this Draft IIA
Report
Chapter 3 and
Appendix B

Derivation of
equality-related
themes

Chapter 3 and
Appendix B

Gather baseline data

relating to health (as
part of SA)

Baseline data and

likely future trends

Chapter 3 and
Appendix C

Identify health specific

issues and relevant
health determinants
using the London
Healthy Urban
Development Unit tool
(as part of SA)

Identify equalities
specific issues

Chapter 3

Ensure inclusion of
health specific
objectives, indicators
and targets in SA
Assessment Framework

Chapter 3 and
Appendix D

HIA information
incorporated in SA
Scoping Report.

Ensure inclusion of
equalities specific
objectives, indicators
and targets in SA
Assessment
Framework
EqIA information
incorporated in SA
Scoping Report.

Consultation as part of
SA Scoping Report
consultation.

Consultation as part
of SA Scoping
Report consultation.

Chapter 3,
Appendix A and
Appendix E

Chapter 3

12

Old oak and park royal development corporation Regulation 18 DRAFT local plan

Local Plan
Stage

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Generating
options and
preferred
options for the
strategy and
implementation
plan to resolve
these
challenges;
appraising the
options and
predicting their
effects
(Regulation 18
Local Plan)
Consultation
on Local Plan
(Regulation 18)

Selecting
finalised
preferred
policy options
for the strategy
and
implementation
plan and
deciding
priorities
Production of
the Draft Local

Sustainability Appraisal including

Strategic Environmental
Assessment
EqIA and HRA (5
weeks)

Habitats
Health Impact
Equalities Impact
Regulation
Assessment
Assessment
Assessment
including
consultation with
Natural England
Review of scoping consultation responses and preparation of Final Scoping Report to inform next stage.
B1/B2.
HIA effects evaluated
EqIA effects
Assess objectives
Developing,
through SA Framework
evaluated through
against the
refining and
including mitigation
SA Framework
Assessment
appraising
Framework
strategic
Develop, refine and Consider HRA
Screening exercise
options, policy appraise strategic
implications of the
of proposed strategic
options and
options
options.
options
preferred
Evaluate/select
policy options. preferred policy
options
C. Prepare Initial SA Report

Where covered
in this Draft IIA
Report

Appendix E
Chapter 6

Chapter 5 and
Chapter 7
Chapter 7

This report

Consultation on Initial SA Report (non-statutory)

This report

Review of consultation responses and necessary actions to inform next stage

Stage to be
completed
Stage to be
completed

B3/B4.
Assessing the
effects of the
Local Plan
Preferred
Options

Predict and assess

effects of options
taken forward
Proposed mitigation
measures
Propose monitoring
programme

C. Prepare SA Report

HIA effects evaluated

through SA Framework
including mitigation

EqIA effects
evaluated through
SA Framework

Monitoring as part
of SA

Monitoring as part of SA

Monitoring as part of
SA

Stage to be
completed
Stage to be
completed

HRA Screening of
draft Local Plan.

HIA documented in SA
Report

EqIA documented in
SA Report

Stage to be
completed

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Local Plan
Stage

Sustainability Appraisal including

Strategic Environmental
Assessment

Health Impact
Assessment

Equalities Impact
Assessment

Where covered
in this Draft IIA
Report

D. Consultation on the SA Report

Habitats
Regulation
Assessment
HRA Screening
Report produced
separately and sent
to Natural England
for agreement of
findings.
As above.

HIA Consultation
included in SA Report
consultation

EqIA Consultation
included in SA
Report consultation

Stage to be
completed

D. Prepare a
supplementary
or revised SA
Report if
necessary

Prepare updated
HRA Report
following Natural
England comments
(if necessary).

HIA assessment of
significant changes
undertaken as part of
SA and options around
mitigation or reduction of
effect identified

EqIA assessment of
significant changes
undertaken as part of
SA

Stage to be
completed

Plan

Consultation of
Draft Local
Plan
(Regulation 19)
Production of
Final Local
Plan

Assess significant
changes

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Prepare
supplementary or
revised SA Report
Adoption of
Local Plan

D. SA Statement

Stage to be
completed
Stage to be
completed

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3 Stage A: Setting the Context and Objectives, Establishing

the Baseline and Deciding on the Scope
3.1

Introduction

The following section describes Stage A of the SA process, as documented in the Scoping Report.
Consultation comments from the Scoping Report consultation in September 2015 are reflected here, as
documented in Appendices A and E.

3.2

Spatial Scope

The proposed study area for the IIA of the Local Plan, in general, is shown in Figure 1-1. However, as
discussed at the Scoping Workshop, some effects, particularly in relation to health and employment and
skills, will likely extend beyond this boundary. Studies in relation to the effects on local populations in the
neighbouring areas to the OPDC boundary are currently ongoing. Relevant data collated as part of these
studies will be integrated into the IIA process when available. Further data may also be collated when further
information is available about the policies and the proposals of the Local Plan. It may then be necessary to
collate more baseline data to enable the assessment of the effects of the Local Plan beyond its boundaries.

3.2.1 Aspects of the Local Plan to be assessed and how

The framework of policies and proposals contained within the Local Plan will seek to regulate and control the
development and use of land and to provide the basis for consistent and transparent decision making on
individual planning applications. As options emerge, each of its components will be assessed to determine
sustainability performance and to provide recommendations for sustainability improvements. The Local Plan
includes policies and proposals, grouped under the following headings:
1. Spatial vision and Objectives
2. The Overarching Spatial Policies
3. The Places
4. Sustainable development
5. Design
6. Housing
7. Employment
8. Town Centre Uses
9. Social Infrastructure
10. Transport
11. Environment and Utilities
The Delivery and Implementation Chapter has not been assessed as this provides delivery information for
how the spatial vision, objectives and policy options will be implemented can would repeat the assessment
undertaken for these sections.

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The intention is to ensure that the process is iterative while maintaining an independent assessment with
regular feedback occurring between the plan-makers and the IIA team, as options are developed.
The method adopted to assess each element of the plan has been slightly different, for example, the spatial
vision has been subject to a qualitative review in light of the IIA Framework objectives and an objective
compatibility exercise has been used to determine if there are any key conflicts between the Local Plan
Objectives and IIA Objectives.
However, a more detailed assessment of the policy options and alternatives has been undertaken using an
assessment matrix.

Assessment of Alternatives
It is a requirement of the SEA Directive that reasonable alternatives are assessed and, therefore, alternative
options have been assessed using the IIA Framework. In accordance with NPPG:
The sustainability appraisal should predict and evaluate the effects of the preferred approach and
reasonable alternatives and should clearly identify the significant positive and negative effects of each
alternative.
Alternatives must be realistic and are likely to emerge from the plan-making process. However, the SEA can
encourage further thinking around alternatives, and highlight where environmentally preferable options exist.
Alternatives have been a focus for several legal challenges within the UK, and so it is important to ensure
reasonable alternatives are meaningfully considered. If there are genuinely no reasonable alternatives to a
plan, alternatives should not be artificially generated.
Overarching strategic options were assessed ahead of the drafting of the Local Plan. The purpose of the
assessment has been to determine the sustainability strengths and weaknesses of each option, such that
this information can be used by the plan-makers to develop the plans policy options and preferred policies.
The preferred policies and policy options were then assessed alongside one another in detail, which enables
a comparison of their predicted sustainability effects, to inform the development of the preferred policies,
which will be published at the next stage of the Local Plans development. A matrix has been used for this
assessment that enables the policies and options to be easily compared.
The types of alternative options reviewed have included:
x Strategic Spatial Strategy Options; and
x Strategic policy options and preferred policy options.
This report documents the first part of Stage B of the SEA process alongside Stage A. This Draft IIA Report,
is being published with the Regulation 18 version of the draft Local Plan.

3.3

Temporal Scope

The Local Plan will set out policies for the period to 2037. This will be used as the temporal scale for the IIA.
This will help to identify whether effects are likely to be permanent (i.e. irreversible at least through the
lifetime of the proposed measure/scheme) or temporary.

3.4

Technical Scope

3.4.1 SEA
The SEA Directive and the SEA Regulations require that the likely significant effects on the environment are
assessed, considering the following factors and interrelationship between them:

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x Biodiversity;
x Population;
x Human health;
x Fauna and flora;
x Soil;
x Water;
x Air;
x Climatic factors;
x Material assets;
x Cultural heritage including architectural and archaeological heritage; and
x Landscape.
The above topics therefore form the technical scope of the SEA.

3.4.2 HIA
The NHS London Health Urban Development Unit (HUDU) Rapid Health Impact Assessment Tool
Framework (January 2013)5 guidance lists the following health determinants, to be considered as a part of
an assessment into health impacts:
1.

Housing quality and design;

2.

Access to healthcare services and other social infrastructure;

3.

Access to open space and nature;

4.

Air quality, noise and neighbourhood amenity;

5.

Accessibility and active travel;

6.

Crime reduction and community safety;

7.

Access to healthy food;

8.

Access to work and training;

9.

Social cohesion and lifetime neighbourhoods;

10. Minimising the use of resources; and

11. Climate change.
The HIA elements of the IIA will therefore seek to assess the Local Plan in terms of its effects on the health
of the local community, with wider effects being considered where relevant. This might include communities
in the surrounding area, incoming residents and people coming in for work, visiting or just travelling through.
This will encompass the determinants described above, where they relate to land use planning. There will be
work developed around mitigating issues that impact negatively on health physical, mental and emotional.
Within the assessment process, the HIA has been integrated throughout the IIA Framework (see section 3),
with health, and impact on health, being considered under all relevant objectives. Most notably, however, the
human health topic of SEA will be expanded upon, to ensure that relevant baseline data, key sustainability
issues and opportunities, objectives and mitigation is identified. Table 2-1 provides further information on
how the HIA process will integrate with the IIA process.

3.4.3 EqIA
5

http://www.healthyurbandevelopment.nhs.uk/wp-content/uploads/2013/12/HUDU-Rapid-HIA-Tool-Jan-2013-Final.pdf

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The EqIA process is designed to ensure that projects, policies and practices do not discriminate or
disadvantage people and also to enable consideration of how equality can be improved or promoted. The
EqIA will consider the impact of a proposal on relevant groups who share characteristics which are protected
under the Equality Act (age, disability, race, faith, gender (including gender reassignment), sexual
orientation, pregnancy and maternity, marriage and civil partnership) as well as others considered to be
vulnerable within society such as low income groups.
This Draft IIA Report, which integrates the requirements of EqIA, sets out the matters that have been
identified as relevant for consideration in the EqIA. The EqIA seeks to identify those groups that may be
affected by the proposals, to analyse what the equality impacts are, and what measures are to be applied to
policy to minimise or eliminate the adverse impacts. Within the assessment process, the EqIA will be
integrated throughout the IIA Framework (see section 3.7), with equalities issues being considered under all
relevant objectives. Table 2-1 provides further information on how the EqIA process will integrate with the IIA
process.

3.4.4 HRA
Within the OPDC area there are no internationally designated SACs, SPAs or Ramsar sites. The closest to
the site are listed in Table 2-1. A HRA screening exercise will be undertaken to determine if they (either in
isolation and/or in combination with other plans or projects) would generate an adverse impact upon the
integrity of a Natura 2000 site, in terms of its conservation objectives and qualifying interests. This process
will be documented in a Screening Report that will be submitted to Natural England for approval. This is a
parallel process to the IIA process and will be reported separately.
Table 2-1 Statutory sites of international nature importance within 20km of the OPDC area

Name of Site

Identification
Number

Designation

Approximate distance
from OPDC boundary

Richmond Park

UK0030246

SAC

7.3km south

Wimbledon Common

UK0030301

SAC

8.3km south

Lee Valley

UK9012111

SPA

14.3km north-east

Lee Valley

UK11034

Ramsar Site

14.3km north-east

South West London Waterbodies

UK9012171

SPA

16.3km south-west

South West London Waterbodies

UK11065

Ramsar Site

16.3km south-west

Epping Forest

UK0012720

SAC

17.8km north-east

3.5 Review of Relevant Plans, Programmes and Environmental

Objectives
3.5.1 Introduction
The box below stipulates the SEA Directive requirements for this stage of the process.
Box 1: SEA Directive Requirements for the Review of Plans Programmes and Environmental
Protection Objectives
an outline of the contents, main objectives of the plan or programme and relationship with other relevant
plans and programmers (Annex 1 (a)).
the environmental protection objectives, established at international, Community or Member State level,
which are relevant to the plan or programme and the way those objectives and any environmental
considerations have been taken into account during its preparation (Annex 1 (e))

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A review of other plans and programmes that may affect the preparation of the Local Plan was undertaken in
order to contribute to the development of both the IIA and the Local Plan. This included:
x Identification of any external social, environmental or economic objectives, indicators or targets that
should be reflected in the IIA process.
x Identification of any baseline data relevant to the IIA.
x Identification of any external factors that might influence the preparation of the plan, for example
sustainability issues.
x Identification of any external objectives or aims that would contribute positively to the development of the
Local Plan.
x Determining whether there are clear potential conflicts or challenges between other identified plans,
programmes or sustainability objectives and the Local Plan.
The review included documents prepared at international, national, regional and local scale. A brief summary
of the documents reviewed and the main findings are summarised in Tables 3-1 and 3-2. Further details are
presented in Appendix B.
Table 3-1

Review of Plans, Policies and Programmes

Plan, Policy or Programme

Directly Relevant
Process

International / European
European Directive 2001/42/EC (SEA Directive)

SEA

European Directive 92/43/EEC and amended by 97/62/EC on the conservation of natural

habitats

HRA, SEA

European Directive: Environmental Noise Directive 2002/49/EC

SEA, HIA, EqIA

EU Directive on Ambient Air Quality and Management 96/62/EC

SEA, HIA, EqIA

Water Framework Directive 2000/60/EC

SEA

Waste Framework Directive 2008/98/EC

SEA

Urban Waste Water Treatment Directive 91/271/EEC

SEA, HIA

Directive on the Promotion of the Use of Energy from Renewable Sources 2009/28/EC

SEA

Health for Growth 2014-2020, European Commission, 2011

HIA, SEA

European Convention on the Protection of the Archaeological Heritage (revised), 1992

SEA

European Landscape Charter 2000

SEA

National

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Plan, Policy or Programme

Directly Relevant
Process

Greater London Authority Act 1999

HIA, EqIA

Equality Act 2010

HIA, EqIA

Wildlife and Countryside Act 1981

HRA

Flood and Water Management Act 2010

SEA, HIA

Energy Act 2013

SEA

Climate Change Act 2008

SEA, HIA, EqIA

Planning (Listed Building and Conservation Areas) Act 1990

SEA

Ancient Monuments and Archaeological Areas Act 1979

SEA

UK Climate Change Programme 2006

SEA, HIA, EqIA

National Planning Policy Framework, Department for Communities and Local Government,
March 2012

SEA, HIA, EqIA

National Planning Policy for Waste, October 2014

SEA, HIA, EqIA

Planning Policy for Traveller Sites, Department for Communities and Local Government,
August 2015

SEA, EqIA

The UK Government Sustainable Development Strategy, HM Government, 2005

SEA, HIA, EqIA

The UK Low Carbon Transition Plan, HM Government, July 2009

SEA

The Carbon Plan, HM Government, December 2011

SEA

UK Renewable Energy Strategy, HM Government, 2009

SEA

Future Water: The Governments Water Strategy for England, Department for Environment,
Food and Rural Affairs, June 2011

SEA, HIA

UK Post-2010 Biodiversity Framework, Joint Nature Conservation Committee and

Department for Environment, Food and Rural Affairs, 2012

SEA

White Paper: Healthy Lives, Healthy People: our strategy for Public Health in England,
Department for Health, June 2011

SEA, HIA, EqIA

UK Air Quality Strategy, Department for Environment, Food and Rural Affairs, 2011

SEA, HIA, EqIA

Noise Policy Statement for England, Department for Environment, Food and Rural Affairs,
March 2010

SEA, HIA, EqIA

Policy statement: Planning for schools development, Department for Communities and Local
Government, August 2011

SEA, EqIA

Written Ministerial Statement: Sustainable Drainage Systems, December 2014

SEA, HIA, EqIA

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Plan, Policy or Programme

Directly Relevant
Process

Regional / London
The London Plan: Spatial Development Strategy for Greater London, Greater London
Authority, July 2011

SEA, HIA, EqIA

Revised Early Minor Alterations to the London Plan, Greater London Authority, October 2013

SEA, HIA, EqIA

Further Alterations to the London Plan, Greater London Authority, March 2015

SEA, HIA, EqIA

Draft Minor Alterations to the London Plan 2015 Housing Standards, and Parking
Standards, Greater London Authority, May 2015

SEA, HIA, EqIA

Land for Industry and Transport Supplementary Planning Guidance, Greater London
Authority, September 2012

SEA, HIA, EqIA

Green Infrastructure and Open Environments: The All London Green Grid, Supplementary
Planning Guidance, Greater London Authority, March 2012

SEA, HIA, EqIA

London Infrastructure Plan 2050 update, March 2015

SEA, HIA, EqIA

London Plan Supplementary Planning Guidance on Housing, Greater London Authority,

November 2012

SEA, HIA, EqIA

London Plan Social Infrastructure Supplementary Planning Guidance, May 2015

SEA, HIA, EqIA

London Plan Town Centres Supplementary Planning Guidance, July 2014

SEA, HIA, EqIA

London Plan Supplementary Planning Guidance, Sustainable Design and Construction,

Greater London Authority, April 2014

SEA, HIA, EqIA

London Plan The Control of Dust and Emissions during Construction and Demolition SPG,
July 2014

SEA, HIA, EqIA

Londons Waste Resource: The Mayors Municipal Waste Management Strategy, November
2011

SEA, HIA, EqIA

London Waste and Recycling Board Waste Management Planning Advice for New Flatted
Properties, December 2014

SEA, HIA, EqIA

Shaping Neighbourhoods: Play and Informal Recreation Supplementary Planning Guidance,

Greater London Authority, 2012

SEA, HIA, EqIA

Green Infrastructure and Open Environments: Londons Foundations: Protecting the

geodiversity of the capital: Supplementary Planning Guidance, Greater London Authority and
London Geodiversity Partnership, March 2012

SEA

Securing Londons Water Future, Greater London Authority, October 2011

SEA, HIA

The Mayors Food Strategy: Healthy and Sustainable Food for London, London Development
Agency, May 2006

SEA, HIA, EqIA

Delivering Londons Energy Future: The Mayors Climate Change Mitigation and Energy
Strategy, Greater London Authority, October 2011

SEA, HIA

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Plan, Policy or Programme

Directly Relevant
Process

Managing Risks and Increasing Resilience: The Mayors Climate Change Adaption Strategy,
Greater London Authority, October 2011

SEA, HIA

Cultural Metropolis: The Mayors Culture Strategy, Greater London Authority, November 2010
and Achievements and Next Steps, Greater London Authority, Greater London Authority,
2014

SEA, HIA, EqIA

The London Health Inequalities Strategy, Greater London Authority, April 2010

SEA, HIA, EqIA

Planning for Equality and Diversity in London: Supplementary Planning Guidance to the
London Plan, Greater London Authority, October 2007

EqIA

River Basin Management Plan. Thames River Basin District, Environment Agency, December
2009

SEA

The Mayors Economic Development Strategy for London, Greater London Authority, May
2010

SEA, EqIA

Mayors Biodiversity Strategy: Connecting with Londons Nature, Greater London Authority,
July 2002

SEA, HRA, HIA

Improving Londoners Access to Nature: London Plan Implementation Report, Greater

London Authority, February 2008

SEA, HIA

London Biodiversity Action Plan, London Biodiversity Partnership, 2001

SEA, HIA

Clearing the Air: The Mayors Air Quality Strategy, Greater London Authority, December 2010

SEA, HIA

Sounder City: The Mayors Ambient Noise Strategy, Greater London Authority, March 2004

SEA, HIA

London View Management Framework Supplementary Planning Guidance, Greater London

Authority, March 2012

SEA

Mayors Transport Strategy, Greater London Authority, May 2010

SEA, HIA, EqIA

The Mayor's Equality Framework: Equal Life Chance for All, Greater London Authority, 2009

EqIA

West London
West London Joint Waste Plan to 2031: London Boroughs of Brent, Ealing, Harrow,
Hillingdon, Hounslow and Richmond Upon Thames, July 2015

SEA, HIA

West London Sub Regional Transport Plan, Transport for London, 2014 update

EqIA, SEA, HIA

Local
Old Oak and Park Royal draft Opportunity Area Planning Framework, Greater London
Authority, February 2015

SEA, HIA, EqIA

Brent
London Borough of Brent Local Development Framework, Core Strategy, Brent Council, July
2010

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Plan, Policy or Programme

Directly Relevant
Process

Brent Parks Strategy 2010-2015, Brent Council, publication date unknown

SEA, HIA, EqIA

Food for Thought: A Food Growing and Allotments Strategy for the London Borough of Brent
and Action Plan 2014/16, Brent Council, publication date unknown

SEA, HIA, EqIA

Draft Community Safety Strategy 2014-17, Safer Brent Partnership, publication date
unknown

SEA, HIA, EqIA

Brent Equality Strategy 2015-19, Brent Council, April 2015

EqIA

Brent Health and Wellbeing Strategy 2014-17, Brent Council and NHS Brent, publication date
unknown

SEA, HIA, EqIA

Cultural Strategy for Brent 2010-15, Brent Council, publication date unknown

EqIA

A Regeneration Strategy for Brent 2010-2030, Brent Council, publication date unknown

SEA, HIA, EqIA

A Plan for Children and Families in Brent 2012-15, Brent Council, publication date unknown

EqIA

Ealing
The Development Strategy 2026: Ealing Core Strategy, Ealing Council, April 2012

SEA

Sustainable Community Strategy 2006-2016 Ealing Council, Refresh July 2011

SEA, HIA, EqIA

Ealing Quality of Life for Older People 2006-2016, Ealing Council, publication date unknown

HIA, EqIA

Arts and Cultural Strategy 2013-2018, Ealing Council, publication date unknown

SEA, EqIA

Ealing Green Space Strategy 2012-2017, Ealing Council, November 2012

EqIA, HIA, SEA

Park Royal Southern Gateway Position Statement, Final Draft, London Borough of Ealing,
April 2008

SEA

Hammersmith and Fulham

Hammersmith and Fulham Core Strategy, Hammersmith and Fulham Council, October 2011

SEA

Hammersmith and Fulham Housing Strategy: Delivering the change we need in housing,
Hammersmith and Fulham Council, May 2015

EqIA, HIA, SEA

Hammersmith and Fulham Health and Wellbeing Strategy 2013-15, Hammersmith and
Fulham Council, publication date unknown

EqIA, HIA, SEA

Parks and Open Spaces Strategy 2008-2018, Hammersmith and Fulham Council, July 2008

EqIA, HIA, SEA

Hammersmith and Fulham CSPAN Physical Activity Strategy 2011-2016, Hammersmith and
Fulham Council, November 2011

EqIA, HIA, SEA

Updated Surface Water Management Plan 2015, Hammersmith and Fulham Council, April
2015

SEA, HIA

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Plan, Policy or Programme

Directly Relevant
Process

Contaminated Land Strategy, Hammersmith and Fulham Council, 2001

SEA

Kensington and Chelsea

Consolidated Local Plan (July 2015)

EqIA, HIA, SEA

Surface Water Management Plan (SWMP, February 2014)

EqIA, HIA, SEA

Local Flood Risk Management Strategy (LFRMS, July 2015)

SEA

Issues and Options Paper for Kensal Gasworks (June 2012)

EqIA, HIA, SEA

St Quintin and Woodlands Draft Neighbourhood Plan (May 2015)

EqIA, HIA, SEA

3.5.2 Key Results from the Review

Environmental, social and economic objectives and issues identified in the review of plans, programmes and
environmental protection objectives (PPPs) of relevance to the IIA were used to generate a series of
common themes. Appendix B presents a summary of how the identification of common themes relates to
each of the PPPs reviewed. How these themes relate to the relevant assessment processes is presented in
Table 3-2. The results of this assessment have been used to inform the development of the draft IIA
Framework. How the resulting draft Objectives relate to the identified themes is also shown in Table 3-2.
Table 3-2

Results of the review of Plans, Policies and Programmes

Common theme

Relevance to SEA, HIA, EqIA and

HRA

Relevance to draft
IIA Objective

Optimise the use of land through increasing the

density of development

SEA: Soil, Material Assets, Population

2, 3, 4, 7, 17, 18

Promote sustainable design and mitigate and

adapt to climate change

SEA: Human Health, Population, Climatic

Factors, Material Assets; HIA; EqIA

1, 2, 3, 4, 5, 6, 7, 8, 9,
10, 11, 15

Promote and protect the water environment

including issues such as quality and resource
use as well as reducing flood risk

SEA: Human Health, Population, Climatic

Factors, Water, Material Assets; HIA;
EqIA

3, 6, 7, 8, 9, 10, 15

Reduce greenhouse gas emissions, increase

energy efficiency and promote the use of
renewable energy and renewable technologies
in appropriate locations

SEA: Climatic Factors, Air, Material

Assets, Population

4, 6, 7, 8

Promote sensitive waste management

SEA: Material Assets, Climatic Factors,

Population, Human Health, Soil,
Landscape; HIA, EqIA

3, 7, 8, 9, 10, 11, 15

Protect and enhance the historic environment

and recognise and recognise and appreciate
landmarks, townscapes and their setting

SEA: Material Assets, Cultural Heritage,

Population, Landscape

1, 2, 3, 5, 6, 7, 8, 12,
13, 18

Environmental

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Common theme

Relevance to SEA, HIA, EqIA and

HRA

Relevance to draft
IIA Objective

Conserve and enhance biodiversity as an

integral part of economic, social and
environmental development

HRA; SEA: Biodiversity, Flora, Fauna,

Population, Material Assets, Climatic
Factors, Soil, Water

1, 6, 9, 10, 11, 15, 18

Achieve more effective geo-conservation and

improve soil quality

SEA: Soil, Climatic Factors, Human

Health, Water, Landscape; HIA

2, 3, 6, 7, 8, 9, 10, 15

Improve air quality

SEA: Air, Climatic Factors, Human

Health, Population, Material Assets; HIA,
EqIA

4, 7, 8, 10, 22, 25, 17,

18

Minimise the adverse impacts of noise on

people living and working in, and visiting the
area

SEA: Population, Human Health, Material

Assets; HIA; EqIA

1, 4, 5, 11, 15, 18

Improve health and well-being and promote

greater levels of physical activity

SEA: Human Health, Population,

Landscape; HIA; EqIA

1, 4, 7, 11, 13, 14, 15,

16, 17

To create an equal society which recognises

peoples different needs, situations and goals,
and removes the barriers that limit what people
can do and be

SEA: Human Health, Population; HIA;

EqIA

13, 14, 15, 16, 17

Maximise the contribution that the arts, culture

and heritage can make to the community

SEA: Population, Material Assets, Cultural

Heritage; HIA; EqIA

1, 12, 13

The need to ensure that new housing

development meets local and regional needs
(for all sections of society)

SEA: Population, Human Health, Material

Assets; HIA; EqIA

1, 5, 13, 14, 15

Promote more sustainable transport choices

and to improve accessibility

SEA: Population, Human Health, Material

Assets, Air, Noise, Climatic Factors; HIA;
EqIA

1, 2, 4, 7, 11, 15, 17

Recognise the importance of open spaces,

sport and recreation and the contribution that
they make to enhancing quality of life

SEA: Population, Human Health,

Landscape, Material Assets; HIA; EqIA

1, 6, 12, 13, 14, 15

Improve educational attainment and training

opportunities

SEA: Population, Human Health; HIA;

EqIA

13, 14, 15, 16, 17, 18

Reduce crime and fear of crime

SEA: Population, Human Health; HIA;

EqIA

1, 4, 13, 14, 15, 16, 17,

18

SEA: Population, Human Health, Material

Assets; HIA; EqIA

16, 17, 18

Social

Economic
Promote sustainable economic development
and a range of employment opportunities

3.6

The Sustainability Baseline and Key Sustainability Issues

3.6.1 Introduction

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Box 2 defines the SEA Directive requirements for this element of the process.
Box 2: SEA Directive Requirements for Baseline Data Collation
the environmental characteristics of areas likely to be significantly affected (Annex 1 (c))
any existing environmental problems which are relevant to the plan or programme, including, in
particular, those relating to any areas of particular environmental importance, such as areas designated
pursuant to Directives 79/409/EEC and 92/43/EC(Annex 1 (d)).

3.6.2 Methodology
Characterising the environmental and sustainability baseline, issues and context is an essential part of
developing the IIA Framework. It comprises the following key elements:
x Characterising the current state of the environment within the Old Oak & Park Royal Development
Corporation area including social and economic aspects; and
x Using this information to identify existing problems and opportunities that could be considered in the Local
Plan.
The environmental, social and economic baseline was characterised through the following methods:
x Review of relevant local, regional and national plans, strategies and programmes;
x Data research based around a series of baseline indicators developed from the SEA Directive topics
(biodiversity, population, human health, flora, fauna, soil, water, air, climatic factors, material assets,
cultural heritage including architectural and archaeological heritage and landscape), ODPM guidance and
NPPG, and the data available for London. This encompassed data relating to HRA. Data was also
collated for additional socio-economic topic areas relating to HIA and EqIA including deprivation, housing
and employment to ensure that a broad range of environmental, social and economic issues were
considered; and
x The results of the scoping workshop with stakeholders in July 2015.
The collation of baseline data also enabled the identification of key sustainability issues and opportunities
affecting the area.
Appendix C summarises the key baseline trends across the area. Each section is subdivided to present the
following:
x The baseline indicators that have been used (some are also contextual indicators and may not actually
form part of the IIA Framework).
x Descriptive text, graphs and statistics about the County.
x Key data gaps.
Appendix C also provides a summary of how the identified key sustainability issues and opportunities might
be addressed in the Local Plan. Sustainability issues and opportunities identified from the baseline review
are summarised in Table 3-3.
The SEA Directive requires material assets to be considered within SA. Material assets refer to the stock of
valuable assets within a study area and can include many things from valuable landscapes, natural and
cultural heritage through to housing stock, schools, hospitals and quality agricultural land. It is considered
that the material assets of the area are appropriately covered in the following baseline sections, and
consequently will not be repeated as a separate section:
x Biodiversity, Flora and Fauna;
x Soils and Geology;

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x Cultural Heritage;
x Landscape;
x Housing; and
x Transportation.

3.6.3 Key Sustainability Issues and Opportunities

Table 3-3 presents a summary of the key sustainability issues and opportunities for OPDC.

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Table 3-3

Key Sustainability Issues and Opportunities

Topic

Key Issue

Implications/Opportunities for the Local Plan

Relevance
to SEA,
HIA, EqIA
and HRA

Population

1, 2, 4, 5, 13,
SEA:
14, 15, 16
Population,
Human Health

The current population of OPDC is considered to be

low, consisting of 4,491 persons in 1,898 households.
The dominant age group is 25 64 years old.
Compared to the national average (16.3%), the area
has a significantly lower ageing population percentage
(aged 65+) of 6.1%. OPDC have been charged with
delivering at least 24,000 new homes within the study
area, which will see the population rise significantly
compared to its current level.
After White British (21.6%), there are significant
populations of Other White (18.6%) and Black
(African/Caribbean and Other total 24%)).

Page 259

There is an Irish Traveller community living within the

study area.

A large transitory construction workforce could also

have negative effects on the community.

Education and x
Qualifications

The influx of future population needs careful management to

reduce inequalities throughout the area and adjoining
boroughs. The Local Plan could seek to model the unknown
future population, drawing on lessons learnt from other major
development projects such as Kings Cross.

Careful consideration should be given to the wider population

trend of an ageing population as well ensuring an attractive
area for young adults and those who may be looking to raise
a family. This provides opportunities for Lifetime
Neighbourhoods and intergenerational mixed housing.

The provision of accessible services should meet existing

and new local population growth needs.

The provision of social infrastructure needs for healthcare

and key services due to a large future population needs to be
prioritised, exploration of developing sites before threshold
population numbers should be explored.

The Local Plan should consider the potential for the

withdrawal of Permitted Development Rights for the
conversion of offices to residential use, to prevent the
reduction in community cohesion and access to facilities.

The percentage of people with no qualifications in 2011 x

was 16%. The percentage of people with NVQ Level 4
qualification or above was 36.5% compared with 44.7%
for Inner London and 27.4% for England.

There is a gap in education facilities within the area.

o
x

HIA
EqIA

Positive trends in the following should be expected:

o

SEA:
Population,
Reducing the number of residents without a qualification;
Human
Health,
Ensuring new population numbers have adequate
Material
educational facilities;
Assets
Ensuring that schools and other education facilities
HIA
outside the OPDC area arent adversely affected.

Opportunities to incorporate work based learning/training

should be incorporated into the Local Plan where possible.
These opportunities could also be linked to the colleges and
universities within the surrounding area.

Relevant
Draft IIA
Objective

13, 14, 15, 16

EqIA

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Topic

Key Issue

Health

15.1% of the areas population stated they have limiting x

long-term illness or disability, higher than the London
average.

Life expectancy for men is 2 years lower than the

national average.

During the period 2010/11 and 2012/13, 11.8% of

children at reception year were considered obese, with
an additional 23.6% carrying excess weight. A further
23.6% of children in year 6 were identified as obese,
with the same figure for London recorded at 22.5%.

Page 260
Crime

There are pockets of health deprivation within the study

area along with a very poor living environment.

Due to its industrial nature and history, there is a lack

of primary care facilities within the OPDC boundaries,
with the exception of Central Middlesex Hospital.

There is currently poor accessibility to district and Local

Park sized open space/green infrastructure/play space.

The area is one of the more deprived areas of the

country in relation to crime levels. Car theft is average
or above average in the centre of the OPDC. Violence
against persons is also high or above average in the

Implications/Opportunities for the Local Plan

Relevance
to SEA,
HIA, EqIA
and HRA

The rise of people who are in good health across the area
SEA:
and the continued reduction of those in poor health should be Population,
supported.
Human
Health,
The scale of development means that new care facilities
Material
need to be delivered, not as standalone but as part of a
Assets
combined approach to social infrastructure provision.
HIA
All new high streets need to obtain 10 out of 10 in the Healthy
EqIA
High Streets measure.

Relevant
Draft IIA
Objective

1, 4, 7, 11, 13,
14, 15, 16

Construction phase impacts should be considered within the

Local Plan, around timing of construction and the impact it
has on local communities- including both psychological and
physical effects.

Incoming population there is an opportunity for the health of

the local community to be built in to the Local Plan principles
from the very beginning. This may include building in street
networks, designed to support exercise and so that children
can play independently; designing areas of multi-generational
play; building in creativity, art, intrigue, surprise to create a
sense of place and a high quality environment; and designing
housing and workspace that supports health and well-being.

The Local Plan should seek to ensure that accessibility to

open spaces, including green spaces, as this can have
benefits for both physical and mental health.

Design measures should be included within the Local Plan,

that encourage a reduction in the need to travel by private car
this could include the provision of a mix of land uses; and
the design of well-connected street networks at the human
scale.

13, 14
Given the proposed retention of Strategic Industrial Location SEA:
(SIL) in Park Royal, the Local Plan should seek to ensure that Population,
the design of new development improves the safety and
Human Health
perceived safety of the community and their property.
HIA

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Topic

Water

Key Issue

Implications/Opportunities for the Local Plan

Relevance
to SEA,
HIA, EqIA
and HRA

majority of the OPDC area.

Secured by Design principles should be reflected in new

development within the OPDC area alongside considering
wider place-making aspirations.

EqIA

Both the River Brent and Grand Union Canal are

characterised by poor chemical and biological water
quality.

The western boundary of the OPDC area is at risk of

fluvial flooding from the River Brent.

The risk of flooding and the mobilisation of contaminants

should be prevented through measures such as a site-wide
drainage strategy and increased awareness. Such measures
could also reduce the risk of flooding.

There is an increased threat from surface water

flooding due to increased precipitation rates generated
by climate change.

The Local Plan should seek to ensure that there is sufficient

infrastructural capacity for new development, ahead of
occupation.

SEA: Water,
Population,
Human
Health, Soil,
Climatic
Factors,
Landscape

The Local Plan should seek to encourage increased

efficiency in the use of water through design measures.

Page 261

Soils and
Geology

Air Quality

There are risks associated with flooding and the

mobilisation of contaminants linked to contaminated
land within the area.

Counters Creek Combined Sewer is nearly at capacity.

In the past 20 years, Thames Water has seen a 15%

increase in water usage throughout London. This is
equivalent to an increase of 10 litres per person per
decade.

There are no areas of Regionally Important

Geodiversity Sites (RIGS) within the area.

The areas heavy manufacturing history has left a

legacy of land contamination which may give rise to
number of development issues.

The principal threat to clean air in London comes from

road traffic. There are areas of high NO2
concentrations in the along the strategic highway
network. Poor air quality can damage peoples health
and quality of life. It can pose particular problems for
vulnerable groups such as the elderly, young children
and people suffering from respiratory diseases.

The Local Plan should seek to coordinate the implementation

of flood mitigation measures with other public realm
requirements including utilities and smart infrastructure.

The Local Plan should seek to protect the areas soils from
contamination and continue to remediate areas that were
impacted in the past.

The Local Plan should seek to support the decontamination

of soil within the local area.

Relevant
Draft IIA
Objective

3, 6, 7, 9, 10,
15

HIA
EqIA

SEA: Soil,
2, 3, 9, 10, 15
Biodiversity,
Human
Health, Water
HIA

SEA: Air,
4, 7, 11, 15
Climatic
Factors,
Material
The Local Plan should seek to ensure that any benefits
Assets,
generated to local air quality from a change in economic land
Human Health
use are not counteracted by the increase in population and
The Local Plan should ensure that impacts on air quality
resulting from demolition and construction are minimised,
specifically with regard to local communities.

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Topic

Key Issue

Air Quality Management Areas (AQMAs) are

designated when local authorities have identified
locations where national air quality objectives are
unlikely to be achieved. The whole of the OPDC area is
considered to be within an AQMA for levels of nitrogen
dioxide (NO2)6 and particulate matter smaller than 10
micrometres (PM10)7. Each of the three boroughs
have identified the same exceedances and types of
pollutants. New types of development in the area may
lead to an improvement in local air quality.

Implications/Opportunities for the Local Plan

development overall.

Relevance
to SEA,
HIA, EqIA
and HRA

Relevant
Draft IIA
Objective

HIA

Page 262
6

Nitrogen dioxide (NO2) is one of a group of gases called nitrogen oxides. Road transport is estimated to be responsible for about 50% of total emissions of nitrogen
oxides, which means that nitrogen dioxide levels are highest close to busy roads and in large urban areas. Gas boilers in buildings are also a source of nitrogen oxides.
There is good evidence that nitrogen is harmful to health. The most common outcomes are respiratory symptoms such as shortness of breath and cough. Nitrogen
dioxide inflames the lining of the lung and reduces immunity to lung infections such as bronchitis. Studies also suggest that the health effects are more pronounced in
people with asthma compared to healthy individuals. http://www.londonair.org.uk/LondonAir/guide/WhatIsNO2.aspx
7

Particles or particulate matter (PM) are tiny bits of solids or liquids suspended in the air. Particles originating from road traffic include carbon emissions from engines,
small bits of metal and rubber from engine wear and braking as well as dust from road surfaces. Others include material from building and industry as well as wind-blown
dust, sea salt, pollens and soil particles. Particles smaller than about 10 micrometres, referred to as PM10, can settle in the airway and deep in the lungs and cause
health problems. The health effects of particle air pollution have been widely studied, and include premature death and the worsening of heart and lung disease, often
increasing admissions to hospital. http://www.londonair.org.uk/LondonAir/guide/WhatIsPM.aspx

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Topic

Key Issue

Implications/Opportunities for the Local Plan

Relevance
to SEA,
HIA, EqIA
and HRA

Climate
Change

Greenhouse gas emissions should be reduced at the rate,

and exceeding where possible, required to meet local and
national targets, helping to mitigate the impacts of climate
change.

The reduction of energy use in the area should be

encouraged both by existing developments and future ones.
This might include the development of a site-wide
decentralised energy generation and storage network and to
create a closed loop system.

4, 6, 7, 11, 15
SEA: Air,
Climatic
Factors,
Material
Assets,
Human Health

Page 263

Biodiversity,
Flora and
Fauna

Energy consumption within the area was similar to the

London average in 2009-11.

There are no designated sites within the OPDC

boundary and no nationally/internationally designated
sites (Sites of Special Scientific Interest
(SSSI)/SPA/SAC/Ramsar) within 2km.

Richmond Park SAC is 6.9km to the south of the

OPDC area and Wimbledon Common SAC is 8km to
the south.

Wormwood Scrubs is a Local Nature Reserve and

possesses a variety of wildlife. It is popular with
birdwatchers and supports woodland, grassland and is
home to common lizards and at least 20 species of
butterfly.
The Grand Union Canal and adjacent area in Old Oak
South is a nature conservation area of Metropolitan
Importance.

HIA

A high proportion of energy generated should be from low,

zero or negative carbon energy sources.

SEA:
Biodiversity,
Flora, Fauna,
Population,
Opportunities should be sought to ensure that protected
Soil, Water,
species have favourable conservation status and are thriving.
Air, Climatic
Factors,
Opportunities should be sought to promote habitat
connectivity both within the area and outside of it. The layout Landscape
of connected habitats and a wider green infrastructure
HIA
scheme of walking and cycling routes could form the basis for
the spatial planning of the OPDC area.

x
x

The Local Plan should seek to ensure that impacts to

designations, species and habitats is minimised as well as
seeking to encourage increased biodiversity within the area.

Relevant
Draft IIA
Objective

1, 9, 10, 11,
12, 15, 18

Wormwood Scrubs Local Nature Reserves and the Grand

Union Canals habitat and species should be protected and
enhanced.

Nature sites and areas of countryside can be designated, which means they have special status as protected areas because of their natural and cultural importance.
There are restrictions on activities and developments that might affect a designated or protected area, e.g. building new houses or roads. This includes areas next to as
well as in those areas. (https://www.gov.uk/check-your-business-protected-area)

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Topic

Cultural
Heritage
assets

Key Issue

Page 264

Implications/Opportunities for the Local Plan

Relevance
to SEA,
HIA, EqIA
and HRA

Relevant
Draft IIA
Objective

The Local Plan should ensure that both designated and

undesignated or undiscovered heritage assets and their
settings, and archaeological remains are protected and,
where appropriate, enhanced.

1, 5, 12, 13,
18

Cultural heritage assets throughout the OPDC area could

provide an opportunity for tourism and leisure. Opportunities
should be sought to safeguard and promote awareness of the
important heritage assets and their settings within the OPDC
area particularly in relation to the areas role in industry and
during the interwar period.

SEA:
Population,
Material
Assets,
Cultural
Heritage,
Landscape

There is potential for impacts to protected species as a

result of an increasing population and the resulting
development required to meet population needs.

There are a number of undeclared heritage assets in

the area.

There is the potential for undiscovered archaeological

remains to exist throughout the area.

There is one listed asset within the OPDC area Brent

Viaduct.

Within the boundary there are two Conservation Areas,

these include: Old Oak Lane; and along the Grand
Union Canal.

x
Adjacent to the study area are the St. Marys
Conservation Area in Hammersmith and Fulham, which
includes the St Marys Cemetery and parts of the
Kensal Green Cemetery. The Kensal Green Cemetery
Conservation Area in The Royal Borough of
Kensington and Chelsea incudes the majority of the
x
listed buildings and monuments and the majority of the
Registered Park and Garden (Grade I registered Park
and Garden of special historic interest which contains
the Grade I listed Anglican Chapel, twelve Grade II*
listed buildings or monuments and 147 Grade II listed
x
buildings or monuments).

Within the surrounding area, the following conservation

areas may also be affected by development within the x
OPDC area:
o

Harlseden;

Old Oak and Wormholt;

Hangerhill Garden Estate; and

Hagerhill (Hay Mills) Estate.

Cultural heritage assets could also provide an opportunity to

enhance the area environmentally, socially, as well as
economically. This should be considered throughout the
development of the Local Plan, with assets being enhanced
and conserved for future use.
Statutory sites outside the OPDC boundary also need to be
protected and safeguarded, particularly in terms of their
setting. Cross-boundary issues with respect to heritage
assets and views need to be addressed.
OPDC could explore the potential for the production of a
Local List of locally significant heritage assets, to be
considered as part of the planning process.
With the Mayors support Historic England has recently
consulted upon and is now finalising guidance for the
comprehensive review programme for Londons
Archaeological Priority Areas. A desk-based appraisal should
be undertaken by OPDC to identify areas of known or
potential archaeological interest meriting identification as new
priority areas.

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Key Issue

Implications/Opportunities for the Local Plan

Relevance
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HIA, EqIA
and HRA

Relevant
Draft IIA
Objective

Other notable listed buildings whose setting could be

affected by development in the Opportunity Area include the
Grade II* listed gatehouse and chapel at Wormwood Scrubs
Prison, the Church of All Souls Harlesden (also Grade II*),
and thirteen Grade II listed buildings within 250m of the
boundary. Further afield are Statutory Listed buildings, the
closest being Kenmont Primary School and Park Royal
Underground Station.

Page 265

The Old Oak Common and Park Royal areas have a

disparate assortment of railway and industrial heritage
that play a valuable role in informing the evolving
character of the area. Specific collections of nondesignated heritage assets are located along the east
of Scrubs Lane, the interwar Rolls Royce works and
Acava Studios on Hythe Road.

A significant number of the heritage assets listed above

are on English Heritages Heritage at Risk Register.
These include Kensal Green Cemetery, as well as 35
monuments within it, including the Anglican Chapel.
Twyford Abbey to the west of the opportunity area is
also a long standing Heritage at Risk case.

Whilst there are at present no archaeological priority

areas within the proposed local plan area, the Greater
London Historic Environment Record holds information
on several archaeological investigations, sites and
finds. Notably the site of Acton Wells 18th century spa
is located within the Opportunity Area. The open
ground of Wormwood Scrubs was the site of a rifle
range and anti-aircraft battery and may preserve as yet
undiscovered earlier remains. The Grand Junction
Canal and Old Oak Common area include aspects of
railway and industrial archaeological interest. The 19th
century Park Royal cemetery would also be of interest
if subject to redevelopment.

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Key Issue

Implications/Opportunities for the Local Plan

Relevance
to SEA,
HIA, EqIA
and HRA

Relevant
Draft IIA
Objective

Landscape
and
Townscape

The OPDC area comprises a largely industrial

townscape with its edges influenced by more
residential areas and strategic roads. Railway
infrastructure is a dominant feature across the site.

Opportunities could be sought to maintain the important

heritage of Old Oak in particular and OPDC more widely.

Access to and awareness of the unique aspects of the area

should be improved.

1, 2, 5, 6, 8,
10, 11, 12, 13,
14, 15, 18

Along the south-eastern boundary lies Wormwood

Scrubs Park which is grassland and some woodland.
The eastern boundary is Kensal Green Cemetery.

The development of the area should enhance adjoining

landscapes situated on the OPDC boundary and vice versa.

SEA:
Landscape,
Material
Assets,
Cultural
Heritage

x
While there are substantial areas of green space on the
periphery of the plan area, the industrial nature of the
area means that most parts have a severe open space x
deficiency.

Integration with the All London Green Grid Area SPG

Frameworks is an important consideration.

Recycling rates are higher for Ealing compared to

x
Brent, Hammersmith & Fulham and London as a whole
though they have increased between 2010 and 2012.
x
There is currently no data available on the municipal
waste sent to landfill in the area.

Opportunities should be sought to continue the reduction in

waste being sent to landfill.

There are several waste sites within the area:

European Metal Recycling; Powerday; Capital Waste
Ltd; UK Tyre Exporters; ODonovans Waste Disposal
Ltd.

Page 266

Waste

Transportation x

Old Oak and Park Royal are poorly connected to the

It is essential that townscape character and quality is

maintained/enhanced through high quality design, careful
siting, and incorporation of soft landscaping.
SEA:
2, 3, 6, 7, 8, 9,
Population,
10, 11, 15, 18
Human
Health
London Waste and Recycling Board there is an opportunity
Material
for the OPDC area to become an exemplar centre for the
creation of an integrated circular economy. This could
Assets, Soil,
include the creation, use and recycling of products locally,
Air,
including the potential for the growing of local food through
Landscape,
the use of vertical farms.
Climatic
The Local Plan should seek to increase rates of recycling,
Factors
reuse and composting of waste, which would otherwise be
HIA
sent to landfill.

The Local Plan should explore the delivery of innovative

waste transport and management techniques supported by
smart city technology.

Due to potential land use changes, theres a need to consider

waste apportionment with the neighbouring boroughs and
where waste will be processed if these uses are displaced by
new development.

Opportunities should be sought to maximise modal shift

towards sustainable transport modes, in particular, walking

EqIA

SEA:
Population,

1, 4, 6, 7, 11,
13, 14, 15, 17,
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Implications/Opportunities for the Local Plan

and cycling.

wider road network.

x

Both Old Oak and Park Royal generate significant

numbers of road freight movements.

Opportunities should be sought that maximises rail transport

of both goods and people.

Access to and from Old Oak station is currently poor.

There are a number of hard edges along the boundary

of the OPDC area, which creates poor legibility for
x
walkers and cyclists.

The Local Plan should seek to ensure that improvements in

the area do not lead to increase pollution/traffic etc.,
elsewhere across London.

Roads in Park Royal are congested.

Opportunities should be sought that maximises opportunity

for green networks and improves connectivity for people
across the area.

Page 267

Green Infrastructure there is an opportunity to create green

infrastructure which facilitates live/work/play/travel through as
well as fast and meandering routes. However, the Local Plan
should manage the spread of routes across the OPDC area,
so that certain routes do not become congested.

The Grand Union Canal presents a great opportunity for both

water travel and freight movements as well as footpaths and
should be considered a strategic transport link within the
area. However, capacity issues should be taken into
consideration.

There is an opportunity to significantly improve accessibility

to and throughout the site, including the creation of legible
routes and reducing hard edges. The Local Plan should
consider alternatives to the use of on-street parking and
servicing at the fronts of buildings, as these can have a
negative effect on the street atmosphere.

Opportunities should be sought to reduce motorised transport

and increase the use of greener, smarter, more sustainable
modes of transport.

Opportunities should be sought to develop road infrastructure

that supports economic growth. During construction in
particular, the Local Plan should consider the limitations of
the road network and the potential impact from construction
on existing businesses that are reliant on the existing road

Relevance
to SEA,
HIA, EqIA
and HRA

Relevant
Draft IIA
Objective

Human
Health, Air,
Climatic
Factors,
Material
Assets

18

HIA
EqIA

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Implications/Opportunities for the Local Plan

Relevance
to SEA,
HIA, EqIA
and HRA

Relevant
Draft IIA
Objective

SEA: Human
Health,
Population

1, 2, 4, 11, 12,
15, 18

network and local communities.

Noise

Road and rail noise are significant contributors to the

ambient noise environment, particularly around the
town centre and main distributor roads.

The Local Plan should seek to minimise the effects from

noise pollution on the existing and incoming population, and
ensure that these effects do not disproportionately affect any
particular socio-economic or equalities group.

HIA
EqIA

Local
Economy

Page 268

The area is characterised by some 2,000 businesses x

the majority (75%) of these are micro in scale. The
OPDC area suffers from employment deprivation.
Theres a strong element of warehousing and other
light to heavy industrial uses. A large proportion of
residents within the area work locally. The
displacement of existing businesses in the area could
lead to a negative effect on the existing community.
x
Affordable workspace much of the available
workspace is affordable at present, due to its poor
quality. There is also an issue relating to density in this
area warehousing uses are low employment
x
generators.

18.6% of the population have been claiming job

seekers allowance for more than a year.

There are inequalities between men and women.

Infrastructure/Utilities a key issue for the area is how

infrastructure/utilities will be improved to accommodate
the new development. In particular, broadband capacity
is very poor at present within Park Royal. Also
x
transport links need significant improvement.

Town centres there is a potential issue that the

development of offices and retail facilities within the
OPDC area would destroy neighbouring town centres,
including Ealing town centre.

Employment and training - There is an opportunity for the

Local Plan to specify that a proportion of incoming
employment opportunities are to be directed towards local
people in the existing and surrounding communities. This
combines with an opportunity to upskill the local workforce,
the majority of whom may currently be in lower-skilled jobs in
the local area.

SEA:
Population,
Human
Health,
Material
Assets

1, 2, 3, 15, 16,
17, 18

HIA
The Local Plan should seek to provide employment and
business opportunities that meet the current and future needs EqIA
of the local and regional economy, within the context of the
neighbouring communities.
The Local Plan should seek to ensure that the appropriate
infrastructure capacity is developed and planned
comprehensively, ahead of the occupation of new
development.
A fine balance between place-making, providing enough
facilities, and not destroying external town centres, needs to
be sought. Improved connectivity from the OPDC area to the
town centres could be beneficial in this respect. Harlesden
town centre would be walkable from the OPDC area.
Healthy New Towns NHS England are seeking to promote
this initiative in the OPDC area. This is based on health-led
employment in the centre, for clean, green and healthy
technology businesses. This may include research
companies etc.
North Acton is seeking to attract a university campus in the

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Implications/Opportunities for the Local Plan

Relevance
to SEA,
HIA, EqIA
and HRA

Relevant
Draft IIA
Objective

OPDC area, which would buffer the industrial area further

north, with an area of student housing further south.
Anecdotal evidence suggests that the campus may be
associated with Imperial College.

Page 269

Deprivation
and Living
Environment

Housing

Town centres there is a potential issue that the

development of offices and retail facilities within the OPDC
area would negatively impact on neighbouring town centres,
including Ealing town centre, if not appropriately managed.

The land uses in the OPDC area are likely to experience a

wholesale change from the existing situation. This could
provide an opportunity to reduce disparities across the area.

x
The area lies within other deprived areas of Brent,
Ealing and Hammersmith & Fulham and falls within the
most deprived areas for living environments.

38.3% of the population in the OPDC area rent

accommodation from private landlords, which is a rate
that is significantly higher than adjoining boroughs.

29.5% of households are owner-occupiers, compared

to 42.9% in Brent, 34% in Hammersmith & Fulham and x
51.1% in Ealing.

There is a shortage in the amount of affordable housing

provided and there is a continuing need for affordable
housing in the area and in London overall.

There is a Traveller site next to Old Oak on Backley

Road, which is linear against the railway line and a
metal refinery.

9% of households in the plan area are lone parent

families and over 90% of these parents are women.
Lone parents experience some of the greatest levels of

Deprivation is a very complex issue and a number of different

issues will need to be addressed for noticeable improvements
to be realised. Enhancements in the OPDC area that deliver
employment opportunities, high quality new housing,
improved public realm, and access to nature, would all
provide benefits towards reducing deprivation.

1, 4, 5, 6, 8, 9,
SEA:
11, 12, 13, 14,
Population,
Human Health 15, 16, 17
HIA
EqIA

1, 5, 11, 13,
Opportunities should be sought to provide housing that meets SEA:
London-wide and local needs including the provision of
14, 15
Population,
affordable, low cost market, student and special needs
Human Health
housing.
HIA
The Local Plan should seek to lift more LSOAs out of the
EqIA
bottom 10% for housing deprivation.

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Topic

Key Issue

Implications/Opportunities for the Local Plan

Relevance
to SEA,
HIA, EqIA
and HRA

Relevant
Draft IIA
Objective

economic and housing need, their household incomes

are only about a third of the average income. They are
more than three times more likely to be dependent on
benefits than the average household, and twice as
likely to be in unsuitable housing.

Nitrogen dioxide (NO2) is one of a group of gases called nitrogen oxides. Road transport is estimated to be responsible for about 50% of total emissions of nitrogen
oxides, which means that nitrogen dioxide levels are highest close to busy roads and in large urban areas. Gas boilers in buildings are also a source of nitrogen oxides.
There is good evidence that nitrogen is harmful to health. The most common outcomes are respiratory symptoms such as shortness of breath and cough. Nitrogen
dioxide inflames the lining of the lung and reduces immunity to lung infections such as bronchitis. Studies also suggest that the health effects are more pronounced in
people with asthma compared to healthy individuals. http://www.londonair.org.uk/LondonAir/guide/WhatIsNO2.aspx

Page 270

Particles or particulate matter (PM) are tiny bits of solids or liquids suspended in the air. Particles originating from road traffic include carbon emissions from engines,
small bits of metal and rubber from engine wear and braking as well as dust from road surfaces. Others include material from building and industry as well as wind-blown
dust, sea salt, pollens and soil particles. Particles smaller than about 10 micrometres, referred to as PM10, can settle in the airway and deep in the lungs and cause
health problems. The health effects of particle air pollution have been widely studied, and include premature death and the worsening of heart and lung disease, often
increasing admissions to hospital. http://www.londonair.org.uk/LondonAir/guide/WhatIsPM.aspx
Nature sites and areas of countryside can be designated, which means they have special status as protected areas because of their natural and cultural importance.
There are restrictions on activities and developments that might affect a designated or protected area, e.g. building new houses or roads. This includes areas next to as
well as in those areas. (https://www.gov.uk/check-your-business-protected-area).

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3.6.4 Cross-boundary considerations

The OPDC area sits within the context of three London boroughs (Ealing, Brent and Hammersmith &
Fulham) with the Royal Borough of Kensington and Chelsea to the east. As such, it has a role to ensure that
the scale of development proposed for the area is with an understanding of the pressures faced by those
boroughs and by London as a whole. The area is bounded by major roads such as the A40, connectivity
from south to north is poor specifically with regard to walking and cycling connections into Park Royal,
south to White City and east to Kensal Canal side. Care should therefore be taken when considering future
development to ensure that the impacts felt by adjoining boroughs isnt too disruptive either during
construction or post-construction phases (e.g. construction traffic when coupled with existing business
traffic). However, equally this creates an opportunity to encourage inward investment which the boroughs
could benefit from.
The area and the remit of the OPDC presents a unique opportunity to incorporate the site areas heritage
within its future development plans. Further, on its boundary, lies the St Marys, Kensal Green Cemetery
(Grade I registered park and garden of special historic interest), which contains a Grade I listed chapel,
twelve Grade II* listed buildings/monuments and 147 Grade II listed buildings/monuments. Views from this
into area and vice versa need to be adequately considered and protected throughout the development of the
OPDC area.
The quantum and change of development types needs to be carefully managed to ensure that existing
businesses are still able to remain open both within the area and outside of it. As the area develops, it will be
important to consider how nearby town centres, such as Harlesden and Ealing, will be affected by the scale
of change proposed.
The OPDC area suffers from high levels of living environment deprivation. There is poor connectivity within
the site as well as out into the wider surroundings. The redevelopment of the area should seek to improve
open space provision all around the area in addition to improving connections to Wormwood Scrubs as well
as enable green infrastructure and services that could be used by residents and non-residents of the area
alike.
There needs to be careful consideration of the future in-migration into the OPDC area. Its important that the
current population (in neighbouring boroughs and within area) doesnt feel pushed out or has cause to be
envious of the facilities and services provided when compared to their own. There should be a concerted
effort to reduce inequality.

3.7

The IIA Framework

3.7.1 Background to the IIA Framework

The IIA Framework underpins the assessment methodology and comprises a series of Sustainability
Objectives (covering social, economic and environmental issues) that are used to test the performance of the
plan being assessed. Whilst the SEA Directive does not require the use of objectives, they are a recognised
tool for undertaking the assessment and are aspirations/goals that an authority/organisation should work
towards achieving.
The IIA Objectives are separate from the objectives of the Local Plan, although there may be some overlaps
between them. To help measure the performance of the Local Plans components against the IIA Objectives,
it is beneficial if they are supported by a series of indicators. Baseline data should be collated to support
each of the indicators, as this provides a means of determining current performance across the OPDC area
and gauging how much intervention or the extent of work needed to achieve the targets that have been
identified. The following section provides further details about the development of the IIA Framework.

3.7.2 Development of the IIA Objectives

The IIA Framework has been developed using the IIA Framework from the Draft OAPF IIA (February 2015)
as a base. This was analysed and refined, using the following:

https://www.london.gov.uk/sites/default/files/OOPR%20OAPF%20draft%20IIA%20Report.pdf

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x Comparison against the updated PPPs and identified key sustainability issues and opportunities;
x Comparison against the SAs developed for the Local Plans for:
x Brent;
x Ealing;
x Hammersmith and Fulham;
x Assessment against the requirements of the NHS London Health Urban Development Unit (HUDU) Rapid
Health Impact Assessment Tool Framework (January 2013);
x Comparison with the Equality Framework included in the Mayor of Londons Equal Life Chances for All
Policy Statement (July 2009);
x Findings from the IIA Workshop; and
x Consultation Comments on the Scoping Report (September 2015) (See Appendix E)
Table 3-4 presents the IIA objectives that have been used in the assessment of the Regulation 18 Local
Plan. Each of the IIA Objectives is supported by a series of sub-objectives to add further clarity and to assist
the assessment process. However, it is noted that the objectives are not mutually exclusive and the
assessment framework should be considered in its entirety. As such, the IIA Objectives are not presented in
any particular order, with all objectives being considered as having equal weighting. The IIA Objectives
included in Table 3-4 below are:
1. To enhance the built environment and encourage place-making
2. To optimise the efficient use of land through increased development densities and building heights,
where appropriate
3. Maximise the reuse of previously developed land and existing buildings, including the remediation of
contaminated land
4. Minimise the need to travel, improve accessibility for all users by public and non-motorised transportation
methods and mitigate impacts on the transport network
5. Improve access to well designed, well-located, market, affordable and inclusive housing of a range of
types and tenures, to meet identified local needs
6. Improve climate change adaptation and mitigation, including minimising the risk of flooding and
addressing the heat island effect
7. To minimise contributions to climate change through greater energy efficiency, generation and storage;
and to reduce reliance on natural resources including fossil fuels for transport, heating and energy
8. To minimise production of waste across all sectors in the plan area, maximise efficiencies for
transporting waste and increasing rates of re-use, recycling and recovery rates as well as composting of
all green waste
9. Improve the quality of the water environment
10. Create and enhance biodiversity and the diversity of habitats across the area and its surroundings
11. To minimise air, noise and light pollution, particularly for vulnerable groups
12. To conserve and enhance the historic environment, heritage assets and their settings
13. Increase community cohesion and reduce social exclusion to encourage a sense of community and
welfare
14. Improve safety and reduce crime and the fear of crime
15. Maximise the health and wellbeing of the population, reduce inequalities in health and promote healthy
living
16. To improve the education and skills levels of all members of the population, particularly vulnerable
groups

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17. Maximise the social and economic wellbeing of the local and regional population and improve access to
employment and training
18. To encourage inward investment alongside investment within existing communities, to create sustainable
economic growth
Where possible, IIA Objectives are also supported by indicators. The indicators selected link to those used to
describe the baseline conditions across the area, as an understanding of the existing conditions is needed to
inform the assessment. Where baseline data is not currently available, indicators have been suggested as to
the type of information that may be appropriate. OPDC are currently undertaking a series of evidence-based
studies, which will support the development of the Local Plan. Once this is available, relevant data will be
added to the IIA baseline, and the indicators refined, as part of the iterative nature of the IIA process.
Throughout the course of the IIA, quantified targets will be identified where possible to supplement this
framework in liaison with OPDC.

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Table 3-4 IIA Framework

IIA Objective and sub-objectives
1

To enhance the built environment and encourage place-making

x

Optimise development opportunities to develop and enhance local

distinctiveness and character

Ensure new buildings and public spaces are appropriately designed and
constructed including enabling the creation of safe and welcoming spaces and
access for all

Relevance to SEA,
HIA, EqIA, HRA

Create new, accessible and managed open spaces- public, communal, private
and childrens play space, public realm and spaces where children can play
independently, which reflect the needs of the community.

Provision of publicly accessible open space in accordance

10
with the London Plan Categorisation :

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Regional Parks (400ha): 3.2 to 8km from homes;

Metropolitan Parks (60ha): 3.2km from homes;

SEA: Population,
Human Health,
Material Assets,
Cultural Heritage,
Landscape

District Parks (20ha): 1.2km from homes;

HIA

Local Parks and Open Spaces (2ha): 400m from

homes;

EqIA

Small Open Spaces (under 2ha): less than 400m

from homes;

Pocket Parks (under 0.4ha): less than 400m from

homes;

Linear Open Spaces (Variable): wherever feasible.

Maximise the contribution that the arts, culture and heritage can make to a
community including building creativity, art, intrigue, character and surprise into
the built environment

Increase in the legibility of public spaces and increase walking and cycling
routes within and adjacent to Old Oak and Park Royal

Encourage the use of contemporary technology in the public realm to support

design, delivery and management

Proportion of accessible open spaces created which have

a long term management and funding plan.

Integration with the All London Green Grid Area

Frameworks

Number of new buildings and public spaces designed to

be inclusive

Proportion of new development incorporating an

appropriate level of open space for recreation

Legibility and quality of the pedestrian and cycle

environment

Proportion of new development incorporating Lifetime

Neighbourhoods principles

x
x

Encourage adherence to the principles of Lifetime Neighbourhoods

Maximise delivery of active frontages in appropriate locations

Link to objectives 12 (heritage), 5 (housing); 13 (community cohesion); 14 (crime and

fear of crime); 15 (health and wellbeing)

10

Indicators (known indicators: underlined; proposed

indicators: italics)

https://www.london.gov.uk/sites/default/files/ALGG_SPG_Mar2012.pdf
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IIA Objective and sub-objectives

To optimise the efficient use of land through increased development densities

and building heights, where appropriate
x

Optimise housing density in a way that makes the most efficient use of land
whilst meeting housing needs

Optimise development density in a way that makes the most efficient use of land
whilst meeting commercial needs and responding to sensitive areas

Indicators (known indicators: underlined; proposed

indicators: italics)
x

Proportion of people who are happy with their local

environment as a place to live

Proportion of new development using technology to

improve legibility

Housing density in comparison to neighbourhood quality

Density of commercial development in comparison to

existing (2015) levels

Relevance to SEA,
HIA, EqIA, HRA

SEA: Population,
Human Health,
Biodiversity, Soil,
Water, Landscape,
Material Assets
HIA

Link to objectives 7 (natural resources use); and 8 (waste)

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Maximise the reuse of previously developed land and existing buildings,

including the remediation of contaminated land

Amount (hectares) of previously developed land available

(Office for National Statistics Local Profiles)

Increase accessibility to household and commercial sustainable waste

management facilities

Quality of soil resources

Materials balance as a result of construction activities

Improve soil quality and achieve more effective geoconservation where

appropriate

Development and implementation of a strategic land

remediation scheme

Contribute to a scheme of strategic land remediation

Amount of soil remediated on site

Distribution of major transport systems roads, rail links

Modal shift of existing travel patterns verses future travel

patterns

Connectivity of the cycling and walking network

SEA: Population,
Human Health, Air,
Climatic Factors,
Material Assets,
Landscape

Km of designated cycling and walking routes

HIA

Proportion of goods arriving and leaving the area by rail in

EqIA

SEA: Population,
Human Health,
Biodiversity, Soil,
Water, Landscape,
Material Assets
HIA

Link to objectives 4 (natural resources use); 6 (waste); and 12 (reuse of existing

buildings)
4

Minimise the need to travel, improve accessibility for all users by public and
non-motorised transportation methods and mitigate impacts on the transport
network
x

Increase the co-location of services and facilities, in accessible locations by

walking, cycling and public transport

Increase the connection of the public realm and internal routes to neighbouring
areas alongside local and strategic cycle and walking networks including via

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Old oak and park royal development corporation Regulation 18 DRAFT local plan

IIA Objective and sub-objectives

Indicators (known indicators: underlined; proposed

indicators: italics)
comparison to road

green infrastructure networks and the canal

x

Prioritise walking and cycling over other forms of transport

Increases the opportunity for the transport of goods and people by rail transport

Consider the impact of construction on local infrastructure on local businesses

and communities

Support the testing and implementation of future transport modes

Mitigate the impact of construction traffic

Maximise the accessibility of stations

Proportion of waste and freight arriving and leading the

area by canal.

Proportion of shared spaces within the urban environment

Controlled parking zones, car clubs and travel plan

measures implemented

Number of accessible public transport interchanges and

bus stops (source: Equal Life Chances for All 2009)

Number of local businesses negatively affected by

construction activities

Increase in traffic on the highway network in and around

the OPDC area

Dwelling Stock (Office for National Statistics Local

Profiles).

Household density (Office for National Statistics Local

Profiles)

Proportion of LSOAs in the bottom 10% for housing

deprivation

Proportion of dwellings meeting all of the health and

wellbeing credits in the Code for Sustainable Homes

Proportion of dwellings that meet internal space standards

Proportion of dwellings with a high SAP rating

Link to objectives 7 (climate change); 11 (pollution); and 14 (safety)

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Improve access to well designed, well-located, market, affordable and inclusive

housing of a range of types and tenures, to meet identified local and regional
needs
x
x

Provision of adaptable homes for independent living for older and disabled
people
Provision of innovative housing typologies to meet needs

Provision of homes to need the needs of older people including extra care
housing, sheltered housing, lifetime homes and wheelchair accessible homes

Provision of housing suitable for family accommodation including single-parent

families

Relevance to SEA,
HIA, EqIA, HRA

Increase in use of high quality design including meeting energy efficiency

standards

Proportion of the population considered to be homeless

(source: Equal Life Chances for All 2009)

Provision of facilities to meet identified needs of Gypsies, Travellers and

Travelling Show people

Amount of family size housing (source: Equal Life

Chances for All 2009)

Ensure all new homes meet Lifetime Homes standards

Proportion of single parent families living in unsuitable

SEA: Population,
Human Health,
Climatic Factors,
Material Assets
HIA
EqIA

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IIA Objective and sub-objectives

Link to objectives 1 and 6 (sustainable design); 13 (community cohesion and social
exclusion); 14 (secured by design); 15 (health)

Indicators (known indicators: underlined; proposed

indicators: italics)
accommodation

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Amount of affordable housing (source: Equal Life

Chances for All 2009)

Amount of Lifetime Homes (source: Equal Life Chances

for All 2009)

Proportion of market, affordable and specialist housing

delivered.

Improve climate change adaptation and mitigation, including minimising the

risk of flooding and addressing the heat island effect

River catchment areas (Environment Agency Thames

Catchment Flood Management Plan, 2009).

Minimise the proportion of new development at risk of flooding from all sources
including surface water, groundwater and reservoir flooding

Distribution of areas at risk of fluvial flooding (Environment

Agency Fluvial Flood Map)

Minimise the increase in risk of flooding elsewhere

Increase the use of sustainable design including Sustainable Urban Drainage,

natural ventilation and shading for temperature adaptation

Areas susceptible to surface water flooding (Environment

Agency Surface Water Flood Map)

Proportion of energy usage in buildings using sustainable

design compared with standard construction

Annual average domestic gas and electricity consumption

per meter (Office for National Statistics Local Profiles)

All energy consumption by sector (Office for National

Statistics Local Profiles and DECC)

Energy consumption per capita

Link to objectives 10 (habitat connectivity); 7 (energy efficiency); 12 (sustainable

adaptation and reuse of existing buildings)
7

To minimise contributions to climate change through greater energy efficiency,

generation and storage; and to reduce reliance on natural resources including
fossil fuels for transport, heating and energy
x

Enable the area to be more self-sufficient in terms of energy generation and

storage

Increase the proportion of energy generated from low, zero or negative carbon
energy sources, through consideration of measures from the outset

Proportion of properties generating energy from low or

zero carbon sources, including solar.

Increase the proportion of journeys made by non-motorised transport

Increase the use of sustainable design to minimise the resource requirements

and outputs of new development

Proportion of new developments incorporating district

heating or heat pumps

Greenhouse gas emissions per capita compared with

London and national averages

Link to objectives 4 (minimise the need to travel); 7 (sustainable design); and 12

Relevance to SEA,
HIA, EqIA, HRA

SEA: Biodiversity,
Human Health, Water,
Air, Climatic Factors,
Material Assets,
Landscape
HIA
EqIA

SEA: Population,
Human Health, Air,
Climatic Factors,
Material Assets
HIA
EqIA

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IIA Objective and sub-objectives

Indicators (known indicators: underlined; proposed

indicators: italics)

(sustainable adaptation and reuse of existing buildings)

Proportion of journeys made by non-motorised transport

Proportion of energy generated from low, zero or negative

carbon energy sources

Number of active / historic landfills on the site

(Environment Agency)

Percentage of household waste sent for reuse, recycling

or composting (ONS Local Profiles)

To minimise production of waste across all sectors in the plan area, maximise
efficiencies for transporting waste and increasing rates of re-use, recycling
and recovery rates as well as composting of all green waste

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Promote the creation of a circular economy for the management of waste

Increase the use of recycled materials for the construction of buildings and
infrastructure

Amount of residual waste per household (ONS) sent to

landfill or incineration

Address the displacement of waste management to other areas

Enable the sustainable management of contaminated soils and hazardous waste

Amount of commercial and industrial waste produced

(Defra)

Increase accessibility to household and commercial sustainable waste

management facilities

Amount of waste recycled and re-used within the area

Amount of waste transported within the area

Improve the quality of the water environment

Water and groundwater quality (Environment Agency)

Promote the improved efficiency in the use of water domestically and

commercially

Development of a site wide drainage strategy

Water consumption per capita

Promote the improved quality of local watercourses

Prevent the risk posed to the water environment from the run-off of contaminants

Increase in infrastructural capacity as a proportion of new

development

Ensure that infrastructural capacity is sufficient to accommodate new

development ahead of occupation

Increased use of existing infrastructure

Number and distribution of designated sites including

Relevance to SEA,
HIA, EqIA, HRA

SEA: Biodiversity,
Population, Human
Health, Soil, Water,
Climatic Factors,
Material Assets,
Landscape
HIA
EqIA

Maximise use of innovative waste collection and waste management techniques

including smart technology

Link to objectives 7 (resources use); 2 (efficient use of land); 3 (remediation)

9

SEA: Water, Human

Health, Soil,
Landscape
HIA

Link to objectives 1 (biodiversity); 3 (climate change adaptation); 4 (climate change

contributions); 5 (pollution); 7 (remediation); and 12 (Grand Union Canal)
10

Create and enhance biodiversity and the diversity of habitats across the area

SEA: Biodiversity,

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IIA Objective and sub-objectives

Indicators (known indicators: underlined; proposed

indicators: italics)

and its surroundings

x

Conserve or enhance existing biodiversity across the plan area, including on

brownfield sites

Increase the connectivity of habitats across the area and its surroundings

Create new areas dedicated to nature conservation

Seek to reduce the potential wide ranging impacts on international sites

Key Biodiversity Action Plan (BAP) species and habitats

present (London BAP)

Protected species with favourable conservation status

Habitat connectivity

Condition of Wormwood Scrubs Local Nature Reserve

Condition of Grand Union Canal area of nature

conservation

Increase in areas of greenspace for biodiversity including

inaccessible areas

To minimise air, noise and light pollution, particularly for communities and
vulnerable groups

Number and distribution of Air Quality Management Areas

11
(AQMAs) (Air Quality Archive )

Number of new local air quality monitoring points

Ill health attributed to air, noise or light pollution

Minimise air pollution caused by traffic and commercial uses during the
construction and operation of development on existing and future communities,
through the use of mitigation measures and the locating of future sensitive users
away from pollution generators

Proportion of the population affected by high levels of

noise during construction and post construction including
a breakdown by equality group

Ensure that new waste management facilities do not negatively impact on

sensitive uses including existing and future homes, and building occupants.

Proportion of the population affected by light pollution from

traffic or industry during construction and post
construction including a breakdown by equality group

Proportion of population living within areas with regular

Link to objectives 3 (remediation); 6 (climate change adaptation); 9 (water

environment); 11 (pollution); and 12 (Grand Union Canal)

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11

11

SAC, SPA, Ramsar sites, SSSI, National Nature Reserves

(NNR), Local Nature Reserves (LNR) and Sites of
Importance for Nature Conservation (SINCs) and Local
Wildlife Sites (MAGIC, www.magic.gov.uk and Local
Authority websites).

Minimise noise pollution caused by traffic and commercial uses during the
construction and operation of development on existing and future communities
through the use of mitigation measures and the locating of future sensitive users
away from pollution generators

Relevance to SEA,
HIA, EqIA, HRA
Flora, Fauna
HRA

SEA: Population,
Human Health, Air,
Material Assets
HIA
EqIA

http://uk-air.defra.gov.uk/aqma/maps
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IIA Objective and sub-objectives

x

Reduce emissions from construction and demolition sites

Minimise light pollution

Indicators (known indicators: underlined; proposed

indicators: italics)

Relevance to SEA,
HIA, EqIA, HRA

exceedances in NOx and particulates

Link to objectives 4 (sustainable transport); 7 (climate change); 15 (health)

12

To conserve and enhance the historic environment, heritage assets and their
settings

Number and distribution of Listed Buildings, Scheduled

Ancient Monuments (SAMs), Conservation Areas and
Registered Historic Parks and Gardens
(www.magic.gov.uk).

Decrease in the number of Heritage Assets at Risk in and

around the area

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Promote the historical interpretation of heritage assets, including the canal,

through the use of multifunctional green infrastructure

Minimise heritage assets lost to new development

Avoid adverse impacts on the setting of heritage assets, including those outside
the OPDC area

Increase in the number of heritage assets identified and

protected through the development of Local List

Maximise the reuse and adaptation of heritage assets for place-making and
minimising the embedded carbon in new development

Increase in the number of heritage assets highlighted and

enhanced or utilised for place-making and interpretation

Enhance local views and landscapes

Reduce the number of Heritage Assets at Risk in and around the area

Development of a local views strategy and proportion of

new developments adhering to its principles

Reduce impacts on heritage assets and their settings in areas adjacent to the
plan area

Increase in the number of heritage assets re-used for

development

Enhance areas of greenspace in connection with areas of importance for

heritage protection

Increase community cohesion and reduce social exclusion to encourage a

sense of community and welfare

Number of offices converted to residential under permitted

development rights

Improve the quality of the public realm and increase the provision, accessibility
and quality of public open spaces including play spaces

Schemes to reduce the impact of construction on the local

community

To increase connectivity and avoid physical barriers and severance across the
area through measures including green infrastructure, creating physical and

Connectivity of pedestrian linkages across the area

SEA: Cultural
Heritage, Material
Assets, Biodiversity,
Climatic Factors,
Landscape
HIA

Link to objectives 1 (place-making), 3 (reuse of existing buildings), 6 (energy

efficiency), 7 (energy generation and sustainable design), 8 (use of recycled
materials) and 18 (encourage inward investment).
13

SEA: Population,
Human Health,
Climatic Factors,
Landscape, Material
Assets
HIA

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IIA Objective and sub-objectives

Indicators (known indicators: underlined; proposed

indicators: italics)

EqIA

social linkages with the surrounding communities

x

Relevance to SEA,
HIA, EqIA, HRA

Manage the construction process to reduce the impact of a potentially large

transitory construction workforce on the local community, specifically in relation
to social infrastructure and housing provision

Link to objectives 1 (place-making); 4 (accessibility); 5 (housing); 14 (crime and fear

of crime); 15 (health)
14

Improve safety and reduce crime and the fear of crime

Crime rates (Indices of Deprivation)

Increase natural surveillance and other measures to design out crime

Encourage increased safety through the use of traffic management and calming
methods

Road traffic accidents and diversity profiling (source:

Equal Life Chances for All 2009)

Percentage of people who feel that there is less

discrimination in their neighbourhood than 3 years ago
(source: Equal Life Chances for All 2009)

Page 281

Link to objectives 1 (place-making); 4 (sustainable transport); 5 (housing); 13

(community cohesion); 15 (health)

15

Percentage of the local population who feel personal

safety on buses, tubes and trains (source: Equal Life
Chances for All 2009)

Percentage of women who feel safe using local bus, tube,

trains, black cabs, and mini cabs at night, alone (source:
Equal Life Chances for All 2009)

Proportion of developments incorporating Secured by

Design principles

Maximise the health and wellbeing of the population, reduce inequalities in

health and promote healthy living

Health Deprivation and Disability (Indices of Deprivation

for England 2010)

Increase accessibility to social infrastructure including health care facilities,

schools, social care and community facilities

Proportion of the population living within walking distance

of health care facilities (see Table 3-5)

Increase the capacity of local social infrastructure

Encouragement of opportunities for buildings with a shared community use and

the co-location of services

Proportion of the population living within walking distance

of education facilities (see Table 3-5)

Facilitate the supply of local food through the provision of space for uses such

SEA: Population,
Human Health,
Material Assets
HIA
EqIA

SEA: Population,
Human Health,
Material Assets, Soil,
Air, Water, Landscape
HIA
EqIA

Proportion of the population living within walking distance

of social care facilities (see Table 3-5)
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IIA Objective and sub-objectives

Reduce the potential for an over-concentration of hot food takeaways in the local
area

Proportion of the population living within walking distance

of community facilities (see Table 3-5)

Minimise construction phase impacts on communities, in relation to both

physical and psychological health

Proportion of the population with access to space for the

growing of food locally

Increase in the capacity of local social infrastructure

Childhood obesity rates

Life expectancy

Percentage of people aged 19 50/64 who have attained

a Level Four NVQ or higher (Office for National Statistics
Local Profiles).

SEA: Population
Human Health,
Material Assets

Percentage of the population aged 16-74 with no

qualifications (Office for National Statistics Local Profiles).

HIA

Education, Skills and Training Deprivation (Indices of

Deprivation for England 2010).

Proportion of the population with access to appropriate

education facilities by sustainable transport modes

Decrease in educational underachievement gap between

disadvantaged groups and the wider community (source:
Equal Life Chances for All 2009)

Maximise the social and economic wellbeing of the local and regional
population and improve access to employment and training

Number of wards with LSOAs in the bottom 20% most

deprived (Indices of Deprivation for England 2010)

Provision of access to a range of high quality local employment opportunities, a

proportion of which will be directed towards local people, both during
construction and permanent jobs, including those from disadvantaged groups

Proportion of new employment and training opportunities

being awarded to local people via local procurement
arrangements

Encourage workforces to reflect local and regional diversity in all occupations

and at all levels

Provision of access to a range of work-based and other training opportunities, a

proportion of which will be directed towards local people, including those from

Proportion of new employment and training opportunities

being awarded to local women via local procurement
arrangements

Employment rate by excluded group compared to

Link to objectives 1 (place-making); 4 (accessibility); 5 (housing); 13 (social and

economic wellbeing)
To improve the education and skills levels of all members of the population,
particularly vulnerable groups
x

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Increase in the availability of formal education across all age groups, including
adults from all equality groups
Increase in the availability of informal education and training for all

Link to objectives 4 (accessibility); 13 (community cohesion); 15 (health and

wellbeing); 117 (social and economic wellbeing); 18 (sustainable economic growth)

17

Relevance to SEA,
HIA, EqIA, HRA

as allotments or farmers markets

x

16

Indicators (known indicators: underlined; proposed

indicators: italics)

EqIA

SEA: Population,
Human Health,
Material Assets
HIA
EqIA

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IIA Objective and sub-objectives

Indicators (known indicators: underlined; proposed

indicators: italics)
employment rate of all Londoners (source: Equal Life
Chances for All 2009)

disadvantaged groups
x

Provision of a range of accessible retail stores, including food stores and smaller
affordable shops for social enterprises

Increase in the provision of facilities for childcare

Encouragement of employers to adopt the London Living Wage

Link to objectives 15 (health and wellbeing); 116 (education and training) and 18
(sustainable economic growth)

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To encourage inward investment alongside investment within existing

communities, to create sustainable economic growth

Workforce profile at all levels (source: Equal Life Chances

for All 2009)

Proportion of the community living within walking distance

of a local shop (see Table 3-5)

Levels of Child Poverty (source: Equal Life Chances for

All 2009)

Number of childcare places (source: Equal Life Chances

for All 2009)

Take-up of subsidised childcare places (including those

for disabled children) benchmarked against the LDA
Childcare Affordability Programme (source: Equal Life
Chances for All 2009)

Economy Local Profiles (ONS)

Employment by industry (ONS- NOMIS)

Increase in the net number of businesses registered in the area

Proportionate coverage of broadband across the area

Increase infrastructure and utilities capacity, including broadband connections

Ensure workspace meets the needs of new and emerging businesses, including
affordable, flexible and micro/SME workspace

Proportion of new employment development that includes

an element of affordable workspace

New businesses categorised as health-led

New businesses that contribute to the growth of the low

carbon goods and services sector

Amount of new employment floorspace in Old Oak

Amount of new industrial floorspace in Park Royal

Deliver retail that does not negatively impact on neighbouring town centres

Encourage the development of employment growth sectors including clean,

green and healthy businesses

Support the relocation of business from Old Oak to Park Royal.

Intensify the use of workspaces within Park Royal

Relevance to SEA,
HIA, EqIA, HRA

SEA: Population,
Human Health,
Material Assets
HIA
EqIA

Link to objectives 16 (education and training) and 17 (social and economic

wellbeing).

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Table 3-5 Accessibility Standards

Local Facility

12

Illustrative
catchment
populations

Minimum reasonable accessibility standards at

different gross densities (assuming bendy routes)
40ppha

60ppha

80ppha

100ppha

Nursery / first school

2,000

600m

500m

400m

400m

Primary / middle school

4,000

800m

700m

600m

500m

Secondary School

8,000

1,200m

1,000m

700m

700m

Secondary School (large)

16,000

1,500m

1,200m

1,000m

1,000m

Health Centre (4 doctors)

10,000

1,200m

1,000m

900m

800m

Local Shop

1,500

500m

400m

400m

300m

Pub

6,000

1,000m

800m

700m

600m

Post Office

5,000

800m

700m

600m

600m

Community Centre

4,000

800m

600m

600m

500m

Local Centre

6,000

1,000m

800m

700m

600m

District Centre / Superstore

24,000

1,900m

1,500m

1,300m

1,200m

Leisure Centre

24,000

1,900

1,500m

1,300m

1,200m

3.8

Assessment Methodology

The appraisal will be presented in an appraisal matrix for each group of policies and allocations. The matrix
is an established method for clearly analysing the performance of the policies or sites and helps meet the
requirements of the SEA Regulations by ensuring that the following elements are considered. This will
enable significant effects to be identified:
x Impact whether the impact will be positive, negative or neutral when assessed against the SA
Objectives.
x Temporal scale whether the impact will be short-term (within 0-5 years of Local Plan implementation),
occur in the medium term (within 5 10 years of Local Plan implementation) or occur in the long-term (10
25 years of Local Plan implementation).
x Spatial scale where the impacts will occur within the area. Any transboundary effects outside of the
study area would also be considered.
x Permanency whether effects will be permanent or temporary.
x Level of certainty the level of certainty in the prediction will be classified as low, medium or high.
x Cumulative and synergistic effects.

12

Barton, Grant and Guise 2003, Shaping Neighbourhoods: A Guide for Health, Sustainability and Vitality, Spon Press, London and

New York. Note: ppha: persons per hectare

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Where negative impacts are identified, measures will be proposed to offset, avoid or otherwise mitigate for
the impact. In addition, measures which may further enhance benefits will also be identified as appropriate.
Tables 3-6 and 3-7 provide an explanation of the notation to be used on the assessment matrices.
Table 3-6 Assessment Scale
Major Positive
Impact (significant)

The option strongly supports the achievement of the IIA Objectives

++

Positive Impact

This option contributions partially to the achievement of the IIA Objective

Neutral/No Impact

There is no clear relationship between the option and/or the achievement of the IIA
Objective

Positive and
negative outcomes

The option has a combination of both positive and negative contributions to the
achievement of the IIA Objective.

Uncertain outcome

It is not possible to determine the nature of the impact as there may be too many
external factors that would influence the appraisal or the impact may depend heavily
upon implementation at the local level. More information is required to assess the
impacts.

Negative Impact

The policy partially detracts from the achievement of the SA Objective.

Major Negative
Impact (significant)

The policy strongly detracts from the achievement of the SA Objective.

--

+/-

Table 3-7 Notation used to identify types of effects

L-T

Effects likely to arise in 10-25 years of Local Plan implementation

M-T

Effects likely to arise in 5-10 years of Local Plan implementation

S-T

Effects likely to arise in 0-5 years of Local Plan implementation

Direct effects.

Indirect effects.

Effects are reversible

IR

Effects are irreversible

H/M/L

High, medium or low certainty of prediction

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4 Stage B: Developing and Refining Options and Assessing

Effects
4.1

Alternatives

As identified in Box 3, the SEA Directive requires that the assessment process considers alternatives:
Box 3: Consideration of Alternatives
..an environmental report shall be prepared in which the likely significant effects on the environment of
implementing the plan or programme, and reasonable alternatives taking into account the objectives and
the geographical scope of the plan or programme, are identified, described and evaluated (2001/42/EC)
(Article 5.1).
Government guidance advises that only realistic and relevant alternatives should be considered and they
should be sufficiently distinct to enable a meaningful comparison of their different environmental effects. This
Draft IIA Report presents the assessment of the strategic plan options as well as the policy options
developed as part of the Regulation 18 Local Plan.

4.2

Appraisal of the Strategic Options

As part of the assessment of alternatives, the key strategic options with regards to affordable housing were
assessed at the outset. The results of this assessment are presented in Chapter 5 of this report..

4.3

Assessment of the Spatial Vision

Good practice guidance recommends that the key aims and principles of the plan should be assessed
against the IIA Objectives, in order to test their compatibility and to determine whether they accord with
broad sustainability principles.
The Spatial Vision for OPDC has been reviewed against the IIA Objectives, and a summary of the key
strengths, weaknesses and recommendations are presented in Chapter 6. Recommendations were made to
offset or alleviate any adverse impacts that were predicted, or to enhance any opportunities that were
identified.

4.4

Assessment of the Strategic Objectives

Good practice guidance also recommends that the goals of a plan should be assessed against the SA
Objectives. The assessment of the Strategic Objectives of the Local Plan against the SA Objectives has
been undertaken using a simple matrix based approach. Chapter 6 presents the complete compatibility of
the Spatial Objectives against the SA Objectives.

4.5

Appraisal of Preferred Policies and Policy Options

The preferred policies and associated policy options were assessed against the IIA Objectives using a matrix
based approach. This identified the positive and negative impacts associated with the policies and included
mitigation measures to address any predicted adverse impacts. As there is a degree of overlap between the
intentions of some of the policies they have been grouped together and the groups of policies, for example,
all those relating to Design have been assessed in a single matrix.
The assessment notations used in the assessment, together with their definition (i.e. how a positive score
was assigned) are presented in Chapter 3 and Appendix G. When undertaking the assessment, the
symbols assigned in the matrix were justified in the commentary box along with any uncertainties.
A summary of the assessment of the appraisal of the Preferred Policies and Options is provided in Chapter
7. The complete results of the assessment are presented in Appendix G.

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4.6

Mitigation

Where appropriate, mitigation measures are recommended to avoid, reduce or offset the potential adverse
impacts as a result of the Local Plan. In addition, potential opportunities to benefit and enhance the social,
economic and environmental receptors are identified. Recommendations within Appendix G are italicised for
clarity.
As the Regulation 18 Local Plan has been developed in parallel to the SA process, mitigation measures
have been incorporated on a continual basis into the Local Plan.

4.7

Appraisal of Cumulative and Synergistic Effects

The SEA Directive requires, inter alia, that cumulative effects should be considered. It stipulates the
consideration of the likely significant effects on the environment and that these effects should include
secondary, cumulative, synergisticeffects (Annex I). The Practical Guide sets out the following definitions
for these terms:
x Secondary or indirect effects comprise effects which do not occur as a direct result of the proposed
activities, but as a result of complex causal pathway (which may not be predictable).
x Cumulative effects arise from a combination of two or more effects, for instance, where several
developments each have insignificant effects but together have a significant effect; or where several
individual effects of the plan or programme have a combined effect.
x Synergistic effects synergy occurs where the joint effect of two or more processes is greater than the
sum of individual effects.
The potential for cumulative, synergistic or secondary or indirect effects as a result of the Local Plan has
been inherently considered within the appraisal, the findings of which are presented in Chapter 7.

4.8

Appraisal of Transboundary Effects

The SEA Directive requires SAs to consider the transboundary effects of the plan on other EU member
states. However, it is not considered likely that the Local Plan could have significant effects upon other
member states. Transboundary effects are, however, mentioned within the IIA where considered appropriate.

4.9

Technical Limitations and Uncertainties

During the assessment of the Regulation 18 Local Plan, there has sometimes been uncertainty when
predicting the potential effects. Where this has occurred, the uncertainty is identified within the appraisal
matrices and accompanied by recommendations to mitigate such impacts.
In addition, a number of data gaps are identified within the baseline context where data is unavailable or out
of date. Obtaining these datasets would help to further increase the knowledge of the areas, and could
potentially be filled through the use of the monitoring framework.
The Regulation 18 Local Plan essentially acts as a guidance document for the future development of OPDC.
There is therefore reliance upon future decision-makers to ensure sustainable development is ensured.

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5 Appraisal of Strategic Options

5.1

Affordable Housing Approaches

Appendix F includes an assessment of approaches to affordable housing provision. A summary of the

assessment findings is presented in Table 5-1. The four strategic options considered are briefly described
below:
x Approach 1 Fixing the percentage: This option describes an approach whereby a single OPDC wide
figure is fixed for the level of affordable housing, subject to a regular review of viability and need. This is
an approach supported in Opportunity Areas in the Mayors draft Housing SPG. For this option OPDC
would need to review viability on a regular basis to keep track of market changes. OPDC may also need
to consider abnormal costs on specific sites in extreme circumstances and where clearly demonstrated
and justified..
x Approach 2 Product dependent range: Under this approach, the option would set a percentage range
for each housing type to be provided recognising that some affordable housing products are more costly
to deliver than others or are more suited to different types of developments. For example there may be a
lower or higher level of affordable housing depending on the type of housing to be provided and the
viability/ affordability of this housing.
x Approach 3 Viability based percentage: This is the approach currently implemented by the three
boroughs. . A target percentage is set but this target is still subject to viability and each individual scheme
would be viability tested to see how much affordable housing it could deliver.
x Approach 4 Negotiate a target on site specific basis: This option seeks the maximum reasonable
amount of affordable housing without specifying a percentage target to achieve for each development. A
review of relevant economic data and viability for each site, to be provided by the applicant and tested by
OPDC, will enable an allocation of affordable housing on the site to be negotiated and determined.

5.1.1 Summary of Assessment

No significant effects were predicted against Approaches 1, 2 and 3 of the assessment. However, significant
negative effects were predicted in relation to the assessment of Approach 4, in relation to IIA Objectives: 13
(community cohesion and social exclusion); 14 (safety, crime and the fear of crime); and 15 (health and
wellbeing). Without an initial target, negotiated levels of provision could be low. This could increase levels of
social exclusion and subsequent knock-on effects for health and anti-social behaviour.
Approach 1 could create a level playing field across the area, which could enable the delivery of affordable
housing. This could help to ensure that all areas are equal in terms of provision, which could help distribute
affordable housing more evenly across the plan area. This could help to ensure that mixed communities and
a sense of place is achieved. However, should this mean that fewer sites are developed, negative effects
may result.
The product dependent range (Approach 2) could lead to inequalities across the OPDC area, as some
housing types, and therefore types of communities, may be seen as more suitable for higher affordable
housing provision than others. This could lead to negative effects against some of the sustainability
objectives.
A viability based percentage (Approach 3) could reduce the provision of affordable housing in areas where
land values are the lowest. This could, therefore, create an imbalance in provision across the plan area,
potentially reducing provision in areas of greatest need, increasing social exclusion. This approach, however,
would include an initial target percentage, which could help negotiations, although it is unclear whether this
target percentage would be an all-area percentage or based on different products or areas. A viability-based
approach could, alternatively, help to deliver more affordable housing as, should a fixed percentage be
required, developers may not develop certain sites due to viability issues. Therefore, a mix of both positive
and negative effects is predicted for this approach.

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Table 5-1 Affordable Housing Approaches: Summary of Assessment

Draft IIA Objective (see Table 6-1 of IIA Scoping
Report )

Impact

Approach 1
(Single) Fixed
contribution
across OPDC
area

Approach 2
Product
dependent
range

Approach 3
Viability
based
percentage

Approach 4
Negotiate a
target on site
specific basis

1. To enhance the built environment and

encourage place-making

2. To optimise the efficient use of land through

increased development densities and building
heights, where appropriate

3. Maximise the reuse of previously developed

land and existing buildings, including the
remediation of contaminated land

4. Minimise the need to travel and improve

accessibility for all users by public and nonmotorised transportation methods

+/-

5. Improve access to well designed, well-located,

market, affordable and inclusive housing of a
range of types and tenures, to meet identified
local needs
6. Improve climate change adaptation and
mitigation, including minimising the risk of flooding
and addressing the heat island effect

+/-

7. To minimise contributions to climate change

through greater energy efficiency, generation and
storage; and to reduce reliance on natural
resources including fossil fuels for transport,
heating and energy

8. To minimise production of waste across all

sectors in the plan area, maximise efficiencies for
transporting waste and increasing rates of re-use,
recycling and recovery rates as well as
composting of all green waste

9. Improve the quality of the water environment

10. Create and enhance biodiversity and the

diversity of habitats across the area and its
surroundings

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Draft IIA Objective (see Table 6-1 of IIA Scoping

Report )

Impact

Approach 1
(Single) Fixed
contribution
across OPDC
area

Approach 2
Product
dependent
range

Approach 3
Viability
based
percentage

Approach 4
Negotiate a
target on site
specific basis

11. To minimise air, noise and light pollution,

particularly for vulnerable groups

12. To conserve and, where appropriate,

enhance, cultural heritage

+/-

--

+/-

13. Increase community cohesion and reduce

social exclusion

14. Improve safety and reduce crime and the fear

of crime

15. Maximise the health and wellbeing of the

population, reduce inequalities in health and
promote healthy living

+/-

+/-

--

--

+/-

+/-

16. To improve the education and skills levels of

all members of the population, particularly
vulnerable groups

17. Maximise the social and economic wellbeing

of the population and improve access to
employment and training

18. To encourage inward investment alongside

investment within existing communities, to create
sustainable economic growth

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6 Appraisal of the Spatial Vision and Objectives

6.1

Appraisal of the Spatial Vision for OPDC

The Regulation 18 Local Plan includes a draft Spatial Vision and objectives, which shape the direction of the
Local Plan policies. The Regulation 18 Local Plan draft Spatial Vision is:
A thriving part of London connected to the UK and internationally. Old Oak and Park Royal will be a centre
for innovation and growth that will shape west London and strengthen Londons role as a global city. A new
commercial hub with catalyst uses, alongside a diverse network of vibrant neighbourhoods, will help create a
London destination recognised as an exemplar in large-scale housing and employment led regeneration.
The draft spatial vision has been appraised against the 18 IIA Objectives. To ensure it further supports the
delivery of the IIA objectives with regard to sustainable modes of transport the following recommendations
are made:

6.1.1 Recommendations
x In terms of accessibility and minimising the need to travel, the Spatial Vision could include reference to
sustainable connections, to infer that the Spatial Vision is based on connectivity through rail links, as
opposed to other modes of transport.
x The Spatial Vision could also include reference to sustainable development, which could infer that
development would need to minimise contributions to and adapt to the effects of climate change as well
as minimise potential impacts on the environment.
x It is also recommended that healthy could be added into the Spatial Vision, to ensure that healthy,
vibrant neighbourhoods are encouraged.

6.2

Appraisal of the Objectives

The Objectives for the Regulation 18 Local Plan set out how the Spatial Vision could be achieved. They
express the purpose of the Local Plan and what it aims to achieve. They embrace the aims and objectives of
other key strategies important to OPDC. The Objectives included for assessment are as follows:
Consolidating
1. Optimise a once in a life-time opportunity created by High Speed 2 and Crossrail to secure investment
that will:
a. deliver a thriving new centre at Old Oak with much needed homes, a mix of employment
space and associated social and physical infrastructure;
b. protect and regenerate the Park Royal industrial area as a cornerstone of the London
economy
Connecting
2. Accessible and high quality national, regional and local transport connections, focused around a new
world class station at Old Oak Common will catalyse comprehensive regeneration with well-designed
streets that will fully connect into surrounding areas.
Creating
3. Deliver a varied mix of uses, including cultural and catalyst uses that supports the growth of a vibrant
London destination.
4. Celebrate existing features of the Grand Union Canal, Wormwood Scrubs, Park Royal, heritage assets,
and local communities to help create a unique sense of place.
5. Utilise the scale of opportunity to embed and showcase exemplar standards of design, smart technology,
environmental, social and economic sustainability, during the planning, construction and operation
stages.

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6. Be flexible and adaptable, both to the effects of a changing climate, and future changes in practices,
including the circular economy and deliver an open and secure digital place.
Communities
7. Create a series of connected and inclusive neighbourhoods, designed to improve the quality of life,
enhance health and well-being, deliver social and economic benefits for local communities and foster a
sense of community and diversity.

6.3

Appraisal Findings

Table 6-1 presents the compatibility of the Regulation 18 Local Plan Objectives against the IIA Objectives.
The assessment can be summarised as follows:
Objective 1: Consolidating (Optimise a once in a life-time opportunity created by High Speed 2 and
Crossrail to secure investment)
The two flagship projects High Speed 2 and Crossrail look to secure investment for London and should
contribute economically to the growth of the Old Oak and Park Royal areas of West London. The presence of
a Crossrail station will be one of the most important transport connections to the site, providing a significant
increase in rail capacity to the West End, City and Canary Wharf. Crossrail will provide excellent regional and
sub-regional connectivity to Old Oak. A thriving new centre at Old Oak should help improve the built
environment and encourage place-making. The new centre is an example of optimising development
opportunities to develop and enhance local distinctiveness and character. This objective will also contribute
towards the delivery of new homes in Old Oak that will provide associated social and physical infrastructure
to meet identified local needs. The mixed use development will provide employment and leisure opportunities
for the Old Oak residents and encourage future investment into the area. The objective also seeks to protect
and regenerate the Park Royal industrial area that will help maintain the character and identity of this
industrial hub of the London economy. The location of this investment should encourage employers to adopt
the London Living Wage and direct employment to local people with a diverse range of skills. The provision
of retail stores at Old Oak are also compatible with the IIA sub objective to help small local businesses and
social enterprises. The surrounding infrastructure will ensure the new facilities are accessible.
Objective 2: Connecting (Accessible and high quality national, regional and local transport connections,
focused around a new world class station at Old Oak Common, which will catalyse comprehensive
regeneration and connect with surrounding areas)
High quality national, regional and local transport connections are focused around a new world class station
at Old Oak Common will provide excellent accessibility and sustainable travel movement for residents and
visitors to this area of West London. The new Old Oak Common station and surrounding interchange will be
the key driver for development in the area and will be the focus of future transport connections. These new
connections are compatible with IIA objective 4 to increase the opportunity for the transport of goods and
people by rail transport and maximising the accessibility of rail stations. The connections will not only provide
access to the retail and commercial area of OPDC, they will provide a more accessible network for many
new homes proposed as part of the development. The objective will also support the aim to increase the net
number of businesses registered in the area and the relocation of business from Old Oak to Park Royal due
to the high quality transport connections. Over the long term, this will help to regenerate the area as the
infrastructure provides a catalyst for inward investment and new residents.
Recommendation: It is recommended that the objective includes reference to sustainable regeneration.
This would reduce demonstrate OPDCs aspiration to address disparities in economic performance and
promote sustainable movement.
Objective 3: Creating (Deliver a varied mix of uses that supports the growth of a vibrant London destination)
The objective seeks to encourage a mix of uses that will support the vibrant growth of London. The IIA
objective aims to encourage the development of employment growth sectors including clean, green and
healthy businesses. Despite this desire the objective must be conscious not to deliver retail negatively
impacts on neighbouring town centres.
Objective 4: Creating (Celebrate existing features of the Grand Union Canal, Wormwood Scrubs, Park
Royal, Heritage assets, and local communities to help create a unique sense of place)

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Previous objectives seek to create new places and landmarks, however this objective wants to preserve
some of the environmentally significant landmarks that exist in the area. The IIA objective seeks to reduce
the potential wide ranging impact on these sites and conserve existing biodiversity across the plan area. For
example, the Grand Union Canal has heritage assets to promote and this can be done through the use of
multifunctional green infrastructure. There is an opportunity to enhance greenspace in connection with areas
such as Grand Union Canal and Wormwood Scrubs to benefit the local community and create a unique
sense of place.
Recommendation: It is recommended that the existing features in the area could provide an opportunity for
tourism and leisure.
Objective 5: Creating (Utilise the scale of opportunity to embed and showcase exemplar environmental,
social and economic standards during planning, construction and operation)
Due to the scale of the development at Old Oak and Park Royal, there is an opportunity to showcase
planning, construction and maintenance methods of best practice. The impact of construction on the
surrounding businesses and communities is very important during any development. This may include
mitigating the impacts of noise, air or light pollution by reducing emissions from construction and demolition
sites. One example of best practice highlighted in an IIA objective is the use of sustainable design compared
with standard construction to demonstrate energy usage and potential energy savings. This would also
apply to the use of recycled materials and natural resources to minimise waste production during
construction. The construction process needs be managed to reduce the impact of a potentially large
construction workforce on the local community, specifically in relation to social infrastructure and housing
provision. These measures should also apply during operation of a building to ensure the users and those
potentially affected are not harmed or disturbed.
Recommendation: It is recommended that the objective includes reference to preservation and
enhancement of green spaces and building a network of green spaces. This would ensure that healthier
living through a connected green infrastructure strategy for health.
Objective 6: Creating (Be flexible and adaptable, both to the effects of a changing climate, and future
changes in practices, including the circular economy, that delivers an open and secure digital place)
The importance of climate change and any other potential external factors that may affect practice need to
be addressed with flexibility and adaptability. The IIA objective highlights methods such as minimising the
proportion of new development at risk of flooding and sustainable design to include urban drainage, natural
ventilation and adaptable to temperature change. Other compatible objectives include enabling the area to
be more self-sufficient to monitor energy generation storage and promote the creation of a circular economy
for the management of waste.
Recommendation: It is recommended that the objective includes reference to embracing the circular
economy to embed resilience. This would present opportunities of more jobs and industries and solutions for
local people to minimise energy use. This could create greater investment in community infrastructure
projects.
Objective 7: Communities (Create a series of connected and inclusive neighbourhoods, designed to
improve the quality of life, enhance health and well-being and deliver benefits for local communities.
Integrated with their surroundings, new development will foster a sense of community and diversity)
The objective seeks to create a series of connected and inclusive neighbourhoods. The most important
factors in creating good communities are sustainable high quality access, community facilities, employment,
recreational/leisure spaces, prevention of social exclusion and equality. The IIA objectives also highlight the
importance of community cohesion by improving the quality of the public realm and the provision of quality
public open spaces. There needs to be good accessibility to social infrastructure, formal/informal education
and training opportunities.
Recommendation: It is recommended that the objective considers using the term social cohesion rather
than fostering a sense of community and references sustainable lifestyles. This would ensure that all
communities are equitable, especially those liable to discrimination, poverty and social exclusion.

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Table 6-1 Compatibility of the Local Plan Objectives with the IIA Objectives
Key

8 = Objectives are potentially incompatible

9= Objectives are compatible

0 = There is no link between objectives

? = The link between the objectives is

uncertain
Objectives

IIA Objective

To enhance the built environment and encourage

place-making

9

To optimise the efficient use of land through increased

development densities and building heights, where
appropriate

9

Maximise the reuse of previously developed land and

existing buildings, including the remediation of
contaminated land

9

Minimise the need to travel, improve accessibility for all

users by public and non-motorised transportation
methods and mitigate impacts on the transport network

9

Improve access to well designed, well-located, market,

affordable and inclusive housing of a range of types and
tenures, to meet identified local needs

9

Improve climate change adaptation and mitigation,

including minimising the risk of flooding and addressing
the heat island effect

To minimise contributions to climate change through

greater energy efficiency, generation and storage; and
to reduce reliance on natural resources including fossil
fuels for transport, heating and energy

To minimise production of waste across all sectors in

the plan area, maximise efficiencies for transporting
waste and increasing rates of re-use, recycling and
recovery rates as well as composting of all green waste

Improve the quality of the water environment

9

10

Create and enhance biodiversity and the diversity of

habitats across the area and its surroundings

9

11

To minimise air, noise and light pollution, particularly for

vulnerable groups

12

To conserve and enhance the historic environment,

heritage assets and their settings

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Objectives
IIA Objective

Increase community cohesion and reduce social

exclusion to encourage a sense of community and
welfare

9

14

Improve safety and reduce crime and the fear of crime

9

9

15

Maximise the health and wellbeing of the population,

reduce inequalities in health and promote healthy living

9

16

To improve the education and skills levels of all

members of the population, particularly vulnerable
groups

9

Maximise the social and economic wellbeing of the local

and regional population and improve access to
employment and training

9

To encourage inward investment alongside investment

within existing communities, to create sustainable
economic growth

9

13

17

18

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7 Appraisal of Regulation 18 Local Plan Policies and Options

th

This Chapter provides a summary of the results of the IIA of the Regulation 18 Local Plan, dated 15
December 2015. The detailed results of the assessments of the Policies and options, are presented in
Appendix G. The policy wording can be found in the Regulation 18 Local Plan which accompanies this Draft
IIA Report for consultation. As noted earlier in this report, the assessments have been grouped by Local Plan
chapter. As such, this is how the assessment is presented in this section.

7.1

The Overarching Spatial Policies

The Policies included within Table G-1 of Appendix G are as follows:

x OSP 1: Optimising growth
x OSP 2: Land use
x OSP 3: Connections and open spaces
x OSP 4: Densities and building heights
x OSP 5: Places
The detailed IIA of these individual policies together with recommendations for mitigation/enhancement
measures is provided in Appendix G. A summary of the key IIA findings is presented below. In order to
improve the sustainability performance of the policy, detailed recommendations are suggested in Appendix
G.

7.1.1 Summary of Assessment

The majority of effects against the policy component are predicted to be positive. No major negative effects
were predicted against the IIA Objectives. Major positive effects are predicted for the following IIA
Objectives:
x 1 (To enhance the built environment and encourage place-making) Policies OSP2, OSP3 and OSP5;
x 2 (To optimise the efficient use of land through increased development densities and building heights,
where appropriate) Policy OSP1;
x 3 (Maximise the reuse of previously developed land and existing buildings, including the remediation of
contaminated land) Policies OSP1; OPS2 and OPS4;
x 4 (Minimise the need to travel, improve accessibility for all users by public and non-motorised
transportation methods and mitigate impacts on the transport network) Policies OSP1, OSP2, OSP3,
and OSP4;
x 5 (Improve access to well designed, well-located, market, affordable and inclusive housing of a range of
types and tenures, to meet identified local needs) Policy OSP2;
x 7 (To minimise contributions to climate change through greater energy efficiency, generation and storage;
and to reduce reliance on natural resources including fossil fuels for transport, heating and energy)
Policy OSP3;
x 12 (To conserve and enhance the historic environment, heritage assets and their settings) Policies
OSP3; and OSP5;
x 13 (Increase community cohesion and reduce social exclusion to encourage a sense of community and
welfare) Policies OSP3 and OSP5;
x 15 (Maximise the health and wellbeing of the population, reduce inequalities in health and promote
healthy living) Policy OSP3;
x 16 (To improve the education and skills levels of all members of the population, particularly vulnerable
groups) Policy OPS2; and
x 17 (Maximise the social and economic wellbeing of the local and regional population and improve access
to employment and training) Policy OSP5.

7.2

The Places

The Policies included within Table G-2 of Appendix G are as follows:

x P1 Old Oak South

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x P2 Old Oak North

x P3 Old Oak High Street
x P4 Grand Union Canal
x P5 Park Royal
x P6 Park Royal Centre
x P7 North Acton
x P8 Scrubs Lane
x P9 Old Oak West
x P10 Wormwood Scrubs
The detailed IIA of these individual policies together with recommendations for mitigation/enhancement
measures is provided in Appendix G. A summary of the key IIA findings is presented below. In order to
improve the sustainability performance of the policy, detailed recommendations are suggested in Appendix
G.

7.2.1 Summary of Assessment

The majority of effects against the policy component are predicted to be positive. No significant negative
effects have been predicted. Major positive effects are predicted for the following IIA Objectives:
x 1 (To enhance the built environment and encourage place-making) Policies P1; P2; P3; P4; P5; P6;
P7; P8; P9; and P10;
x 2 (To optimise the efficient use of land through increased development densities and building heights,
where appropriate) Policies P1; P2; P3; P4; P5; P6; P7; P8 and P9;
x 3 (Maximise the reuse of previously developed land and existing buildings, including the remediation of
contaminated land) Policies P1; P2; P3; P4; P5; P6; P7; P8; and P9;
x 4 (Minimise the need to travel, improve accessibility for all users by public and non-motorised
transportation methods and mitigate impacts on the transport network) Policies P1; P2; P3; P4; P5; P6;
P7; P8; P9; and P10;
x 5 (Improve access to well designed, well-located, market, affordable and inclusive housing of a range of
types and tenures, to meet identified local needs) Policy P7;
x 10 (Create and enhance biodiversity and the diversity of habitats across the area and its surroundings)Policies P5; and P10;
x 12 (To conserve and enhance the historic environment, heritage assets and their settings) Policies P4;
and P8;
x 13 (Increase community cohesion and reduce social exclusion to encourage a sense of community and
welfare) Policies P1; P3; P4; P6; P7; P8 and P10;
x 14 (Improve safety and reduce crime and the fear of crime) P3; P4; P6; and P7;
x 15 (Maximise the health and wellbeing of the population, reduce inequalities in health and promote
healthy living) Policy P10;
x 16 (To improve the education and skills levels of all members of the population, particularly vulnerable
groups) Policy P7; and
x 18 (To encourage inward investment alongside investment within existing communities, to create
sustainable economic growth) P1; P2; P5; P6; P7; P8; and P9.

7.3

Sustainable development

The Policies included within Table G-3 of Appendix G are as follows:

x SD1: Sustainable development
The detailed IIA of these individual policies together with recommendations for mitigation/enhancement
measures is provided in Appendix G. A summary of the key IIA findings is presented below. In order to
improve the sustainability performance of the policy, detailed recommendations are suggested in Appendix
G.

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7.3.1 Summary of Assessment

The majority of effects against the policy component are predicted to be positive. No major negative effects
were predicted against the IIA Objectives. Only one major positive effects was predicted for the following IIA
Objective: 18 (To encourage inward investment alongside investment within existing communities, to create
sustainable economic growth).

7.4

Design

The Policies included within Table G-4 of Appendix G are as follows:

x D1: Strategic Policy for design
x D2: Streets and public realm
x D3: Public amenity space
x D4: New buildings
x D5: Existing buildings
x D6: Heritage
x D7: Amenity
x D8: Inclusive design
The detailed IIA of these individual policies together with recommendations for mitigation/enhancement
measures is provided in Appendix G. A summary of the key IIA findings is presented below. In order to
improve the sustainability performance of the policy, detailed recommendations are suggested in Appendix
G.

7.4.1 Summary of Assessment

The majority of effects against the policy component are predicted to be positive. No major effects, either
positive or negative, were predicted for policies D3, D4, D5, D7 and D8. Major positive effects are predicted
for the following IIA Objectives:
x 1 (To enhance the built environment and encourage place-making) Policies D1 and D2;
x 5 (Improve access to well designed, well-located, market, affordable and inclusive housing of a range of
types and tenures, to meet identified local needs) Policy D1;
x 12 (To conserve and enhance the historic environment, heritage assets and their settings) - Policy D6;
and
x 14 (Improve safety and reduce crime and the fear of crime) Policy D1.

7.5

Housing

The Policies included within Table G-5 of Appendix G are as follows:

x H1: Strategic Policy for Housing
x H2: Housing supply
x H3: Housing mix
x H4: Affordable housing
x H5: Existing housing
x H6: Housing in the Private Rented Sector
x H7: Housing with shared facilities
x H8: Specialist housing for older people and/or vulnerable people
x H9: Gypsy and Travellers accommodation
x H10: Student housing
The detailed IIA of these individual policies together with recommendations for mitigation/enhancement
measures is provided in Appendix G. A summary of the key IIA findings is presented below. In order to

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improve the sustainability performance of the policy, detailed recommendations are suggested in Appendix
G.

7.5.1 Summary of Assessment

The majority of effects against the policy component are predicted to be positive. No major effects, either
positive or negative, were predicted for policies H4; H5; H6; H7; H9; and H10. No major negative effects
were predicted against the IIA Objectives. Major positive effects are predicted for the following IIA
Objectives:
x 1 (To enhance the built environment and encourage place-making) Policy H1;
x 5 (Improve access to well designed, well-located, market, affordable and inclusive housing of a range of
types and tenures, to meet identified local needs) Policies H1; H2; and H3;
x 13 (Increase community cohesion and reduce social exclusion to encourage a sense of community and
welfare) Policies H1;H3; and H8;
x 15 (Maximise the health and wellbeing of the population, reduce inequalities in health and promote
healthy living) Policy H1.

7.6

Employment

The Policies included within Table G-6 of Appendix G are as follows:

x E1: Strategic Policy: Delivering a diverse economy
x E2: Old Oak
x E3: Park Royal
x E4: Open workspaces
x E5: Local access to employment and training
The detailed IIA of these individual policies together with recommendations for mitigation/enhancement
measures is provided in Appendix G. A summary of the key IIA findings is presented below. In order to
improve the sustainability performance of the policy, detailed recommendations are suggested in Appendix
G.

7.6.1 Summary of Assessment

The majority of effects against the policy component are predicted to be positive. No major effects, either
positive or negative, were predicted for Policy E4. No major negative effects were predicted against the IIA
Objectives. Major positive effects are predicted for the following IIA Objectives:
x 16 (To improve the education and skills levels of all members of the population, particularly vulnerable
groups) Policy E5;
x 17 (Maximise the social and economic wellbeing of the local and regional population and improve access
to employment and training) Policy E1; E2; E3; and E5;
x 18 (To encourage inward investment alongside investment within existing communities, to create
sustainable economic growth) Policy E1; E2; and E3.

7.7

Town Centre Uses

The Policies included within Table G-7 of Appendix G are as follows:

x TC1: Strategic Policy: Town centre uses
x TC2: Town centre hierarchy
x TC3: Vibrancy
x TC4: Retail and eating and drinking establishment needs
x TC5: Culture, sports and leisure facilities
x TC6: Visitor accommodation
x TC7: Hours of operation for night time economy uses

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The detailed IIA of these individual policies together with recommendations for mitigation/enhancement
measures is provided in Appendix G. A summary of the key IIA findings is presented below. In order to
improve the sustainability performance of the policy, detailed recommendations are suggested in Appendix
G.

7.7.1 Summary of Assessment

The majority of effects against the policy component are predicted to be positive. No major negative effects
were predicted against the IIA Objectives. Major positive effects are predicted for the following IIA
Objectives:
x 1 (To enhance the built environment and encourage place-making) Policies TC1; TC2; TC3; TC4; and
TC7;
x 2 (To optimise the efficient use of land through increased development densities and building heights,
where appropriate) Policy Option TC4 Option 1;
x 3 (Maximise the reuse of previously developed land and existing buildings, including the remediation of
contaminated land) Policy TC2; and Policy Option TC4 Option 1;
x 4 (Minimise the need to travel, improve accessibility for all users by public and non-motorised
transportation methods and mitigate impacts on the transport network) Policies TC2; TC3; TC3 Option
1; TC4; and TC6;
x 13 (Increase community cohesion and reduce social exclusion to encourage a sense of community and
welfare) Policies TC1; TC3; and TC4;
x 15 (Maximise the health and wellbeing of the population, reduce inequalities in health and promote
healthy living) Policy TC5;
x 16 (To improve the education and skills levels of all members of the population, particularly vulnerable
groups) Policy TC5;
x 17 (Maximise the social and economic wellbeing of the local and regional population and improve access
to employment and training) Policies TC1; TC2; TC2 Policy Option 1; and TC5;
x 18 (To encourage inward investment alongside investment within existing communities, to create
sustainable economic growth) Policies TC1 and TC7.

7.8

Social Infrastructure

The Policies included within Table G-8 of Appendix G are as follows:

x SI1: Strategic Policy: Social infrastructure
x SI2: Educational
x SI3: Health
x SI4: Community facilities
x SI5: Public houses
The detailed IIA of these individual policies together with recommendations for mitigation/enhancement
measures is provided in Appendix G. A summary of the key IIA findings is presented below. In order to
improve the sustainability performance of the policy, detailed recommendations are suggested in Appendix
G.

7.8.1 Summary of Assessment

The majority of effects against the policy component are predicted to be positive. No major negative effects
were predicted against the SA Objectives. Major positive effects are predicted for the following IIA
Objectives:
x 1 (To enhance the built environment and encourage place-making) Policies SI4; and SI5;
x 2 (To optimise the efficient use of land through increased development densities and building heights,
where appropriate ) Policies SI1 and SI1 Option 1; and SI3;
x 3 (Maximise the reuse of previously developed land and existing buildings, including the remediation of
contaminated land) Policies SI1;
x 4 (Minimise the need to travel, improve accessibility for all users by public and non-motorised
transportation) Policies SI2 and SI2 Option 1; SI3; and SI4;

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x 12 (To conserve and enhance the historic environment, heritage assets and their settings) Policy SI5;
x 13 (Increase community cohesion and reduce social exclusion to encourage a sense of community and
welfare) Policies SI1; SI2; SI4; and SI5;
x 15 (Maximise the health and wellbeing of the population, reduce inequalities in health and promote
healthy living) Policy SI1 and SI1 Option 1; and SI3;
x 16 (To improve the education and skills levels of all members of the population, particularly vulnerable
groups) Policies SI2; and SI3;
x 17 (Maximise the social and economic wellbeing of the local and regional population and improve access
to employment and training) Policies SI1 Option 1; and SI2;
x 18 (To encourage inward investment alongside investment within existing communities, to create
sustainable economic growth) Policies SI4 and SI5.

7.9

Transport

The Policies included within Table G-9 of Appendix G are as follows:

x T1: Strategic Policy for Transport
x T2: Walking
x T3: Cycling
x T4: Rail
x T5: Buses
x T6: Roads and streets
x T7: Parking
x T8: Freight, servicing and deliveries
x T9: Construction
x T10: Transport Assessments and Travel Plans
The detailed IIA of these individual policies together with recommendations for mitigation/enhancement
measures is provided in Appendix G. A summary of the key IIA findings is presented below. In order to
improve the sustainability performance of the policy, detailed recommendations are suggested in Appendix
G.

7.9.1 Summary of Assessment

The majority of effects against the policy component are predicted to be positive. No major effects, either
positive or negative, were predicted for Policies T6; T8 and T10. Major positive effects are predicted for the
following IIA Objectives:
x 4 (Minimise the need to travel, improve accessibility for all users by public and non-motorised
transportation methods and mitigate impacts on the transport network) Policies T1; and T4;
x 8 (To minimise production of waste across all sectors in the plan area, maximise efficiencies for
transporting waste and increasing rates of re-use, recycling and recovery rates as well as composting of
all green waste) Policy T9;
x 11 (To minimise air, noise and light pollution, particularly for vulnerable groups) Policy T1;
x 13 (Increase community cohesion and reduce social exclusion to encourage a sense of community and
welfare) Policy T5;
x 15 (Maximise the health and wellbeing of the population, reduce inequalities in health and promote
healthy living) Policies T1; and T2;
x 16 (To improve the education and skills levels of all members of the population, particularly vulnerable
groups) Policy T5;
x 17 (Maximise the social and economic wellbeing of the local and regional population and improve access
to employment and training) Policies T3 and T4;
x 18 (To encourage inward investment alongside investment within existing communities, to create
sustainable economic growth) Policy T1 Option 1; T2; T3; T4; and T7.

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Significant negative effects were predicted against the following IIA Objective:
x 11 (To minimise air, noise and light pollution, particularly for vulnerable groups) Policy T8 Option 1.

7.10 Environment and Utilities

The Policies included within Table G-10 of Appendix G are as follows:
x EU1: Strategic Policy for the environment and utilities
x EU2: Smart
x EU3: Water
x EU4 Waste management
x EU5: Waste minimisation, and use as a resource
x EU6: Energy
x EU7: Digital communications infrastructure
x EU8: Green infrastructure and biodiversity
x EU9: Extraction of minerals
x EU10: Air quality
x EU11: Noise
x EU12: Land contamination
The detailed IIA of these individual policies together with recommendations for mitigation/enhancement
measures is provided in Appendix G. A summary of the key IIA findings is presented below. In order to
improve the sustainability performance of the policy, detailed recommendations are suggested in Appendix
G.

7.10.1 Summary of Assessment

The majority of effects against the policy component are predicted to be positive. No major effects, either
positive or negative, were predicted for policies EU2; EU4; EU7; EU9; EU10; and EU11. No major negative
effects were predicted against the SA Objectives. Major positive effects are predicted for the following IIA
Objectives:
x 1 (To enhance the built environment and encourage place-making) Policy EU8;
x 3 (Maximise the reuse of previously developed land and existing buildings, including the remediation of
contaminated land) Policy EU12;
x 6 (Improve climate change adaptation and mitigation, including minimising the risk of flooding and
addressing the heat island effect) Policies EU1; EU3; EU5; EU6; and EU8;
x 7 (To minimise contributions to climate change through greater energy efficiency, generation and storage;
and to reduce reliance on natural resources including fossil fuels for transport, heating and energy)
Policy EU6 and EU6 Option 1;
x 8 (To minimise production of waste across all sectors in the plan area, maximise efficiencies for
transporting waste and increasing rates of re-use, recycling and recovery rates as well as composting of
all green waste) Policies EU1; and EU5;
x 9 (Improve the quality of the water environment) Policy EU3;
x 10 (Create and enhance biodiversity and the diversity of habitats across the area and its surroundings)
Policy EU8;
x 12 (To conserve and enhance the historic environment, heritage assets and their settings) Policy EU8;
x 15 (Maximise the health and wellbeing of the population, reduce inequalities in health and promote
healthy living) Policy EU1; and
x 17 (Maximise the social and economic wellbeing of the local and regional population and improve access
to employment and training) - Policy EU1.

7.11 Habitats Regulations Assessment Screening

An initial HRA screening exercise, undertaken in parallel to this IIA, concludes the following:

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This HRA Screening of the OPDC Regulation 18 Draft Local Plan has considered the potential implications
of the plan for European Sites within 20km of the OPDC area boundary.
It is important to note that none of the policies set out in the OPDC Local Plan would lead to direct impacts
upon European Sites.
The closest European site is more than 7km from the OPDC boundary. It is considered that potential effects
are very unlikely to be significant, given the distance between the European Sites and the developments
likely to arise from the OPDC Local Plan policies, as well as the standard mitigation measures that are
required of such developments (such as pollution prevention).
The assessment of in-combination effects of various plans and policies revealed that it is not considered that
the OPDC Local Plan would contribute to significant in-combination effects.

7.12 Cumulative Effects

Table 7-1

Cumulative Effects

Receptor

Cumulative / Synergistic
Effect

Causes

Potential
Trend

Crime Rates and

Fear of Crime

Crime and fear of crime may

reduce in response to wider
regeneration initiatives in
addition to the Local Plan
provisions.

Regeneration provisions would also contribute

to improved aspirations and environments in
conjunction with the proposals in the Local
Plan. This may reduce crime and fear of crime
levels in the long-term.

Positive

Health of the
Levels of health and well-being
Boroughs population have the potential to improve in
the long term.

Housing Provision

Positive
Cumulative measures to promote walking and
cycling together with co-location of jobs, homes
and accessible greenspace can benefit healthy
lifestyles and wellbeing.

Housing will be provided to meet The Local Plan would contribute to meeting
regional housing needs.
local needs and would
contribute to regional targets.

Positive

Access to goods and Access to services and facilities

services
for local people and visitors
would be improved.

Sustainable accessibility across the area and

connecting to the wider boroughs is a key
feature of the Local Plan.

Positive

Sustainable
Economic Growth

The Local Plan would help

facilitate employment creation,
business development and
economic growth.

The efforts of all the plans would help to raise

the image of the area and attract inward
investment.

Positive

Economic Inclusion

Promotion of employment in
areas of high employment /
income deprivation.

Improved accessibility within the area as a

whole, with improved public transport and
walking / cycling opportunities and co-location
of jobs and homes, should ensure easy access
to employment for all.

Biodiversity

Positive and
The Local Plan seeks to ensure While the Local Plan seeks to encourage
protection of biodiversity
biodiversity enhancements, the overall quantum Negative
resources. However, potential
of development could have negative effects.
negative impacts could occur as
a result of development within
some brownfield sites.

Townscape Quality

Protection and enhancement of

The development of employment sites would

help to meet regional needs.

The Local Plan seeks to encourage the

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Receptor

Cumulative / Synergistic
Effect

Causes

landscape and townscape

through regeneration of town
centres and brownfield sites.

development of a significant brownfield site,

which could lead to significant benefits against
this objective.

Heritage Assets

Heritage assets would be

directly affected by the Local
Plan, and there is potential for
undesignated heritage assets to
be affected also.

Undesignated heritage assets should be

identified and a suitable strategy developed
ahead of the commencement of development,
otherwise potentially negative effects could
result.

Uncertain

Climate Change

Potential negative effects of

traffic growth, or positive effects
from a reduction in congestion
and improved connectivity.

The Local Plan requires housing and

employment growth which will all lead to an
increase in resource use, emissions and traffic
generation. However, the plan seeks to
promote development near to existing centres
and transport hubs and to promote sustainable
travel modes. Energy projects relate to lowcarbon sources of energy.

Positive and
negative

Air Quality
Energy Efficiency
Natural Resources
Sustainable
Transport

Potential negative and positive

contributions towards climate
change.
Potential positive effects as a
result of promotion of
sustainable travel.
The prudent use of natural
resources.

Potential
Trend

Potential flood risk within the provision of

specific measures to reduce this, could lead to
significant cumulative negative effects.

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8 Next Steps
This Draft IIA Report has now been issued for consultation alongside the Regulation 18 Local Plan to all key
stakeholders (including statutory consultees and the public) for comment. The Regulation 18 Local Plan
along with this accompanying IIA Report and associated appendices will be consulted on for eight weeks.
Following the close of the consultation period, OPDC will review the feedback and revise the Plan as
appropriate. The IIA Report will then be updated to reflect the assessment of these amendments or additions
prior to the Regulation 19 Local Plan being published. The IIA Report will also include aspects relating to the
SA process, such as a draft Monitoring Framework, as outlined in Table 2-1 of this report. The next
consultation on the IIA Report will be undertaken alongside the consultation on the Regulation 19 Local Plan.

If you would like to comment on this Draft IIA Report, please send comments to:

localplan@opdc.london.gov.uk
or
Local Plan Consultation
Old Oak and Park Royal Development Corporation
City Hall,
The Queen's Walk,
More London Riverside,
London
SE1 2AA

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Arcadis Consulting (UK) Limited

Arcadis Cymru House
St Mellons Business Park Fortran Road
Cardiff
CF3 0EY
United Kingdom
T: +44 (0)29 2079 9275

arcadis.com

Page 307

OLD OAK AND PARK ROYAL

DEVELOPMENT CORPORATION
LOCAL PLAN
Integrated Impact Assessment
Appendices

DECEMBER 2015

Page 308

CONTACTS
DAVID HOURD
Technical Director

Arcadis.

dd 01925 800753

5th Floor
401 Faraday Street
Birchwood Park
Warrington
WA3 6GA
UK

m 07872 675 607

e David.Hourd@arcadis.com

Arcadis Consulting (UK) Limited is a private limited company registered in England & Wales (registered number 02212959). Registered Office at Manning
House, 22 Carlisle Place, London, SW1P 1JA, UK. Part of the Arcadis Group of Companies along with other entities in the UK.
Copyright 2015 Arcadis. All rights reserved. arcadis.com

Page 309

VERSION CONTROL
Issue

Revision No.

Date Issued

Description of
Revision: Page
No.

Description of
Revision:
Comment

Reviewed by:

17/12/2015

Various

Draft IIA Report

David Hourd

21/12/2015

Various

Final Draft IIA

Report

David Hourd

Page 310

APPENDICES
APPENDIX A
Scoping Workshop Attendees and Findings

APPENDIX B
Review of Plans, Programmes and Environmental Protection Objectives

APPENDIX C
Baseline Data

APPENDIX D
Initial Analysis of other relevant SA Frameworks

APPENDIX E
Consultation Responses to IIA Scoping Report

APPENDIX F
Strategic Options Assessment

APPENDIX G
Assessment of Preferred Policies and Options (December 2015)

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APPENDIX A
Scoping Workshop Attendees and Findings

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Table A-1 Workshop Attendees

Name

Role

Organisation

Peter Farnham

Planner

OPDC

Rachel Flowers

Health Advisor

OPDC

Andrew Jones

Environment team

GLA

David English

Historic Places Advisor

Historic England

Claire Jones

Planner

LB Brent

Samuel Cuthbert

Planner

LB Ealing

Stuart Lines

Associate Director of Public Health

LB Hammersmith and Fulham

Lucy Saunders

Public Health Director

TfL/GLA

Gillian Kavanagh

Planner

RB Kensington & Chelsea

Steve Walker

Principal Planner - London

Environment Agency

Katherine Fletcher

Heritage and Conservation Officer

Historic England

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Old oak and park royal development corporation local plan

Table A-2
Topic

Key Sustainability Issues and Opportunities from Scoping Workshop: Consultee responses
Summary of issues raised by Scoping Workshop attendees

Economy,
Issues
employment and x
Infrastructure/Utilities a key issue for the area is how infrastructure/utilities will be improved to
training
accommodate the new development. In particular, broadband capacity is very poor at present
within Park Royal. Also transport links need significant improvement.

Implications for the Local Plan

x

Town centres there is a potential issue that the development of offices and retail facilities
within the OPDC area would destroy neighbouring town centres, including Ealing town centre.

Affordable workspace much of the available workspace is affordable at present, due to its poor
quality. There is also an issue relating to density in this area warehousing uses are low
x
employment generators.

Page 315

Displacement of existing businesses especially hostile in Old Oak

How do we create jobs for local people if the business make-up of area changes? (i.e. Proposals
for R&D into climate change, circular economies but current use is more low-skilled and
manufacturing)

The effect of the construction phase of

development could be significantly negative for
existing business, through the potential impact
on the transport network. A large transitory
construction workforce could also have negative
effects on the community.

Potential for the withdrawal of PD Rights for the

conversion of offices to residential use, to
prevent the reduction in community cohesion
and access to facilities.

Managing affordability

Managing and creating robust S106 and CIL

agreements

Microbusiness disruption during construction (they exist hand to mouth sometimes)

Opportunities

Incoming retail could be developed in small

clusters. This could help to reduce the impact on
other town centres. A fine balance between
place-making, providing enough facilities, and
not destroying external town centres, needs to
be sought. Improved connectivity from the OPDC
area to the town centres could be beneficial in
this respect. Harlesden town centre would be
walkable from the OPDC area.

Healthy New Towns The OPDC is looking to submit a bid to become a Healthy New Town to
NHS England. This is based on health-led employment in the centre, for clean, green and
healthy technology businesses. This may include research companies etc.

North Acton could expand on its existing student accommodation to attract further university
x
facilities in the OPDC area, which would buffer the industrial area further north, with an area of
student housing further south. Anecdotal evidence suggests that the campus may be associated
with Imperial College.
x

Affordable workspace there is potential to create flexible/shared office environments, whereby

users can rent desk-space without the need for a formal lease agreement for an entire office.

The land uses in the OPDC area are likely to experience a wholesale change from the existing

Management of robust conditions that are

deliverable and enforceable.

Old oak and park royal development corporation local plan

Topic

Summary of issues raised by Scoping Workshop attendees

Implications for the Local Plan

situation. This could provide an opportunity to reduce disparities across the area, although may
push out existing businesses.

Social

Employment and training - There is an opportunity for the Local Plan to specify that incoming
employment opportunities are to be directed towards local people in the existing and
surrounding communities. This combines with an opportunity to upskill the local workforce, the
majority of whom may currently be in lower-skilled jobs in the local area.

Issues
x

Accessibility there is currently poor public transport access to the OPDC area to get in to the
area, would have to get a train to a tube station and then walk into the area from there. Further,
there is poor wayfaring within the site.

Page 316

Lack of primary healthcare

Hard edges there are a number of hard edges within the site, which create poor legibility.

There is a Traveller site next to Old Oak on Backley Road, which is linear against the railway
line and a metal refinery.

Lack of affordable housing

Unknown future population that needs to be modelled draw on lessons learnt from Kings
Cross

How will site link to other areas outside OA boundaries?

Canal towpath plans need to be aware of how constrained the space is can we accommodate
all uses and users?

Opportunities
x

Incoming population there is an opportunity for the health of the local community to be built in
to the Local Plan principles from the very beginning. This may include building in street
networks, designed so that children can play independently; or building in creativity, art, intrigue,

HIA scope should consider the surrounding area,

incoming residents and people coming in for
work/visiting/travelling through.

Construction phase impacts should be

considered within the Local Plan- including both
psychological and physical effects.

Ensure Local Plan robust enough to deal with

minimum %ages of affordable housing

The Local Plan should consider minimising the

use of on-street parking and servicing at the
fronts of buildings, as these can have a negative
effect on the street atmosphere.

Old oak and park royal development corporation local plan

Topic

Summary of issues raised by Scoping Workshop attendees

Implications for the Local Plan

surprise to create a sense of place and a high quality environment.

Environment

There is an opportunity to significantly improve accessibility to and throughout the site, including
the creation of legible routes and reducing hard edges.

Issues
x

There is currently poor accessibility to open space/green infrastructure/play space.

River Brent and the Grand Union Canal the water quality in these areas is currently very poor
biological and chemical.

Page 317

Remediation Land contamination is a key issue in the area, particularly in certain areas,
depending on the presence of London Clay.

There are currently 2 large waste sites, which serve London. Concerns were raised regarding
their potential displacement. This may lead to a waste apportionment issue/create problems of
pollution outside of the plan area as a result of development in the OPDC area.

The Local Plan could minimise the use of onstreet parking and servicing at the fronts of
buildings, as these can have a negative effect on
the street atmosphere.

Adoption and maintenance of new assets

London Legacy Development Corporation
lessons learnt?

Cross-boundary issues with respect to heritage

assets and views need to be addressed.

Thames Water and Counters Creek combined

sewer discussion/CIL/S106 payments to deal
with a system already at capacity

Heritage at Risk there are areas within the scope of the Local Plan which are considered to be
negatively managed from a townscape and heritage perspective. Twyford Abbey and Hereford
St Mary are included in the local list of heritage assets at risk. In addition to assets themselves,
x
wider views should also be take into account. Although archaeology is not considered to be a
priority in this area, this will also need to be assessed.

Surface Water assessments to be more than site-wide but dealt with on strategic level TW
keen to ensure that new developments do not assume that capacity is available (due to
provision of new TW assets).

Opportunities
x

Green Infrastructure there is an opportunity to create green infrastructure which facilitates

live/work/play/travel through as well as fast and meandering routes.

Improvement to AQMA likely due to redevelopment of area but needs to ensure that population

The Local Plan should facilitate the use of green

infrastructure, but also manage the spread of
routes across the OPDC area, so that certain
routes do not become congested.

The Local Plan should seek to ensure that

improvements in the area do not lead to increase
3

Old oak and park royal development corporation local plan

Topic

Summary of issues raised by Scoping Workshop attendees

increase doesnt counteract that.

Page 318

There is an opportunity to create SUDS across the area and reduce potentially polluting
discharges to watercourses also need to address differences in catchments between east and
west.

London Waste and Recycling Board there is an opportunity for the OPDC area to become an
example centre for the creation of an integrated circular economy. This could include the
creation, use and recycling of products locally, including the potential for the growing of local
food through the use of vertical farms.

Urban Heat Island Effect opportunity to crease a decentralised energy hub and create a closed
loop system.

An increase in population and new industries may create an opportunity to reduce pollution
locally and increase efficiency/cleanliness.

Implications for the Local Plan

pollution/traffic etc, elsewhere across London.

APPENDIX B
Review of Plans, Programmes and Environmental Protection Objectives

Page 319

Table B-1 Sustainability Themes derived from the review of Policies, Plans and Programmes
PPPs Reviewed
Common theme
International/ National
Regional / London

West London/Local

Environment
x
x
x

Promote
sustainable design
and mitigate and
adapt to climate
change

x
x
x

Climate change Act 2008

UK Climate Change Programme 2006
National Planning Policy Framework
2012
Sustainable Development Strategy 2005
National Planning Policy for Waste 2014
Written Ministerial Statement:
Sustainable Drainage Systems 2014

x
x
x
x
x
x
x

Page 320

x
x
x
x
Promote and
protect the water
environment
including issues
such as quality and
resource use as
well as reducing
flood risk

Reduce greenhouse
gas emissions,
increase energy
efficiency and
promote the use of
renewable energy
and renewable
technologies in

x
x
x
x
x
x

x
x
x
x
x

Water Framework Directive 2000/60/EC

Urban Waste Water Treatment Directive
91/271/EEC
Flood and Water Management Act 2010
National Planning Policy Framework
2012
Sustainable Development Strategy 2005
Future Water 2011
National Planning Policy for Waste 2014
Written Ministerial Statement:
Sustainable Drainage Systems 2014

Directive on the Promotion of the Use of

Energy from Renewable Sources
2209/28/EC
Energy Act 2013
National Planning Policy Framework
2012
Sustainable Development Strategy 2005
The UK Low Carbon Transition Plan

x
x
x
x
x
x
x
x
x
x
x
x

The London Plan 2011, 2013, 2015

Green Infrastructure and Open
Environments SPG 2012
Social Infrastructure SPG 2015
London Infrastructure Plan 2050
update 2015
Sustainable Design and
Construction SPG 2014
The Mayors Food Strategy 2008
The Mayors Climate Change
Mitigation and Energy Strategy
2011
The Mayors Climate Change
Adaption Strategy 2011
London Plan Town Centres SPG
2014
The London Plan 2011, 2013, 2015
Green Infrastructure and Open
Environments SPG 2012
Social Infrastructure SPG 2015
London Infrastructure Plan 2050
update 2015
Sustainable Design and
Construction SPG 2014
Securing Londons Water Future
2011
Thames River Basin District RBMP
2009

x
x
x
x

The London Plan 2011, 2013, 2015

Sustainable Design and
Construction SPG 2014
The Mayors Climate Change
Mitigation and Energy Strategy
2011
The Mayors Climate Change
Adaption Strategy 2011

x
x
x
x
x

x
x
x
x
x
x
x

Brent Core Strategy 2010

Ealing Core Strategy 2012
Hammersmith and Fulham Core Strategy 2011
Ealing Sustainable Community Strategy 20062016
Kensington and Chelsea Consolidated Local
Plan 2015

Brent Core Strategy 2010

Ealing Core Strategy 2012
Hammersmith and Fulham Core Strategy 2011
Hammersmith and Fulham Updated Surface
Water Management Plan 2015
Kensington and Chelsea Surface Water
Management Plan 2014
Kensington and Chelsea Local Flood Risk
Management Strategy 2015
Kensington and Chelsea Consolidated Local
Plan 2015

Brent Core Strategy 2010

Ealing Core Strategy 2012
Hammersmith and Fulham Core Strategy 2011
Ealing Sustainable Community Strategy 20062016
Kensington and Chelsea Consolidated Local
Plan 2015
1

PPPs Reviewed
Common theme
International/ National
appropriate
locations

x
x
x
x
x
x
x
x

2009
The Carbon Plan 2011
UK Renewable Energy Strategy 2009
National Planning Policy for Waste 2014
Waste Framework Directive 2008/98/EC
National Planning Policy Framework
2012
Sustainable Development Strategy 2005
National Planning Policy for Waste 2014

Regional / London
x
x
x
x
x
x
x
x

Promote sensitive
waste management

Page 321

x
x
x
Protect and
enhance the historic
environment and
recognise and
recognise and
appreciate
landmarks,
townscapes and
their setting

x
x
x
x
x
x

Conserve and
enhance
biodiversity as an
integral part of
economic, social
and environmental
development

x
x
x
x

European Convention on the Protection

of the Archaeological Heritage (revised)
(1992)
European Landscape Charter 2000
Planning (Listed Building and
Conservation Areas) Act 1990
Ancient Monuments and Archaeological
Areas Act 1979
National Planning Policy Framework
2012
Sustainable Development Strategy 2005
European Directive 92/43/EEC and
amended by 97/62/EC on the
conservation of natural habitats
Wildlife and Countryside Act 1981
National Planning Policy Framework
2012
Sustainable Development Strategy 2005
UK Post-2010 Biodiversity Framework
2012

x
x
x

London Infrastructure Plan 2050

update 2015

x
x
x
x

The London Plan 2011, 2013, 2015

Sustainable Design and
Construction SPG 2014
The Control of Dust and Emissions
during Construction and Demolition
SPG 2014
London Waste and Recycling Board
Waste Management Planning
Advice for New Flatted Properties,
2014
The Mayors Municipal Waste
Management Strategy, 2011
London Infrastructure Plan 2050
update 2015
The London Plan 2011, 2013, 2015
London View Management
Framework SPG 2012
London Plan Town Centres SPG
2014

x
x

x
x
x
x
x
x
x
x
x
x

West London/Local

West London Joint Waste Plan 2015

Ealing Sustainable Community Strategy 20062016
Kensington and Chelsea Consolidated Local
Plan 2015

x
x
x
x
x
x

Brent Core Strategy 2010

Ealing Core Strategy 2012
Hammersmith and Fulham Core Strategy 2011
Ealing Green Space Strategy 2012-2017
Kensington and Chelsea Consolidated Local
Plan 2015
x

The London Plan 2011, 2013, 2015

Green Infrastructure and Open
Environments SPG 2012
Social Infrastructure SPG 2015
Mayors Biodiversity Strategy 2002
London Biodiversity Action Plan
2001
London Infrastructure Plan 2050
update 2015

x
x
x
x

Brent Core Strategy 2010

Ealing Core Strategy 2012
Hammersmith and Fulham Core Strategy 2011
Kensington and Chelsea Consolidated Local
Plan 2015

PPPs Reviewed
Common theme
International/ National

Achieve more
effective
geoconservation
and improve soil
quality
Optimise the use of
land through
increasing the
density of
development

Page 322

x
x

Improve air quality

x
x

National Planning Policy for Waste 2014

EU Directive on Ambient Air Quality and

Management 96/62/EC
National Planning Policy Framework
2012
Sustainable Development Strategy 2005
UK Air Quality Strategy 2011

Regional / London

Londons Foundations Protecting

the Geodiversity of the Capital 2012
The Mayors Food Strategy 2008

The London Plan 2011, 2013, 2015

x
x

The London Plan 2011, 2013, 2015

Green Infrastructure and Open
Environments SPG 2012
Social Infrastructure SPG 2015
Mayors Air Quality Strategy 2010
The Control of Dust and Emissions
during Construction and Demolition
SPG 2014
London Plan Town Centres SPG
2014

x
x
x
x

The London Plan 2011, 2013, 2015

Green Infrastructure and Open
Environments SPG 2012
Social Infrastructure SPG 2015
The Mayors Ambient Noise
Strategy 2004
London Plan Town Centres SPG
2014

x
x
x
x

Brent Core Strategy 2010

Ealing Core Strategy 2012
Hammersmith and Fulham Core Strategy 2011
St Quintin and Woodlands Draft
Neighbourhood Plan 2015

The London Plan 2011, 2013, 2015

Green Infrastructure and Open
Environments SPG 2012

x
x
x

Brent Core Strategy 2010

Ealing Core Strategy 2012
Hammersmith and Fulham Core Strategy 2011

x
x
x
x

x
Minimise the
adverse impacts of
noise on people
living and
working in, and
visiting the area

x
x

European Directive: Environmental Noise

Directive 2002/49/EC
National Planning Policy Framework
2012
Noise Policy Statement for England 2010

West London/Local

x
x
x
x
x
x

Food Growing and Allotments Strategy for

Brent 2014/16
Hammersmith and Fulham Contaminated Land
Strategy 2001

Brent Core Strategy 2010

Ealing Core Strategy 2012
Hammersmith and Fulham Core Strategy 2011
Kensington and Chelsea Consolidated Local
Plan 2015

Social
Improve health and
well-being and
promote greater

x
x

Health for Growth 2014-2020

National Planning Policy Framework
2012

x
x

PPPs Reviewed
Common theme
International/ National
levels of physical
activity

x
x
x

Sustainable Development Strategy 2005

Health Lives, Healthy People 2011
National Planning Policy for Waste 2014

Regional / London
x
x
x
x
x
x
x
x
x

Page 323

Social Infrastructure SPG 2015

The Control of Dust and Emissions
during Construction and Demolition
SPG 2014
Draft Housing SPG 2015
Sustainable Design and
Construction SPG 2014
Play and Informal Recreation SPG
2012
The Mayors Food Strategy 2008
The London Health Inequalities
Strategy 2010
Improving Londoners Access to
Nature 2008
London Infrastructure Plan 2050
update 2015
London Plan Town Centres SPG
2014

West London/Local
x
x
x
x
x
x
x
x
x
x
x
x

x
x
To create an equal
society which
recognises peoples
different needs,
situations and
goals, and removes
the barriers that
limit what people
can do and be

Equality Act 2010

National Planning Policy Framework
2012

x
x
x
x
x
x
x
x
x

Maximise the
contribution that the
arts, culture and

x
x
x

The London Plan 2011, 2013, 2015

Sustainable Design and
Construction SPG 2014
Social Infrastructure SPG 2015
Play and Informal Recreation SPG
2012
The Mayors Food Strategy 2008
The London Health Inequalities
Strategy 2010
Planning for Equality and Diversity
in London SPG 2007
Improving Londoners Access to
Nature 2008
The Mayors Equality Framework
2009

x
x
x
x
x
x

The London Plan 2011, 2013, 2015

Play and Informal Recreation SPG
2012

x
x
x
x

Brent Parks Strategy 2010-2015

Food Growing and Allotments Strategy for
Brent 2014/16
Brent Draft Community Safety Strategy 201417
Brent Health and Wellbeing Strategy 2014-17
A Plan for Children and Families in Brent 20122015
Ealing Quality of Life for Older People 20062016
Ealing Green Space Strategy 2012-2017
Hammersmith and Fulham Health and
Wellbeing Strategy 2013-15
Hammersmith and Fulham Parks and Open
Spaces Strategy 2008-2018
Hammersmith and Fulham CSPAN Physical
Activity Strategy 2011
Ealing Sustainable Community Strategy 20062016
Kensington and Chelsea Consolidated Local
Plan 2015
Brent Core Strategy 2010
Ealing Core Strategy 2012
Hammersmith and Fulham Core Strategy 2011
Brent Equality Strategy 2015-19
A Regeneration Strategy for Brent 2010-2030
A Plan for Children and Families in Brent 20122015
Ealing Quality of Life for Older People 20062016
Old Oak and Park Royal draft Opportunity Area
Planning Framework 2015
Ealing Sustainable Community Strategy 20062016
St Quintin and Woodlands Draft
Neighbourhood Plan 2015
Food Growing and Allotments Strategy for
Brent 2014/16
Cultural Strategy for Brent 2010-15
4

PPPs Reviewed
Common theme
International/ National

Regional / London
x
x
x
x

heritage can make

to the community

x
x

Social Infrastructure SPG 2015

The Mayors Food Strategy 2008
The Mayors Culture Strategy 2014
Shaping Neighbourhoods:
Character and Context 2014
London Plan Town Centres SPG
2014

West London/Local
x
x
x
x
x
x

Page 324

The need to ensure

that new housing
development meets
local needs (for all
sections of society)

x
x

x
x
x
National Planning Policy Framework
2012
Planning Policy for Traveller Sites 2015
x

x
x
x

The London Plan 2011, 2013, 2015

Draft Housing SPG 2015
Sustainable Design and
Construction SPG 2014
London Infrastructure Plan 2050
update 2015
London Plan Town Centres SPG
2014
x

x
x
x
x
x
x
x
x
x
x

Promote more
sustainable
transport choices
and to improve
accessibility

x
x
x

National Planning Policy Framework

2012
Sustainable Development Strategy 2005

x
x
x
x
x
x
x

The London Plan 2011, 2013, 2015

Land for Industry and Transport
SPG 2012
Mayors Transport Strategy 2010
London Infrastructure Plan 2050
update 2015
London Plan Town Centres SPG
2014

x
x
x
x
x
x
x

Ealing Arts and Cultural Strategy 2013-2018

Old Oak and Park Royal draft Opportunity Area
Planning Framework 2015
Ealing Sustainable Community Strategy 20062016
Kensington and Chelsea Consolidated Local
Plan 2015
Kensington and Chelsea Issues and Options
Paper for Kensal Gasworks 2012
St Quintin and Woodlands Draft
Neighbourhood Plan 2015
Brent Core Strategy 2010
Ealing Core Strategy 2012
Hammersmith and Fulham Core Strategy 2011
Ealing Quality of Life for Older People 20062016
Hammersmith and Fulham Housing Strategy
2015
Old Oak and Park Royal draft Opportunity Area
Planning Framework 2015
Ealing Sustainable Community Strategy 20062016
Kensington and Chelsea Consolidated Local
Plan 2015
Kensington and Chelsea Issues and Options
Paper for Kensal Gasworks 2012
St Quintin and Woodlands Draft
Neighbourhood Plan 2015
West London Sub Regional Transport Plan
2010
Brent Core Strategy 2010
Ealing Core Strategy 2012
Hammersmith and Fulham Core Strategy 2011
Old Oak and Park Royal draft Opportunity Area
Planning Framework 2015
Park Royal Southern Gateway Position
Statement 2008
Kensington and Chelsea Consolidated Local
Plan 2015
Kensington and Chelsea Issues and Options
5

PPPs Reviewed
Common theme
International/ National

Regional / London

West London/Local
x

x
Recognise the
importance of open
spaces, sport and
recreation and the
contribution that
they make to
enhancing quality of
life

National Planning Policy Framework

2012

x
x
x
x
x
x
x

The London Plan 2011, 2013, 2015

Green Infrastructure and Open
Environments SPG 2012
Social Infrastructure SPG 2015
Play and Informal Recreation SPG
2012
The Mayors Food Strategy 2008
Improving Londoners Access to
Nature 2008
London Infrastructure Plan 2050
update 2015

x
x
x
x
x
x
x
x
x

Page 325

Improve educational
attainment and
training
opportunities

x
x
x
x
x

Reduce crime and

fear of crime

Policy statement: Planning for schools

development 2011
National Planning Policy Framework
2012
National Planning Policy Framework
2012

x
x
x

x
x
x
x

The London Plan 2011, 2013, 2015

Social Infrastructure SPG 2015
London Infrastructure Plan 2050
update 2015

The London Plan 2011, 2013, 2015

Sustainable Design and
Construction SPG 2014
Social Infrastructure SPG 2015
Play and Informal Recreation SPG
2012

x
x
x
x
x
x
x
x
x

Paper for Kensal Gasworks 2012

St Quintin and Woodlands Draft
Neighbourhood Plan 2015
Brent Core Strategy 2010
Ealing Core Strategy 2012
Hammersmith and Fulham Core Strategy 2011
Brent Parks Strategy 2010-2015
Food Growing and Allotments Strategy for
Brent 2014/16
Ealing Green Space Strategy 2012-2017
Hammersmith and Fulham Parks and Open
Spaces Strategy 2008-2018
Old Oak and Park Royal draft Opportunity Area
Planning Framework 2015
St Quintin and Woodlands Draft
Neighbourhood Plan 2015
Brent Core Strategy 2010
Ealing Core Strategy 2012
Hammersmith and Fulham Core Strategy 2011
Ealing Sustainable Community Strategy 20062016
Brent Core Strategy 2010
Ealing Core Strategy 2012
Hammersmith and Fulham Core Strategy 2011
Brent Draft Community Safety Strategy 201417
Ealing Sustainable Community Strategy 20062016

Economic

PPPs Reviewed
Common theme
International/ National
x
x
Promote
sustainable
economic
development and a
range of
employment
opportunities

National Planning Policy Framework

2012
Sustainable Development Strategy 2005

Regional / London
x
x
x
x
x

The London Plan 2011, 2013, 2015

Land for Industry and Transport
SPG 2012
The Mayors Economic
Development Strategy 2010
London Infrastructure Plan 2050
update 2015
London Infrastructure Plan 2050
update 2015

West London/Local
x
x
x
x
x
x
x
x
x

Brent Core Strategy 2010

Ealing Core Strategy 2012
Hammersmith and Fulham Core Strategy 2011
A Regeneration Strategy for Brent 2010-2030
Old Oak and Park Royal draft Opportunity Area
Planning Framework 2015
Ealing Sustainable Community Strategy 20062016
Park Royal Southern Gateway Position
Statement 2008
Kensington and Chelsea Consolidated Local
Plan 2015
Kensington and Chelsea Issues and Options
Paper for Kensal Gasworks 2012

Page 326
7

Figure B-1 Hammersmith and Fulham Core Strategy 2011: Key Diagram

Page 327

Figure B-2 Ealing Core Strategy 2012: Key Diagram

Page 328
9

Figure B-3 Brent Core Strategy 2010: Key Diagram

Page 329
10

Figure B-4 Kensington and Chelsea Consolidated Local Plan 2015: Key Diagram

Page 330

11

APPENDIX C
Baseline Data

Page 331

12

C. The Sustainability Baseline and Key Sustainability

Issues
C.1 Population
The following baseline indicators have been used to identify key population trends and characteristics:
1

Total population (2011 Census and Neighbourhood Statistics ).

Area of Ealing, Brent and Hammersmith & Fulham (Office for National Statistics Local Profiles).

Population density (Office for National Statistics Local Profiles).

Age structure of the population (Office for National Statistics Local Profiles and 2011 Census).

Mean household size (Office for National Statistics Local Profiles).

Ethnic groups represented in the population (Office for National Statistics Local Profiles).

Faith communities represented in the population (OAPF Draft IIA Report, GLA, February 2015)

Gender balance and pay gap (OAPF Draft IIA Report, GLA, February 2015)

C.1.1

OPDC Area

The population of OPDC is just under 5,000 people contained in 1,898 households. Figure C1-1 indicates
the population density of the area.

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13

Figure C1-1

Comparative Population Density

Source: OAPF Draft IIA Report, GLA, February 2015

The OPDC area covers some 650 hectares and due to its predominantly industrial nature has a much
lower population density than its adjoining boroughs. Given the proposed minimum new homes of 25,500
this density is set to change. This influx of future population needs careful management to ensure
inequalities dont worsen throughout the area and adjoining boroughs.
Figure C1-2
Age profile

Source: Census 2011

As shown in Figure C1-2, the OPDC area contains a large proportion of working age adults and a smaller
population of ages 65+ than the surrounding boroughs. Careful consideration should be given to the wider

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14

population trend of an ageing population as well ensuring an attractive area for young adults and those
who may be looking to raise a family.
Figure C1-3

Components of population change

Components of population change

mid-2011 to mid-2012

Brent
Hammersmith and Fulham
Ealing
London

Live births
Thousands
5.3
2.7
5.7
134.0

Deaths
Thousands
1.6
0.9
1.9
47.6

Natural
change
Thousands
3.8
1.8
3.8
86.5

Net migration
& other
changes
Total change
Thousands
Thousands
-1.3
2.4
-4.4
-2.6
-2.5
1.4
17.5
104.0 Source:

ONS Local Profiles

Although there is a net loss of population from Brent, Ealing and Hammersmith & Fulham, there is a
continued influx of people into London and this needs to be addressed as part of the areas redevelopment
proposals.
The population of OPDC is ethnically diverse. Data indicates that 21.6% of the population were White British,
with 18.6% identifying themselves as White Other (Table C1-4). Black African or Black Others are the main
ethnic minority within OPDC, representing 24% of the population
.
Table C1-4 Percentage of population by ethnic group

Source: Census 2011

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15

The largest religious community in the OPDC area is Christian at 48.7%, which is higher than the London
average of 48.4%, but lower than the English average of 59.4%. This is followed by Muslim at 21.7%,
compared to a London average of 12.4% and an English average of 5%. Within the plan area, 14.6%
stated no religion, which is lower than the London average of 20.7% and English average of 24.7%. Other
minorities include Hindu (3.9%), Buddhist (1.4%), Sikh (1.2%), other religion (0.8%) and Jewish (0.3%).
Table C1-5 Percentage of population by religion

Source: Census 2011

A study on the gender pay gap by the Government Equalities Office showed that 10% of the overall pay
gap can be attributed to occupational sex segregation. A 10% greater share of men in an occupation is
associated with 2 per cent higher average hourly wages. 12% of the gap is due to the industries in which
men and women work, 21% is due to difference in years of experience of full-time work, 16% is due to
negative effect on wages of having previously worked part time or having taken time out of the labour
market to loof after family. 36% of the pay gap cannot be explained by any of the characteristics that have
been controlled for in the study.
Table C1-6 Percentage of population by gender

Source: Census 2011

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16

Table C1-7 Marital Status

Source: Census 2011

C.1.3

Data Gaps and Uncertainties

Future population makeup for OPDC area

Proportion of the population that is transgender/has undergone gender reassignment

Sexual Orientation of the population

Data on pregnancy and maternity in relation to the local population and employment

C.2

Education and Qualifications

The following baseline indicators have been used to characterise levels of education and attainment:

Percentage of people aged 19 50/64 who have attained a Level Four NVQ or higher (Office for
National Statistics Local Profiles).

Percentage of the population aged 16-74 with no qualifications (Office for National Statistics Local
Profiles).

Education, Skills and Training Deprivation (Indices of Deprivation for England 2010).

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C.2.1

OPDC Area

The areas level of skills and educational deprivation is average though there is great disparity between the
adjoining boroughs. The low population density also creates uncertainty in the identification of trends.
The percentage of people with no qualifications in 2011 was 16%. The percentage of people with NVQ Level
4 qualification or above was 36.5% compared with 44.7% for Inner London and 27.4% for England.
Table C2-1 Percentage of the population and level of qualification achieved

Source: Census 2011

Figure C2-1 Education, Skills and Training Deprivation in OPDC

Source: Indices of Deprivation 2010 for England

Brent in particular has a higher percentage of at least one member of staff who isnt fully proficient at their
job when compared to London and therefore the Local Plan should seek to include job skills training
opportunities and further education facilities.

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Figure C2-2 Education facilities adjoining OPDC Area

Source: OAPF Draft IIA Report, GLA, February 2015

As can be seen from Figure C2-2 there is a gap in education facilities within the area. The Local Plan and
future development needs to ensure adequate provision for the new residents and existing alike.

C.2.2

Data Gaps and Uncertainties

Accessibility to secondary school education.

Number and location of establishments offering life-long learning opportunities.

C.3

Health

The following baseline data has been used to identify key trends:

Census 2011 health status data

Census 2011 life expectancy

Children living in poverty

Childhood obesity rates

Health Deprivation and Disability (Indices of Deprivation for England 2010)

Provision of GPs and Healthcare

It is noted that a number of the other topics within this baseline will also have an influence on health levels,
including data on: population, education, air quality, noise, crime, employment, deprivation and living
environment, housing, biodiversity and open space (landscape and townscape).

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19

C.3.1

OPDC Area

The health of people in the OPDC area is relatively good 51.6% state they are in Very Good Health (see
Figure C3-1). Deprivation is higher than average and 37.5% of children were living in poverty in 2010. Life
expectancy for males in is 76.2% years, which was lower than the average for London. The average life
expectancy for females was 83.6 years which is higher than the London average (82.8%). 8.6% of births
between 2008 and 2012 were low birth weight births, which compares with a 7.4% nationally.
During the period 2010/11 and 2012/13, 11.8% of children at reception year were considered obese, with an
additional 23.6% carrying excess weight. A further 23.6% of children in year 6 were identified as obese, with
the same figure for London recorded at 22.5%.
Table C3-1 Census 2011 Health

The OPDC area includes at least one LSOA in the bottom 20% for health deprivation and disability; see
Figure C3-1 below.

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Figure C3-1 Health Deprivation and Disability in OPDC

Source: Indices of Deprivation 2010 for England

Due to its industrial nature and history, there is a lack of primary care facilities within the OPDC boundaries,
with the exception of Central Middlesex Hospital, as seen from Figure C3-2.
Figure C3-2 Provision of GPs and Healthcare in OPDC

Source: OAPF Draft IIA Report, GLA, February 2015

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C.3.5

Data Gaps and Uncertainties

Proportion of population in area with access to hospital / GP / Dentist

How children travel to school

Play and open space quality, quantity and accessibility

Further detailed information on disability and accessibility throughout the OPDC area and its buildings

C.4

Crime

The following baseline data has been identified:

Crime rates (Indices of Deprivation).

Car theft

Violence against persons (rank)

Total Crime (rank)

C.4.1

OPDC Area

Crime in and around the OPDC area is predominantly violent crime or anti-social behaviour offences. The
area is one of the more deprived areas of the country in terms of crime.
Figure C4-1 Crime Deprivation in OPDC

Source: Indices of Deprivation 2014

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Figure C4-2 Car Theft

Source: OAPF Draft IIA Report, GLA, February 2015

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23

Car theft is average or above average in the centre of the OPDC (see Figure C4-2). Violence against
persons is alo high or above average in the majority of the OPDC area. Given the industrial nature of the
site, the Local Plan should seek to ensure that the design new development improves the safety and
perceived safety of the community and their property.
Figure C4-3 Violence against Persons

Source: OAPF Draft IIA Report, GLA, February 2015

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24

Figure C4-4 Total Crime Rank

Source: OAPF Draft IIA Report, GLA, February 2015

C.4.2

Data Gaps and Uncertainties

Percentage of people who feel safe in the place where they live

Percentage of people who feel safe travelling on public transport at night

How to best incorporate influx of population

C.5

Water

The following baseline indicators have been used to characterise the water environment within in the OPDC
area:

River catchment areas (Environment Agency Thames Catchment Flood Management Plan, 2009)

Distribution of areas at risk of fluvial flooding (Environment Agency Fluvial Flood Map)

Areas susceptible to surface water flooding (Environment Agency Surface Water Flood Map)

Water and groundwater quality (Environment Agency).

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C.5.1

OPDC Area

Water is an essential resource required for both domestic and industrial use. The study areas western
boundary follows the lie of the River Brent and the Grand Union Canal runs from west to east of the area.
The main source of flood risk to the area lies fluvial flood risk at its western edge and from surface water
puddling along the road network of area (Figures C5-1 and C5-2). There is particular risk around Old Oak
Common station and the area immediately to the north of Central Middlesex Hospital in Park Royal. Fluvial
flooding is associated with the River Brent. There are small areas of Flood Zone 2 and 3 in the north-western
corner of the area.
Figure C5-1 Fluvial Flood Risk

Source: Environment Agency Flood Map

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Figure C5-2

Surface Water Flood Risk in OPDC

Source: Environment Agency Flood Map

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27

Each Londoner on average consumed 161 litres of water per day compared to the England and Wales
average of 149 litres per day. In the past 20 years, Thames Water has seen a 15% increase in water usage
throughout London. This is equivalent to an increase of 10 litres per person per decade.
Both River Brent and Grand Union Canal are currently characterised as having poor water quality for their
chemical and biological makeup. The Thames RBMP Actions for the Lower Brent indicate a desire to provide
fish easement for three weirs between Brent Junction and Queensbury Road. Development with within the
OPDC area could contribute to an improvement in the watercourses water quality overall.

C.5.2

Data Gaps and Uncertainties

Further objectives could be identified from adjoining Boroughs Surface Water Management Plan

Thames Water have indicated that Counters Creek is at capacity for any new influx into the combined
sewer system but formal assessment has not been identified.

C.6

Soil and Land Quality

The following baseline indicators have been used to characterise the soil and land quality conditions across
the borough and within the four London boroughs:

Amount (hectares) of previously developed land available (Office for National Statistics Local Profiles).

Number of active / historic landfills on the site (Environment Agency)

C.6.1

OPDC Area

The 2010 ONS Local Profile in Table C6-1 highlights the amount of previously developed land available in
the three boroughs that make up the Old Oak and Park Royal Development Corporation. This reflects the
high density urban environment of the borough.
Table C6-1

Previously Developed Land

Ealing
Hammersmith and Fulham
Brent
London

Vacant land
Hectares
0

Vacant
buildings
Hectares
0

0
0
640

10
20
330

Land Land that is

currently in
unused or
use with
may be
Derelict land
known available for
and redevelopme redevelopme
buildings nt potential
nt
Hectares
Hectares
Hectares
0
0
140
0
30
270

0
10
340

100
150
3,660

Source: ONS Local Profiles

According to the Environment Agency website there is one historic landfill within the area boundary (Twyford
Service Station). The last waste received at this site was in 1968. However there are other sites, particularly
within Old Oak which will need to be relocated and the waste apportionment dealt with due the proposed
change in land use of the area.

C.6.2

Data Gaps and Uncertainties

Area of contaminated land returned to beneficial use

Type of contaminants within the OPDC area

Extent of current and historic waste sites and waste transfer sites

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C.7

Air Quality

The following baseline indicators have been used to identify environmental conditions and key trends:
2

Number and distribution of Air Quality Management Areas (AQMAs) (Air Quality Archive )

Monitoring data for NO2 and PM10

C.7.1

OPDC Area

The principal threat to clean air in London comes from road traffic. Poor air quality can damage peoples
health and quality of life. It can pose particular problems for vulnerable groups such as the elderly, young
children and people suffering from respiratory diseases.
AQMAs are designated when local authorities have identified locations where national air quality objectives
are unlikely to be achieved. The whole of the OPDC area is considered to be within an AQMA for levels of
NO2 and PM10. Each of the three boroughs have identified the same exceedances and types of pollutants.
There are three monitoring sites though only two are within the OPDC boundary itself as shown in Figure
C7-1. Hanger Lane Gyratory (Ealing) Air Quality monitoring Station in operation since 2003 and Western
Avenue Air Quality Monitoring Station in operation since 2010 are roadside stations located at the southern
boundary of the OA and are operated to LAQN standards. The highest recorded annual mean (see Figure
C7-3) (1st January 2014 1st January 2015) of Nitrogen Dioxide (NO2) concentration was measured at
Hanger Lane Gyratory (67.6JP) followed by Western Avenue at 64.367.6JP both exceeding the objective
mean of 40JP. There are areas of high NO2 concentrations in the OPDC area, particularly along the
strategic highway network.
Figure C7-1
AQMA in the OPDC

Source: Defra

http://uk-air.defra.gov.uk/aqma/maps

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Figure C7-2

AQMA Objectives

Source: Defra

Figure C7-3

Air Quality Monitoring data 1st January 2014-1st January 2015

Source: OAPF Draft IIA Report, GLA, February 2015

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30

C.7.2

Data Gaps and Uncertainties

Extent to which new development should adhere to the Mayors Air Quality Neutral benchmark.

How existing business can reduce reliance on road freight traffic with introduction of rail improvements

C.8

Energy and Climate Change

The following baseline indicators have been used:

Annual average domestic gas and electricity consumption per meter (Office for National Statistics
Local Profiles).

All energy consumption by sector (Office for National Statistics Local Profiles and DECC).

C.8.1

OPDC Area

Although climate change is a global phenomenon, action to avoid its most serious effects and to minimise
the emission of greenhouse gases needs to occur at a local level. The area will not be immune to the
impacts of climate change, either directly or as a result of policy responses at the national and international
levels.
Table C8-1
Average consumption of ordinary domestic electricity

Source: ONS Local Profiles

The three boroughs perform similarly when compared to London and each other for average consumption
domestic electricity. The scale of development should seek to encourage as energy efficient development as
possible, as well as consider the positive benefit of a site-wide decentralised energy network.
Table C8-2

Energy Consumption by Sector

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31

Energy consumption by sector

2011

Ealing
Hammersmith and Fulham
Brent
London

Total
gWh
5,127
3,198
4,037
134,347

Industry and
commercial
gWh
1,746
1,386
1,199
50,341

Domestic
gWh
2,249
1,227
2,044
55,547

Transport
gWh
1,132
586
794
28,178

Source: ONS Local Profiles

The Planning and Energy Act 2008 allows local authorities to include policies in their local plans setting out
reasonable requirements for:

A proportion of energy used in development in their area to be energy from renewable sources

A proportion of energy used in development in their area to be low carbon energy from sources in the
locality of the development

The above policies should be carefully considered and balanced in the Local Plan with the need to ensure
that the environment of the borough is not adversely affected.

C.8.2

Data Gaps and Uncertainties

Area specific energy data

Greenhouse gas emissions data

Levels of energy efficiency in homes and commercial buildings

Energy consumption in industrial units within Park Royal and Old Oak

C.9

Biodiversity, Flora and Fauna

The following baseline indicators have been used to characterise conditions across the four boroughs and
within the LLDC area boundary:

Number and distribution of designated sites including SAC, SPA, Ramsar sites, SSSI, National Nature
Reserves (NNR), Local Nature Reserves (LNR) and Local Wildlife Sites (LWS) (MAGIC,
www.magic.gov.uk and Local Authority websites).

Key Biodiversity Action Plan (BAP) species and habitats present (London BAP).

C.9.1

OPDC Area

London is a surprisingly green city and approximately 48% is surfaced in vegetation, rivers and still waters.
London supports thousands of species, from algae and fungi to molluscs and mammals
Within the OPDC area there are no SACs, SPAs, Ramsar sites, SSSIs or NNRs. There is one LNR:
Wormwood Scrubs. The Grand Union Canal and adjacent area in Old Oak South is a nature conservation
area of Metropolitan Importance. Other designated sites in proximity to the plan area are listed in Table C91.

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32

Table C9-1 Closest statutory sites of international, national and local nature importance
Site Name

Designation

Approximate direction and distance from the

OPDC area

Wormwood Scrubs

LNR

Within OPDC boundary

Fox Wood

LNR

675 metres, southwest

Westbere Copse

LNR

3.4km, northeast

Barn Elms Wetland Centre SSSI

4.4km, south

Richmond Park

SAC

6.9km, south

Wimbledon Common

SAC

8km, south

Wormwood Scrubs Local Nature Reserves habitat and species should be protected and enhanced.
Figure C9-1
Designated Sites

Source: Magic.gov.uk, 4 August 2015

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33

Figure C9-2 International Designations

Source: Magic.gov.uk, 4 August 2015

The area presents an opportunity to create and protect other sites within the boundary as well as promote
green habitat connectivity to areas outside the boundary.
The UK government published Biodiversity: The UK Action Plan in 1994. This plan combined new and
existing conservation initiatives with an emphasis on a partnership approach. It contains 59 objectives for
conserving and enhancing species and habitats as well as promoting public awareness and contributing to
international conservation efforts. Following on from the initial strategy publication, 391 Species Action Plans
(SAPs) and 45 Habitat Action Plans (HAPs) were published for the UK's most threatened (i.e. "priority")
species and habitats. In additional there are approximately 150 Local Biodiversity Action Plans, normally at
county level. These plans usually include actions to address the needs of the UK priority habitats and
species in the local area, together with a range of other plans for habitats and species that are of local
3
importance or interest (Biodiversity Action Reporting System ).
The London BAP is made up of many individual species and habitat plans. Each plan gives information on
the status and threats to the species or habitat. London BAP species and habitats include the following:
Habitat Action Plans

Acid grassland
http://www.ukbap-reporting.org.uk/

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34

Chalk grassland

Heathland

Parks and urban greenspaces

Private gardens

Reedbeds

Rivers and streams

Standing water

Tidal Thames

Wasteland

Woodland

Species Action Plans

Bats

Black poplar

House sparrow

Mistletoe

Reptiles

Sand martin

Stag beetle

Water vole

Source: London BAP 4

C.9.2

Data Gaps and Uncertainties

No records of other priority habitats and species within the boundary area

Data relating to biodiversity on brownfield land/railway sidings in particular

Data relating to the connectivity of greenspaces and the mapping of any greenspaces (nondesignated) across the area

C.10

Cultural Heritage

The following baseline indicators have been used to characterise the heritage baseline:

Number and distribution of Listed Buildings, Scheduled Ancient Monuments (SAMs), Conservation
5
Areas and Registered Historic Parks and Gardens .

Historic England Heritage Assessment of Old Oak

http://www.lbp.org.uk/londonpriority.html

www.magic.gov.uk

http://research.historicengland.org.uk/redirect.aspx?id=6294

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C.10.1

OPDC Area

There is one listed asset within the OPDC area Brent Viaduct.
There are no SAMs within the area.
Within the boundary there are 2 Conservation Areas, these include:

Old Oak Lane; and

along Grand Union Canal.

Adjacent to the study area are the St. Marys Conservation Area in Hammersmith and Fulham, which
includes the St Marys Cemetery and parts of the Kensal Green Cemetery. The Kensal Green Cemetery
Conservation Area in The Royal Borough of Kensington and Chelsea incudes the majority of the listed
buildings and monuments and the majority of the Registered Park and Garden (Grade I registered Park and
Garden of special historic interest which contains the Grade I listed Anglican Chapel, twelve Grade II* listed
buildings or monuments and 147 Grade II listed buildings or monuments).
Within the surrounding area, the following conservation areas may also be affected by development within
the OPDC area:

Harlseden;

Old Oak and Wormholt;

Hangerhill Garden Estate; and

Hagerhill (Hay Mills) Estate.

Prior to the mid-nineteenth century, Old Oak Common area was common-ground and farmland sitting beside
the Grand Junction Canal (now the Grand Union Canal) from its development in 1794. With the arrival of the
railways in 1838 and their expansion into the twentieth century, industry shortly followed along the railways
and the canal making use of these connections. By the late nineteenth century, Old Oak Common had been
transformed into an industrial area home to heavy industries and works supporting the railways.
Following the First World War, the increase in motorised transport saw the arrival of motor car production
with Park Ward manufacturing Rolls Royce vehicles at its site on Hythe Road. In the latter half of the
twentieth century, redevelopment of some of the Victorian industrial buildings for lighter industry and office
floorspace was carried out reflecting the restructuring of the national economy.
To the west in Park Royal, the area generally known as Twyford was farmland until the Royal Agricultural
Show took place from 1903 to 1905 (which provides the areas name). Following 1905, the industrial
character began to emerge with the area used as a munitions factory during the First World War alongside
manufacturing and food production. By 1932 there were 73 factories employing 13,500 workers which grew
to over 45,000 in the 1960s following relatively light bomb damage in the Second World War and the postwar boom period. Through the latter part of the twentieth century, industrial restructuring saw the relocation
of large multinational firms, such as Heinz, away from Park Royal.
Other notable listed buildings whose setting could be affected by development in the Opportunity Area
include the Grade II* listed gatehouse and chapel at Wormwood Scrubs Prison, the Church of All Souls
Harlesden (also Grade II*), and thirteen Grade II listed buildings within 250m of the boundary. Further afield
are Statutory Listed buildings, the closest being Kenmont Primary School and Park Royal Underground
Station.

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36

The Old Oak Common and Park Royal areas have a disparate assortment of railway and industrial heritage
that play a valuable role in informing the evolving character of the area. Specific collections of nondesignated heritage assets are located along the east of Scrubs Lane, the interwar Rolls Royce works and
Acava Studios on Hythe Road. The OPDC would be seeking to designate and manage new Conservation
Areas and a Local List.
A significant number of the heritage assets listed above are on English Heritages Heritage at Risk Register.
These include Kensal Green Cemetery, as well as 35 monuments within it, including the Anglican Chapel.
Twyford Abbey to the west of the opportunity area is also a long standing Heritage at Risk case.
Whilst there are at present no archaeological priority areas within the proposed local plan area, the Greater
London Historic Environment Record holds information on several archaeological investigations, sites and
finds. Notably the site of Acton Wells 18th century spa is located within the Opportunity Area. The open
ground of Wormwood Scrubs was the site of a rifle range and anti-aircraft battery and may preserve as yet
undiscovered earlier remains. The Grand Junction Canal and Old Oak Common area include aspects of
railway and industrial archaeological interest. The 19th century Park Royal cemetery would also be of
interest if subject to redevelopment.

C.10.2

Data Gaps and Uncertainties

Planning permissions adversely affecting known or potential designated assets (historic buildings,
archaeological sites etc.)

Boroughs Local Lists of Heritage Assets

The following baseline indicators have been used to characterise the landscape and townscape baseline:

Designated sites

Land uses on the study area

Conservation Areas

Open Space

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37

Figure C10-1Sites of Cultural and Archaeological Importance

Page 357
Source: Old Oak & Park Royal Opportunity Area Planning Framework (2015)
38

C.11.1

OPDC Area

There are no Areas of Outstanding Natural Beauty (AONBs) within OPDC.

The OPDC area comprises a largely industrial townscape with its edges influenced by more residential
spaces. Railway infrastructure is a dominant feature across the site.
Figure C11-1 Land Uses in the Study Area

Source: OAPF Draft IIA Report, GLA, February 2015

The study area lies between two catchment areas River Brent and the lost river of Counters Creek (now a
combined sewer). Park Royal is predominantly warehousing and industrial units with Central Middlesex
Hospital in the centre of it.
Old Oak is industrial units with the Cargiant site a dominant feature. At present a Crossrail depot is also
being built there.
There is a Conservation Area along Old Oak Lane and along Grand Union Canal. The old Rolls Royce
factory forms part of Old Oak.
Along the south-eastern boundary lies Wormwood Scrubs Park which is grassland and some woodland. The
eastern boundary is Kensal Green Cemetery. While there are substantial areas of green space on the
periphery of the plan area, the industrial nature of the area means that most parts have a severe open space
deficiency. Integration with the All London Green Grid Area Frameworks is an important consideration.

C.11.2

Data Gaps and Uncertainties

Number of noise and light pollution complaints

Percentage of new housing completions in area achieving design standards such as Building for Life
and Lifetime Homes

C.12

Waste

The following baseline indicators have been used to characterise the existing conditions:

Percentage of household waste sent for reuse, recycling or composting (ONS Local Profiles).

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39

Amount of residual waste per household (ONS).

Amount of commercial and industrial waste produced (Defra).

C.12.1

OPDC Area

There are no area-specific statistics for the study area.

Recycling rates are higher for Ealing compared to Brent, Hammersmith & Fulham and London as a whole
though they have increased between 2010 and 2012 (Table C12-1).
Table C12-1 Household Waste Sent for Reuse, Recycling or Composting

There is currently no data available on the municipal waste sent to landfill in the area.
There are several waste sites within the area:

European Metal Recycling

Powerday

Capital Waste Ltd

UK Tyre Exporters

ODonovans Waste Disposal Ltd.

C.12.2

Data Gaps and Uncertainties

Percentage of municipal waste sent to landfill in study area.

Waste facilities available in each borough and how to deal with apportionment

C.13

Transportation

The following baseline indicators have been used to characterise the existing conditions across the borough:

Distribution of major transport systems roads, rail links

Draft Old Oak and Park Royal Opportunity Area Planning Framework, Transport Strategy, February
2015

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40

C.13.1

OPDC Area

The Transport Strategy made a number of high level assumptions and modelled the impacts of areas
proposals. It didnt take into account the transport impacts resulting from the relocation of existing activities.
Further work is being explored to consider these elements. There is also a number of transport proposals
identified which are contingent on land coming available which is likely to be beyond the 2031 timescales.
The new Old Oak Common station and surrounding interchange will be the key driver for development in the
area and will be the focus of future transport connections. HS2 will provide 18 trains per hour between Old
Oak and the North, with Birmingham Airport just 31 minutes from Old Oak. The new Crossrail station at Old
Oak will provide up to 24 trains per hour into central London, as well as services towards Heathrow and
Reading. The presence of a Crossrail station will be one of the most important transport connections to the
site, providing a significant increase in rail capacity to the West End, City and Canary Wharf. Crossrail will
provide excellent regional and sub-regional connectivity to Old Oak.
Figure C13-1 Transport Infrastructure at Old Oak

Source: OAPF Transport Strategy, GLA, February 2015

The study didnt consider the impacts of the number of homes being proposed nor the number of jobs. As
such this needs careful consideration in the Local Plan.
Old Oak and Park Royal generate a significant number of road freight movements. The current road network
is shown in Figure C13-2. Park Royal is home to Londons largest industrial area and has significant
wholesale, transport and warehouse activity. Any new proposals must consider the existing road users and
capacity requirements, along with ensuring improvements in non-road transport, such as rail and by foot or
cycle.

Figure C13-2 Road Network

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41

Source: OAPF Draft IIA Report, GLA, February 2015

The Grand Union Canal presents a great opportunity for both water travel and freight movements as well as
footpaths and should be considered a strategic transport link within the area.
Noise is defined as unwanted sound. Sensitive receptors to noise include residential areas, educational
facilities, health care facilities and places of worship. Road and rail noise are significant contributors to the
ambient noise environment, particularly around the town centre and main distributor roads. Department for
Environment, Food and Rural Affairs (Defra) Online road, rail and industrial noise mapping shows the extent
to which these noise sources may affect sensitive receptors. Built up areas shield unwanted sound and
cause the effect to decrease over a short distance. Open areas such as parks allow the noise to travel over a
longer distance and disturb users of such spaces.

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Figure C13-3 Road Traffic Noise average daytime

Source: www.services.defra.gov.uk/wps/portal/noise in OAPF Draft IIA Report, GLA, February 2015

Figure C13-4 Rail Noise average daytime

Source: www.services.defra.gov.uk/wps/portal/noise in OAPF Draft IIA Report, GLA, February 2015

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43

C.13.2

Data Gaps and Uncertainties

Impacts on proposed quantum of development on existing businesses and residents in terms of

access by road and rail

C.14

Economy

The following baseline indicators have been used to characterise economic conditions across the borough:

Economy Local Profiles (ONS)

Employment by industry (ONS- NOMIS).

C.14.1

OPDC Area

Smaller businesses, independent traders and entrepreneurs tend to dominate the study area. The image of
Park Royal and Old Oak developments range from larger freight and wholesale businesses through to
microbusinesses that survive because the area offers a place for their industry not available elsewhere in
London coupled with inexpensive rents. On one hand while this can contribute to an entrepreneurial spirit, on
the other it can translate into a weakness from an economic standpoint.
This is contributing towards pressure for redevelopment and regeneration. Redevelopment would help
alleviate housing shortages in London but careful consideration needs to be given to how any new provision
of retail will impact on other neighbouring town centres such as Ealing. Similarly, redevelopment of the area
is likely to give rise to local pressures from existing businesses who are likely to be unwilling to relocate.
In 2010, 18.6% of the adult population were long-term unemployed (claiming job seekers allowance for over
1 year). This figure is above the national average of 10.1% and the London-wide figure of 11.5%.
A higher than average proportion of the areas population are classified in sales and customer service
occupations, process plant occupations, elementary occupations and skilled trades compared to London as
a whole. Professional occupations and associate professional and technical occupations however are lower
than Londons average but higher than regional and national averages. This data is presented in Table C141.
Table C14-1 Employment by Occupation Jul 2011-Jun 2012

Source: OAPF Draft IIA Report, GLA, February 2015

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44

Table C14-2 Local Industry Units by Broad Industry Group

Source: OAPF Draft IIA Report, GLA, February 2015

Table C14-2 shows the employment by industry in the study area and surrounding boroughs. Theres a
higher than the London average of manufacturing, construction, wholesale and accommodation & food
services within the Park Royal and Old Oak study area.
These more intensive industries need to be accommodated in terms of the proposed redevelopment whilst
also allowing new industries to flourish especially by providing space for green technologies.
The area ranks among the most deprived in terms of its employment deprivation as can be seen from Figure
C14-1.

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45

Figure C14-1 Local Industry Units by Broad Industry Group

Source: OAPF Draft IIA Report, GLA, February 2015

As such, consideration needs to be made to as how this can be addressed within the Local Plan whilst also
considering how this redevelopment, its economic potential and new population increase will sit within the
wider borough and London context.

B.14.2

Data Gaps and Uncertainties

Planning consents for employment uses and take up of employment floorspace

Noise impacts from commercial uses

Commercial / retail rental data

No. / % of people working from home

B.15

Deprivation and Living Environment

The following baseline data has been identified:

Number of wards with LSOAs in the bottom 20% most deprived (Indices of Deprivation for England
2010).

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46

B.15.1

OPDC Area

The Indices of Deprivation 2010 were published by Communities and Local Government in March 2011. The
purpose of the Indices is to identify small areas of England which are experiencing multiple aspects of
deprivation. It replaces the Indices of Deprivation 2007 as the official measure of deprivation in England.
Deprivation is a multi-faceted and complex problem which influences and is influenced by a wide range of
factors. The ID2010 contains seven domains which relate to income deprivation, employment deprivation,
health deprivation and disability, education skills and training deprivation, barriers to housing and services,
living environment deprivation, and crime.
The average Indices of Multiple Deprivation (IMD) score measure reflects the average level of deprivation
across LSOAs in the borough. In 2010, the study areas average IMD score ranks it has being in the most
deprived LSOAs within London.
However, its difficult to look at any trends for the study area due to the OPDCs recent formation and is
made up of parts of a number of LSOAs.
Figure C15-1 Indices of Multiple Deprivation in OPDC

Source: OAPF Draft IIA Report, GLA, February 2015

Given its largely industrial nature, its also reasonable to assume that the small residential population
coupled with its industrial make-up means that the levels of deprivation within the area may be skewed.

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Figure C15-2 Overall living environment deprivation levels in OPDC

Source: Indices of Deprivation

As seen from Figure C15-2, what is clear irrespective of the set-up of the OPDC area is that it suffers from
high levels of living environment deprivation probably due much to the fact that it is largely industrial rather
mixed use or residential and this needs to be a significant consideration in the Local Plan.

B.15.2

Data Gaps and Uncertainties

Provision of childcare

Deprivation statistics for the area

B.16

Housing

The following baseline indicators have been used to characterise the status of housing across the borough:

Dwelling Stock (Office for National Statistics Local Profiles)

Household density (Office for National Statistics Local Profiles)

Household composition (OAPF Draft IIA Report, GLA, February 2015)

The area only contains some 1,898 households, with the rest being industrial and warehouse units. Given
the remit of the OPDC the housing numbers within the area is set to rise sharply in Old Oak. Currently
dwelling stock suggests that compared to adjoining boroughs owner-occupiers is a lower percentage than
that of Ealing and a large percentage are in private landlords hands.

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Table C16-1 Dwelling Stock by Tenure and Condition

Source: OAPF Draft IIA Report, GLA, February 2015

Household density at its most dense in the south-eastern part of the area due to the predominantly industrial
use of the area itself as can be seen from Figure C16-1.
Figure C16-1 Household Density

Source: OAPF Draft IIA Report, GLA, February 2015

Affordable housing considerations as well as housing unit proportions (types and tenures) need to be
considered in the Local Plan.

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9% of households in the plan area are lone parent families and over 90% of these parents are women. The
proportion of such households in the population doubles since the 1991 census. Single parents make up a
high proportion of households living in social housing (23% of council tenants and 32% of housing
associated tenants).
Lone parents experience some of the greatest levels of economic and housing need, their household
incomes are only about a third of the average income. They are more than three times more likely to be
dependent on benefits than the average household, and twice as likely to be in unsuitable housing.

C.16.2

Data Gaps and Uncertainties

Future population composition

C.17

Crossboundary Issues

For many authorities, the geographical scale of particular baseline issues means that they relate closely to
neighbouring authorities. For example, housing provision and prices, employment migration and commuting,
service provision and education can all result in flows of people across boundaries. In order to help to
characterise the baseline further, some of these key crossboundary issues have been identified below.

There is not enough affordable housing being constructed in London to meet current demand; and as
the number of households in London grows, demand for affordable housing will increase. These
issues may be exacerbated in future years if trends remain the same. There are therefore
opportunities for the OPDC Local Plan to contribute to reducing this trend.

Surface water flood risk and the measures to manage this may also be a crossboundary issue e.g.
surface water runoff from one borough having an impact on a neighbouring borough. OPDC need to
work in partnership with the neighbouring boroughs to ensure flood risk is reduced for future
generations.

Employment and economic activity rates within OPDC area is particularly important especially when
consideration needs to be made with adjoining town centres as well as existing business that may not
have anywhere else to go.

There is a severe lack of open space currently in the area and in the adjacent boroughs overall - it is
important that the OPDC Local Plan incorporates open space.

Although Wormwood Scrubs and the Grand Union Canal are important biodiversity assets, other
space within the area and the adjoining boroughs need to be developed. The benefits of this could be
at least two-fold. The Local Plan should support the existing biodiversity but also encourage more
biodiversity into other sections of the study and promote green connectivity. Green spaces need to be
multi-functional and evenly located so as to avoid over-reliance on one particular space.

Impact of significant quantum of development on the surrounding heritage assets and settings needs
to be carefully managed.

Cumulative impacts regarding major roads and the impact on the new rail infrastructure should be
considered.

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APPENDIX D
Initial Analysis of other relevant SA Frameworks

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51

Development of SA Framework Objectives

Note: although some of the objectives may be comparable to more than one objective, a best fit approach has been taken. It is noted that relevant assessment criteria/subobjectives from each of the frameworks will be drawn upon where relevant. It is also noted that although the HUDU Matrix assessment criteria relate to project-level
assessments, these have been interpreted to become more relevant at the policy assessment level.

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SA

1. Biodiversity. To conserve
and enhance natural habitats
and wildlife and bring nature
closer to people.

Biodiversity EN4.
To conserve and
enhance
biodiversity.

9. Protect and
enhance the natural
environment and
biodiversity.

Hammersmith and
Fulham SA

HUDU Matrix Assessment Criteria: kay

aspects

Maintain or enhance biodiversity

Commentary
(including Key issues
and PPPs), HRA and
Draft SA Objective (in
bold)

1. Conserve and
enhance biodiversity
and promote the use of
green infrastructure
The HRA findings will
be integrated into the
SA through assessment
under this objective.

2. Water Quality & Water

Resources. To improve the
quality of groundwater and to
achieve the wise management
and sustainable use of water
resources. Minimise the risk of
surface flooding and promote
sustainable urban drainage.

Water Quality &

Resources EN2.
To improve water
quality; conserve
water resources
and provide for
sustainable sources
of water supply.

12. Improve water

quality, conserve
water resources
and minimise the
impact of flooding.

Incorporation of sustainability drainage

techniques

2. Improve the quality of

water resources and
achieve their
sustainable use
3. Minimise the risk of
and from flooding

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3. Natural resources. To
minimise the global, social
and environmental impact of
consumption of resources by
using sustainably produced,
harvested and manufactured
products. Recycle demolition
materials in construction and
minimise the consumption of
water and energy in
developments

4. Climate Change. To
address the causes of climate
change through minimising
the emissions of greenhouse
gases. Encourage energy
generation from renewable
and low carbon sources, and
promote energy efficiency.

Hammersmith and
Fulham SA

HUDU Matrix Assessment Criteria: kay

aspects

Careful
consumption 10.
Responsible
consumption of
resources in the
borough.

Climate Change
EN7. To reduce
contributions to
climate change and
reduce vulnerability
to climate change.

11. Reduce
contributions to and
vulnerability to
climate change.

Climate Change
11. Reduce climate
change and its
impact on the
borough.

Commentary
(including Key issues
and PPPs), HRA and
Draft SA Objective (in
bold)

The aspects of this

objective will be
covered under
proposed objectives
relating to: water
resources; energy;
regeneration and waste.

Incorporation of low and zero carbon

energy source planning

Layout of development and schemes to

maximise passive energy use, and
respond to winter and summer
temperatures including ventilation,
shading and landscaping.

Proposals which incorporate sustainable

4. To minimise
contributions to climate
change through greater
energy efficiency and to
reduce reliance on
fossil fuels for transport,
heating, energy and
electricity.
Reducing vulnerability

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aspects

design and construction techniques

Page 373
5. Air Quality. To improve air
quality.

Air Quality EN3. To

improve air quality.

5. Minimise
detrimental noise
impacts.
10. Improve air
quality.

6. Energy. To achieve greater

energy efficiency and to
reduce reliance on fossil fuels
for transport, heating, energy

Reduce pollution
8. Reduce the level
of pollution.

Minimisation of construction impacts

Minimisation of noise pollution caused by

traffic and commercial uses

Minimisation of air pollution cause by

traffic and commercial uses

Commentary
(including Key issues
and PPPs), HRA and
Draft SA Objective (in
bold)
to climate change will
be targeted through
other objectives
including those related
to reducing flood risk,
sustainable water use,
minimising other
resource use,
sustainable design and
green infrastructure.

5. To minimise air,
noise and light pollution,
particularly for
vulnerable groups

The aspects of this

objective will be merged
under the climate
change objective

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aspects

and electricity.

Page 374

7. Waste. To minimise
production of waste across all
sectors in the OA and
increasing rates of re-use,
recycling and recovery rates
as well as composting of all
green waste.

8. Soil conditions and

contamination.
Ensure all contaminated sites
are remediated prior to
development with the option of
in-situ treatment investigated.

9. Accessibility / Availability
(Transport). To ensure that
all residents and visitors have

Commentary
(including Key issues
and PPPs), HRA and
Draft SA Objective (in
bold)
above.

Waste
Management EN8.
To minimise the
production of waste
and use of nonrenewable
materials.

14. Reduce waste

generation and
increase waste
recycling.

Proposals which encourage recycling

(including building materials)

Land and Soil

EN9. To conserve
and enhance land
quality and soil
resources.

Traffic EN1. To
reduce the effect of
traffic on the

6. To minimise
production of waste
across all sectors in the
OA and increasing rates
of re-use, recycling and
recovery rates as well
as composting of all
green waste.

The aspects of this

objective will be
included under the
regeneration objective
below.

15. Reduce
vehicular
dependency and

Reduce transport
impacts 9. Reduce
the effect of

Prioritisation and encouragement of

walking and cycling including through the
use of shared spaces and cycle

7. Minimise the need to

travel through improving
accessibility by walking,

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access to key services and

amenities and increase the
proportion of journeys made
by public transport, by bicycle
and by foot (relative to those
taken by car).

environment

promote the use of

sustainable modes
of transport.

transport on the
environment.

Page 375

Accessibility S7.
To improve
accessibility to key
services especially
for those most in
need.
Efficient
Movement EC5. To
encourage efficient
patterns of
movement in
support of economic
growth.

10. Built and Historic

Environment. To enhance
and protect the existing built
environment (including the
architectural distinctiveness,
townscape /landscape and
archaeological heritage), and
ensure new buildings are

Landscape &
Townscape EN5.
To maintain and
enhance the quality
of landscapes and
townscapes.
Historic

3. Preserve and
enhance the local
historic environment
and cultural
heritage.

Heritage 7. Improve
the local
environment and
heritage

HUDU Matrix Assessment Criteria: kay

aspects

lanes/parking, including inclusive

accessible routes.
x

Connectivity of public realm and internal

routes to local and strategic cycle and
walking networks

Traffic calming measures and

minimisation of road injuries

Connectivity of new development to public

transport, local services and facilities,
reducing the need to travel by car

Commentary
(including Key issues
and PPPs), HRA and
Draft SA Objective (in
bold)
cycling and public
transport

8. To enhance and
protect the existing built
environment (including
the architectural
distinctiveness,
townscape /landscape
and archaeological
heritage), and ensure

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appropriately designed and

constructed

Environment &
Cultural Assets
EN6. To conserve
and, where
appropriate,
enhance the historic
environment and
cultural assets.

11. Regeneration and Land

Use. To stimulate
regeneration that maximises
benefit to the most deprived
areas and communities and to
improve efficiency in land use
through the sustainable reuse
of previously developed land
and existing buildings.

Regeneration EC3.
To reduce
disparities in
economic
performance and
promote sustainable
regeneration.

13. Enhance
existing buildings
and facilities, and
encourage the
reuse/remediation
of vacant land and
under-utilised
buildings.

12. Housing. To ensure that

Housing S.4 to

6. Improve access
to well designed,

Hammersmith and
Fulham SA

HUDU Matrix Assessment Criteria: kay

aspects

Commentary
(including Key issues
and PPPs), HRA and
Draft SA Objective (in
bold)
new buildings are
appropriately designed
and constructed

Proposals which make the best use of

existing land

Affordable homes

Health and wellbeing credits of the Code

9. To stimulate
regeneration that
maximises benefit to
the most deprived areas
and communities and to
improve efficiency in
land use through the
sustainable reuse of
previously developed
land and existing
buildings, including the
remediation of
contaminated land.

10. Improve access to

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all Londoners have access to

good quality, well-located,
affordable housing that
promotes liveability.

provide everybody
with the opportunity
to live in a decent
home.

affordable, inclusive
and appropriately
located housing.

4. Provide decent
and affordable
homes

Page 377
13. Employment. To offer
everyone the opportunity for
rewarding, well-located and
satisfying employment.

Growth EC1. To
encourage
sustainable
economic growth.
Employment EC2.

16. Promote local

employment
opportunities,
training and skills
attainment.
17. Support

Satisfying work 6.
Increase the
opportunities for
satisfying and well
paid work.

HUDU Matrix Assessment Criteria: kay

aspects

for Sustainable Homes

x

Housing needs of older people including

extra care housing, sheltered housing,
lifetime homes and wheelchair accessible
homes

Adaptable homes for independent living

for older and disabled people

Good design through layout and

orientation

Range of housing types and sizes,

including affordable housing, in response
to local housing needs

Energy efficient housing (high SAP rating)

Provision of access to local employment

and training opportunities including
temporary construction and permanent
end-use jobs

Provision of childcare facilities

Commentary
(including Key issues
and PPPs), HRA and
Draft SA Objective (in
bold)
well designed, welllocated, affordable and
inclusive housing of a
range of types and
tenures, to meet
identified local needs.

11. To offer everyone

the opportunity for
rewarding, well-located
and satisfying
employment locally

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aspects

Commentary
(including Key issues
and PPPs), HRA and
Draft SA Objective (in
bold)

To offer everybody
the opportunity for
rewarding and
satisfying
employment.

sustainable
economic growth.

Sustainable
Economy 12.
Improve the
sustainability of the
local economy.

Provision of managed and affordable

workspace for local businesses, including
live/work units

Opportunities for work for local people via

local procurement arrangements

12. To encourage
indigenous and inward
investment to create
sustainable economic
growth

Page 378

Investment EC4.
To encourage and
accommodate both
indigenous and
inward investment.

14. Liveability and Place. To

create and sustain liveable,
mixed use physical and social
environments that promote
long-term social cohesion,
sustainable lifestyles and a
sense of place.

15. Open space. Improve the

quality of the public realm and
increase the number of public

Community
Identity S6. To
encourage a sense
of community,
identity and welfare

Aspects of this objective

will be addressed under
equality and diversity as
well as accessibility and
health and wellbeing
objectives.

8. Protect and
enhance public
open space.

Retention and enhancement of existing

open and natural spaces including
improved accessibility

13. Improve the quality

of the public realm and
increase the provision,
accessibility and quality

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open spaces.

Page 379

16. Education and Skills. To

improve the education and
skills levels of the population.

17. Safety and security.

Reduce the amount of crime
and reduce the fear of crime
through building and public
realm design principles.

18. Health and Well-being.

Education and
skills S3. To
improve the
education and skills
of the population

18. Improve
opportunities for
education and
training.

Crime Prevention
and Community
Safety S5. To
reduce crime and
anti-social activity

4. Reduce crime,
fear of crime and
antisocial
behaviour.

Health and

1. Actively support
inclusive access to

Education and
skills 3. Improve
the education and
skills of young
people and adults.

Health 2. Improve
health of population

HUDU Matrix Assessment Criteria: kay

aspects

Commentary
(including Key issues
and PPPs), HRA and
Draft SA Objective (in
bold)

Provision of new open or natural space

of public open spaces.

Provision of play spaces for children and

young people

Provision of allotments and community

farms to facilitate the supply of local food

Contribution to meeting primary,

secondary and post 19 educational needs

14. To improve the

education and skills
levels of the population
.

Proposals and policies seeking to design

out crime including increasing natural
surveillance

Creation of attractive, multi-use public

spaces and buildings

Community engagement

Retention and provision of additional

15. To reduce crime

and the fear of crime
through building and
public realm design
principles

16. To maximise the

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To maximise the health and

well-being of the population,
reduce inequalities in health
and promote healthy living.

Wellbeing S2. To
improve the health
and wellbeing of the
population.

essential health,
community and
local services.

overall

7. Reduce health
inequalities and
promote healthy
living.

Page 380
19. Equality and Diversity.
To ensure equitable outcomes
for all communities,
particularly those most liable
to experience discrimination,
poverty and social exclusion.

Prosperity and
Social Inclusion
S1. To reduce
poverty and social
exclusion.

2. Promote
community
involvement,
voluntary and
partnership working.
19. Promote cultural
and community

Social Justice 1.
Increase equality
and social justice.
Social cohesion 5.
Increase local
residents sense of
community and

HUDU Matrix Assessment Criteria: kay

aspects

social infrastructure
x

Meeting identified needs for healthcare

services

Meeting identified needs for other social

infrastructure eg schools, social care and
community facilities (including capacity,
location and accessibility)

Opportunities for shared community use

and co-location of services

Provision of a range of retail uses,

including for affordable shops, a range of
food stores and avoidance of an overconcentration of hot food takeaways.

Connectivity of existing communities

through layout and movement, avoiding
physical barriers and severance and land
uses and spaces which encourage social
interaction

Provision of a mix of uses and a range of

Commentary
(including Key issues
and PPPs), HRA and
Draft SA Objective (in
bold)
health and well-being of
the population, reduce
inequalities in health
and promote healthy
living.

17. To ensure equitable

outcomes for all
communities,
particularly those most
liable to experience
discrimination, poverty

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identity.

social cohesion.

HUDU Matrix Assessment Criteria: kay

aspects

community facilities
x

Opportunities for the voluntary and

community sectors

Adherence to the principles of Lifetime

Neighbourhoods

Commentary
(including Key issues
and PPPs), HRA and
Draft SA Objective (in
bold)
and social exclusion.

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APPENDIX E
Consultation Responses to IIA Scoping Report

Page 382

Consultation Responses to Scoping Report, September 2015

Respondent

Relevant comment extract

(a) Do you have any further suggestions regarding the scope of the IIA and its
proposed appraisal of the Local Plan?
Answer: The issue of sustainability should be emphasized from the beginning of the
description of the scope of the IIA. The size of this development means that it will have
a profound effect on the environment both of the OPDC area and the surroundings.

Brent Friends
of the Earth

The SEA Directive refers to the promotion of accepted measures that promote
sustainability including reasonable alternatives.
We are concerned that such accepted measures notably potential energy saving
systems such as district heating and the possible provision of heat pumps should be
considered at an early stage since they would affect the design and construction of the
buildings themselves and need to be considered at a very early stage in the Plan..

Response

Agree. Text amended to reflect this.

Agree. Additional indicator included.

Page 383

Brent Friends
of the Earth

(b) Are there any additional PPPs that should be considered for review?
Answer: No local Authority Air Quality Action Plans have been included. Most of the
existing area is categorized as an AQMA, Air Quality Management Area. This has
implications for the future transport policy and is most important I relation to the Health
Impact Assessment.

Noted.

Brent Friends
of the Earth

(c) Are there any additional themes that could be drawn out of the review of
PPPs?
Answer. The issues of sustainability, health impact, transport, climate change are all
intertwined with the provision of affordable energy, air quality, the actual construction of
buildings, the quality of the means of transport and the levels of carbon dioxide
reduction, so, although they may be classified as separate themes in relation to the
various impact assessments they will have common issues which need to be included
wherever relevant.

Noted. The role of the IIA Report is to

coordinate the assessment of these
elements to provide holistic
recommendations.

Respondent

Brent Friends
of the Earth

Relevant comment extract

Response

(d) Do you agree with the sustainability issues and opportunities that we have
identified? Are there additional issues that both the IIA and the Local Plan
should consider?
Answer:
We are concerned that the standards of construction of all buildings, houses and flats,
public buildings and commercial and industrial development, should all reach the best
standards of energy efficiency and not simply satisfy the latest regulatory standards.

Agree. Objective 7 seeks to help to

ensure this.

Also that every effort should be made to promote the use of renewable energy through
incorporating solar energy panels where practicable, considering too the use of heat
pumps and the provision of district heating.
In relation to transport we hope that the use of the canal will be promoted and that
consideration should be given to establishing a low emission zone which would require
that all vehicles entering the area are low emission vehicles that have to pass the
necessary tests at regular intervals.

Noted. Objective 7 seeks to help to

ensure this alongside enabling other
renewable energy generation sources.
Agree. New indicator for Objective 4
included:
Proportion of waste and freight arriving
and leading the area by canal.
Noted. The OPDC area is within the
Greater London Low Emission Zone.

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Brent Friends
of the Earth

(e) Is there any additional baseline information that you feel it would be
important to include?
Answer:
The changes in the area will be so great that existing baseline information would not
provide an adequate comparison. It would be better to make comparisons with the
highest possible recommended values so that the IIA measures show how effectively
the OPDC is likely to achieve the best possible standards.

Disagree. The existing baseline provides

an initial starting point to monitor the
delivery of the Local Plan.

Brent Friends
of the Earth

(f) Are there any particular topics or geographical areas of specific concern to
your organisation?
Answer:
We have already said that our main concerns are that energy efficiency, use of
renewable energy and prevention of air pollution are incorporated into all policies and
buildings.
We also believe that a sufficient number of affordable dwellings should be included in
the housing plans.

Noted.

Respondent

Relevant comment extract

Response
Disagree. A net increase in businesses is
considered to be a sound objective to be
considered by the IIA.

Building
Products Index
Ltd

Yes there should be changes to IIA Framework,IIA Objectives/Sub Objectives Box

18 first bullet point" increase in the net number of businesses registered in the area"
This is a bad objective and should be removed. The quantity of businesses is not a
suitable objective, the quality of businesses is a better objective, or the ratio between
the square metre a buisness occupies and the number of people employed might be
better if you are seeking to attract employment to the area.

Noted. The quality of workspace is

considered to be addressed through the
delivery of workspaces for new and
emerging businesses alongside the
encouragement of development of
employment growth sectors.
Noted. The workspace densities are
considered in the final bullet point of
Objective 18.

Page 385

Noted. Objective 17 considers the number

of people being employed in the area.

Car Giant

2. Section 4.2 outlines a series of environmental, social and economic objectives that
have been used to generate some common themes. We recognise the importance of
the need to ensure that new housing development meets local needs however we do
think that there should also be recognition that Old Oak Common is also a Strategic
regional housing site and that the objective should be to meet the need to ensure that
new housing development addresses local and London needs.

Agree. Text amended to state "to ensure

that new housing development meets
local and regional needs"

Car Giant

A common theme has also been included within 4.2 to reduce crime and fear of
crime. Whilst we agree with this objective, it is inevitable that there is potential for
crime to increase when comparing the number of residents now to the number
residents in the future. However, we believe that there is an opportunity to make the
area safer and the objective should be to promote safer communities and reducing
fear of crime.

Disagree. The wording is considered

appropriate for the relevant objective.

Respondent

Relevant comment extract

Car Giant

3. Section 5 identifies the key Sustainability Issues and Opportunities for the OPDC.
Within the Local Economy topic section the table outlines that the Local Plan should
seek to provide business opportunities that meet the current and future needs of the
local economy, within the context of the neighbouring communities and that there is
an opportunity for the Local Plan to specify that incoming employment opportunities
are to be directed towards local people in the existing and surrounding. Whilst we
dont disagree with the overall objectives of providing business opportunities and
employment opportunities, we do think that these points contradict the GLAs vision that
this opportunity area will be a major employment centre of London-wide significance
and we suggest that the wording should be revised to illustrate maximising
opportunities for local people to access jobs.

Page 386

Car Giant

Car Giant

Car Giant

In addition to this, the table states (page33) that retail should be in small clusters and
the Local Plan should manage the affordability of newly generated economic
activities. We support the principle of retail development but we want to highlight that
fragmentation of retail in clusters has the potential to not be compatible with
commercially sustainable retail which should be considered going forward.

In addition, we agree with the principle of affordable new generated economic

opportunities, but we do think that this provides risk to the potential investment of
offices and therefore suggest that the Local Plan should promote the commercial
viability of employment space instead.
4. Section 6 illustrates the draft IIA objective and sub- objectives and starts to introduce
indicators and approach to target setting. We believe that some of the potential targets
outlined throughout need further consideration and evaluation and we would like to
engage further and have more focused discussions with the OPDC on these targets
once the Local Plan has further developed. Some examples to note is firstly the
indicator/objective for a proportion of family housing. We feel that the objective would
be improved if it was not so prescriptive and instead stated provision of
accommodation suitable for a range of different household types.

Response
Agree. Text amended to state: "The Local
Plan should seek to provide employment
and business opportunities that meet the
current and future needs of the local and
regional economy, within the context of
the neighbouring communities."
Noted. Text amended to state: "there is an
opportunity for the Local Plan to specify
that a proportion of incoming employment
opportunities are to be directed towards
local people in the existing and
surrounding
Agree. The following sentences have
been removed: " Incoming retail should
be developed in small clusters. This could
help to reduce the impact on other town
centres."

Disagree. This implication is not

considered to be a significant risk.

Noted. Further engagement will be carried

out through the plan making process.
Disagree. The sub-objectives are
considered to be appropriate in supporting
the overarching objective.

Respondent

Relevant comment extract

Response

Car Giant

Further to this, there are a number of objectives relating to employment and economy.
On page 48, it has been proposed to offer a proportion of new employment and
training opportunities to local people and local women via procurement
arrangements. For Old Oak to succeed as a business destination it needs to be more
than a local employment destination. We believe that the real objective is not the
proportion of jobs offered to local people, but making the most of opportunities for local
people to access employment here.

Noted. The reference provided relates to

an indicator for monitoring the delivery of
the objective. The proportion of jobs
offered to local people is considered to be
a representation of the opportunities for
local people to access employment.

2a) Do you have any further suggestions regarding the scope of the IIA and its
proposed appraisal of the Local Plan?

Diocese of
London

The long term management and funding of the public spaces such as open spaces,
highways, pedestrian and cycle routes along with community facilities and social
infrastructure will be crucial to the success of the development as a community through
its life.

Noted. Objective 1, sub-objective 3 will be

amended to reference management of
open spaces.

Page 387

Further consultation is supported concerning the desire and viability of locally managed
spaces and places that allow for genuine community engagement and involvement.
This could help determine what is required from the communitys perspective as plans
evolve and if the capacity exists to support such local initiatives.

Diocese of
London

Diocese of
London

Health Impact assessments should look at provision of interventions that improve

health and are complementary to local health services. The prospect of the OPDC
area taking a fresh look at health provision is exciting and such improvements in local
health and related services that promote and support well-being would be welcomed
and potentially have a beneficial impact in adjoining areas if spaces, places, and
services are more widely accessed.

Concerning the Equalities Impact Assessment, the future make-up of the local
population(s) cannot be predicted with any accuracy. The principles for the
assessment are provided by statute and we would welcome the OPDC involving
members of the areas diverse community to help test out approaches and complete
such assessments that will support key decisions ahead. We would be keen to help
the OPDC with the EIAs that will allow us all to gain further understanding of the
issues faced day to day and to work closely with those with most to lose when services

Noted.

Noted. This suggestion will be used to

inform OPDC engagement processes and
updates to the Local Plan.

Respondent

Relevant comment extract

Response

and developments fail to meet their needs within the plans for development ahead. To
guard against this risk, the communitys involvement and influence on key aspects of
design and accessibility will greatly enhance what takes shape within the OPDC area.
2(b) Are there any additional PPPs that should be considered for review?
Diocese of
London

The Mayor of Londons Supplementary Planning Guidance on Social Infrastructure

2015.

Noted. Mayor's Culture Strategy is

already included within the list of PPPs
and subsequent assessment.

The Mayor of Londons Cultural Strategy to help guide introducing facilities,

destinations and activities across the OPDC area.
2(e) Is there any additional baseline information that you feel it would be
important to include?

Page 388

Diocese of
London

The plans showing social infrastructure include as the crow flies distances from
facilities. Ideally baseline data should show actual travel times from new development
(particularly residential) to those facilities as new facilities may not be available from
the outset, given that the area has little connectivity currently.

Noted. Consideration will be given to

provided actual travel times in the IIA.

N.B. Burlington Danes Academy and primary school, Wood Lane are not shown on the
plans.

Diocese of
London

Diocese of
London

Re: The list of issues the authority wants to solve - we would welcome increased
community engagement that builds on their knowledge and experience to help shape
the Local Plan. These assessments and their review should identify and tackle areas
of concern to community stakeholders.

The base line data concerning the current and small resident population in and around
Old Oak Common Lane are valuable pointers but need to recognised in the context of
significant population growth and change. The make-up of the large population
increase within new developments cannot be accurately predicted nor can its various
needs and priorities be established with certainty at this stage.

Noted.

Noted.

Respondent

Relevant comment extract

Response

2(f) Are there any particular topics or geographical areas of specific concern to your
organisation?
The Diocese of London oversees all the parishes which fall within the OPDC area. Our
particular concern is to ensure the Diocese is able to meet the spiritual needs of both
the present and the new community although ministering to the whole person means
the church has a long track-record in supporting those both in terms of need and
celebration.
Diocese of
London

Through the London Diocesan Board for Schools we also sponsor schools which are
inclusive, have an open admissions policy and a balanced Christian ethos.

Noted

The Diocese is part of a joint venture that provides modern health facilities to meet
contemporary needs.

Page 389

Local parish facilities are in use across the Diocese to deliver community services
involving local groups and volunteers.
The Diocese works with other faith communities, locally, and regionally.

Objective 1 To enhance the built environment and encourage place-making

Diocese of
London

The Diocese strongly supports this objective and the sub-objectives. We aim to ensure
that our own places of worship, schools and ancillary facilities achieve these aims and
of course churches are often the most distinctive and beautiful buildings in an area and
help to provide a sense of place and legibility. We would welcome an additional subobjective that emphasises the creation of safe and welcoming spaces for all

Agree. Objective 1 amended to reflect this

aspiration

We support the principle of Lifetime Neighbourhoods

Respondent

Relevant comment extract

Response

Objective 2 To optimise the efficient use of land through increased development

densities and building heights, where appropriate

Diocese of
London

Page 390

We have concerns about these objectives and sub-objectives. The pressures to make
efficient use of land and to create development value that can fund essential
infrastructure are understood but if Old Oak is to be a real neighbourhood it must
become a community and attract those who want to invest long-term in the area such
as families for whom high density is not necessarily appropriate. The optimisation of
future developments should not risk creating an area with housing and services that
serves its community poorly. Lessons can be learned from other recent developments
across London. We would draw your attention to the Olympic Park SPG which states:
[This] SPG emphasises the importance of family housing, supported by new and
improved open spaces and social infrastructure such as schools and health facilities.
This will be in contrast to much recent apartment dominated development and help
establish lifetime neighbourhoods where people will choose to live, settle and raise
families.

Noted. Objective 5 considers the delivery

of a range of housing types and tenures
including family housing.

Assessments associated with family and other specific housing needs should help
develop standards and policies safeguarding the community for a lifetime whilst
meeting current demand for homes.

Objective 4 Minimise the need to travel and improve accessibility for all users
Diocese of
London

We understand that Old Oak Common transport interchange will be amongst the most
connected in the UK. There needs to be a distinction between the importance of the
interchange and its promotion nationally and the local movement of visitors, residents
and local traffic within the OPDC area once studies have been conducted. OOC needs
to be a destination in its own right as well as an efficient interchange.

Noted. Objective 1 considers the role of

creating a destination through land uses
and wider placemaking.

Respondent

Relevant comment extract

Response

Objective 5 Improve access to well designed, well located, market, affordable

and inclusive housing of a range of types
Diocese of
London

As noted above, we believe that new homes should be liveable and a proper
allocation of internal space specified to better support the needs of different family
sizes and other households.

Noted. Objective 5 considers the delivery

of Lifetime Homes standards.

Objective 13 Increase community cohesion and reduce social exclusion

The Diocese strongly supports this objective and the sub-objectives noted above.
Some of the indicators used for Objective 15 relating to walking distance could usefully
be used for the second sub-objective here.

Page 391

Diocese of
London

We note that the Brent Local Plan SA has the following objective:
Community Identity S6. To encourage a sense of community, identity and welfare.
Although difficult to measure, the Diocese strongly believes this will be critical to
assessing the success of the new community. Amending the proposed objective to
incorporate this would be welcomed and demonstrate that the OPDC is putting the
community at the heart of its planning process.

Noted. As the IIA Framework should be

considered as a whole, it is not
considered necessary to repeat the subobjectives of Objective 15. Objective 1
considers developing and enhancing local
distinctiveness.
Agree. Wording of Objective 13 modified.

The provision of appropriate places and spaces that support such aspects of
community life should be encouraged.

Respondent

Relevant comment extract

Response

Objective 15 Maximise the health and wellbeing of the population, reduce

inequalities in health and promote healthy living
The Diocese strongly supports this objective and particularly the sub-objectives noted
above.

Diocese of
London

With regard to the indicator Increase in the capacity of local social infrastructure, we
would be interested to know how this will be measured
We note that there is no indicator for access to retail facilities which should be included
and the impact there could be on neighbouring high street areas that could suffer as a
result of developments.

Noted. The GLA Social Infrastructure

SPG suggests how social infrastructure
capacity can be measured.
Agree. Wording of Objective 17 amended
to reflect access to retail facilities.

Page 392

We would welcome assessment of the potential offered by an engaged and active

community in running their open spaces, community gardens and shared facilities.
The OPDC might want to consider this approach with developers.

Environment
Agency

Consultation Question (b)

Are there any additional PPPs that should be considered for review?
Environment Agency comments We feel the following PPPs should also be considered
for review:
International/European
The revised Waste Framework Directive which can be found at the following websites:
http://ec.europa.eu/environment/waste/framework/
and
https://www.gov.uk/guidance/waste-legislation-and-regulations
National
Separate collection of waste paper, plastic, metal and glass:
https://www.gov.uk/guidance/separate-collection-of-waste-paper-plastic-metal-andglass
Flood Risk Regulations 2009 and Flood and Water Management Act 2010:
www.legislation.gov.uk/uksi/2009/3042/pdfs/uksi_20093042_en.pdf
http://www.legislation.gov.uk/ukpga/2010/29/contents

Noted. Flood and Water Management Act

2010 is already included in the review. It
is considered that it is not necessary to
include the Flood Risk Regulations in
addition, as these interpret the Act. It is
considered that guidance relating to the
separation of waste, as referenced, is
relevant to public and private waste
collectors (as stated on the link quoted)
and is not directly relevant to land use
planning, although the sustainable
management of waste will be addressed
using other guidance.

10

Respondent

Environment
Agency

Relevant comment extract

Page 393

Regional/London
The control of dust and emissions during construction and demolition Supplementary
Planning Guidance:
https://www.london.gov.uk/sites/default/files/Dust%20and%20Emissions%20SPG%20
8%20July%202014_0.pdf
Environment Agency Waste and Air Quality Evidence Gathering Project Summary
Report December 2013
London's Wasted Resource: The Mayor's Municipal Waste Management Strategy
Making Business Sense of Waste: The Mayors Business Waste Management
Strategy:
https://www.london.gov.uk/priorities/environment/publications/the-mayors-wastemanagement-strategies
London Waste and Recycling Board Waste Management Planning Advice for New
Flatted Properties:
http://www.lwarb.gov.uk/wp-content/uploads/2015/05/Final-report-Waste-ManagementPlanning-Advice-for-Flatted-Properties.pdf
Securing Londons Water Future-The Mayors Water Strategy:
https://www.london.gov.uk/priorities/environment/publications/securing-london-s-waterfuture-the-mayor-s-water-strategy
The table includes the 2009 River Basin Management Plan (RBMP) but the 2015
RBMP is due to published imminently and therefore should inform the forthcoming
Local Plan.
Local
We understand that the OPDC are in the process of preparing a suite of detailed
evidence to support the Local Plan. We recommend that the following documents are
included in the evidence suite:

Response

Noted. Although not a PPP, OPDC will

liaise with EA to acquire the Waste and
Air Quality Evidence Gathering Report to
be used for baseline evidence. A London
specific air quality strategy is included in
the review. It is considered that the
business-specific waste management
strategy is not directly relevant. The
Mayor's water strategy is included in the
review. The 2015 Thames River Basin
Management Plan will be added once
published, as part of the iterative process
of IIA.
Noted. OPDC is developing an Integrated
Water Management Plan.

Integrated Water Management Strategy

11

Relevant comment extract

Response

Environment
Agency

Brent, Ealing & Hammersmith and Fulham

We note that you have referenced LB Hammersmith and Fulhams Surface Water
Management Plan (SWMP) as relevant evidence to the SEA. The OPDC Local Plan
should also reference and be informed by LBs Ealing and Brent Surface Water
Management Plan. The SWMPs have designated Critical Drainage Areas (CDAS)
within the OPDC boundary so it is important that the recommendations of the Local
Plan and policies ensure a joined up approach is taken in addressing surface water
flood risk issues in the CDAs.
The Local Plan should also be informed by the 3 boroughs separate Strategic Flood
Risk Assessments. However, it is a possibility that these documents are have been
superceded by more relevant information which is why we also recommend that the
OPDC carries out a new Strategic Flood Risk Assessment.

Noted.

Environment
Agency

Consultation Question (c)

Are there any additional themes that could be drawn out of the review of PPPs?
Environment Agency comments We support the inclusion of Water as a theme
providing this considers flood risk, water quality and water resources.
We recommend that the flood risk theme includes an assessment of all local sources
of flooding such as surface water and ground water, river flooding and as the site is
downstream from the Welsh Harp reservoir it is important that the potential risk of
flooding from reservoirs is assessed.
We recommend that the Water theme also includes an objective to achieve
sustainable drainage throughout the site.
We recommend that a theme is included to promote, protect and enhance Green
Infrastructure. The provision of well planned and good quality Green Infrastructure (GI)
will provide multiple benefits. These include reducing flood risk, improving ecological
value and enhancing biodiversity, improving air quality, reducing the urban heat island
effect and improving amenity value. Good quality GI can help to achieve the objectives
of the SEA and the HIA.

Agree. It is considered that the water

'theme' includes the key issues identified.
The more detailed information will
included in the IIA Framework for use in
the assessments. Objective 6 considers
the use of sustainable drainage. It is
considered that this could include GI. GI is
also relevant to a number of other IIA
Objectives, and will be considered as a
multiple benefit throughout the
assessment.

Page 394

Respondent

12

Page 395

Respondent

Relevant comment extract

Response

Environment
Agency

Consultation Question (d)

Do you agree with the sustainability issues and opportunities that we have
identified? Are there additional issues that both the IIA and the Local Plan
should consider?
Environment Agency Comments
Water
We broadly support the key issues listed in this section but feel that opportunity should
be taken to strengthen the wording of:
The risk of flooding and the mobilisation of contaminants should be minimised through
measures such as a site-wide drainage strategy and increased awareness.
We recommend that the wording is changed to state that the mobilisation of
contaminants should be prevented. It may also be appropriate to state that the risk of
flooding should be minimized by the use of Sustainable Drainage Systems throughout
the site wide drainage strategy.
The Local Plan should also seek to ensure that any contaminated groundwater is
remediated through the redevelopment of the area.

Noted. Objective 9 of the IIA Framework

considers the risk to the water
environment from the run-off of
contaminants. Flood risk and sustainable
drainage is specifically addressed under
Objective 6.
Noted. Objective 6 identifies the use of
sustainable urban drainage.
Noted. This suggestion will be used to
inform the development of the Local Plan.

Environment
Agency

Soils and Geology

We recommend that the Local Plan promotes the CL:AIRE Definition of Waste:
Development Industry Code of Practice. This will help to ensure that materials are reused on site in a sustainable manner.
http://www.claire.co.uk/index.php?option=com_content&view=category&id=977&Itemid
=330

Noted. The IIA Scoping Report includes

guidance relating to waste policy.
However, it is considered that guidance
for contractors is not directly relevant for
the IIA.
Noted. This suggestion will be used to
inform the development of the Local Plan.

Environment
Agency

Air Quality
Air quality is a serious problem in London. We therefore recommend that the Local
Plan ensures that the Sustainable Design and Construction Supplementary Planning
Guidance is followed. We also recommend that the Local Plan requires all new Waste
facilities to fully enclose operations and considers requiring existing facilities to enclose
operations due to the increase in population and sensitive receptors as a result of the
redevelopment of the OPDC area.

Noted. The IIA Scoping Report references

the GLA Sustainable Design and
Construction SPG.
Noted. This suggestion will be used to
inform the development of the Local Plan.

13

Page 396

Respondent

Relevant comment extract

Response

Environment
Agency

Climate Change
We recommend that flood risk management and SuDS should be included in the
opportunities for climate change adaptation. Flood Risk to the OPDC may increase as
a result of climate change and therefore the Local Plan presents an opportunity to
promote Sustainable Drainage Systems (SuDS) which can help to reduce flood risk,
reduce the urban heat island effect and increase the energy efficiency of buildings.

Noted. Objective 6 identifies the use of

sustainable urban drainage.
Noted. This suggestion will be used to
inform the development of the Local Plan.

Environment
Agency

Biodiversity Flora and Fauna

Invasive species such as Japanese Knotweed and Giant Hogweed are present
throughout the Brent Catchment. We therefore think the Local Plan should seek to
address this issue and take a strategic approach to removal of these species within the
OPDC area.

Noted. This suggestion will be used to

inform the development of the Local Plan.

Environment
Agency

Waste
We agree that the potential land use changes mean that the Local Plan needs to
consider any impact on the ability of neighboring boroughs to meet their waste
apportionment. The OPDC should also consider the potential reduction in waste
processing capacity as a result of the proposed changes in land use, particularly as the
redevelopment of the area may result in significant amounts of construction and
demolition waste. If these waste processing facilities need replacing the OPDC should
assess appropriate locations on a strategic level.
The report has identified waste sites within the OPDC boundary and we recommend
that the Local Plan considers whether it is appropriate to introduce new residential
development in close proximity to these sites if they are to remain and if any mitigation
measures will be required.

Noted. This suggestion will be used to

inform the development of the Local Plan.

Environment
Agency

Deprivation and Living Environment

The provision of good quality and well connected GI will help to provide access to
nature and improve amenity of the OPDC area and provide benefits which could
contribute to reducing deprivation.

Agree. Objective 13 sub-objectives

amended to specifically reflect this.
Noted. This suggestion will be used to
inform the development of the Local Plan.

14

Relevant comment extract

Response

Environment
Agency

Consultation Question (f)

Are there any particular topics or geographical areas of specific concern to your
organisation?
Environment Agency comments
We are aware that there are drainage capacity issues in the wider area which should
be addressed through cross boundary co-operation. Possible solutions may include
achieving drainage solutions within the OPDC boundary and exploring opportunities to
retrofit SuDS in neighbouring boroughs.
The Alperton Housing Zone will may also add pressure to the existing infrastructure but
may also present an opportunity to provide contribute to strategic water infrastructure
and GI solutions. This may also result in the Grand Union Canal being used more
frequently by the residents of both the OPDC area and the Housing Zone. This needs
to be considered and provides more justification for maximising opportunities to
increase GI along the Grand Union Canal.

Noted. Objective 6 identifies the use of

sustainable urban drainage.
Noted. This suggestion will be used to
inform the development of the Local Plan.

Historic
England

Historic England welcomes the attention given by the IIA scoping report to Heritage at
Risk, and the importance of development within the OPDC area seeking opportunities
to protect and enhance these assets. However, we have some concerns that treatment
of cultural heritage throughout the document is uneven and at times confused. While
the IIA goes into a satisfactory level of detail in section 5.4 in relation to Kensal Green
Cemetery we would expect to see this consideration flow through the document. We
note that there is confusion in this part of the document about the St Marys
Conservation Area in Hammersmith and Fulham, which includes St Marys Cemetery
and parts of the Grade I registered landscape of Kensal Green Cemetery, and Kensal
Green Cemetery Conservation Area in RBKC, which includes the vast majority of the
listed buildings and monuments and the majority of the Registered Park and Garden.
This is important in relation to the issue of the setting. This needs to be addressed in a
manner that is proportionate to the significance of the heritage assets that will be
affected by the development proposed at Old Oak and Park Royal, with particular
consideration required regarding the potential impacts on the heritage significance of
those assets.

Agree. Table 5-1 in Appendix C

amended for clarification.

We also consider that the IIA does not fully take into account the wider positive role
that heritage can play environmentally, socially and economically.

Noted. Text added to Table 5-1. It is

considered that the IIA Framework covers
the wider benefits, which will be explored
in the assessment through the subobjectives included.

Page 397

Respondent

Historic
England

15

Respondent

Relevant comment extract

Response

Historic
England

Historic England welcomed the opportunity to participate in the Scoping Workshop that
partially informs this document. We note that the section relating to Heritage at Risk in
Appendix A is confusing due to typographical errors.

Noted. IIA Scoping Report amended to

address errors.

Page 398

Historic
England

Unfortunately this confusion is also evident in the Baseline Data (section C.10) where
the map is not only difficult to read with regard to conservation areas, some of which
are not illustrated, but it does not include Registered Parks and Gardens of Special
Historic Interest that could be affected, nor does it show the five APAs within a 500m
radius of the OPDC area, and the spread of listed buildings and monuments in Kensal
Green Cemetery appears inaccurate. The associated list of conservation areas that
may be affected by development within the OPDC area on p.24 should be expanded to
include Kensal Green Cemetery Conservation Area and Oxford Gardens Conservation
Area, both of which are in the Royal Borough of Kensington and Chelsea. Also, we
note that the Hanger Hill Garden Estate and Hanger Hill (Haymills) Estate
Conservation Areas in Ealing are both mislabelled.

Agree. Heritage map has been updated.

Text regarding the potential to explore the
production of a Local List to protect and/or
enhance heritage assets added to Table
5-1 and IIA Framework.

In the accompanying text on p.25 the St Marys Cemetery and Kensal Green Cemetery,
and their respective designations, are not clearly differentiated.
While the OPDC does not currently have a list of locally significant buildings, the three
local boroughs who previously acted as planning authorities for this area have
produced local lists. As such you may also wish to make reference to undesignated
heritage assets, which should also be considered as part of the planning process.

Historic
England

Question A.
Do you have any further suggestion regarding the scope of the IIA and its
proposed appraisal of the Local Plan?
It is important that the references to heritage in the IIA inform the policies in the new
Local Plan and any related plans or documents that flow from it. These themes and
their interrelationships should inform the whole plan. Since the conservation of the
historic environment is a strategic priority in the NPPF, the IIA should facilitate the
development of a positive strategy for the historic environment as set out in paragraphs
126 and 157 (8) of the NPPF. For this reason, we would expect consideration of the
historic environment to include and go beyond the relevant issues highlighted on p. 20
of the IIA (Common themes), which currently overlook the role of the historic

Agree. The IIA Framework is to be

considered as a whole, with the
interrelationships between the objectives
noted in the framework for clarity. The
relationship between the historic
environment and sustainable design and
energy generation will be noted.

16

Respondent

Relevant comment extract

Response

environment in providing low carbon and green options for developments.

Page 399

Question B.
Are there any additional Plans, Policies or Programmes that should be
considered for review?
The list of international documents omits the European Landscape Charter (2000), also
known as the Florence Charter. We would encourage you to add this.

Historic
England

We would query the inclusion of the Government Office for London Circular 1/2000:
Strategic Planning in London in your list of national plans policies and programmes.
This document has been superseded. We would encourage you to include Historic
Englands Historic Environment Good Practice Advice in Planning Notes on:
1. The Historic Environment in Local Plans (2015);
2. Managing Significance in Decision-Taking in the Historic Environment (2015); and
3. The Setting of Heritage Assets (2015).
We would also encourage you to make reference to the English Heritage publication
Strategic Environmental Assessment, Sustainability Appraisal and The Historic
Environment (2013). These documents are all available on our website:
https://historicengland.org.uk/images-books/publications/.

Noted. Agree with comment with regards

to the European Landscape Charter and
the London Circular 1/2000. However, it is
considered that the other documents
referenced are guidance as opposed to
PPPs. These will be used as reference
document, but not included in the PPP
review itself.

At a local level you may wish to make reference to the lists of locally significant
buildings that have been produced by the London boroughs of Brent, Ealing and
Hammersmith and Fulham.

17

Respondent

Historic
England

Relevant comment extract

Question C.
Are there any additional themes that could be drawn out of the review of PPPs?
As per our response to question A, the environmental theme of protecting and
enhancing the historic environment is also relevant to draft IIA objectives 6, 7 and 8.
This is particularly relevant when considering adapting and reusing existing buildings
and infrastructure such as the Grand Union Canal. Furthermore, we consider that the
wording of theme should be amended to read and recognise and appreciate
landmarks, townscapes and their setting. This is important as there are numerous
very highly graded heritage assets whose setting could be dramatically changed by
development within the OPDC area.

Page 400

Historic England welcomes the social theme that specifically seeks to maximise the
contribution that the arts, culture and heritage can make to the community. Given the
heritage significance of the canal passing through the opportunity area, and the
proximity of various highly significant heritage assets such as Kensal Green and
Twyford Abbey, we would also suggest that heritage has the potential to contribute
strongly to the economic development of the area through the reuse of buildings and
tourism. As such you could, in our opinion, add objective 12 to the list of relevant
objectives for the economic theme.

Response

Agree. Theme modified in Table 4-2 and

Appendix B. Cross-references added to
Table 4-2 and Objective 12 in the IIA
Framework.

18

Relevant comment extract

Historic
England

Question D.
Do you agree with the sustainability issues and opportunities that we have
identified? Are there additional issues that both the IIA and the Local Plan
should consider?
In line with our guidance Strategic Environmental Assessment, Sustainability Appraisal
and The Historic Environment (2013), we would encourage the Cultural Heritage
Objective (12) to be reworded to say To conserve and enhance the historic
environment, heritage assets and their settings. This would reflect the fact that the
most significant impacts of the planned development at Old Oak and Park Royal for the
historic environment, will be on the setting of heritage assets in the surrounding area.
We would also encourage you to make the following alterations to the sub-objectives in
objective 12 (Heritage):
Reword the second sub-objective to say Avoid the loss of heritage assets to new
development
Add to the wording of the third sub-objective to say Avoid adverse impacts on the
setting of heritage assets, including those outside OPDC area
An additional indicator for objective 12 could be the development of a heritage
strategy, potentially including works to enhance or better reveal heritage significance in
and around the OPDC area, celebrating local character/features including as part of a
public engagement strategy. Such a heritage strategy could be linked to objectives 13,
15, 16 and 17 to enhance the social benefits to the new and existing communities
derived from the heritage of Old Oak Park Royal. This work could also highlight
economic opportunities which would link it to objective 18.

Page 401

Respondent

Historic
England

In addition to these comments about objective 12 (heritage), we would recommend that

further consideration be given to the following IIA objectives and sub-objectives:
Objective 1 (p.38) could be developed to state Optimise development opportunities
to develop and enhance local distinctiveness and character and Maximise the
contribution intrigue, character and surprise into the built environment.
Objective 3 (p. 39) could be linked to objective 12 with specific regard to reusing
existing buildings.
Objectives 6 and 7 (p. 42) could be linked to objective 12 in terms of the sustainable
adaption and reuse of existing buildings, and embodied energy that historic buildings
contain.
Objectives 9 and 10 (pp. 43-44) could be linked to objective 12 in terms of better
revealing heritage significance and helping people enjoy the Grand Union Canal

Response

Agree. Wording for Objective 12

amended.
Disagree. Wording considered to be
appropriate for minimising loss of heritage
assets.
Agree. Text amended to reflect this.
Disagree. Although the suggestion would
be beneficial, it is not appropriate for the
role of an IIA objective.

Agree. Wording for Objectives 1, 3, 6, 7, 9

and 10 amended.

19

Page 402

Respondent

Relevant comment extract

Response

Historic
England

Question E.
Is there any additional baseline information that you feel it would be important to
include?
In addition to the general points raised above that relate to the baseline information, we
are pleased to note that the English Heritage Old Oak Area Assessment is mentioned
on p. 23 of the Baseline Data review. We would encourage the OPDC to complete a
similar piece of characterisation work for the Park Royal area. Further work considering
particular areas or building types may also help inform later stages of the plan making
process. These are likely to be particularly useful if the OPDC choose to designate any
conservation areas or create a local list of buildings and structures of heritage
significance.

Noted.

Historic
England

Question F.
Are there any particular topics or geographical areas of specific concern to your
organisation?
As our comments on the IIA highlight, the most sensitive and significant heritage
assets that will be affected by development in the opportunity area, are those located
outside of its boundaries. The most notable of these is Kensal Green Cemetery. The
consequence of this is that the setting of heritage assets should be an important
consideration in the development of the Local Plan to ensure that it will result in
sustainable development as defined by the NPPF. We look forward to working with the
OPDC in developing the local plan to achieve this aim, as well as to develop
characterful places that will add to Londons rich built legacy.

Noted.

20

Respondent

Historic
England
Archaeology

Page 403
Natural
England

Relevant comment extract

We welcome the references to archaeology in the scoping report. Whilst there are at
present no archaeological priority areas within the proposed local plan area, the
Greater London Historic Environment Record holds information on several
archaeological investigations, sites and finds. Notably the site of Acton Wells 18th
century spa is located within the Opportunity Area. The open ground of Wormwood
Scrubs was the site of a rifle range and anti-aircraft battery and may preserve as yet
undiscovered earlier remains. The Grand Junction Canal
and Old Oak Common area include aspects of railway and industrial archaeological
interest. The 19th century Park Royal cemetery would also be of interest if subject to
redevelopment.
Thus although the Opportunity Area is not generally of high archaeological potential,
major redevelopment could affect a range of undesignated heritage assets of
archaeological interest. With the Mayors support Historic England has recently
consulted upon and is now finalising guidance for the comprehensive review
programme for Londons Archaeological Priority Areas so we recommend that this
document is referred to as a relevant Regional Policy & Programme. A desk-based
appraisal should then be undertaken to identify areas of
known or potential archaeological interest meriting identification as new priority areas
to inform implementation of NPPF historic environment policy.
Under the section looking at the Review of plans and programmes in Table 4.1 where
West London is considered, the entry for the West London Waste Plan can be updated
to say that the plan has now been adopted and is no longer the Proposed Submission
Plan.

Response

Noted. Text added to baseline and key

issues. The guidance itself is not
considered to be a PPP, although
subsequent strategies or baseline data
will be added at a later stage of the IIA as
part of the iterative process.

Agree. Text amended to reflect this.

21

Respondent

Relevant comment extract

1. Additional Consultation, (paragraph 1.9.3, page 6) of the Scoping Report says An

important element of the IIA, HIA and EqIA in particular, is to engage the community
throughout the development of the Local Plan. As such, key representatives from the
community will be consulted. These representatives have been identified in
collaboration with the OPDC Community Engagement Officer.
Resident

Page 404

We note that we have not been approached by OPDC officers regarding the scoping
report and know no others that have been. (NB this was discussed at the GUA meeting
on 7th October). We would very much like to know - who have been identified as key
representatives, what was the process for their identification and have any of those
identified been advised of this.

Resident

2. Community members have not been involved in discussion around the scoping
report; the formative stage of the development of the Local Plan, thus the opportunity
for inclusion of community-based realistic alternatives to be included in the OPDCs
Issues & Options Local Plan has not been proactively provided.

Response
OPDCs Communications and Community
Engagement team has been liaising with
relevant community groups and
stakeholders to identify key points of
contact in these groups. A consultation
database has been compiled on this basis
and the IIA Scoping Report was sent on 4
September 2015 to all stakeholders on
this database. A copy of the Scoping
Report was also placed on OPDCs
website. The IIA was publicly consulted
on from 4 September to 9 October 2015.
With regards to the IIA consultation,
OPDC officers spoke with Amanda Souter
(Resident Board Member) and Rahul
Gokhale (Business Community Board
Member) on 4 and 7 September and
asked them to be representatives of the
community in respect of the IIA. These
are considered to be well placed to
undertake this given their roles on the
OPDC Board and wider community
activities.
The SEA Directive requires OPDC to
consult the Consultation Bodies on the
scope and level of detail of the
Environmental Report (in this case a full
Integrated Impact Assessment Report,
which will ultimately document the
findings of the IIA). The Consultation
Bodies are Historic England, Natural
England and the Environment Agency.
To enable a wider range of stakeholders
to input into the Local Plan development
process from an early stage, OPDC
22

Respondent

Relevant comment extract

Response
considered it appropriate to exceed
legislative requirement and invite
interested parties to submit comments.
All stakeholders on OPDCs consultation
database were contacted via email on 4
September 2015 and a copy was placed
on OPDCs website.

Page 405

OPDC is in week 30 of a 25-30 year

project. The statutory function as a local
planning authority means that staffing has
focused on a team that will progress
evidence base for policies and ensure
robust processes are in place to manage
planning applications. The Strategy and
Programmes team, including
Communications and Engagement, is still
embryonic; therefore, your patience is
appreciated while the Corporation
continues to staff up to serve local
residents and businesses, meet groups to
forge relationships and works to set-up a
community group.
On 12 October, OPDC Communications
and Planning officers presented to a small
group of GUA members to start these
meetings and to explain how local
communities can get involved in the
planning process. OPDC convened a
second meeting with GUA members on 3
November to discuss the Scoping Report
and wider Local Plan process with a
public workshop on the vision and
objectives held on 30 November prior to
the Local Plan consultation in early 2016.

23

Respondent

Relevant comment extract

Response
The provided community-based vision
and objectives provide a comprehensive
and detailed range of suggestions which
are being used to directly inform the draft
Local Plan proposed vision and
objectives. Where the suggestions are
more relevant for policy options, these
have also been used to inform the
development of these options.

The European Assessment Directive or the European Union requires that realistic
alternatives are assessed. Recent legal judgements have also asserted the importance
of public authorities consulting upon arguable yet discarded options.
Resident

Page 406

We ask that community-based alternatives set out in the following Vision and
Objectives are assessed, with positive and negative effects identified, and included in
the OPDCs Issues & Options Local Plan.

As the provided community-based vision

and objectives have directly and positively
informed the development of the draft
OPDC Local Plan, that will be subject to
the IIA, a separate IIA on these is not
considered necessary.
Following a public workshop on the vision
and objectives on 30 November, further
community input has been provided into
the development of the vision and
objectives.
As agreed at the workshop, feedback on
this work and how the provided
community-based vision and objectives
have informed the Local Plan will be
provided in January 2016. There will also
be subsequent opportunity to comment on
the vision and objectives during the first
Local Plan consultation from February
2016.

24

Respondent

Page 407

Resident

Relevant comment extract

3. A key issue for all section of the community in and around the OPDC is the impact of
a 30 year construction period including issues of dust, noise, vibration and pollution,
and ability of the boroughs to meet the potential accommodation, facilities and amenity
needs of construction workers. This has not been fully considered in the report. It must
be fully identified and planned for as quite separate IIA and Local Plan objectives.

Response
Agree. Amendments made:
Key Sustainability issues and
opportunities
Health (p.25) Construction phase
impacts should be considered within the
Local Plan, around timing of construction
and the impact it has on communities including both psychological and physical
effects.
Air quality (p.26) The Local Plan should
ensure that impacts on air quality resulting
from demolition and construction are
minimised, specifically with regard to local
communities.
Transportation (p.32) Opportunities
should be sought to develop road
infrastructure that supports economic
growth. During construction in particular,
the Local Plan should consider the
limitations of the road network and the
potential impact from construction on
existing businesses that are reliant on the
existing road network and local
communities.
Draft IIA Objectives and sub-objectives
4. Minimise the need to travel and
improve accessibility for all users by
public and non-motorised transportation
methods.
Consider the impact of construction on
local infrastructure on local businesses
and communities.
Mitigate the impact of construction traffic
11. To minimise air, noise and light
pollution, particularly for communities and
vulnerable groups
Minimise noise pollution caused by
25

Respondent

Relevant comment extract

Response

Page 408

traffic and commercial uses during the

construction and operation of
development on existing and future
communities, through the use of
mitigation measures and the locating of
future sensitive users away from pollution
generators.
Minimise air pollution caused by traffic
and commercial uses during the
construction and operation of
development on existing and future
communities, through the use of
mitigation measures and the locating of
future sensitive users away from pollution
generators.
Minimise light pollution
13. Increase community cohesion and
reduce social exclusion
Manage the construction process to
reduce the impact of a potentially large
transitory construction workforce on the
local community, specifically in relation to
social infrastructure and housing
provision.
15. Maximise the health and wellbeing of
the population, reduce inequalities in
health and promote healthy living
Minimise construction phase impacts on
communities, in relation to both physical
and psychological health

26

Respondent

Relevant comment extract

1. Additional Consultation, (paragraph 1.9.3, page 6) of the Scoping Report says An

important element of the IIA, HIA and EqIA in particular, is to engage the community
throughout the development of the Local Plan. As such, key representatives from the
community will be consulted. These representatives have been identified in
collaboration with the OPDC Community Engagement Officer.
Resident

Page 409

We note that we have not been approached by OPDC officers regarding the scoping
report and know no others that have been. (NB this was discussed at the GUA meeting
on 7th October). We would very much like to know - who have been identified as key
representatives, what was the process for their identification and have any of those
identified been advised of this.

Resident

2. Community members have not been involved in discussion around the scoping
report; the formative stage of the development of the Local Plan, thus the opportunity
for inclusion of community-based realistic alternatives to be included in the OPDCs
Issues & Options Local Plan has not been proactively provided.

Response
OPDCs Communications and Community
Engagement team has been liaising with
relevant community groups and
stakeholders to identify key points of
contact in these groups. A consultation
database has been compiled on this basis
and the IIA Scoping Report was sent on 4
September 2015 to all stakeholders on
this database. A copy of the Scoping
Report was also placed on OPDCs
website. The IIA was publicly consulted
on from 4 September to 9 October 2015.
With regards to the IIA consultation,
OPDC officers spoke with Amanda Souter
(Resident Board Member) and Rahul
Gokhale (Business Community Board
Member) on 4 and 7 September and
asked them to be representatives of the
community in respect of the IIA. These
are considered to be well placed to
undertake this given their roles on the
OPDC Board and wider community
activities.
The SEA Directive requires OPDC to
consult the Consultation Bodies on the
scope and level of detail of the
Environmental Report (in this case a full
Integrated Impact Assessment Report,
which will ultimately document the
findings of the IIA). The Consultation
Bodies are Historic England, Natural
England and the Environment Agency.
To enable a wider range of stakeholders
to input into the Local Plan development
process from an early stage, OPDC
27

Respondent

Relevant comment extract

Response
considered it appropriate to exceed
legislative requirement and invite
interested parties to submit comments.
All stakeholders on OPDCs consultation
database were contacted via email on 4
September 2015 and a copy was placed
on OPDCs website.

Page 410

OPDC is in week 30 of a 25-30 year

project. The statutory function as a local
planning authority means that staffing has
focused on a team that will progress
evidence base for policies and ensure
robust processes are in place to manage
planning applications. The Strategy and
Programmes team, including
Communications and Engagement, is still
embryonic; therefore, your patience is
appreciated while the Corporation
continues to staff up to serve local
residents and businesses, meet groups to
forge relationships and works to set-up a
community group.
On 12 October, OPDC Communications
and Planning officers presented to a small
group of GUA members to start these
meetings and to explain how local
communities can get involved in the
planning process. OPDC convened a
second meeting with GUA members on 3
November to discuss the Scoping Report
and wider Local Plan process with a
public workshop on the vision and
objectives held on 30 November prior to
the Local Plan consultation in early 2016.

28

Respondent

Relevant comment extract

Response
The provided community-based vision
and objectives provide a comprehensive
and detailed range of suggestions which
are being used to directly inform the draft
Local Plan proposed vision and
objectives. Where the suggestions are
more relevant for policy options, these
have also been used to inform the
development of these options.

The European Assessment Directive or the European Union requires that realistic
alternatives are assessed. Recent legal judgements have also asserted the importance
of public authorities consulting upon arguable yet discarded options.
Resident

Page 411

We ask that community-based alternatives set out in the following Vision and
Objectives are assessed, with positive and negative effects identified, and included in
the OPDCs Issues & Options Local Plan.

As the provided community-based vision

and objectives have directly and positively
informed the development of the draft
OPDC Local Plan, that will be subject to
the IIA, a separate IIA on these is not
considered necessary.
Following a public workshop on the vision
and objectives on 30 November, further
community input has been provided into
the development of the vision and
objectives.
As agreed at the workshop, feedback on
this work and how the provided
community-based vision and objectives
have informed the Local Plan will be
provided in January 2016. There will also
be subsequent opportunity to comment on
the vision and objectives during the first
Local Plan consultation from February
2016.

29

Respondent

Relevant comment extract

Response
Agree. Amendments made:

Page 412

Resident

3. A key issue for all section of the community in and around the OPDC is the impact of
a 30 year construction period including issues of dust, noise, vibration and pollution,
and ability of the boroughs to meet the potential accommodation, facilities and amenity
needs of construction workers. This has not been fully considered in the report. It must
be fully identified and planned for as quite separate IIA and Local Plan objectives.

Key Sustainability issues and

opportunities
Health (p.25) Construction phase
impacts should be considered within the
Local Plan, around timing of construction
and the impact it has on communities including both psychological and physical
effects.
Air quality (p.26) The Local Plan should
ensure that impacts on air quality resulting
from demolition and construction are
minimised, specifically with regard to local
communities.
Transportation (p.32) Opportunities
should be sought to develop road
infrastructure that supports economic
growth. During construction in particular,
the Local Plan should consider the
limitations of the road network and the
potential impact from construction on
existing businesses that are reliant on the
existing road network and local
communities.
Draft IIA Objectives and sub-objectives
4. Minimise the need to travel and
improve accessibility for all users by
public and non-motorised transportation
methods.
Consider the impact of construction on
local infrastructure on local businesses
and communities.
Mitigate the impact of construction traffic
11. To minimise air, noise and light
pollution, particularly for communities and
vulnerable groups
30

Respondent

Relevant comment extract

Response

Page 413

Minimise noise pollution caused by

traffic and commercial uses during the
construction and operation of
development on existing and future
communities, through the use of
mitigation measures and the locating of
future sensitive users away from pollution
generators.
Minimise air pollution caused by traffic
and commercial uses during the
construction and operation of
development on existing and future
communities, through the use of
mitigation measures and the locating of
future sensitive users away from pollution
generators.
Minimise light pollution
13. Increase community cohesion and
reduce social exclusion
Manage the construction process to
reduce the impact of a potentially large
transitory construction workforce on the
local community, specifically in relation to
social infrastructure and housing
provision.
15. Maximise the health and wellbeing of
the population, reduce inequalities in
health and promote healthy living
Minimise construction phase impacts on
communities, in relation to both physical
and psychological health

31

Page 414

Respondent

Relevant comment extract

Response

Resident

Design Strategy & Density: all new design should be in keeping with the original
architecture of the area, which is Victorian and Edwardian. Constructions should only
be 5 storeys high near the main station or commercial hubs, but residential dwellings
should be lower and be surrounded by sufficient green areas (currently underrepresented on the Old Oak Green Grid on page 39) for a village feel. No tall buildings
should be visible from the TITRA conservation area or Park Royal Bridge. Any plan to
repeat the bland, gloomy, soulless design of North Acton should be immediately
discarded - that recent development is an eyesore. Only appealing and thoughtful
development please.

Noted. The following objectives consider

the design, massing and height of
buildings: Objective 1 considers
enhancement of the built environment and
encouragement of place-making.
Objective 2 considers the optimisation of
the efficient use of land through increased
development densities and building
heights, where appropriate.

Resident

Old Oak Lane should become a secondary road and be freed from lorries and HGVs,
many of which are a danger to pedestrians due to the high speed at which they drive.
Trucks and large commercial vehicles should be redirected to Atlas Road and the new
highways connecting Hythe Road and Old Oak Common, for example. Channel Gate
Road, which was created by bulldozing our Victorian cottages must be closed down,
landscaped, and given back to the TITRA community for future generations.

Noted. Objective 4 considers the transport

network and Objective 14 considers the
use of traffic calming measures.

Resident

Regarding the need to liaise with the local communities that will not be a problem. We
have always welcomed the opportunity and pro-actively asked to engage if necessary.

Noted.

Resident

Can I also say that I was surprised to read in your literature that 'the wider area around
Old Oak and Park Royal contains some of the most deprived communities in England'.
Did a resident pen this, or someone who has never lived here? Please explain.

Noted. This statement is based on the

Indices of Multiple Deprivation.

Resident

You should change all references to "Middlesex Hospital" to "Central Middlesex

Hospital".

Agree. Text amended to reflect this.

RBKC

(a) Do you have any further suggestions regarding the scope of the IIA and its
proposed appraisal of the Local Plan?
In terms of the spatial scope which is set out at section 2.2, RBKC notes that Studies
in relation to the effects on local populations in the neighbouring areas to the OPDC
boundary are currently ongoing. However, we would further welcome specific mention
of local populations in the neighbouring area of RBKC. We would also anticipate that
these additional studies will account for the Kensal Canalside Opportunity Area which
is proximate to the OPDC.

Disagree. Reference to local populations

in neighbouring areas is considered
sufficient for the purposes of the draft IIA
Scoping Report

32

Relevant comment extract

Response

RBKC

(b) Are there any additional PPPs that should be considered for review?
RBKC considers that the following documents are absent from Table 4-1 and should
be included because their implications go beyond authority boundaries:
Kensington & Chelsea
Consolidated Local Plan (July 2015) particularly with regard to Chapter 3 Our
Vision and Strategic Objectives (including the Key Diagram) and Chapter 5 Kensal,
Chapter 20 Kensal Gas Works
Surface Water Management Plan (SWMP, February 2014)
Local Flood Risk Management Strategy (LFRMS, July 2015)
Issues and Options Paper for Kensal Gasworks (June 2012)
St Quintin and Woodlands Draft Neighbourhood Plan (May 2015)
Regional / London
Social Infrastructure SPG (May 2015)
The Control of Dust and Emissions During Construction and Demolition SPG (July
2014)
Town Centres SPG (July 2014)
London Planning Statement SPG (May 2014)
London Infrastructure Plan 2050 Update (March 2015)
National
National Planning Policy for Waste (October 2014)
Planning Policy for Traveller Sites has since been updated in August 2015
Written Ministerial Statement: Sustainable Drainage Systems (December 2014)
(equivalent to national planning policy)

Agree. Text amended. It is considered

that the London Planning Statement SPG
is more relevant to the Local Plan
preparation than the IIA.

RBKC

(c) Are there any additional themes that could be drawn out of the review of
PPPs?
RBKC considers the themes which have been identified are comprehensive for the
purposes if the Impact Assessment.

Noted

RBKC

(d) Do you agree with the sustainability issues and opportunities that we have
identified? Are there additional issues that both the IIA and the Local Plan
should consider?
RBKC welcomes the section 5.4 which addresses cross boundary considerations and
references St Marys and Kensal Green Cemetery. However, we would encourage the
OPDC to expand on a commitment to stitching the edge, a principle mentioned at the
scoping meeting (21 July 2015). There is no reference to consideration of how
boundaries will be developed in this IIA document, or how potential issues could be

Page 415

Respondent

Agree. Objective 2, bullet point 2

amended to state: Optimise development
density in a way that makes the most
efficient use of land whilst meeting
commercial needs and responding to
sensitive areas.
Agree. Objective 4, bullet point 2, will be
amended to state: Increase the
33

Respondent

Relevant comment extract

Response

mitigated. This is of particular importance for Kensal Canalside.

connection of the public realm and

internal routes to neighbouring areas
alongside local and strategic cycle and
walking networks including via green
infrastructure networks and the canal

Page 416

RBKC

(f) Are there any particular topics or geographical areas of specific concern to
your organisation?
Yes, as discussed above RBKC is mainly concerned about the cross boundary
considerations, including Kensal Canalside, St Marys and Kensal Green Cemetery,
and also the economic impact particularly on retail centres and transport linkages.
RBKC is also concerned about the impact on surface water drainage and flooding in
the Counters Creek catchment area, which includes a large proportion of RBKCs area.
Please see RBKCs response to the Old Oak and Park Royal Planning Opportunity
Area Framework document (14 April 2015).

Noted. Objective 4 considers surface

water drainage and flooding.

RBKC

(g) Are there any changes you consider should be made to the IIA Framework, IIA
Objectives / sub-objectives or indicators?
The Council reiterates its request that direct reference is made to improving links to
other opportunity areas via rail. Both Crossrail (Kensal Canalside) and the Overground
(White City) stand to benefit from direct access to the Opportunity Areas and
embracing connectivity between the Mayors key growth areas should be included
within the objectives and indicators.

Agree. Objective 4, bullet point 2,

amended to state: Increase the
connection of the public realm and
internal routes to neighbouring areas
alongside local and strategic cycle and
walking networks including via green
infrastructure networks and the canal

RBKC

The Council welcomes the indicator for objective 12 which includes Decrease in the
number of Heritage Assets at Risk in and around the area. However, we would
request that St Marys and Kensal Green Cemetery is mentioned as it borders the
OPDC area, and so the need to protect this heritage assets context is critical.

Disagree. Reference to heritage assets at

risk in and around the area is considered
sufficient for the purposes of the draft IIA
Scoping Report

34

Respondent

St Quintin and
Woodlands
Neighbourhood
Forum

Relevant comment extract

Page 417

General
The document has been published for consultation with no covering statement from the
OPDC. It is a lengthy and technical document, which contains no summary of
conclusions as to its implications for the development of the OPDC Local Plan. As a
document on which the general public and local residents
associations can become meaningfully engaged, it is challenging to say the least.
Nevertheless, the document states at paragraph 1.9.3 that An important element of the
IIA, HIA and EqIA in particular, is to engage the community throughout the
development of the Local Plan. As such, key representatives from the community will
be consulted. These representatives have been identified in collaboration with the
OPDC Community Engagement Officer.
As far as we can ascertain through contact with many local residents associations and
community organisations, there has been no such attempt to draw the attention to this
document to key representatives from the community. It has been published on the
OPDC consultation webpage, but we are not aware of any further efforts to draw it to
the attention of those living in and around the OPDC area. We wish this to be noted as
a matter of record.

Response
OPDCs Communications and Community
Engagement team has been liaising with
relevant community groups and
stakeholders to identify key points of
contact in these groups. A consultation
database has been compiled on this basis
and the IIA Scoping Report was sent on 4
September 2015 to all stakeholders on
this database. A copy of the Scoping
Report was also placed on OPDCs
website. The IIA was publicly consulted
on from 4 September to 9 October 2015.
With regards to the IIA consultation,
OPDC officers spoke with Amanda Souter
(Resident Board Member) and Rahul
Gokhale (Business Community Board
Member) on 4 and 7 September and
asked them to be representatives of the
community in respect of the IIA. These
are considered to be well placed to
undertake this given their roles on the
OPDC Board and wider community
activities.

35

Respondent

Relevant comment extract

Response
Noted. Information has been added to
section2.2.1 . The draft IIA Scoping
Report represents the initial stage in the
SA process for the emerging Local Plan
and sets the scope for the remainder of
the process. Its purpose is to:

St Quintin and
Woodlands
Neighbourhood
Forum

Page 8 on Assessment of Alternatives for SEA screening states It is a requirement of

the SEA Directive that reasonable alternatives are assessed and, therefore,
alternative options will be assessed using the IIA Framework. In accordance with
NPPG:
The sustainability appraisal should predict and evaluate the effects of the preferred
approach and reasonable alternatives and should clearly identify the significant
positive and negative effects of each alternative.

Page 418

We have struggled to find any part of the Hyder report which sets out any reasonable
alternatives ...

Set the scope and level of detail of the

SA;
Identify relevant plans, policies,
programmes and initiatives that will inform
the SA process and the Local Plan;
Identify relevant baseline information;
Identify key sustainability issues and
problems; and
Present an SA Framework, consisting of
sustainability objectives and indicators,
against which the Local Plan can be
assessed.
Assessment of Alternatives relates to the
options suggested in the Regulation 18
version of the draft Local Plan.

36

Respondent

Relevant comment extract

Response

... or explains why it is assumed that the OPDC area should be planned on the basis of
an incoming 24,000 homes and 55,000 jobs. These figures are now included in the
2015 London Plan, as a result of the additions made through the FALP exercise. But
we can find little or no rationale or detailed justification for these targets in the FALP
documentation.
In the IIA there is a statement at Appendix C Baseline Data Page 2 which reads Given
the proposed minimum new homes of 25,500 this density is set to change. No
explanation of the rationale or planning justification for this proposed new density for
the OPDC area is provided.

Page 419

St Quintin and
Woodlands
Neighbourhood
Forum

Hammersmith and Fulham Council consulted on a revised Draft Local Plan from 9th
January to 20th February 2015. We appreciate that planning powers for this northern
part of the borough are now in the hands of the OPDC, but this does not negate the
work that the Borough Council has previously undertaken in respect of the Old Oak
area.
This LBHF Draft Local Plan stated in relation to the Old Oak Opportunity Area at
paragraph 6.8 The Mayor of Londons Further Alterations to the London Plan (FALP)
2014 identifies Old Oak as an Opportunity Area. It includes land in the OORA in LBHF
and land within the London Boroughs
of Ealing and Brent and covers 155 hectares in total. The Opportunity Area is identified
as having the potential to provide up to 24,000 homes and 55,000 jobs, making it
Londons largest Opportunity Area in terms of its potential contribution to growth. The
Council considers that approximately 18,000 homes and 50,000 jobs could be
accommodated within LBHF and that approximately 6,000 homes and 20,000 jobs
could be delivered within the next 20 years covered by this Local Plan, thereby helping
to accommodate a substantial quantum of Londons homes
and jobs needs. It is important that the new homes are available to Londoners rather
than to international investors.

The current version of the London Plan

(consolidated with amendments with from
the FALP) was adopted in March 2015
following an Examination in Public.
As such the London Plan's minimum
housing targets and indicative
employment figures for Old Oak and Park
Royal are form part of the Development
Plan for the OPDC area.
The Old Oak and Park Royal OAPF
supplements the London Plan,
establishing the principles for the range of
densities across Old Oak.
This strategic planning policy and
guidance provides the baseline for the
draft IIA Scoping Report.

37

Respondent

St Quintin and
Woodlands
Neighbourhood
Forum

Relevant comment extract

Response

We support the view of LBHF that planning for 24,000 homes, rather than
approximately 18,000, is potentially excessive development of the OPDC area and
needs a fuller justification than has as yet been provided. The risk remains that such
development will lead to densities and building
heights which fail to integrate with existing communities in the area, and which will
overload the road network and other infrastructure such a drainage and water supply.

The current version of the London Plan

(consolidated with amendments with from
the FALP) was adopted in March 2015
following an Examination in Public.

Page 420

The LBHF Draft Local Plan suggests a series of options for the Old Oak Regeneration
Area Alternative Options - Policy OORA (Strategic Policy Old Oak Regeneration
Area)
Maintain the current policy where existing strategic industrial land and waste uses are
safeguarded.
Defer the regeneration of parts of the site until suitable transport nodes are operational
Optimise the quantum of development as far as possible but prohibit tall buildings in
the regeneration area.
Rather than a mix of employment and residential, land use could be weighted towards
the provision of employment.
Rather than a mix of employment and residential, land use could be weighted towards
the provision of more residential use.
The St Quintin and Woodlands Forum supports the use of the Old Oak regeneration
area for a combination of new jobs and new homes. But we have serious concerns that
the London Plan targets severely under-estimate the capacity of the existing and
planned road network to cope with the scale of development envisaged, and as
reflected in Hyders IIA scoping study. We understand that EU and UK SEA legislation
requires that reasonable alternatives are consulted on, and we do not see that this
has happened in this case?

As such the London Plan's minimum

housing targets and indicative
employment figures for Old Oak and Park
Royal are form part of the Development
Plan for the OPDC area.
The Old Oak and Park Royal OAPF
supplements the London Plan,
establishing the principles for the range of
densities across Old Oak.
This strategic planning policy and
guidance provides the baseline for the
draft IIA Scoping Report.
Assessment of Alternatives relates to the
options suggested in the Regulation 18
version of the draft Local Plan.

38

Respondent

Relevant comment extract

Response

Paragraph 4.2 of the Hyder document is headed Key Results from the Review and
reads:

St Quintin and
Woodlands
Neighbourhood
Forum

Environmental, social and economic objectives and issues identified in the review of
plans, programmes and environmental protection objectives (PPPs) of relevance to the
IIA were used to generate a series of common themes. Appendix B presents a
summary of how the identification of common themes relates to each of the PPPs
reviewed. How these themes relate to the relevant assessment processes is presented
in Table 4-2. The results of this assessment have been used to inform the
development of the draft IIA Framework. How the resulting draft Objectives relate to
the identified themes is also shown in Table 4-2.

Noted. Table 4-2 renamed 'Results of

review of Plans, Policies and
Programmes.

Page 421

It is very hard for the lay reader or member of the public can understand how the
subsequent table can be labelled as Key Results. There are no results stated. The
document states the results of this assessment have been used to inform the
development of the draft IIA framework, without explaining in what manner? There is
no sense of which findings or results from the assessment have proved more
influential than any other.
The current version of the London Plan
(consolidated with amendments with from
the FALP) was adopted in March 2015
following an Examination in Public.

St Quintin and
Woodlands
Neighbourhood
Forum

On question a) the scope of the IIA seems inadequate in failing to provide any
explanation or jus-tification for the main London Plan policies for the OPDC Local Plan
(55 jobs and 24,000 homes) and failing to identify or explore any reasonable
alternatives.

As such the London Plan's minimum

housing targets and indicative
employment figures for Old Oak and Park
Royal are form part of the Development
Plan for the OPDC area.
The Old Oak and Park Royal OAPF
supplements the London Plan,
establishing the principles for the range of
densities across Old Oak.
This strategic planning policy and
guidance provides the baseline for the
39

Respondent

Relevant comment extract

Response
draft IIA Scoping Report.

Page 422

St Quintin and
Woodlands
Neighbourhood
Forum

The island
triangle
residents
association

On question d) sustainability issues which are not explored include the scale of
proposed development on local infrastructure (road network, sewers and drainage,
water supply) all of which are already vulnerable to the cumulative impact of approved
developments in White City East (Imperial West, Westfield 2, Stanhope/BBC, St
James).

The document is very encouraging. TITRA strongly supports the emerging themes
such as:
- Increasing economic development and encouraging upskilling, employment and
inward investment
- Renewal of existing business sites (including brownfield) to enable future
development / business growth
- Different types of residential housing, especially affordable
- Improving transport, particularly rail, cycling and pedestrian access
- Social infrastructure, whether shops, schools, health care units and other amenities

Noted. Title of Objective 4 amended to

state Minimise the need to travel, improve
accessibility for all users by public and
non-motorised transportation methods
and mitigate impacts on the transport
network.
Objective 9 considers the capacity of
water infrastructure to meet future
demand.

Noted.

40

Respondent

Relevant comment extract

2.1. No commitment to existing communities
We, as local residents, believe that the IIA must have explicit PPPs for safeguarding
and enhancing existing residential communities.
There are 5,000 people living in large and small housing estates and cottages and they
seem to be absent from the document or the workshops that preceded it. These
residential areas have a range of construction, waste-related and other pollution and
transport issues (from development being pushed to the edges of London boroughs)
which require direct consideration (and suitable mitigation) by the Local Plan
assessment:

Page 423

The island
triangle
residents
association

Area Major issues

North Acton conservation area Heavy traffic & pollution from HGVs on Old Oak Lane /
same issues from HGVs using Channel Gate Road access to Willesden Euroterminal
Powerday waste plant pollution and odours since its opening
Clean Power energy recovery plant - in partnership with Network Rail which
threatens pollution in Kensal Rise and Harlesden as well as the North Acton
conservation area
Years of disruption from HS2 construction works & traffic access to Euroterminal site
Parking and rubbish dumping issues
Wells House Road Encirclement and land take from HS2 construction
Years of serious disruption from HS2 construction / TfL Old Oak Common station
construction
Midland Terrace Years of serious disruption from HS2 construction / TfL Old Oak
Common station construction.
Wesley Road Lack of amenities such as shops
Parking issues
The advent of HS2 in summary will lead to land-take, disruption from 24/7 construction
and
road closures which will, to say the least, degrade the quality of life in these different
communities. This association believes that these issues must be properly assessed
by
proper monitoring / data, taking on board residents' views and adopting preventative
measures where possible.

Response
Agree. Amendments made:
Key Sustainability issues and
opportunities
Health (p.25) Construction phase
impacts should be considered within the
Local Plan, around timing of construction
and the impact it has on communities including both psychological and physical
effects.
Air quality (p.26) The Local Plan should
ensure that impacts on air quality resulting
from demolition and construction are
minimised, specifically with regard to local
communities.
Transportation (p.32) Opportunities
should be sought to develop road
infrastructure that supports economic
growth. During construction in particular,
the Local Plan should consider the
limitations of the road network and the
potential impact from construction on
existing businesses that are reliant on the
existing road network and local
communities.
Draft IIA Objectives and sub-objectives
4. Minimise the need to travel and
improve accessibility for all users by
public and non-motorised transportation
methods.
Consider the impact of construction on
local infrastructure on local businesses
and communities.
Mitigate the impact of construction traffic
11. To minimise air, noise and light
pollution, particularly for communities and
vulnerable groups
41

Respondent

Relevant comment extract

Response

Page 424

Minimise noise pollution caused by

traffic and commercial uses during the
construction and operation of
development on existing and future
communities, through the use of
mitigation measures and the locating of
future sensitive users away from pollution
generators.
Minimise air pollution caused by traffic
and commercial uses during the
construction and operation of
development on existing and future
communities, through the use of
mitigation measures and the locating of
future sensitive users away from pollution
generators.
Minimise light pollution
13. Increase community cohesion and
reduce social exclusion
Manage the construction process to
reduce the impact of a potentially large
transitory construction workforce on the
local community, specifically in relation to
social infrastructure and housing
provision.
15. Maximise the health and wellbeing of
the population, reduce inequalities in
health and promote healthy living
Minimise construction phase impacts on
communities, in relation to both physical
and psychological health

42

Respondent

Page 425

The island
triangle
residents
association

Relevant comment extract

In addition, the North Acton road infrastructure as a whole is already overworked and
beset
by traffic jams through the day often because of very minor roadworks which leads
to
increased levels of pollution.
Our association believes that the authorities together with local residents will have to
set up
local air quality monitoring capabilities locally to align with the Local Plan with Theme
5s
aspiration of improving air quality. Whatever the planned level of development,
residents (in
existing and new communities) need proof that nearby activities - waste sites, major
construction work like HS2 aren't causing problems.
TITRA has recently taken part in a small academic study by Mapping for Change, a
whollyowned
subsidiary of UCL, which has confirmed that properties on Old Oak Lane experience
NO2 levels above EU limits (BBC London report on the project is here:
http://www.bbc.co.uk/news/uk-england-london-34439468).
However, the TITRA community has no localised monitoring of risks such as
particulates
(PMs) which present an even more alarming pollution risk, given multiple local waste
sites,
waste haulage, cement batching, excavation and construction material stockpiling and
rail
transport activities in North Acton alone. Since TITRA has been able to do air quality
NO2
monitoring at very modest cost, and the association is aware that the OPDC is starting
to
collaborate with smart city technology providers, we believe that localised air quality
monitoring would be a realistic and an invaluable application for such technologies.

Response

Noted. This information will be used to

inform the emerging Air Quality Study and
proposed air quality policies within the
emerging Local Plan and OPDC corporate
environmental target setting. An additional
indicator has been added in IIA Objective
11.

TITRA asks that these different environmental pollution and construction blight issues
are explicitly acknowledged in the IIA and commitments to remedial measures brought
into its core themes.

43

Relevant comment extract

Response

The island
triangle
residents
association

2.2 No waste treatment plants near residents homes

TITRA notes that under IIA Theme 8: waste management, that the OPDC wants to
reduce waste displacement (exporting domestic waste out of London area) and
promote a circular economy for waste, there should be a counterbalancing principle of
no waste treatment sites being located adjacent to resident areas in line with London
Plan 2015s commitment to ensuring quality of life and a clean environment for the
capitals residents.

Noted. Objective 11 amended to

recgonise the need for waste
management facilities to not negatively
impact on sensitives uses including
existing and future homes and building
occupants. A sub objective has been
added in IIA Objective 11.

The island
triangle
residents
association

If the corporation is to realise its target of 24,000 new homes, then our association
believes that it should be clarifying that:
1) energy recovery sites that will adversely affect residential areas / entertainment
/cultural hubs
2) any waste facilities need a major buffer between sites and residential areas TITRA
suggests at least 1000 metres. Sadly, the authorities and borough planners never
seem to accept the misery and degradation to peoples quality of life that arises from
such plants and inadequately-enforced environmental controls. The Old Oak Lane
conservation area (and Harlesden) is proof that a mere 50-100m is nowhere near
sufficient distance between waste processing sites and residential areas, even with the
supposed latest 'best available technology' waste management technology in place.

Noted. This information will be used to

inform the emerging Air Quality Study and
proposed air quality policies within the
emerging Local Plan and OPDC corporate
environmental target setting. A sub
objective has been added in IIA Objective
11.

The island
triangle
residents
association

Also with regard to the waste issue, TITRA is very concerned by the implications of IIA
Theme 3 sub-themes intention to: increase accessibility to household and commercial
sustainable waste management facilities. This statement looks to our association to
be a covert statement of support for the location of waste handling sites along the
canal in Old Oak as envisaged in the 2015 London Plan and the OPDCs OAPF. Our
association cannot accept that intention without clear safeguards and an entirely new
approach by London planning authorities establishing buffer zones between peoples
homes and waste sites.

Noted. It is the intention of the subobjective to minimise travel to such

facilities as household waste recycling
centres, to encourage people to recycle
and minimise travel distances. A sub
objective has been added in IIA Objective
11.

The island
triangle
residents
association

TITRA emphasises that without evidence of new, more sympathetic thinking to existing
and new residents needs and risks to their health, the likely result of the IIAs
potentially ambiguous industrial development and waste treatment themes is that
waste / industrial uses will be pushed to the edge of the development zone
replicating the disastrous development in recent decades whereby the three boroughs
of Ealing, Brent & Hammersmith & Fulham simply pushed development to the margins
i.e. North Acton of their respective areas. This would jeopardise new housing
developments in Old Oak as well as old ones.

Page 426

Respondent

Noted. Objective 11 amended to

recognise the need for waste
management facilities to not negatively
impact on sensitives uses including
existing and future homes and building
occupants.
OPDC Board adopted the West London
Waste Plan to safeguard:
44

Respondent

Relevant comment extract

Response
Twyford Waste Transfer Station;
Quattro, Victoria Road.
In addition OPDC will continue to work
with stakeholders regarding the long-term
aspirations of Powerday.

Page 427

The island
triangle
residents
association

TITRA requires a clear statement for no waste treatment sites near to residential
areas.

Noted. This information will be used to

inform the emerging Air Quality Study and
proposed air quality policies within the
emerging Local Plan and OPDC corporate
environmental target setting.

The island
triangle
residents
association

2.3. Innovation in housing

TITRA welcomes IIA theme 5s commitment to affordable and inclusive housing of a
range of types and tenures, to meet identified local needs but asks whether greater
emphasis can be given to innovative forms of housing for the development area.
While a number of the capitals universities have provided student / graduate
accommodation blocks, these buildings are largely unattractive high rise blocks with
only limited retail space or community resources on the ground floor in the example
of the North Acton gyratory, this is already giving a ghost town feel to the area. The
association believes that the OPDC, with its co-ordinated planning powers for the
development zone, has a unique opportunity to create the conditions for innovative
small-scale housing and rented accommodation types that gets away from the current
trend for ghost towns of high rise blocks.

Agree. Objective 5 to make reference to

the delivery of innovative housing
typologies to meet needs

45

Respondent

The island
triangle
residents
association

Relevant comment extract

3.0 Additional PPPs
3.1 Sustainable communities
TITRA acknowledges that the OPDC has carried out a thorough assessment ahead of
the local plan but there is no sense in the document that the PPPs have really
examined how it is going to deliver sustainable communities.
Looking at the North Acton area alone, apart from The Collectives building on Old Oak
Lane (whose developer has given thought to community needs with a planned
canalside space and multiple building uses), there is little doubt that Old Oak will see
further high rise residential build but the general experience of North Acton (and future
developers plans for Portal Way central area / piazza surrounded by 30-storey plus
buildings) is that there is:

Page 428

Hardly any use of ground floor retail / community facilities

Very limited attempts to animate or liven up public spaces
Mainly high rise units leading to under-used, wind-blown public areas
Existing residential areas are being / will be overwhelmed by high rise units or
isolated by the impacts of construction work being carried over years and decades
The association asks that since the lifeless public space and construction-driven
isolation of existing communities are already issues in North Acton, that it should be
acknowledged and addressed with a core PPP to create the conditions for sustainable
communities in the assessment whether from community events, Wi-Fi in public
spaces and so on.

Response

Noted. It is considered that Objective 1 of

the IIA Framework will address these
potential issues.

46

Page 429

Respondent

Relevant comment extract

The island
triangle
residents
association

4.0. Additional themes

4.1 Greater clarity required on industrial and residential development
TITRA notes that while the Local Plan will boost economic growth and employment,
the IIA has commitments to activities such as waste handling in the zone, which can
potentially be read as encouraging dirty sites in proximity to residential areas.
The result of the less-than-clear industrial development and waste treatment themes in
the IIA document is that waste and industrial uses will potentially be pushed to the
edge of the development zone which could replicate the disastrous and polluting
development in recent decades whereby the three boroughs of Ealing, Brent &
Hammersmith & Fulham simply pushed development to the edge of their boroughs.
These previous, flawed policies have left residential communities like the Old Oak
conservation area with 1) a legacy of pollution and 2) needing to constantly press local
polluters and the authorities to enforce pollution controls. For sites such as
Euroterminal and Powerday, these tasks have been going on for more than a decade.
TITRA asks for explicit commitments by the completed assessment for:
A clear separation of industrial/waste and residential development
Acknowledgment that communities may need information and resources if they are
having deal with such issues
Smart monitoring of polluting sites leading to more effective enforcement of pollution
prevention and controls

Response

Noted. Objective 11 amended to

recognise the need for waste
management facilities to not negatively
impact on sensitives uses including
existing and future homes and building
occupants.
Noted. This information will be used to
inform the emerging Air Quality Study and
proposed air quality policies within the
emerging Local Plan and OPDC corporate
environmental target setting.

47

Respondent

Relevant comment extract

Response
Noted. Amendments to be made:

Page 430

The island
triangle
residents
association

5.0 Do you agree with the sustainability issues identified?

5.1. Mitigation of pollution during Old Oaks redevelopment & beyond
TITRA agrees with the broad idea of making Old Oaks renewal sustainable but it
requires that specific pollution issues as well as the impact of area
construction/transport/logistics on existing communities should be assessed. This
omission has to be resolved with a direct commitment in the IIA to:
Effective monitoring of vehicles and traffic movements on existing as well as new
roads in the development zone (ideally using smart technologies and sensors as
mentioned above)
More effective enforcement of HGV and car pollution controls (including more
effective environmental controls and better supervision of tenant companies working
hours on the Willesden Euroterminal Yard)
Where necessary restriction of HGVs and other polluting vehicles numbers.

Key Sustainability issues and

opportunities
Health (p.25) Construction phase
impacts should be considered within the
Local Plan, around timing of construction
and the impact it has on communities including both psychological and physical
effects.
Air quality (p.26) The Local Plan should
ensure that impacts on air quality resulting
from demolition and construction are
minimised, specifically with regard to local
communities.
Transportation (p.32) Opportunities
should be sought to develop road
infrastructure that supports economic
growth. During construction in particular,
the Local Plan should consider the
limitations of the road network and the
potential impact from construction on
existing businesses that are reliant on the
existing road network and local
communities.
Draft IIA Objectives and sub-objectives
4. Minimise the need to travel and
improve accessibility for all users by
public and non-motorised transportation
methods.
Consider the impact of construction on
local infrastructure on local businesses
and communities.
Mitigate the impact of construction traffic
11. To minimise air, noise and light
pollution, particularly for communities and
vulnerable groups
48

Respondent

Relevant comment extract

Response

Page 431

Minimise noise pollution caused by

traffic and commercial uses during the
construction and operation of
development on existing and future
communities, through the use of
mitigation measures and the locating of
future sensitive users away from pollution
generators.
Minimise air pollution caused by traffic
and commercial uses during the
construction and operation of
development on existing and future
communities, through the use of
mitigation measures and the locating of
future sensitive users away from pollution
generators.
Minimise light pollution
13. Increase community cohesion and
reduce social exclusion
Manage the construction process to
reduce the impact of a potentially large
transitory construction workforce on the
local community, specifically in relation to
social infrastructure and housing
provision.
15. Maximise the health and wellbeing of
the population, reduce inequalities in
health and promote healthy living
Minimise construction phase impacts on
communities, in relation to both physical
and psychological health
This information will be used to inform the
emerging Air Quality Study and proposed
air quality policies within the emerging
Local Plan and OPDC corporate
environmental target setting.
49

Page 432

Respondent

Relevant comment extract

Response

The island
triangle
residents
association

6.1 Waste sites in Old Oak

Aside of the issue of waste sites discussed in section 2.2. above, TITRA is very
concerned by the lack of clarity over the permitted uses of the Willesden Euroterminal
site, including:
1) Pollution from HGV traffic accessing the Euroterminal site
2) The likely use of the site by HS2 for tunnel waste / construction spoil removal
3) Network Rail and its partner Clean Powers plans for developing an energy recovery
site at the Willesden Euroterminal whether HS2 is built or not and whether the
partners have asked the OPDC whether it will support this development.

Noted. This information will be used to

inform discussions with relevant
stakeholders.

The island
triangle
residents
association

The document is very encouraging. TITRA strongly supports the emerging themes
such as:
- Increasing economic development and encouraging upskilling, employment and
inward investment
- Renewal of existing business sites (including brownfield) to enable future
development / business growth
- Different types of residential housing, especially affordable
- Improving transport, particularly rail, cycling and pedestrian access
- Social infrastructure, whether shops, schools, health care units and other amenities

Noted.

50

Respondent

Relevant comment extract

Response

2.1. No commitment to existing communities

We, as local residents, believe that the IIA must have explicit PPPs for safeguarding
and enhancing existing residential communities.

Agree. Amendments made:

There are 5,000 people living in large and small housing estates and cottages and they
seem to be absent from the document or the workshops that preceded it. These
residential areas have a range of construction, waste-related and other pollution and
transport issues (from development being pushed to the edges of London boroughs)
which require direct consideration (and suitable mitigation) by the Local Plan
assessment:

Page 433

The island
triangle
residents
association

Area Major issues

North Acton conservation area Heavy traffic & pollution from HGVs on Old Oak Lane /
same issues from HGVs using Channel Gate Road access to Willesden Euroterminal
Powerday waste plant pollution and odours since its opening
Clean Power energy recovery plant - in partnership with Network Rail which
threatens pollution in Kensal Rise and Harlesden as well as the North Acton
conservation area
Years of disruption from HS2 construction works & traffic access to Euroterminal site
Parking and rubbish dumping issues
Wells House Road Encirclement and land take from HS2 construction
Years of serious disruption from HS2 construction / TfL Old Oak Common station
construction
Midland Terrace At least 6 Years of serious disruption from HS2 construction / TfL
Old Oak Common station construction. The compound behind the houses will only be
released after 2032!
Wesley Road Lack of amenities such as shops
Parking issues
Lack of amenities is true for all the local areas and during construction even the
existing once are likely to disappear.
The advent of HS2 will lead to land-take, disruption from 24/7 construction and road
closures which will to say the least, degrade the quality of life in these communities.
The association feels that these issues some be acknowledged, even if action on them
may necessarily be years away.

Key Sustainability issues and

opportunities
Health (p.25) Construction phase
impacts should be considered within the
Local Plan, around timing of construction
and the impact it has on communities including both psychological and physical
effects.
Air quality (p.26) The Local Plan should
ensure that impacts on air quality resulting
from demolition and construction are
minimised, specifically with regard to local
communities.
Transportation (p.32) Opportunities
should be sought to develop road
infrastructure that supports economic
growth. During construction in particular,
the Local Plan should consider the
limitations of the road network and the
potential impact from construction on
existing businesses that are reliant on the
existing road network and local
communities.
Draft IIA Objectives and sub-objectives
4. Minimise the need to travel and
improve accessibility for all users by
public and non-motorised transportation
methods.
Consider the impact of construction on
local infrastructure on local businesses
and communities.
Mitigate the impact of construction traffic
11. To minimise air, noise and light
pollution, particularly for communities and
vulnerable groups
51

Respondent

Relevant comment extract

Response

Page 434

Minimise noise pollution caused by

traffic and commercial uses during the
construction and operation of
development on existing and future
communities, through the use of
mitigation measures and the locating of
future sensitive users away from pollution
generators.
Minimise air pollution caused by traffic
and commercial uses during the
construction and operation of
development on existing and future
communities, through the use of
mitigation measures and the locating of
future sensitive users away from pollution
generators.
Minimise light pollution
13. Increase community cohesion and
reduce social exclusion
Manage the construction process to
reduce the impact of a potentially large
transitory construction workforce on the
local community, specifically in relation to
social infrastructure and housing
provision.
15. Maximise the health and wellbeing of
the population, reduce inequalities in
health and promote healthy living
Minimise construction phase impacts on
communities, in relation to both physical
and psychological health

52

Respondent

The island
triangle
residents
association

Relevant comment extract

In addition, the North Acton road infrastructure is overworked and beset by traffic jams
through the day which leads to pollution. TITRA has recently carried out its own air
pollution monitoring of NO2 to recognised government standards through Mapping for
Change, a wholly-owned subsidiary of UCL. This small-scale study has confirmed that
properties on Old Oak Lane experience NO2 levels above EU limits.
We ask that these different issues are explicitly acknowledged and scope for future
remedial measures brought into the assessments core themes.

Response

Noted. This information used to inform

proposed air quality policies within the
emerging Local Plan and OPDC corporate
environmental target setting. An indicator
has been added in IIA Objective 11.

Page 435

The island
triangle
residents
association

2.2 No waste treatment plants near residents homes

TITRA notes that under IIA Theme 8: waste management, that the OPDC wants to
reduce waste displacement (exporting domestic waste out of London area) and
promote a circular economy for waste, there should be a counterbalancing principle of
no waste treatment sites being located adjacent to resident areas in line with London
Plan 2015s commitment to ensuring quality of life and a clean environment for the
capitals residents.

Noted. Objective 11 amended to

recognise the need for waste
management facilities to not negatively
impact on sensitives uses including
existing and future homes and building
occupants. A sub objective has been
added in IIA Objective 11.

The island
triangle
residents
association

If the corporation is to realise its target of 24,000 new homes, then our association
believes that it should be clarifying that:
1) energy recovery sites that will adversely affect residential areas / entertainment
/cultural hubs
2) any waste facilities need a major buffer between sites and residential areas TITRA
suggests at least 1000 metres. Sadly, the authorities and borough planners never
seem to accept the misery and degradation to peoples quality of life that arises from
such plants and inadequately-enforced environmental controls. The Old Oak Lane
conservation area (and Harlesden) is proof that a mere 50-100m is nowhere near
sufficient distance between waste processing sites and residential areas, even with the
supposed latest 'best available technology' waste management technology in place.

Noted. This information will be used to

inform the emerging Air Quality Study and
proposed air quality policies within the
emerging Local Plan and OPDC corporate
environmental target setting. An indicator
has been added in IIA Objective 11.

53

Respondent

Relevant comment extract

Response

The island
triangle
residents
association

Also with regard to the waste issue, TITRA is very concerned by the implications of IIA
Theme 3 sub-themes intention to: increase accessibility to household and commercial
sustainable waste management facilities. This statement looks to our association to
be a covert statement of support for the location of waste handling sites along the
canal in Old Oak as envisaged in the 2015 London Plan and the OPDCs OAPF. Our
association cannot accept that intention without clear safeguards and an entirely new
approach by London planning authorities establishing buffer zones between peoples
homes and waste sites.

Noted. It is the intention of the subobejctive to minimise travel to such

facilities as household waste recycling
centres, to encourage people to recycle
and minimise travel distances. A sub
objective has been added in IIA Objective
11.

Page 436

The island
triangle
residents
association

TITRA emphasises that without evidence of new, more sympathetic thinking to existing
and new residents needs and risks to their health, the likely result of the IIAs
potentially ambiguous industrial development and waste treatment themes is that
waste / industrial uses will be pushed to the edge of the development zone
replicating the disastrous development in recent decades whereby the three boroughs
of Ealing, Brent & Hammersmith & Fulham simply pushed development to the margins
i.e. North Acton of their respective areas. This would jeopardise new housing
developments in Old Oak as well as old ones.

Noted. Objective 11 amended to

recognise the need for waste
management facilities to not negatively
impact on sensitives uses including
existing and future homes and building
occupants.
OPDC Board adopted the West London
Waste Plan to safeguard:
Twyford Waste Transfer Station;
Quattro, Victoria Road.
In addition OPDC will continue to work
with stakeholders regarding the long-term
aspirations of Powerday.

The island
triangle
residents
association

TITRA requires a clear statement for no waste treatment sites near to residential
areas.

Noted. This information will be used to

inform the emerging Air Quality Study and
proposed air quality policies within the
emerging Local Plan and OPDC corporate
environmental target setting.

54

Respondent

The island
triangle
residents
association

Relevant comment extract

2.3. Innovation in housing
TITRA welcomes IIA theme 5s commitment to affordable and inclusive housing of a
range of types and tenures, to meet identified local needs but asks whether greater
emphasis can be given to innovative forms of housing for the development area.
While a number of the capitals universities have provided student / graduate
accommodation blocks, these buildings are largely unattractive high rise blocks with
only limited retail space or community resources on the ground floor in the example
of the North Acton gyratory, this is already giving a ghost town feel to the area. The
association believes that the OPDC, with its co-ordinated planning powers for the
development zone, has a unique opportunity to create the conditions for innovative
small-scale housing and rented accommodation types that gets away from the current
trend for ghost towns of high rise blocks.

Response

Agree. Objective 5 amended to make

reference to the delivery of innovative
housing typologies to meet needs

Page 437

In addition, everything that is being created around North Acton stations seems to be
for the benefit of the students and does not seem to take into account local residents,
who if nothing else, were here first.

55

Respondent

The island
triangle
residents
association

Relevant comment extract

3.0 Additional PPPs
3.1 Sustainable communities
TITRA acknowledges that the OPDC has carried out a thorough assessment ahead of
the local plan but there is no sense in the document that the PPPs have really
examined how it is going to deliver sustainable communities.
Looking at the North Acton area alone, apart from The Collectives building on Old Oak
Lane (whose developer has given thought to community needs with a planned
canalside space and multiple building uses), there is little doubt that Old Oak will see
further high rise residential build but the general experience of North Acton (and future
developers plans for Portal Way central area / piazza surrounded by 30-storey plus
buildings) is that there is:

Page 438

Limited use of ground floor retail / community facilities

Very limited attempt to animate or liven up public spaces
Mainly high rise units leading to under-used, wind-blown public areas
Existing residential areas are being/will be overwhelmed by high rise building or
isolated by the impacts of construction work being carried over years, even decades

Response

Noted. It is considered that Objective 1 of

the IIA Framework will address these
potential issues.

The association asks that since the lifeless public space and construction-driven
isolation of existing communities are already issues in North Acton, that it should be
acknowledged and addressed with a core PPP to create the conditions for sustainable
communities in the assessment whether from community events, Wi-Fi in public
spaces and so on.

The island
triangle
residents
association

In addition, the density of development seems to be completely overwhelming and

giving nothing back to the existing communities. As per the London Plan, the
maximum allowed in an urban area is 650 habitable rooms per hectare. Surely,
around North Acton that has been severely exceeded with all the planning applications
coming to the fore.

Noted. OPDC has a scheme of delegation

with LB Ealing. As such the borough will
continue to determination planning
applications within North Acton.
The London Plan density matrix is
supplemented by the GLA Housing SPG
which provides guidance for delivering
higher housing densities.

56

Page 439

Respondent

Relevant comment extract

The island
triangle
residents
association

4.0. Additional themes

4.1 Greater clarity required on industrial and residential development
TITRA notes that while the Local Plan will boost economic growth and employment,
the IIA has commitments to activities such as waste handling in the zone, which can
potentially be read as encouraging dirty sites in proximity to residential areas.
The result of the less-than-clear industrial development and waste treatment themes in
the IIA document is that waste and industrial uses will potentially be pushed to the
edge of the development zone which could replicate the disastrous and polluting
development in recent decades whereby the three boroughs of Ealing, Brent &
Hammersmith & Fulham simply pushed development to the edge of their boroughs.
These previous, flawed policies have left residential communities like the Old Oak
conservation area with 1) a legacy of pollution and 2) needing to constantly press local
polluters and the authorities to enforce pollution controls. For sites such as
Euroterminal and Powerday, these tasks have been going on for more than a decade.
TITRA asks for explicit commitments by the completed assessment for:
A clear separation of industrial/waste and residential development
Acknowledgment that communities may need information and resources if they are
having deal with such issues
Smart monitoring of polluting sites leading to more effective enforcement of pollution
prevention and controls

Response

Noted. Objective 11 amended to

recognise the need for waste
management facilities to not negatively
impact on sensitives uses including
existing and future homes and building
occupants.
Noted. This information will be used to
inform the emerging Air Quality Study and
proposed air quality policies within the
emerging Local Plan and OPDC corporate
environmental target setting.

57

Respondent

Relevant comment extract

Response
Noted. Amendments made:

Page 440

The island
triangle
residents
association

5.0 Do you agree with the sustainability issues identified?

5.1. Mitigation of pollution during Old Oaks redevelopment & beyond
TITRA agrees with the broad idea of making Old Oaks renewal sustainable but it
requires that specific pollution issues as well as the impact of area
construction/transport/logistics on existing communities should be assessed. This
omission has to be resolved with a direct commitment in the IIA to:
Effective monitoring of vehicles and traffic movements on existing as well as new
roads in the development zone (ideally using smart technologies and sensors as
mentioned above)
More effective enforcement of HGV and car pollution controls (including more
effective environmental controls and better supervision of tenant companies working
hours on the Willesden Euroterminal Yard)
Where necessary restriction of HGVs and other polluting vehicles numbers.

Key Sustainability issues and

opportunities
Health (p.25) Construction phase
impacts should be considered within the
Local Plan, around timing of construction
and the impact it has on communities including both psychological and physical
effects.
Air quality (p.26) The Local Plan should
ensure that impacts on air quality resulting
from demolition and construction are
minimised, specifically with regard to local
communities.
Transportation (p.32) Opportunities
should be sought to develop road
infrastructure that supports economic
growth. During construction in particular,
the Local Plan should consider the
limitations of the road network and the
potential impact from construction on
existing businesses that are reliant on the
existing road network and local
communities.
Draft IIA Objectives and sub-objectives
4. Minimise the need to travel and
improve accessibility for all users by
public and non-motorised transportation
methods.
Consider the impact of construction on
local infrastructure on local businesses
and communities.
Mitigate the impact of construction traffic
11. To minimise air, noise and light
pollution, particularly for communities and
vulnerable groups
58

Respondent

Relevant comment extract

Response

Page 441

Minimise noise pollution caused by

traffic and commercial uses during the
construction and operation of
development on existing and future
communities, through the use of
mitigation measures and the locating of
future sensitive users away from pollution
generators.
Minimise air pollution caused by traffic
and commercial uses during the
construction and operation of
development on existing and future
communities, through the use of
mitigation measures and the locating of
future sensitive users away from pollution
generators.
Minimise light pollution
13. Increase community cohesion and
reduce social exclusion
Manage the construction process to
reduce the impact of a potentially large
transitory construction workforce on the
local community, specifically in relation to
social infrastructure and housing
provision.
15. Maximise the health and wellbeing of
the population, reduce inequalities in
health and promote healthy living
Minimise construction phase impacts on
communities, in relation to both physical
and psychological health
This information will be used to inform the
emerging Air Quality Study and proposed
air quality policies within the emerging
Local Plan and OPDC corporate
environmental target setting.
59

Page 442

Respondent

Relevant comment extract

Response

The island
triangle
residents
association

6.1 Waste sites in Old Oak

Aside of the issue of waste sites discussed in section 2.2. above, TITRA is very
concerned by the lack of clarity over the permitted uses of the Willesden Euroterminal
site, including:
1) Pollution from HGV traffic accessing the Euroterminal site
2) The likely use of the site by HS2 for tunnel waste / construction spoil removal
3) Network Rail and its partner Clean Powers plans for developing an energy recovery
site at the Willesden Euroterminal whether HS2 is built or not and whether the
partners have asked the OPDC whether it will support this development.

Noted. This information will be used to

inform discussions with relevant
stakeholders.

The island
triangle
residents
association

We are also concerned over the destruction of all the small sites of green spaces
around this already isolated and largely industrial area and would like to respectfully
request that this issue is given priority in replacing any cut down vegetation as quickly
as possible and with semi mature trees. The are already suffers with severe pollution
and planting at the end of construction would create a desert during the long years.
Also, mature trees protect the environment in many ways and young saplings actually
produce CO2 before they become mature. This issue is important to the local
residents for many reasons, some of which are visual, some which are noise reduction.
We have watched these trees grow and mature over 30 years and would like them
protected rather than cut down for convenience. We would like the green spaces to be
increased in number and size rather than reduced. At the moment, the only additional
planting on the plans is forecast in the newly created areas.

West London
Line Group

Allow for growth for all types of transportation by safeguarding enough space at key
locations for sufficient vehicles to serve each of these. This implies being cautious as
to the amount of land to be used for building development, as well as generous with
the space needed for passenger circulation in and around stations. Stratford station
(East London) could well offer lessons here since, despite its size and recent
development, it can feel dangerously crowded at times of peak usage.

Noted. Development proposals will need

to demonstrate through relevant
submission material that access and
circulation is safe and supports wider
placemaking.

West London
Line Group

Allow for growth in all rail services in and around Old Oak Common at all four stations
(main HS2/GWML/Crossrail complex, Hythe Road and Old Oak Common Land
Overground stations, and Willesden Junction), with passive provision for platform and
turnback extensions. For example, the Overground platforms and turnbacks should at
a future time be able to accommodate 10 or preferably 12-car trains.

Noted. Transport modelling for future

capacity requirements will be undertaken
by the relevant transport authorities
including HS2, Transport for London and
Network Rail.

Noted. OPDC will work with relevant

stakeholders in relation to the reprovision
of trees and street greening.
The emerging draft Local Plan will be
supported by a Green Infrastructure
Strategy and Public Realm Strategy which
will provide guidance in relation to the
location and amount of street greening
and new open spaces within Old Oak and
Park Royal

60

Respondent

West London
Line Group

Relevant comment extract

Most importantly, for the benefit of the country, the sub-region and the local area, make
provision for a five 12-car platform station on top of the HS2 station box to allow direct
and proximate connections between HS2/Crossrail/GWML services and West London
Line/West Coast Main Line/Midland Main Line services. These additional links should
be provided (i) to underpin the economic success of the MDC area, (ii) to allow good
connections here to Heathrow, and (iii) to reduce the stress on Crossrail at Old Oak
Common and tube and other services at Euston upon the opening of both Phases 1
and 2 of HS2. Any architectural statements presently destined for the roof of the HS2
atrium should be raised one floor to surmount these WLL platforms instead.

Response

Noted. Transport modelling for future

capacity requirements will be undertaken
by the relevant transport authorities
including HS2, Transport for London and
Network Rail.
This will be used to inform the design of
the station and any potential over station
development.

No other building should be placed on top of the HS2 station box

Page 443
West London
Line Group

1. Additional Consultation, (paragraph 1.9.3, page 6) of the Scoping Report says An

important element of the IIA, HIA and EqIA in particular, is to engage the community
throughout the development of the Local Plan. As such, key representatives from the
community will be consulted. These representatives have been identified in
collaboration with the OPDC Community Engagement Officer.
We note that we have not been approached by OPDC officers regarding the scoping
report and know no others that have been. (NB this was discussed at the GUA meeting
on 7th October). We would very much like to know - who have been identified as key
representatives, what was the process for their identification and have any of those
identified been advised of this.

OPDCs Communications and Community

Engagement team has been liaising with
relevant community groups and
stakeholders to identify key points of
contact in these groups. A consultation
database has been compiled on this basis
and the IIA Scoping Report was sent on 4
September 2015 to all stakeholders on
this database. A copy of the Scoping
Report was also placed on OPDCs
website. The IIA was publicly consulted
on from 4 September to 9 October 2015.
With regards to the IIA consultation,
OPDC officers spoke with Amanda Souter
(Resident Board Member) and Rahul
Gokhale (Business Community Board
Member) on 4 and 7 September and
asked them to be representatives of the
community in respect of the IIA. These
are considered to be well placed to
undertake this given their roles on the
OPDC Board and wider community
activities.

61

Respondent

Relevant comment extract

Response
The SEA Directive requires OPDC to
consult the Consultation Bodies on the
scope and level of detail of the
Environmental Report (in this case a full
Integrated Impact Assessment Report,
which will ultimately document the
findings of the IIA). The Consultation
Bodies are Historic England, Natural
England and the Environment Agency.

Page 444

To enable a wider range of stakeholders

to input into the Local Plan development
process from an early stage, OPDC
considered it appropriate to exceed
legislative requirement and invite
interested parties to submit comments.
West London
Line Group

2. Community members have not been involved in discussion around the scoping
report; the formative stage of the development of the Local Plan, thus the opportunity
for inclusion of community-based realistic alternatives to be included in the OPDCs
Issues & Options Local Plan has not been proactively provided.

All stakeholders on OPDCs consultation

database were contacted via email on 4
September 2015 and a copy was placed
on OPDCs website.
OPDC is in week 30 of a 25-30 year
project. The statutory function as a local
planning authority means that staffing has
focused on a team that will progress
evidence base for policies and ensure
robust processes are in place to manage
planning applications. The Strategy and
Programmes team, including
Communications and Engagement, is still
embryonic; therefore, your patience is
appreciated while the Corporation
continues to staff up to serve local
residents and businesses, meet groups to
forge relationships and works to set-up a
community group.
62

Respondent

Relevant comment extract

Response
On 12 October, OPDC Communications
and Planning officers presented to a small
group of GUA members to start these
meetings and to explain how local
communities can get involved in the
planning process. OPDC convened a
second meeting with GUA members on 3
November to discuss the Scoping Report
and wider Local Plan process with a
public workshop on the vision and
objectives held on 30 November prior to
the Local Plan consultation in early 2016.

Page 445
63

Respondent

Relevant comment extract

Response
The provided community-based vision
and objectives provide a comprehensive
and detailed range of suggestions which
are being used to directly inform the draft
Local Plan proposed vision and
objectives. Where the suggestions are
more relevant for policy options, these
have also been used to inform the
development of these options.

Page 446

West London
Line Group

The European Assessment Directive or the European Union requires that realistic
alternatives are assessed. Recent legal judgements have also asserted the importance
of public authorities consulting upon arguable yet discarded options.
We ask that community-based alternatives set out in the following Vision and
Objectives are assessed, with positive and negative effects identified, and included in
the OPDCs Issues & Options Local Plan.

As the provided community-based vision

and objectives have directly and positively
informed the development of the draft
OPDC Local Plan, that will be subject to
the IIA, a separate IIA on these is not
considered necessary.
Following a public workshop on the vision
and objectives on 30 November, further
community input has been provided into
the development of the vision and
objectives.
As agreed at the workshop, feedback on
this work and how the provided
community-based vision and objectives
have informed the Local Plan will be
provided in January 2016. There will also
be subsequent opportunity to comment on
the vision and objectives during the first
Local Plan consultation from February
2016.

64

Respondent

Relevant comment extract

Response
Agree. Amendments made:

Page 447

West London
Line Group

3. A key issue for all section of the community in and around the OPDC is the impact of
a 30 year construction period including issues of dust, noise, vibration and pollution,
and ability of the boroughs to meet the potential accommodation, facilities and amenity
needs of construction workers. This has not been fully considered in the report. It must
be fully identified and planned for as quite separate IIA and Local Plan objectives.

Key Sustainability issues and

opportunities
Health (p.25) Construction phase
impacts should be considered within the
Local Plan, around timing of construction
and the impact it has on communities including both psychological and physical
effects.
Air quality (p.26) The Local Plan should
ensure that impacts on air quality resulting
from demolition and construction are
minimised, specifically with regard to local
communities.
Transportation (p.32) Opportunities
should be sought to develop road
infrastructure that supports economic
growth. During construction in particular,
the Local Plan should consider the
limitations of the road network and the
potential impact from construction on
existing businesses that are reliant on the
existing road network and local
communities.
Draft IIA Objectives and sub-objectives
4. Minimise the need to travel and
improve accessibility for all users by
public and non-motorised transportation
methods.
Consider the impact of construction on
local infrastructure on local businesses
and communities.
Mitigate the impact of construction traffic
11. To minimise air, noise and light
pollution, particularly for communities and
vulnerable groups
65

Respondent

Relevant comment extract

Response

Page 448

Minimise noise pollution caused by

traffic and commercial uses during the
construction and operation of
development on existing and future
communities, through the use of
mitigation measures and the locating of
future sensitive users away from pollution
generators.
Minimise air pollution caused by traffic
and commercial uses during the
construction and operation of
development on existing and future
communities, through the use of
mitigation measures and the locating of
future sensitive users away from pollution
generators.
Minimise light pollution
13. Increase community cohesion and
reduce social exclusion
Manage the construction process to
reduce the impact of a potentially large
transitory construction workforce on the
local community, specifically in relation to
social infrastructure and housing
provision.
15. Maximise the health and wellbeing of
the population, reduce inequalities in
health and promote healthy living
Minimise construction phase impacts on
communities, in relation to both physical
and psychological health

66

Respondent

Relevant comment extract

1. Additional Consultation, (paragraph 1.9.3, page 6) of the Scoping Report says An

important element of the IIA, HIA and EqIA in particular, is to engage the community
throughout the development of the Local Plan. As such, key representatives from the
community will be consulted. These representatives have been identified in
collaboration with the OPDC Community Engagement Officer.
Resident

Page 449

We note that we have not been approached by OPDC officers regarding the scoping
report and know no others that have been. (NB this was discussed at the GUA meeting
on 7th October). We would very much like to know - who have been identified as key
representatives, what was the process for their identification and have any of those
identified been advised of this.

Resident

2. Community members have not been involved in discussion around the scoping
report; the formative stage of the development of the Local Plan, thus the opportunity
for inclusion of community-based realistic alternatives to be included in the OPDCs
Issues & Options Local Plan has not been proactively provided.

Response
OPDCs Communications and Community
Engagement team has been liaising with
relevant community groups and
stakeholders to identify key points of
contact in these groups. A consultation
database has been compiled on this basis
and the IIA Scoping Report was sent on 4
September 2015 to all stakeholders on
this database. A copy of the Scoping
Report was also placed on OPDCs
website. The IIA was publicly consulted
on from 4 September to 9 October 2015.
With regards to the IIA consultation,
OPDC officers spoke with Amanda Souter
(Resident Board Member) and Rahul
Gokhale (Business Community Board
Member) on 4 and 7 September and
asked them to be representatives of the
community in respect of the IIA. These
are considered to be well placed to
undertake this given their roles on the
OPDC Board and wider community
activities.
The SEA Directive requires OPDC to
consult the Consultation Bodies on the
scope and level of detail of the
Environmental Report (in this case a full
Integrated Impact Assessment Report,
which will ultimately document the
findings of the IIA). The Consultation
Bodies are Historic England, Natural
England and the Environment Agency.
To enable a wider range of stakeholders
to input into the Local Plan development
process from an early stage, OPDC
67

Respondent

Relevant comment extract

Response
considered it appropriate to exceed
legislative requirement and invite
interested parties to submit comments.
All stakeholders on OPDCs consultation
database were contacted via email on 4
September 2015 and a copy was placed
on OPDCs website.

Page 450

OPDC is in week 30 of a 25-30 year

project. The statutory function as a local
planning authority means that staffing has
focused on a team that will progress
evidence base for policies and ensure
robust processes are in place to manage
planning applications. The Strategy and
Programmes team, including
Communications and Engagement, is still
embryonic; therefore, your patience is
appreciated while the Corporation
continues to staff up to serve local
residents and businesses, meet groups to
forge relationships and works to set-up a
community group.
On 12 October, OPDC Communications
and Planning officers presented to a small
group of GUA members to start these
meetings and to explain how local
communities can get involved in the
planning process. OPDC convened a
second meeting with GUA members on 3
November to discuss the Scoping Report
and wider Local Plan process with a
public workshop on the vision and
objectives held on 30 November prior to
the Local Plan consultation in early 2016.

68

Respondent

Relevant comment extract

Response
The provided community-based vision
and objectives provide a comprehensive
and detailed range of suggestions which
are being used to directly inform the draft
Local Plan proposed vision and
objectives. Where the suggestions are
more relevant for policy options, these
have also been used to inform the
development of these options.

The European Assessment Directive or the European Union requires that realistic
alternatives are assessed. Recent legal judgements have also asserted the importance
of public authorities consulting upon arguable yet discarded options.
Resident

Page 451

We ask that community-based alternatives set out in the following Vision and
Objectives are assessed, with positive and negative effects identified, and included in
the OPDCs Issues & Options Local Plan.

As the provided community-based vision

and objectives have directly and positively
informed the development of the draft
OPDC Local Plan, that will be subject to
the IIA, a separate IIA on these is not
considered necessary.
Following a public workshop on the vision
and objectives on 30 November, further
community input has been provided into
the development of the vision and
objectives.
As agreed at the workshop, feedback on
this work and how the provided
community-based vision and objectives
have informed the Local Plan will be
provided in January 2016. There will also
be subsequent opportunity to comment on
the vision and objectives during the first
Local Plan consultation from February
2016.

69

Respondent

Relevant comment extract

Response
Agree. Amendments made:

Page 452

Resident

3. A key issue for all section of the community in and around the OPDC is the impact of
a 30 year construction period including issues of dust, noise, vibration and pollution,
and ability of the boroughs to meet the potential accommodation, facilities and amenity
needs of construction workers. This has not been fully considered in the report. It must
be fully identified and planned for as quite separate IIA and Local Plan objectives.

Key Sustainability issues and

opportunities
Health (p.25) Construction phase
impacts should be considered within the
Local Plan, around timing of construction
and the impact it has on communities including both psychological and physical
effects.
Air quality (p.26) The Local Plan should
ensure that impacts on air quality resulting
from demolition and construction are
minimised, specifically with regard to local
communities.
Transportation (p.32) Opportunities
should be sought to develop road
infrastructure that supports economic
growth. During construction in particular,
the Local Plan should consider the
limitations of the road network and the
potential impact from construction on
existing businesses that are reliant on the
existing road network and local
communities.
Draft IIA Objectives and sub-objectives
4. Minimise the need to travel and
improve accessibility for all users by
public and non-motorised transportation
methods.
Consider the impact of construction on
local infrastructure on local businesses
and communities.
Mitigate the impact of construction traffic
11. To minimise air, noise and light
pollution, particularly for communities and
vulnerable groups
70

Respondent

Relevant comment extract

Response

Page 453

Minimise noise pollution caused by

traffic and commercial uses during the
construction and operation of
development on existing and future
communities, through the use of
mitigation measures and the locating of
future sensitive users away from pollution
generators.
Minimise air pollution caused by traffic
and commercial uses during the
construction and operation of
development on existing and future
communities, through the use of
mitigation measures and the locating of
future sensitive users away from pollution
generators.
Minimise light pollution
13. Increase community cohesion and
reduce social exclusion
Manage the construction process to
reduce the impact of a potentially large
transitory construction workforce on the
local community, specifically in relation to
social infrastructure and housing
provision.
15. Maximise the health and wellbeing of
the population, reduce inequalities in
health and promote healthy living
Minimise construction phase impacts on
communities, in relation to both physical
and psychological health

71

Page 454

Respondent

Relevant comment extract

Response

Friends of
Wormwood
Scrubs

2. Consultation Question (d) (sustainability issues and opportunities)

Table 5 -1 p 28
Topic: Biodiversity, Flora and Fauna
Key Issue: Wormwood Scrubs
The Friends would emphasise the biodiversity of the Scrubs associated with its
uniquely rural nature.
Implications/Opportunities
The Friends endorse all these. With regard to the protection and enhancement of the
Scrubs habitat and species, we draw attention to the ecological enhancement
proposals for the Scrubs at present being developed jointly by HS2 and LBHF.

Noted. The biodiversity designations for

Wormwood Scrubs are referenced within
table 5-1 and opportunities for the Local
Plan to protect and enhance the habitat
and species recognised.

Friends of
Wormwood
Scrubs

3. Consultation Question (f) (particular topics or geographic areas of specific concern)

5.4 text fourth para: The redevelopment of the area should seek to improve open
space provision all around the area in addition to improving connections to Wormwood
Scrubs as well as enable green infrastructure and services that could be used by
residents and non-residents of the area alike.
(a) The Scrubs is (of course) of specific concern to the Friends. We have consistently
argued for creation of open space within the OPDC area without recourse to the
Scrubs as a substitute for such open space. We endorse Draft IIA Objectives 1. bullet
point 3 Create new, accessible, open-spaces-public, communal, private and childrens
play space, public realm and spaces where children can play independently.
(b) Existing connections to the Scrubs are perfectly adequate for its existing use.
Any future connection must not be at the expense of its existing character or adversely
affect its biodiversity (see Question (d) above).

Noted.

Friends of
Wormwood
Scrubs

4. Draft IIA Objective 10: proposed indicator Condition of Wormwood Scrubs LNR we
repeat reference to the ecological enhancement proposals in 2. above.

Noted

72

Respondent

Relevant comment extract

Response

Hammersmith
Society

First of all, we have to be critical of the format of the document itself. It is really quite
indigestible even to a group such as ours, with many professionals as members. We
have already emphasised in our comments on the Draft Statement of Community
Engagement, which was considerably more accessible than the IIA document, the
importance of the OPDC producing consultation documents that are clearly and simply
set out and in plain English. The IIA document has no preamble or introduction to
explain its purpose in terms that a reasonable lay person can easily understand nor
does it provide a summary of conclusions or priorities. Only the second introductory
paragraph under 1.1 is comprehensible, the rest being jargon. However the sections at
5.4 Cross boundary considerations and Section 6 would have acted as a quite
comprehensible introduction.

Noted. A non-technical summary for the

Draft IIA of the Regulation 18 version of
the Local Plan will be provided.

Page 455
Hammersmith
Society

We acknowledge that such a document is a required part of the Local Plan process,
and that there is a need for speed. However, the document promotes the importance of
community involvement throughout the Local Plan process. To our knowledge, and
from our involvement with the Grand Union Alliance, key representatives have not
been identified by OPDC as is suggested with a view to working through the document.

OPDCs Communications and Community

Engagement team has been liaising with
relevant community groups and
stakeholders to identify key points of
contact in these groups. A consultation
database has been compiled on this basis
and the IIA Scoping Report was sent on 4
September 2015 to all stakeholders on
this database. A copy of the Scoping
Report was also placed on OPDCs
website. The IIA was publicly consulted
on from 4 September to 9 October 2015.
With regards to the IIA consultation,
OPDC officers spoke with Amanda Souter
(Resident Board Member) and Rahul
Gokhale (Business Community Board
Member) on 4 and 7 September and
asked them to be representatives of the
community in respect of the IIA. These
are considered to be well placed to
undertake this given their roles on the
OPDC Board and wider community
activities.

73

Relevant comment extract

Response

Hammersmith
Society

Define that the Vision is really about the eastern Old Oak side of the OPDC area and
that the western side will remain but be enhanced as an Industrial/business area.

Disagree. Park Royal is considered

valuable industrial area which should
benefit from enhancements and support.
The proposed Vision reflects this.

Hammersmith
Society

Recognise that the OPDC is potentially about the development around a nationally
important transport hub (HS2/Crossrail1 etc) and a series of neighbourhood both
existing and proposed. OPDC's success will be judged largely on how well it reconciles
these differing requirements.

Noted. This information will be used to

inform the emerging draft Local Plan.

Hammersmith
Society

Recognise that for the OPDC will be more than the sum of these parts and that there
should be elements of the development which would be of wider appeal. This was
identified in Key Objective 3 of the OAPF which stated : Potential for large scale
catalyst uses such as new educational facility, football stadium, sports complex, health,
arts leisure or cultural centre : This society favours arts, leisure and/or a cultural centre
which might include elements such as a lido, ice skating, concert hall.

Agree. Cultural uses are envisaged to

play a key role in the regeneration of the
area. This information will be used to
inform the emerging draft Local Plan.

Page 456

Respondent

The current version of the London Plan

(consolidated with amendments with from
the FALP) was adopted in March 2015
following an Examination in Public.

Hammersmith
Society

The scale of the residential development needs to be defined and justified so that it is
not just accepted that the apparently random number of 24,000 new homes is targeted
without proper consideration of the type of neighbourhoods that will result.

As such the London Plan's minimum

housing targets for 24,000 new homes
and indicative employment figures for Old
Oak and Park Royal are form part of the
Development Plan for the OPDC area.
The Old Oak and Park Royal OAPF
supplements the London Plan,
establishing the principles for the range of
densities across Old Oak.
The minimum 24,000 target was
developed through a development
capacity exercise which has been refined
to reflect local sensitives and
development opportunities in the OAPF.
74

Respondent

Relevant comment extract

Response
This strategic planning policy and
guidance provides the baseline for the
draft IIA Scoping Report.
The OAPF provides principles for the
delivery of densities that respond to
sensitive areas in and around the OPDC
area. The Local Plan will develop this
guidance further.

Page 457

Hammersmith
Society

The neighbourhoods need to be of a human scale and distinctive : The densities need
to be appropriate so that a wide range of homes can be provided and if some are in
towers these are limited in height to say 10 storeys.

Noted. The OPDC Local Plan will be

supported by a Character Study and
Development Capacity Study to inform
scale of development and local character.

Hammersmith
Society

Neighbourhood areas need to be completed in phases and have access to proper

community facilities (e.g. Appropriate retail, schools, doctor's surgeries etc).

Agree. The delivery of development will

be defined through the Development
Capacity Study and required infrastructure
identified

Hammersmith
Society

The phasing of development (over the potential 30 year period) needs to be carefully
considered so that completed neighbourhoods are protected from the potential
disruption/disturbance of living in an almost continuous building site.

Noted. Managing the impact on

surrounding neighbourhoods is being
suggested within the emerging Local
Plan.

There is no mention of private amenity spaces nor for that matter landscaping : There
needs to be proper and commensurate provision of open spaces both as parks but
also play spaces for all age groups.

Noted. The GLA Housing SPG sets out

requirements for private amenity spaces
for development. The emerging Local
Plan will be supported by a Public Realm
Strategy that will provide guidance for
landscaping and the wider public realm

Hammersmith
Society

75

Respondent

Relevant comment extract

Response

Hammersmith
Society

The standard of architectural design throughout has got to be of exceptionally good

quality : Not just the same old stuff we see being rolled out all over London : The new
stations particularly the HS2/Crossrail station should be the subject of an
international competition : It is after all potentially the second largest after Waterloo :
Think Kings Cross or Birmingham New Street. To achieve this will probably require the
appointment of a highly respected and able design champion.

Noted. Architectural quality is critical to

the success of Old Oak. As such the
Place Review Group has been
established to independently assess
major planning applications and emerging
planning policies.

Hammersmith
Society

There should be a strong emphasis in the Local Plan regarding conservation areas and
the use of heritage assets

Noted. Conservation and heritage policy

options will be proposed within the Local
Plan

Hammersmith
Society

The GUA have rightly identified that canal should be not just cleaned up and used, but
also developed with boat basins and the like to provide vitality and greater use of the
canal. The point could also be made of using the canal for the transport of materials
during the construction works in order to reduce the burden on local roads.

Noted. This information will be used to

inform the emerging draft Local Plan.

Page 458
Harlesden
Town Team

1. Additional Consultation, (paragraph 1.9.3, page 6) of the Scoping Report says An

important element of the IIA, HIA and EqIA in particular, is to engage the community
throughout the development of the Local Plan. As such, key representatives from the
community will be consulted. These representatives have been identified in
collaboration with the OPDC Community Engagement Officer.
We note that we have not been approached by OPDC officers regarding the scoping
report and know no others that have been. (NB this was discussed at the GUA meeting
on 7th October). We would very much like to know - who have been identified as key
representatives, what was the process for their identification and have any of those
identified been advised of this.

OPDCs Communications and Community

Engagement team has been liaising with
relevant community groups and
stakeholders to identify key points of
contact in these groups. A consultation
database has been compiled on this basis
and the IIA Scoping Report was sent on 4
September 2015 to all stakeholders on
this database. A copy of the Scoping
Report was also placed on OPDCs
website. The IIA was publicly consulted
on from 4 September to 9 October 2015.
With regards to the IIA consultation,
OPDC officers spoke with Amanda Souter
(Resident Board Member) and Rahul
Gokhale (Business Community Board
Member) on 4 and 7 September and
asked them to be representatives of the
community in respect of the IIA. These
are considered to be well placed to
undertake this given their roles on the
76

Respondent

Relevant comment extract

Response
OPDC Board and wider community
activities.

Page 459
Harlesden
Town Team

2. Community members have not been involved in discussion around the scoping
report; the formative stage of the development of the Local Plan, thus the opportunity
for inclusion of community-based realistic alternatives to be included in the OPDCs
Issues & Options Local Plan has not been proactively provided.

The SEA Directive requires OPDC to

consult the Consultation Bodies on the
scope and level of detail of the
Environmental Report (in this case a full
Integrated Impact Assessment Report,
which will ultimately document the
findings of the IIA). The Consultation
Bodies are Historic England, Natural
England and the Environment Agency.
To enable a wider range of stakeholders
to input into the Local Plan development
process from an early stage, OPDC
considered it appropriate to exceed
legislative requirement and invite
interested parties to submit comments.
77

Respondent

Relevant comment extract

Response
All stakeholders on OPDCs consultation
database were contacted via email on 4
September 2015 and a copy was placed
on OPDCs website.

Page 460

OPDC is in week 30 of a 25-30 year

project. The statutory function as a local
planning authority means that staffing has
focused on a team that will progress
evidence base for policies and ensure
robust processes are in place to manage
planning applications. The Strategy and
Programmes team, including
Communications and Engagement, is still
embryonic; therefore, your patience is
appreciated while the Corporation
continues to staff up to serve local
residents and businesses, meet groups to
forge relationships and works to set-up a
community group.
On 12 October, OPDC Communications
and Planning officers presented to a small
group of GUA members to start these
meetings and to explain how local
communities can get involved in the
planning process. OPDC convened a
second meeting with GUA members on 3
November to discuss the Scoping Report
and wider Local Plan process with a
public workshop on the vision and
objectives held on 30 November prior to
the Local Plan consultation in early 2016.

78

Respondent

Relevant comment extract

Response
The provided community-based vision
and objectives provide a comprehensive
and detailed range of suggestions which
are being used to directly inform the draft
Local Plan proposed vision and
objectives. Where the suggestions are
more relevant for policy options, these
have also been used to inform the
development of these options.

Page 461

Harlesden
Town Team

The European Assessment Directive or the European Union requires that realistic
alternatives are assessed. Recent legal judgements have also asserted the importance
of public authorities consulting upon arguable yet discarded options.
We ask that community-based alternatives set out in the following Vision and
Objectives are assessed, with positive and negative effects identified, and included in
the OPDCs Issues & Options Local Plan.

As the provided community-based vision

and objectives have directly and positively
informed the development of the draft
OPDC Local Plan, that will be subject to
the IIA, a separate IIA on these is not
considered necessary.
Following a public workshop on the vision
and objectives on 30 November, further
community input has been provided into
the development of the vision and
objectives.
As agreed at the workshop, feedback on
this work and how the provided
community-based vision and objectives
have informed the Local Plan will be
provided in January 2016. There will also
be subsequent opportunity to comment on
the vision and objectives during the first
Local Plan consultation from February
2016.

79

Respondent

Relevant comment extract

Response
Agree. Amendments made:

Page 462

Harlesden
Town Team

3. A key issue for all section of the community in and around the OPDC is the impact of
a 30 year construction period including issues of dust, noise, vibration and pollution,
and ability of the boroughs to meet the potential accommodation, facilities and amenity
needs of construction workers. This has not been fully considered in the report. It must
be fully identified and planned for as quite separate IIA and Local Plan objectives.

Key Sustainability issues and

opportunities
Health (p.25) Construction phase
impacts should be considered within the
Local Plan, around timing of construction
and the impact it has on communities including both psychological and physical
effects.
Air quality (p.26) The Local Plan should
ensure that impacts on air quality resulting
from demolition and construction are
minimised, specifically with regard to local
communities.
Transportation (p.32) Opportunities
should be sought to develop road
infrastructure that supports economic
growth. During construction in particular,
the Local Plan should consider the
limitations of the road network and the
potential impact from construction on
existing businesses that are reliant on the
existing road network and local
communities.
Draft IIA Objectives and sub-objectives
4. Minimise the need to travel and
improve accessibility for all users by
public and non-motorised transportation
methods.
Consider the impact of construction on
local infrastructure on local businesses
and communities.
Mitigate the impact of construction traffic
11. To minimise air, noise and light
pollution, particularly for communities and
vulnerable groups
80

Respondent

Relevant comment extract

Response

Page 463

Minimise noise pollution caused by

traffic and commercial uses during the
construction and operation of
development on existing and future
communities, through the use of
mitigation measures and the locating of
future sensitive users away from pollution
generators.
Minimise air pollution caused by traffic
and commercial uses during the
construction and operation of
development on existing and future
communities, through the use of
mitigation measures and the locating of
future sensitive users away from pollution
generators.
Minimise light pollution
13. Increase community cohesion and
reduce social exclusion
Manage the construction process to
reduce the impact of a potentially large
transitory construction workforce on the
local community, specifically in relation to
social infrastructure and housing
provision.
15. Maximise the health and wellbeing of
the population, reduce inequalities in
health and promote healthy living
Minimise construction phase impacts on
communities, in relation to both physical
and psychological health

81

Respondent

Relevant comment extract

Response

Regents Canal
Network

A great concern is the future proofing of the OPDC project with its predicted 25-30
year development. A planning mechanism needs to be employed that allows stages of
updating and revision of the development plans as the project proceeds. The housing
and transport requirement of 10 years ago would not be appropriate now as they have
changed noticeably, so the OPDC plans made now may not suit in 10 years time, let
alone the full term of the project. Having been involved with the Kings Cross Central
Development for many years, I can confirm that lessons must be learned from
unrevised outdated decisions that are set in stone.

Noted. The OPDC Local Plan is being

informed by evidence base which enables
it to take a flexible approach to
accommodate change. The Local Plan will
be reviewed annually through the Annual
Monitoring Report. Should changes be
required, the Local Plan will be updated in
accordance with due processes.

Regents Canal
Network

On the positive side, it seems that lessons have been learned from the disorder and
inadequacies of the LLDC, and the set up and management of the OPDC is far more
competent, and also includes close consideration and involvement of the community
which is lacking in the Lee Valley.

Noted

Page 464

Regents Canal
Network

The poor quality of some of the documentation supplied by OPDC is of concern as it is

so dense and inaccessible. The result can be a lack of clarity from which
misjudgments and misinterpretations can result, or may have even occurred in the
recent flurry of erudite and indigestible documents.
This has been caused in part by the undue haste in the planning proceedings, and as
identified by the London Assembly, among others. Can the timetable be readjusted,
and good order and careful thought processes prevail.

Noted. With regard to the IIA scoping

report, the content and structure is
informed by statutory requirements.
The timetable for the Regulation 18
consultation has been amended in
response to concerns raised by
stakeholders to take place in late January
to deliver an 8 week formal consultation
period alongisde supplementary
processes.

82

Respondent

Relevant comment extract

Response
The current version of the London Plan
(consolidated with amendments with from
the FALP) was adopted in March 2015
following an Examination in Public.

Regents Canal
Network

One other matter that needs to be addressed is the over-ambitious density proposals
for this neighbourhood that is not central London. The density of housing can be fairly
high even in this location, but the predicted total of 24,000 new homes will impose an
unreasonable density for West London, particularly as large numbers of mega towers
will not be acceptable in this neighbourhood. Again lessons should be learned from
unsuitable towering developments that have been parachuted into sensitive areas all
over London with pressure from the Mayor.

As such the London Plan's minimum

housing targets for 24,000 new homes
and indicative employment figures for Old
Oak and Park Royal are form part of the
Development Plan for the OPDC area.
The Old Oak and Park Royal OAPF
supplements the London Plan,
establishing the principles for the range of
densities across Old Oak.

Page 465

This strategic planning policy and

guidance provides the baseline for the
draft IIA Scoping Report.
The OAPF provides principles for the
delivery of densities that respond to
sensitive areas in and around the OPDC
area. The Local Plan will develop this
guidance further.
The main issue for the Regents Network is for the Grand Union Canal to be given
careful consideration, as mentioned in the GUA response.

Regents Canal
Network

The Grand Union Canal is a navigation. The use by boats travelling along the canal
is being encouraged to bring Londons canals back to life. This will include freight
transport as well as leisure boating. It could become very busy with ten or fifteen
barges passing every hour. But it will still be a wonderful environment and will remain
calm and gentle.

Noted. This information will be used to

inform the development of the draft Local
Plan.

There needs to be a strict limit to moored boats along the main channel. There may
be opportunities for a group of boats to be moored in a wider stretch or a lay-by, where
there can be a mooring facility and infrastructure, but opportunistic mooring in any
83

Respondent

Relevant comment extract

Response

available space and along to towpath should be discouraged. After all, the canal is not
a housing estate, and as the London Plan says, the canal should not be used as an
extension of the developable land in London (BRN Policy 7.27, Para 7.84). It is added
that nor should parts of it be a continuous line of moored craft.
However, at any opportunity there should be provision of Visitor Moorings, with
adequate infrastructure and services.
Everything along the canal and in the vicinity should be calm. It is perfectly ok if
nothing happens along the canal, and the open water itself becomes the feature. Our
canals have become to be appreciated as a quiet haven, even in the centre of London

Page 466

That the canals should be animated is a perverse notion perpetrated by British

Waterways and now the Canal and River Trust, which has been solidly objected to by
Regents Network and others for many years. But it was BWB talking as a property
developer rather than a navigation authority, and it is unfortunate that this notion is
often repeated, and more than likely coming from property developers wanting to
exploit the canals. The last thing the canal needs is to be animated.
There have been suggestions that side basins could be constructed along the canal,
but this is not favoured unless there is a sound reason for their use. The basins could
be destinations for water transport passengers or freight, or for visitor moorings for
instance. As a water feature let into the surrounding developments, a basin would be a
weak objective unless carefully designed and as a special undertaking. In any event, if
a water feature is required then it is possible to construct a pond in any location other
than canalside, and could include fountains if it is further away. Canals and fountains
do not go well together.
New buildings should be set back from the edge of the canal, to preserve and protect
the waterways character and individuality. Pressure from property developers for their
buildings to be close to water in order to increase their rents and profits is not
acceptable. Heritage, environment, scenery and views come before profit. Buildings
in the canal vicinity should also be low level to avoid enclosing the waterway, and
historically it was more typical to have an open wharf at the canalside with the
warehouse set back. Dining areas in front of restaurants and cafes should also be set
back rather than at the waters edge.
Towpaths are now for pedestrian use, although the occasional horse-drawn tourist
barge would not go amiss, as we have on other parts of the canal network.
84

Respondent

Relevant comment extract

Response

Incidentally, it is a requirement that any canalside railings, equipment, lighting and so

on should be designed so that a towing rope would not be snagged, even these days.
As the towpaths are used by walkers, family groups, baby buggies, dogs on leads, the
elderly and wheelchairs etc, then they are not suitable as a cycle route as they are not
sufficiently wide to be considered for sharing. A genuine leisure cyclist or a family
cycle group could be acceptable as pedestrians could readily be given priority with
perfect safety and without great disturbance. Any cyclist venturing on to a towpath
should know that they are restricted to travelling more or less at walking speed, and
not expect to get anywhere very quickly.
The take-over of towpaths by fast cyclists is not acceptable, and the towpaths have
become unpleasant, and dangerous, for pedestrians. It should be the cyclist who use
alternative routes to get to their destinations, rather than the pedestrians finding
alternatives routes as is the case at the present. It is the pedestrians that have priority,
but that is no longer the case along many stretches of towpath in London.

Page 467

Cycling is strongly supported. It is an important enough activity for it to be given

special attention, and there is a widespread development of cycle paths, and the
funding available to continue expanding the cycle networks. OPDC should set new
standards and take the opportunity with the comprehensive development of such a
large area to provide dedicated cycle paths, or in the case of new shared paths they
should be of sufficient generous width to share with pedestrians safely. It will also
avoid frightening the horses.
The future use and activity on the canals in West London for freight is developing ,
with particular focus on the Park Royal area and other local industrial and business
centres that are canalside. It is seen that this will help to alleviate the gridlock on the
roads a certain amount, but more importantly will have a marked effect on the
improvement of air quality as canal transport is 80% less polluting than lorries.
There is no doubt of the advantages of using the canals in the OPDC area during the
construction phases of the development over a number of years, which will reduce
lorry movements and pollution. However, although this has been mentioned, no
transport plan includes details of the use of water transport. There is the opportunity for
establishing a number of convenient loading and consolidation sites, and including the
use of conveyors.

85

Respondent

Regents Canal
Network

Page 468
Regents Canal
Network

Relevant comment extract

1. Additional Consultation, (paragraph 1.9.3, page 6) of the Scoping Report says An

important element of the IIA, HIA and EqIA in particular, is to engage the community
throughout the development of the Local Plan. As such, key representatives from the
community will be consulted. These representatives have been identified in
collaboration with the OPDC Community Engagement Officer.
We note that we have not been approached by OPDC officers regarding the scoping
report and know no others that have been. (NB this was discussed at the GUA meeting
on 7th October). We would very much like to know - who have been identified as key
representatives, what was the process for their identification and have any of those
identified been advised of this.

2. Community members have not been involved in discussion around the scoping
report; the formative stage of the development of the Local Plan, thus the opportunity
for inclusion of community-based realistic alternatives to be included in the OPDCs
Issues & Options Local Plan has not been proactively provided.

Response
OPDCs Communications and Community
Engagement team has been liaising with
relevant community groups and
stakeholders to identify key points of
contact in these groups. A consultation
database has been compiled on this basis
and the IIA Scoping Report was sent on 4
September 2015 to all stakeholders on
this database. A copy of the Scoping
Report was also placed on OPDCs
website. The IIA was publicly consulted
on from 4 September to 9 October 2015.
With regards to the IIA consultation,
OPDC officers spoke with Amanda Souter
(Resident Board Member) and Rahul
Gokhale (Business Community Board
Member) on 4 and 7 September and
asked them to be representatives of the
community in respect of the IIA. These
are considered to be well placed to
undertake this given their roles on the
OPDC Board and wider community
activities.
The SEA Directive requires OPDC to
consult the Consultation Bodies on the
scope and level of detail of the
Environmental Report (in this case a full
Integrated Impact Assessment Report,
which will ultimately document the
findings of the IIA). The Consultation
Bodies are Historic England, Natural
England and the Environment Agency.
To enable a wider range of stakeholders
to input into the Local Plan development
process from an early stage, OPDC
86

Respondent

Relevant comment extract

Response
considered it appropriate to exceed
legislative requirement and invite
interested parties to submit comments.
All stakeholders on OPDCs consultation
database were contacted via email on 4
September 2015 and a copy was placed
on OPDCs website.

Page 469

OPDC is in week 30 of a 25-30 year

project. The statutory function as a local
planning authority means that staffing has
focused on a team that will progress
evidence base for policies and ensure
robust processes are in place to manage
planning applications. The Strategy and
Programmes team, including
Communications and Engagement, is still
embryonic; therefore, your patience is
appreciated while the Corporation
continues to staff up to serve local
residents and businesses, meet groups to
forge relationships and works to set-up a
community group.
On 12 October, OPDC Communications
and Planning officers presented to a small
group of GUA members to start these
meetings and to explain how local
communities can get involved in the
planning process. OPDC convened a
second meeting with GUA members on 3
November to discuss the Scoping Report
and wider Local Plan process with a
public workshop on the vision and
objectives held on 30 November prior to
the Local Plan consultation in early 2016.

87

Respondent

Relevant comment extract

Response
The provided community-based vision
and objectives provide a comprehensive
and detailed range of suggestions which
are being used to directly inform the draft
Local Plan proposed vision and
objectives. Where the suggestions are
more relevant for policy options, these
have also been used to inform the
development of these options.

Page 470

Regents Canal
Network

The European Assessment Directive or the European Union requires that realistic
alternatives are assessed. Recent legal judgements have also asserted the importance
of public authorities consulting upon arguable yet discarded options.
We ask that community-based alternatives set out in the following Vision and
Objectives are assessed, with positive and negative effects identified, and included in
the OPDCs Issues & Options Local Plan.

As the provided community-based vision

and objectives have directly and positively
informed the development of the draft
OPDC Local Plan, that will be subject to
the IIA, a separate IIA on these is not
considered necessary.
Following a public workshop on the vision
and objectives on 30 November, further
community input has been provided into
the development of the vision and
objectives.
As agreed at the workshop, feedback on
this work and how the provided
community-based vision and objectives
have informed the Local Plan will be
provided in January 2016. There will also
be subsequent opportunity to comment on
the vision and objectives during the first
Local Plan consultation from February
2016.

88

Respondent

Relevant comment extract

Response
Agree. Amendments to be made:

Page 471

Regents Canal
Network

3. A key issue for all section of the community in and around the OPDC is the impact of
a 30 year construction period including issues of dust, noise, vibration and pollution,
and ability of the boroughs to meet the potential accommodation, facilities and amenity
needs of construction workers. This has not been fully considered in the report. It must
be fully identified and planned for as quite separate IIA and Local Plan objectives.

Key Sustainability issues and

opportunities
Health (p.25) Construction phase
impacts should be considered within the
Local Plan, around timing of construction
and the impact it has on communities including both psychological and physical
effects.
Air quality (p.26) The Local Plan should
ensure that impacts on air quality resulting
from demolition and construction are
minimised, specifically with regard to local
communities.
Transportation (p.32) Opportunities
should be sought to develop road
infrastructure that supports economic
growth. During construction in particular,
the Local Plan should consider the
limitations of the road network and the
potential impact from construction on
existing businesses that are reliant on the
existing road network and local
communities.
Draft IIA Objectives and sub-objectives
4. Minimise the need to travel and
improve accessibility for all users by
public and non-motorised transportation
methods.
Consider the impact of construction on
local infrastructure on local businesses
and communities.
Mitigate the impact of construction traffic
11. To minimise air, noise and light
pollution, particularly for communities and
vulnerable groups
89

Respondent

Relevant comment extract

Response

Page 472

Minimise noise pollution caused by

traffic and commercial uses during the
construction and operation of
development on existing and future
communities, through the use of
mitigation measures and the locating of
future sensitive users away from pollution
generators.
Minimise air pollution caused by traffic
and commercial uses during the
construction and operation of
development on existing and future
communities, through the use of
mitigation measures and the locating of
future sensitive users away from pollution
generators.
Minimise light pollution
13. Increase community cohesion and
reduce social exclusion
Manage the construction process to
reduce the impact of a potentially large
transitory construction workforce on the
local community, specifically in relation to
social infrastructure and housing
provision.
15. Maximise the health and wellbeing of
the population, reduce inequalities in
health and promote healthy living
Minimise construction phase impacts on
communities, in relation to both physical
and psychological health

90

Respondent

Relevant comment extract

1. Additional Consultation, (paragraph 1.9.3, page 6) of the Scoping Report says An

important element of the IIA, HIA and EqIA in particular, is to engage the community
throughout the development of the Local Plan. As such, key representatives from the
community will be consulted. These representatives have been identified in
collaboration with the OPDC Community Engagement Officer.
Resident

Page 473

We note that we have not been approached by OPDC officers regarding the scoping
report and know no others that have been. (NB this was discussed at the GUA meeting
on 7th October). We would very much like to know - who have been identified as key
representatives, what was the process for their identification and have any of those
identified been advised of this.

Resident

2. Community members have not been involved in discussion around the scoping
report; the formative stage of the development of the Local Plan, thus the opportunity
for inclusion of community-based realistic alternatives to be included in the OPDCs
Issues & Options Local Plan has not been proactively provided.

Response
OPDCs Communications and Community
Engagement team has been liaising with
relevant community groups and
stakeholders to identify key points of
contact in these groups. A consultation
database has been compiled on this basis
and the IIA Scoping Report was sent on 4
September 2015 to all stakeholders on
this database. A copy of the Scoping
Report was also placed on OPDCs
website. The IIA was publicly consulted
on from 4 September to 9 October 2015.
With regards to the IIA consultation,
OPDC officers spoke with Amanda Souter
(Resident Board Member) and Rahul
Gokhale (Business Community Board
Member) on 4 and 7 September and
asked them to be representatives of the
community in respect of the IIA. These
are considered to be well placed to
undertake this given their roles on the
OPDC Board and wider community
activities.
The SEA Directive requires OPDC to
consult the Consultation Bodies on the
scope and level of detail of the
Environmental Report (in this case a full
Integrated Impact Assessment Report,
which will ultimately document the
findings of the IIA). The Consultation
Bodies are Historic England, Natural
England and the Environment Agency.
To enable a wider range of stakeholders
to input into the Local Plan development
process from an early stage, OPDC
91

Respondent

Relevant comment extract

Response
considered it appropriate to exceed
legislative requirement and invite
interested parties to submit comments.
All stakeholders on OPDCs consultation
database were contacted via email on 4
September 2015 and a copy was placed
on OPDCs website.

Page 474

OPDC is in week 30 of a 25-30 year

project. The statutory function as a local
planning authority means that staffing has
focused on a team that will progress
evidence base for policies and ensure
robust processes are in place to manage
planning applications. The Strategy and
Programmes team, including
Communications and Engagement, is still
embryonic; therefore, your patience is
appreciated while the Corporation
continues to staff up to serve local
residents and businesses, meet groups to
forge relationships and works to set-up a
community group.
On 12 October, OPDC Communications
and Planning officers presented to a small
group of GUA members to start these
meetings and to explain how local
communities can get involved in the
planning process. OPDC convened a
second meeting with GUA members on 3
November to discuss the Scoping Report
and wider Local Plan process with a
public workshop on the vision and
objectives held on 30 November prior to
the Local Plan consultation in early 2016.

92

Respondent

Relevant comment extract

Response
The provided community-based vision
and objectives provide a comprehensive
and detailed range of suggestions which
are being used to directly inform the draft
Local Plan proposed vision and
objectives. Where the suggestions are
more relevant for policy options, these
have also been used to inform the
development of these options.

The European Assessment Directive or the European Union requires that realistic
alternatives are assessed. Recent legal judgements have also asserted the importance
of public authorities consulting upon arguable yet discarded options.
Resident

Page 475

We ask that community-based alternatives set out in the following Vision and
Objectives are assessed, with positive and negative effects identified, and included in
the OPDCs Issues & Options Local Plan.

As the provided community-based vision

and objectives have directly and positively
informed the development of the draft
OPDC Local Plan, that will be subject to
the IIA, a separate IIA on these is not
considered necessary.
Following a public workshop on the vision
and objectives on 30 November, further
community input has been provided into
the development of the vision and
objectives.
As agreed at the workshop, feedback on
this work and how the provided
community-based vision and objectives
have informed the Local Plan will be
provided in January 2016. There will also
be subsequent opportunity to comment on
the vision and objectives during the first
Local Plan consultation from February
2016.

93

Respondent

Relevant comment extract

Response
Agree. Amendments to be made:

Page 476

Resident

3. A key issue for all section of the community in and around the OPDC is the impact of
a 30 year construction period including issues of dust, noise, vibration and pollution,
and ability of the boroughs to meet the potential accommodation, facilities and amenity
needs of construction workers. This has not been fully considered in the report. It must
be fully identified and planned for as quite separate IIA and Local Plan objectives.

Key Sustainability issues and

opportunities
Health (p.25) Construction phase
impacts should be considered within the
Local Plan, around timing of construction
and the impact it has on communities including both psychological and physical
effects.
Air quality (p.26) The Local Plan should
ensure that impacts on air quality resulting
from demolition and construction are
minimised, specifically with regard to local
communities.
Transportation (p.32) Opportunities
should be sought to develop road
infrastructure that supports economic
growth. During construction in particular,
the Local Plan should consider the
limitations of the road network and the
potential impact from construction on
existing businesses that are reliant on the
existing road network and local
communities.
Draft IIA Objectives and sub-objectives
4. Minimise the need to travel and
improve accessibility for all users by
public and non-motorised transportation
methods.
Consider the impact of construction on
local infrastructure on local businesses
and communities.
Mitigate the impact of construction traffic
11. To minimise air, noise and light
pollution, particularly for communities and
vulnerable groups
94

Respondent

Relevant comment extract

Response

Page 477

Minimise noise pollution caused by

traffic and commercial uses during the
construction and operation of
development on existing and future
communities, through the use of
mitigation measures and the locating of
future sensitive users away from pollution
generators.
Minimise air pollution caused by traffic
and commercial uses during the
construction and operation of
development on existing and future
communities, through the use of
mitigation measures and the locating of
future sensitive users away from pollution
generators.
Minimise light pollution
13. Increase community cohesion and
reduce social exclusion
Manage the construction process to
reduce the impact of a potentially large
transitory construction workforce on the
local community, specifically in relation to
social infrastructure and housing
provision.
15. Maximise the health and wellbeing of
the population, reduce inequalities in
health and promote healthy living
Minimise construction phase impacts on
communities, in relation to both physical
and psychological health

95

Respondent

Relevant comment extract

1. Additional Consultation, (paragraph 1.9.3, page 6) of the Scoping Report says An

important element of the IIA, HIA and EqIA in particular, is to engage the community
throughout the development of the Local Plan. As such, key representatives from the
community will be consulted. These representatives have been identified in
collaboration with the OPDC Community Engagement Officer.
Resident

Page 478

We note that we have not been approached by OPDC officers regarding the scoping
report and know no others that have been. (NB this was discussed at the GUA meeting
on 7th October). We would very much like to know - who have been identified as key
representatives, what was the process for their identification and have any of those
identified been advised of this.

Resident

2. Community members have not been involved in discussion around the scoping
report; the formative stage of the development of the Local Plan, thus the opportunity
for inclusion of community-based realistic alternatives to be included in the OPDCs
Issues & Options Local Plan has not been proactively provided.

Response
OPDCs Communications and Community
Engagement team has been liaising with
relevant community groups and
stakeholders to identify key points of
contact in these groups. A consultation
database has been compiled on this basis
and the IIA Scoping Report was sent on 4
September 2015 to all stakeholders on
this database. A copy of the Scoping
Report was also placed on OPDCs
website. The IIA was publicly consulted
on from 4 September to 9 October 2015.
With regards to the IIA consultation,
OPDC officers spoke with Amanda Souter
(Resident Board Member) and Rahul
Gokhale (Business Community Board
Member) on 4 and 7 September and
asked them to be representatives of the
community in respect of the IIA. These
are considered to be well placed to
undertake this given their roles on the
OPDC Board and wider community
activities.
The SEA Directive requires OPDC to
consult the Consultation Bodies on the
scope and level of detail of the
Environmental Report (in this case a full
Integrated Impact Assessment Report,
which will ultimately document the
findings of the IIA). The Consultation
Bodies are Historic England, Natural
England and the Environment Agency.
To enable a wider range of stakeholders
to input into the Local Plan development
process from an early stage, OPDC
96

Respondent

Relevant comment extract

Response
considered it appropriate to exceed
legislative requirement and invite
interested parties to submit comments.
All stakeholders on OPDCs consultation
database were contacted via email on 4
September 2015 and a copy was placed
on OPDCs website.

Page 479

OPDC is in week 30 of a 25-30 year

project. The statutory function as a local
planning authority means that staffing has
focused on a team that will progress
evidence base for policies and ensure
robust processes are in place to manage
planning applications. The Strategy and
Programmes team, including
Communications and Engagement, is still
embryonic; therefore, your patience is
appreciated while the Corporation
continues to staff up to serve local
residents and businesses, meet groups to
forge relationships and works to set-up a
community group.
On 12 October, OPDC Communications
and Planning officers presented to a small
group of GUA members to start these
meetings and to explain how local
communities can get involved in the
planning process. OPDC convened a
second meeting with GUA members on 3
November to discuss the Scoping Report
and wider Local Plan process with a
public workshop on the vision and
objectives held on 30 November prior to
the Local Plan consultation in early 2016.

97

Respondent

Relevant comment extract

Response
The provided community-based vision
and objectives provide a comprehensive
and detailed range of suggestions which
are being used to directly inform the draft
Local Plan proposed vision and
objectives. Where the suggestions are
more relevant for policy options, these
have also been used to inform the
development of these options.

The European Assessment Directive or the European Union requires that realistic
alternatives are assessed. Recent legal judgements have also asserted the importance
of public authorities consulting upon arguable yet discarded options.
Resident

Page 480

We ask that community-based alternatives set out in the following Vision and
Objectives are assessed, with positive and negative effects identified, and included in
the OPDCs Issues & Options Local Plan.

As the provided community-based vision

and objectives have directly and positively
informed the development of the draft
OPDC Local Plan, that will be subject to
the IIA, a separate IIA on these is not
considered necessary.
Following a public workshop on the vision
and objectives on 30 November, further
community input has been provided into
the development of the vision and
objectives.
As agreed at the workshop, feedback on
this work and how the provided
community-based vision and objectives
have informed the Local Plan will be
provided in January 2016. There will also
be subsequent opportunity to comment on
the vision and objectives during the first
Local Plan consultation from February
2016.

98

Respondent

Relevant comment extract

Response
Agree. Amendments to be made:

Page 481

Resident

3. A key issue for all section of the community in and around the OPDC is the impact of
a 30 year construction period including issues of dust, noise, vibration and pollution,
and ability of the boroughs to meet the potential accommodation, facilities and amenity
needs of construction workers. This has not been fully considered in the report. It must
be fully identified and planned for as quite separate IIA and Local Plan objectives.

Key Sustainability issues and

opportunities
Health (p.25) Construction phase
impacts should be considered within the
Local Plan, around timing of construction
and the impact it has on communities including both psychological and physical
effects.
Air quality (p.26) The Local Plan should
ensure that impacts on air quality resulting
from demolition and construction are
minimised, specifically with regard to local
communities.
Transportation (p.32) Opportunities
should be sought to develop road
infrastructure that supports economic
growth. During construction in particular,
the Local Plan should consider the
limitations of the road network and the
potential impact from construction on
existing businesses that are reliant on the
existing road network and local
communities.
Draft IIA Objectives and sub-objectives
4. Minimise the need to travel and
improve accessibility for all users by
public and non-motorised transportation
methods.
Consider the impact of construction on
local infrastructure on local businesses
and communities.
Mitigate the impact of construction traffic
11. To minimise air, noise and light
pollution, particularly for communities and
vulnerable groups
99

Respondent

Relevant comment extract

Response

Page 482

Minimise noise pollution caused by

traffic and commercial uses during the
construction and operation of
development on existing and future
communities, through the use of
mitigation measures and the locating of
future sensitive users away from pollution
generators.
Minimise air pollution caused by traffic
and commercial uses during the
construction and operation of
development on existing and future
communities, through the use of
mitigation measures and the locating of
future sensitive users away from pollution
generators.
Minimise light pollution
13. Increase community cohesion and
reduce social exclusion
Manage the construction process to
reduce the impact of a potentially large
transitory construction workforce on the
local community, specifically in relation to
social infrastructure and housing
provision.
15. Maximise the health and wellbeing of
the population, reduce inequalities in
health and promote healthy living
Minimise construction phase impacts on
communities, in relation to both physical
and psychological health

100

Changes to IIA Framework following Scoping Consultation

Changes shown in red and bold text (additions) or strikethrough (deleted text)

Draft IIA Objective and sub-objectives

To enhance the built environment and encourage placemaking

Page 483

Optimise development opportunities to develop and

enhance local distinctiveness and character

Ensure new buildings and public spaces are

appropriately designed and constructed including
enabling the creation of safe and welcoming spaces
and access for all

Indicators (known indicators: underlined;

proposed indicators: italics)

Regional Parks (400ha): 3.2 to 8km from

homes;

Metropolitan Parks (60ha): 3.2km from

homes;

SEA: Population,
Human Health,
Material Assets,
Cultural Heritage,
Landscape
HIA

Create new, accessible and managed open spacespublic, communal, private and childrens play space,
public realm and spaces where children can play
independently, which reflect the needs of the
community.
Maximise the contribution that the arts, culture and
heritage can make to a community including building
creativity, art, intrigue, character and surprise into the
built environment
Increase in the legibility of public spaces and increase
walking and cycling routes within and adjacent to Old

Provision of publicly accessible open space in

accordance with the London Plan
7
Categorisation :

Relevance to SEA,
HIA, EqIA, HRA

District Parks (20ha): 1.2km from homes;

Local Parks and Open Spaces (2ha): 400m

from homes;

Small Open Spaces (under 2ha): less than

400m from homes;

Pocket Parks (under 0.4ha): less than 400m

from homes;

Linear Open Spaces (Variable): wherever

feasible.

EqIA

Proportion of accessible open spaces created

which have a long term management and

https://www.london.gov.uk/sites/default/files/ALGG_SPG_Mar2012.pdf
1

Draft IIA Objective and sub-objectives

Indicators (known indicators: underlined;

proposed indicators: italics)

Oak and Park Royal

Encourage the use of contemporary technology in the

public realm to support design, delivery and
management

Encourage adherence to the principles of Lifetime

Neighbourhoods

funding plan

Integration with the All London Green Grid Area

Frameworks

Number of new buildings and public spaces

designed to be inclusive

Proportion of new development incorporating an

appropriate level of open space for recreation

Legibility and quality of the pedestrian and cycle

environment

Proportion of new development incorporating

Lifetime Neighbourhoods principles

Proportion of people who are happy with their

local environment as a place to live

Proportion of new development using technology

to improve legibility

Housing density in comparison to neighbourhood

quality

Density of commercial development in

comparison to existing (2015) levels

Maximise delivery of active frontages in appropriate

locations

Page 484

Link to objectives 12 (heritage), 5 (housing); 13 (community

cohesion); 14 (crime and fear of crime); 15 (health and wellbeing)

To optimise the efficient use of land through increased

development densities and building heights, where
appropriate

Optimise housing density in a way that makes the most

efficient use of land whilst meeting housing needs

Optimise development density in a way that makes the

most efficient use of land whilst meeting commercial
needs and responding to sensitive areas

Relevance to SEA,
HIA, EqIA, HRA

SEA: Population,
Human Health,
Biodiversity, Soil,
Water, Landscape,
Material Assets
HIA

Draft IIA Objective and sub-objectives

Indicators (known indicators: underlined;

proposed indicators: italics)

Relevance to SEA,
HIA, EqIA, HRA

Link to objectives 7 (natural resources use); and 8 (waste)

3

Amount (hectares) of previously developed land

available (Office for National Statistics Local
Profiles)

Quality of soil resources

Materials balance as a result of construction

activities

Development and implementation of a strategic

land remediation scheme

Link to objectives 4 (natural resources use); 6 (waste); and 12

(reuse of existing buildings)

Amount of soil remediated on site

Minimise the need to travel, improve accessibility for all

users by public and non-motorised transportation
methods and mitigate impacts on the transport network

Distribution of major transport systems roads,

rail links

Modal shift of existing travel patterns verses

future travel patterns

SEA: Population,
Human Health, Air,
Climatic Factors,
Material Assets,
Landscape

Connectivity of the cycling and walking network

HIA

Km of designated cycling and walking routes

EqIA

Proportion of goods arriving and leaving the area

by rail in comparison to road

Maximise the reuse of previously developed land and

existing buildings, including the remediation of
contaminated land

Page 485

Increase accessibility to household and commercial

sustainable waste management facilities

Improve soil quality and achieve more effective

geoconservation where appropriate

Contribute to a scheme of strategic land remediation

Increase the co-location of services and facilities, in

accessible locations by walking, cycling and public
transport
Increase the connection of the public realm and internal
routes to neighbouring areas alongside local and
strategic cycle and walking networks including via green
infrastructure networks and the canal

Prioritise walking and cycling over other forms of

transport

Proportion of waste and freight arriving and

leading the area by canal

Increases the opportunity for the transport of goods and

Proportion of shared spaces within the urban

SEA: Population,
Human Health,
Biodiversity, Soil,
Water, Landscape,
Material Assets
HIA

Draft IIA Objective and sub-objectives

Indicators (known indicators: underlined;

proposed indicators: italics)
environment

people by rail transport

Consider the impact of construction on local

infrastructure on local businesses and communities

Controlled parking zones, car clubs and travel

plan measures implemented

Support the testing and implementation of future

transport modes

Number of accessible public transport

interchanges and bus stops (source: Equal Life
Chances for All 2009)

Mitigate the impact of construction traffic

Maximise the accessibility of stations

Number of local businesses negatively affected

by construction activities

Increase in traffic on the highway network in and

around the OPDC area

Dwelling Stock (Office for National Statistics

Local Profiles).

Household density (Office for National Statistics

Local Profiles)

Proportion of LSOAs in the bottom 10% for

housing deprivation

Link to objectives 7 (climate change); 11 (pollution); and 14 (safety)

Page 486

Improve access to well designed, well-located, market,

affordable and inclusive housing of a range of types and
tenures, to meet identified local and regional needs

Provision of adaptable homes for independent living for

older and disabled people
Provision of innovative housing typologies to meet
needs
Provision of homes to need the needs of older people
including extra care housing, sheltered housing, lifetime
homes and wheelchair accessible homes
Provision of housing suitable for family accommodation
including single-parent families
Increase in use of high quality design including meeting

Relevance to SEA,
HIA, EqIA, HRA

SEA: Population,
Human Health,
Climatic Factors,
Material Assets
HIA

Proportion of dwellings meeting all of the health

and wellbeing credits in the Code for Sustainable
Homes

Proportion of dwellings that meet internal space

standards

Proportion of dwellings with a high SAP rating

Proportion of the population considered to be

EqIA

Draft IIA Objective and sub-objectives

Indicators (known indicators: underlined;

proposed indicators: italics)
homeless (source: Equal Life Chances for All
2009)

energy efficiency standards

Provision of facilities to meet identified needs of

Gypsies, Travellers and Travelling Show people

Amount of family size housing (source: Equal Life

Chances for All 2009)

Proportion of single parent families living in

unsuitable accommodation

Amount of affordable housing (source: Equal Life

Chances for All 2009)

Amount of Lifetime Homes (source: Equal Life

Chances for All 2009)

Proportion of market, affordable and specialist

housing delivered.

River catchment areas (Environment Agency

Thames Catchment Flood Management Plan,
2009).

Distribution of areas at risk of fluvial flooding

(Environment Agency Fluvial Flood Map)

Areas susceptible to surface water flooding

(Environment Agency Surface Water Flood Map)

Ensure all new homes meet Lifetime Homes standards

Link to objectives 1 and 6 (sustainable design); 13 (community

cohesion and social exclusion); 14 (secured by design); 15 (health)

Page 487
6

Improve climate change adaptation and mitigation,

including minimising the risk of flooding and addressing
the heat island effect

Relevance to SEA,
HIA, EqIA, HRA

Minimise the proportion of new development at risk of

flooding from all sources including surface water,
groundwater and reservoir flooding

Minimise the increase in risk of flooding elsewhere

Increase the use of sustainable design including

Sustainable Urban Drainage, natural ventilation and
shading for temperature adaptation

SEA: Biodiversity,
Human Health,
Water, Air, Climatic
Factors, Material
Assets, Landscape
HIA

EqIA

Proportion of energy usage in buildings using

sustainable design compared with standard
construction

Link to objectives 10 (habitat connectivity); 7 (energy efficiency); 12

5

Draft IIA Objective and sub-objectives

Indicators (known indicators: underlined;

proposed indicators: italics)

Relevance to SEA,
HIA, EqIA, HRA

(sustainable adaptation and reuse of existing buildings)

7

To minimise contributions to climate change through

greater energy efficiency, generation and storage; and to
reduce reliance on natural resources including fossil
fuels for transport, heating and energy

Enable the area to be more self-sufficient in terms of

energy generation and storage

Annual average domestic gas and electricity

consumption per meter (Office for National
Statistics Local Profiles)

All energy consumption by sector (Office for

National Statistics Local Profiles and DECC)

HIA

Energy consumption per capita

EqIA

Page 488

Increase the proportion of energy generated from low,

zero or negative carbon energy sources, through
consideration of measures from the outset

Proportion of properties generating energy

from low or zero carbon sources, including
solar.

Increase the proportion of journeys made by nonmotorised transport

Proportion of new developments

incorporating district heating or heat pumps

Increase the use of sustainable design to minimise the

resource requirements and outputs of new development

Greenhouse gas emissions per capita compared

with London and national averages

Proportion of journeys made by non-motorised

transport

Proportion of energy generated from low, zero or

negative carbon energy sources

Number of active / historic landfills on the site

(Environment Agency)

Percentage of household waste sent for reuse,

recycling or composting (ONS Local Profiles)

Amount of residual waste per household (ONS)

Link to objectives 4 (minimise the need to travel); 7 (sustainable

design); and 12 (sustainable adaptation and reuse of existing
buildings)

To minimise production of waste across all sectors in the

plan area, maximise efficiencies for transporting waste
and increasing rates of re-use, recycling and recovery
rates as well as composting of all green waste

Promote the creation of a circular economy for the

SEA: Population,
Human Health, Air,
Climatic Factors,
Material Assets

SEA: Biodiversity,
Population, Human
Health, Soil, Water,
Climatic Factors,
Material Assets,
Landscape
6

Draft IIA Objective and sub-objectives

Indicators (known indicators: underlined;

proposed indicators: italics)

management of waste

Relevance to SEA,
HIA, EqIA, HRA

sent to landfill or incineration

HIA
EqIA

Page 489

Increase the use of recycled materials for the

construction of buildings and infrastructure

Amount of commercial and industrial waste

produced (Defra)

Address the displacement of waste management to

other areas

Amount of waste recycled and re-used within the

area

Enable the sustainable management of contaminated

soils and hazardous waste

Amount of waste transported within the area

Increase accessibility to household and commercial

sustainable waste management facilities

Maximise use of innovative waste collection and waste

management techniques including smart technology

Water and groundwater quality (Environment

Agency)

Development of a site wide drainage strategy

Water consumption per capita

Increase in infrastructural capacity as a

proportion of new development

Increased use of existing infrastructure

Link to objectives 7 (resources use); 2 (efficient use of land); 3

(remediation)
9

Improve the quality of the water environment

Promote the improved efficiency in the use of water

domestically and commercially

Promote the improved quality of local watercourses

Prevent Reduce the risk posed to the water

environment from the run-off of contaminants

Ensure that infrastructural capacity is sufficient to

accommodate new development ahead of occupation

SEA: Water,
Human Health,
Soil, Landscape
HIA

Draft IIA Objective and sub-objectives

Indicators (known indicators: underlined;

proposed indicators: italics)

Relevance to SEA,
HIA, EqIA, HRA

Link to objectives 1 (biodiversity); 3 (climate change adaptation); 4

(climate change contributions); 5 (pollution); 7 (remediation); and 12
(Grand Union Canal)
10

Create and enhance biodiversity and the diversity of

habitats across the area and its surroundings

Conserve or enhance existing biodiversity across the

plan area, including on brownfield sites

Increase the connectivity of habitats across the area and

its surroundings

Page 490

Create new areas dedicated to nature conservation

Seek to reduce the potential wide ranging impacts on

international sites

Link to objectives 3 (remediation); 6 (climate change adaptation); 9

(water environment); 11 (pollution); and 12 (Grand Union Canal)

Number and distribution of designated sites

including SAC, SPA, Ramsar sites, SSSI,
National Nature Reserves (NNR), Local Nature
Reserves (LNR) and Sites of Importance for
Nature Conservation (SINCs) and Local Wildlife
Sites (MAGIC, www.magic.gov.uk and Local
Authority websites).

Key Biodiversity Action Plan (BAP) species and

habitats present (London BAP)

Protected species with favourable conservation

status

Habitat connectivity

Condition of Wormwood Scrubs Local Nature

Reserve

Condition of Grand Union Canal area of nature

conservation

Increase in areas of greenspace for biodiversity

including inaccessible areas

SEA: Biodiversity,
Flora, Fauna
HRA

Draft IIA Objective and sub-objectives

11

To minimise air, noise and light pollution, particularly for

communities and vulnerable groups

Minimise noise pollution caused by traffic and

commercial uses during the construction and operation
of development through the location of on existing and
future communities through the use of mitigation
measures and the locating of future sensitive users
away from high noise pollution generators and the use
of mitigation measures

Page 491

Minimise air pollution caused by traffic and commercial

uses during the construction and operation of
development on existing and future communities,
through the location of use of mitigation measures
and the locating of future sensitive users away from
areas of high air pollution generators and the use of
mitigation measures

Ensure that new waste management facilities do not

negatively impact on sensitive uses including
existing and future homes, and building occupants

Reduce emissions from construction and demolition

sites

Minimise light pollution

Indicators (known indicators: underlined;

proposed indicators: italics)

Relevance to SEA,
HIA, EqIA, HRA

Number and distribution of Air Quality

Management Areas (AQMAs) (Air Quality
8
Archive )

SEA: Population,
Human Health, Air,
Material Assets

Number of new local air quality monitoring points

HIA

Ill health attributed to air, noise or light pollution

EqIA

Proportion of the population affected by high

levels of noise during construction and post
construction including a breakdown by equality
group

Proportion of the population affected by light

pollution from traffic or industry during
construction and post construction including a
breakdown by equality group

Proportion of population living within areas with

regular exceedances in NOx and particulates

Link to objectives 4 (sustainable transport); 7 (climate change); 15

http://uk-air.defra.gov.uk/aqma/maps
9

Draft IIA Objective and sub-objectives

Indicators (known indicators: underlined;

proposed indicators: italics)

Relevance to SEA,
HIA, EqIA, HRA

(health)
12

To conserve and where appropriate enhance cultural

heritage the historic environment, heritage assets and
their settings

Promote the historical interpretation of heritage assets,

including the canal, through the use of multifunctional
green infrastructure

Page 492

Minimise heritage assets lost to new development

Avoid adverse impacts on the setting of heritage assets,

including those outside the OPDC area

Maximise the reuse and adaptation of heritage assets

for place-making and minimising the embedded
carbon in new development

Enhance local views and landscapes

Reduce the number of Heritage Assets at Risk in and

around the area

Reduce impacts on heritage assets and their settings in

areas adjacent to the plan area

Enhance areas of greenspace in connection with areas

of importance for heritage protection

Number and distribution of Listed Buildings,

Scheduled Ancient Monuments (SAMs),
Conservation Areas and Registered Historic
Parks and Gardens (www.magic.gov.uk).

Decrease in the number of Heritage Assets at

Risk in and around the area

Increase in the number of heritage assets

identified and protected through the
development of Local List

Increase in the number of heritage assets

highlighted and enhanced or utilised for placemaking and interpretation

Development of a local views strategy and

proportion of new developments adhering to its
principles

Increase in the number of heritage assets reused for development

SEA: Cultural
Heritage, Material
Assets,
Biodiversity,
Climatic Factors,
Landscape
HIA

Link to objectives 1 (place-making), 3 (reuse of existing buildings), 6

(energy efficiency), 7 (energy generation and sustainable
design), 8 (use of recycled materials) and 18 (encourage inward
10

Draft IIA Objective and sub-objectives

Indicators (known indicators: underlined;

proposed indicators: italics)

Relevance to SEA,
HIA, EqIA, HRA

investment).
13

Increase community cohesion and reduce social

exclusion to encourage a sense of community and
welfare

Improve the quality of the public realm and increase the

provision, accessibility and quality of public open spaces
including play spaces

Page 493

To increase connectivity and avoid physical barriers and

severance across the area through measures
including green infrastructure, creating physical and
social linkages with the surrounding communities

Manage the construction process to reduce the impact

of a potentially large transitory construction workforce on
the local community, specifically in relation to social
infrastructure and housing provision

Number of offices converted to residential under

permitted development rights

Schemes to reduce the impact of construction on

the local community

Connectivity of pedestrian linkages across

the area

SEA: Population,
Human Health,
Climatic Factors,
Landscape,
Material Assets
HIA
EqIA

Link to objectives 1 (place-making); 4 (accessibility); 5 (housing); 14

(crime and fear of crime); 15 (health)
14

Improve safety and reduce crime and the fear of crime

Crime rates (Indices of Deprivation)

Increase natural surveillance and other measures to

design out crime

Road traffic accidents and diversity profiling

(source: Equal Life Chances for All 2009)

Encourage increased safety through the use of traffic

management and calming methods

Percentage of people who feel that there is less

discrimination in their neighbourhood than 3
years ago (source: Equal Life Chances for All
2009)

SEA: Population,
Human Health,
Material Assets
HIA

Link to objectives 1 (place-making); 4 (sustainable transport); 5

(housing); 13 (community cohesion); 15 (health)

EqIA

Percentage of the local population who feel

11

Draft IIA Objective and sub-objectives

Indicators (known indicators: underlined;

proposed indicators: italics)

Relevance to SEA,
HIA, EqIA, HRA

personal safety on buses, tubes and trains

(source: Equal Life Chances for All 2009)

15

Maximise the health and wellbeing of the population,

reduce inequalities in health and promote healthy living

Page 494

Increase accessibility to social infrastructure including

health care facilities, schools, social care and
community facilities

Percentage of women who feel safe using local

bus, tube, trains, black cabs, and mini cabs at
night, alone (source: Equal Life Chances for All
2009)

Proportion of developments incorporating

Secured by Design principles

Health Deprivation and Disability (Indices of

Deprivation for England 2010)

Proportion of the population living within walking

distance of health care facilities

Proportion of the population living within walking

distance of education facilities

Proportion of the population living within walking

distance of social care facilities

Proportion of the population living within walking

distance of community facilities

Proportion of the population with access to space

for the growing of food locally

Increase in the capacity of local social

infrastructure

Childhood obesity rates

Increase the capacity of local social infrastructure

Encouragement of opportunities for buildings with a

shared community use and the co-location of services

Facilitate the supply of local food through the provision

of space for uses such as allotments or farmers markets

Reduce the potential for an over-concentration of hot

food takeaways in the local area

Minimise construction phase impacts on communities,

in relation to both physical and psychological health

Link to objectives 1 (place-making); 4 (accessibility); 5 (housing); 13

SEA: Population,
Human Health,
Material Assets,
Soil, Air, Water,
Landscape
HIA
EqIA

12

Draft IIA Objective and sub-objectives

(social and economic wellbeing)

16

To improve the education and skills levels of all members

of the population, particularly vulnerable groups

Increase in the availability of formal education across all

age groups, including adults from all equality groups

Increase in the availability of informal education and

training for all

Page 495

Link to objectives 4 (accessibility); 13 (community cohesion); 15

(health and wellbeing); 117 (social and economic wellbeing); 18
(sustainable economic growth)

17

Maximise the social and economic wellbeing of the local

and regional population and improve access to
employment and training

Provision of access to a range of high quality local

employment opportunities, a proportion of which will
be directed towards local people, both during
construction and permanent jobs, including those from
disadvantaged groups
Encourage workforces to reflect local and regional

Indicators (known indicators: underlined;

proposed indicators: italics)

Relevance to SEA,
HIA, EqIA, HRA

Life expectancy

Percentage of people aged 19 50/64 who have

attained a Level Four NVQ or higher (Office for
National Statistics Local Profiles).

SEA: Population,
Human Health,
Material Assets

Percentage of the population aged 16-74 with no

qualifications (Office for National Statistics Local
Profiles).

HIA
EqIA

Education, Skills and Training Deprivation

(Indices of Deprivation for England 2010).

Proportion of the population with access to

appropriate education facilities by sustainable
transport modes

Decrease in educational underachievement gap

between disadvantaged groups and the wider
community (source: Equal Life Chances for All
2009)

Number of wards with LSOAs in the bottom 20%

most deprived (Indices of Deprivation for England
2010)

SEA: Population,
Human Health,
Material Assets

Proportion of new employment and training

opportunities being awarded to local people via
local procurement arrangements

HIA

EqIA

Proportion of new employment and training

opportunities being awarded to local women via
local procurement arrangements
13

Draft IIA Objective and sub-objectives

diversity in all occupations and at all levels

Provision of access to a range of work-based and other

training opportunities, a proportion of which will be
directed towards local people, including those from
disadvantaged groups

Employment rate by excluded group compared to

employment rate of all Londoners (source: Equal
Life Chances for All 2009)

Workforce profile at all levels (source: Equal Life

Chances for All 2009)

Page 496

Provision of a range of accessible retail stores,

including food stores and smaller affordable shops for
social enterprises

Proportion of the community living within

walking distance of a local shop (see Table 62)

Increase in the provision of facilities for childcare

Levels of Child Poverty (source: Equal Life

Chances for All 2009)

Encouragement of employers to adopt the London

Living Wage

Number of childcare places (source: Equal Life

Chances for All 2009)

Take-up of subsidised childcare places (including

those for disabled children) benchmarked against
the LDA Childcare Affordability Programme
(source: Equal Life Chances for All 2009)

Economy Local Profiles (ONS)

Employment by industry (ONS- NOMIS)

Proportionate coverage of broadband across the

area

Proportion of new employment development that

includes an element of affordable workspace

New businesses categorised as health-led

Link to objectives 15 (health and wellbeing); 116 (education and

training) and 18 (sustainable economic growth)

18

Indicators (known indicators: underlined;

proposed indicators: italics)

To encourage inward investment alongside investment

within existing communities, to create sustainable
economic growth

Increase in the net number of businesses registered in

the area

Increase infrastructure and utilities capacity, including

broadband connections

Ensure workspace meets the needs of new and

Relevance to SEA,
HIA, EqIA, HRA

SEA: Population,
Human Health,
Material Assets
HIA
EqIA

14

Draft IIA Objective and sub-objectives

Indicators (known indicators: underlined;

proposed indicators: italics)

emerging businesses, including affordable, flexible and

micro/SME workspace

New businesses that contribute to the growth

of the low carbon goods and services sector

Deliver retail that does not negatively impact on

neighbouring town centres

Amount of new employment floorspace in Old

Oak

Encourage the development of employment growth

sectors including clean, green and healthy businesses

Amount of new industrial floorspace in Park

Royal

Support the relocation of business from Old Oak to Park

Royal.

Intensify the use of workspaces within Park Royal

Relevance to SEA,
HIA, EqIA, HRA

Page 497

Link to objectives 16 (education and training) and 17 (social and

economic wellbeing).

15

APPENDIX F
Strategic Options Assessment

Page 498

Table F-1 Affordable Housing Approaches

Draft IIA Objective
(see Table 6-1 of IIA
Scoping Report )

Approach 1 (Single) Fixed contribution across

OPDC area

Approach 2 Product dependent range

Approach 3 Viability based percentage

Approach 4 Negotiate a target on site specific basis

Impact

Impact

Impact

Impact

Commentary

Commentary

Commentary

Commentary

Page 499

1. To enhance the
built environment
and encourage
place-making

How affordable housing is delivered is

not directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

2. To optimise the
efficient use of land
through increased
development
densities and
building heights,
where appropriate

How affordable housing is delivered is

not directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

3. Maximise the
reuse of previously
developed land and
existing buildings,
including the
remediation of
contaminated land

How affordable housing is delivered is

not directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

4. Minimise the need

to travel and
improve
accessibility for all
users by public and
non-motorised
transportation
methods

How affordable housing is delivered is

not directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

5. Improve access
to well designed,
well-located,
market, affordable
and inclusive
housing of a range
of types and
tenures, to meet
identified local
needs

+/-

The approach could help to create a

level playing field across the area,
which could enable the delivery of
affordable housing. This could help to
ensure that all areas are equal in terms
of provision, which could help distribute
affordable housing more evenly across
the plan area. This could help to ensure
that mixed communities and a sense of
place is achieved.
However, should this mean that fewer
sites are developed, negative effects

The product dependent range could lead to

inequalities across the plan area, as some
housing types, and therefore types of
communities, may be seen as more
suitable for higher affordable housing
provision than others. This could lead to
negative effects against this objective.

+/-

A viability based percentage could reduce

the provision of affordable housing in
areas where land values are the lowest.
This could, therefore, create an imbalance
in provision across the plan area,
potentially reducing provision in areas of
greatest need. This approach, however,
would include an initial target percentage,
which could help negotiations, although it
is unclear whether this target percentage
would be an all-area percentage or based
on different products or areas.

A site specific approach could reduce the

provision of affordable housing in areas
where land values are the lowest. This
could, therefore, create an imbalance in
provision across the plan area, potentially
reducing provision in areas of greatest
need. Without an initial target, negotiated
levels of provision could be low.
A site specific approach could,
alternatively, lead to the
provision of an increase in
market housing overall, which

Draft IIA Objective

(see Table 6-1 of IIA
Scoping Report )

Approach 1 (Single) Fixed contribution across

OPDC area

Approach 2 Product dependent range

Approach 3 Viability based percentage

Approach 4 Negotiate a target on site specific basis

Impact

Impact

Impact

Impact

Commentary

Commentary

may result.

Page 500

6. Improve climate
change
adaptation and
mitigation,
including
minimising the
risk of flooding
and addressing
the heat island
effect
7. To minimise

A viability-based approach could,

alternatively, help to deliver more
affordable housing as, should a fixed
percentage be required, developers may
not develop certain sites due to viability
issues. Therefore, a mix of both positive
and negative effects is predicted.

Commentary

could reduce the significance

of negative effects against this
objective.

How affordable housing is delivered is

not directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

How affordable housing is delivered is

not directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

How affordable housing is delivered is

not directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

contributions to
climate change
through greater
energy efficiency,
generation and
storage; and to
reduce reliance
on natural
resources
including fossil
fuels for
transport, heating
and energy
8. To minimise
production of waste
across all sectors in
the plan area,
maximise
efficiencies for
transporting waste
and increasing rates
of re-use, recycling
and recovery rates
as well as
composting of all

Commentary

Draft IIA Objective

(see Table 6-1 of IIA
Scoping Report )

Approach 1 (Single) Fixed contribution across

OPDC area

Approach 2 Product dependent range

Approach 3 Viability based percentage

Approach 4 Negotiate a target on site specific basis

Impact

Impact

Impact

Impact

Commentary

Commentary

Commentary

Commentary

green waste

Page 501

9. Improve the
quality of the water
environment

How affordable housing is delivered is

not directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

10. Create and

enhance
biodiversity and the
diversity of habitats
across the area and
its surroundings

How affordable housing is delivered is

not directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

11. To minimise air,

noise and light
pollution,
particularly for
vulnerable groups

How affordable housing is delivered is

not directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

12. To conserve
and, where
appropriate,
enhance, cultural
heritage

How affordable housing is delivered is

not directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

13. Increase
community
cohesion and
reduce social
exclusion

+/-

The approach could help to create a

level playing field across the area,
which could enable the delivery of
affordable housing. This could help to
ensure that all areas are equal in terms
of provision, which could help distribute
affordable housing more evenly across
the plan area. This could help to reduce
social exclusion.
However, should this mean that fewer
sites are developed, negative effects
may result.

The product dependent range

could lead to inequalities
across the plan area, as some
housing types, and therefore
some communities, may be
seen as more suitable for
higher affordable housing
provision than others. This
could lead to negative effects
against this objective as it may
create inequalities and
increase social exclusion
across the area.

+/-

A viability based percentage could reduce

the provision of affordable housing in
areas where land values are the lowest.
This could, therefore, create an imbalance
in provision across the plan area,
potentially reducing provision in areas of
greatest need, increasing social
exclusion. This approach, however, would
include an initial target percentage, which
could help negotiations, although it is
unclear whether this target percentage
would be an all-area percentage or based
on different products or areas.

--

A site specific approach could reduce the

provision of affordable housing in areas
where land values are the lowest. This
could, therefore, create an imbalance in
provision across the plan area, potentially
reducing provision in areas of greatest
need. Without an initial target, negotiated
levels of provision could be low. This could
increase levels of social exclusion in
relation to access to affordable housing.

A viability-based approach could,

alternatively, help to deliver more
affordable housing as, should a fixed
percentage be required, developers may
not develop certain sites due to viability
issues. Therefore, a mix of both positive
3

Draft IIA Objective

(see Table 6-1 of IIA
Scoping Report )

Approach 1 (Single) Fixed contribution across

OPDC area

Approach 2 Product dependent range

Approach 3 Viability based percentage

Approach 4 Negotiate a target on site specific basis

Impact

Impact

Impact

Impact

Commentary

Commentary

Commentary

Commentary

and negative effects is predicted.

14. Improve safety
and reduce crime
and the fear of
crime

+/-

The approach could help to create a

level playing field across the area,
which could enable the delivery of
affordable housing. This could help to
ensure that all areas are equal in terms
of provision, which could help distribute
affordable housing more evenly across
the plan area. This could help to reduce
social exclusion and subsequently
reduce levels of crime and anti-social
behaviour.

The product dependent range could lead to

inequalities across the plan area, as some
housing types, and therefore types of
communities, may be seen as more
suitable for higher affordable housing
provision than others. This could lead to
negative effects against this objective as it
may create inequalities and increase social
exclusion across the area and subsequently
reduce levels of crime and anti-social
behaviour.

+/-

However, should this mean that fewer

sites are developed, negative effects
may result.

+/-

The approach could help to create a

level playing field across the area,
which could enable the delivery of
affordable housing. This could help to
ensure that all areas are equal in terms
of provision, which could help distribute
affordable housing more evenly across
the plan area. This could help to reduce
social exclusion and subsequently
improve human health.
However, should this mean that fewer
sites are developed, this could lead to
negative effects.

--

A site specific approach could reduce the

provision of affordable housing in areas
where land values are the lowest. This
could, therefore, create an imbalance in
provision across the plan area, potentially
reducing provision in areas of greatest
need, which could have knock on effects for
anti-social behaviour. Without an initial
target, negotiated levels of provision could
be low. This could increase levels of social
exclusion and subsequent levels of
crime/fear of crime.

--

A site specific approach could reduce the

provision of affordable housing in areas
where land values are the lowest. This
could, therefore, create an imbalance in
provision across the plan area, potentially
reducing provision in areas of greatest
need, which could have knock on effects for
health. Without an initial target, negotiated
levels of provision could be low. This could
increase levels of social exclusion and
subsequent knock-on effects for health.

A viability-based approach could,

alternatively, help to deliver more
affordable housing as, should a fixed
percentage be required, developers may
not develop certain sites due to viability
issues. Therefore, a mix of both positive
and negative effects is predicted.

Page 502
15. Maximise the
health and
wellbeing of the
population, reduce
inequalities in
health and promote
healthy living

A viability based percentage could reduce

the provision of affordable housing in
areas where land values are the lowest.
This could, therefore, create an imbalance
in provision across the plan area,
potentially reducing provision in areas of
greatest need, increasing social
exclusion. This approach, however, would
include an initial target percentage, which
could help negotiations, although it is
unclear whether this target percentage
would be an all-area percentage or based
on different products or areas.

The product dependent range could lead to

inequalities across the plan area, as some
housing types, and therefore types of
communities, may be seen as more
suitable for higher affordable housing
provision than others. This could lead to
negative effects against this objective as it
may create inequalities and increase social
exclusion across the area. This could have
negative effects for health in certain areas.

+/-

A viability based percentage could reduce

the provision of affordable housing in
areas where land values are the lowest.
This could, therefore, create an imbalance
in provision across the plan area,
potentially reducing provision in areas of
greatest need, increasing social
exclusion. This approach, however, would
include an initial target percentage, which
could help negotiations, although it is
unclear whether this target percentage
would be an all-area percentage or based
on different products or areas.
A viability-based approach could,
alternatively, help to deliver more
affordable housing as, should a fixed
percentage be required, developers may
not develop certain sites due to viability
issues. Therefore, a mix of both positive
and negative effects is predicted.

Draft IIA Objective

(see Table 6-1 of IIA
Scoping Report )

Approach 1 (Single) Fixed contribution across

OPDC area

Approach 2 Product dependent range

Approach 3 Viability based percentage

Approach 4 Negotiate a target on site specific basis

Impact

Impact

Impact

Impact

Commentary

Commentary

Commentary

Commentary

Page 503

16. To improve the

education and skills
levels of all
members of the
population,
particularly
vulnerable groups

How affordable housing is delivered is

not directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

17. Maximise the

social and
economic wellbeing
of the population
and improve access
to employment and
training

How affordable housing is delivered is

not directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

18. To encourage
inward investment
alongside
investment within
existing
communities, to
create sustainable
economic growth

How affordable housing is delivered is

not directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

How affordable housing is delivered is not

directly relevant to this objective.

APPENDIX G
Assessment of Policy Options, Preferred Policy Options and Alternative
Options

Page 504

The tables below provide an explanation of the notation used in the assessment matrices.
Performance of Policy

Page 505

Major Positive Impact

(significant)

The option strongly supports the achievement of the IIA Objectives

++

Positive Impact

This option contributions partially to the achievement of the IIA Objective

Neutral/No Impact

There is no clear relationship between the option and/or the achievement of the IIA Objective

Positive and negative

outcomes

The option has a combination of both positive and negative contributions to the achievement of the IIA
Objective.

Uncertain outcome

It is not possible to determine the nature of the impact as there may be too many external factors that would
influence the appraisal or the impact may depend heavily upon implementation at the local level. More
information is required to assess the impacts.

Negative Impact

The policy partially detracts from the achievement of the SA Objective.

Major Negative Impact

(significant)

The policy strongly detracts from the achievement of the SA Objective.

--

+/-

Temporal Scale

L-T

Effects likely to arise in 10-25 years of Local Plan implementation

M-T

Effects likely to arise in 5-10 years of Local Plan implementation

S-T

Effects likely to arise in 0-5 years of Local Plan implementation

Direct effects.
1

Indirect effects.

Effects are reversible

IR

Effects are irreversible

H/M/L

High, medium or low certainty of prediction

Page 506
2

Table G-1 Chapter 3: The Overarching Spatial Policies

x
x
x
x
x

OSP 1: Optimising growth

OSP 2: Land use
OSP 3: Connections and open spaces
OSP 4: Densities and building heights
OSP 5: Places

IIA Objective

Page 507

To enhance
the built
environment
and
encourage
place-making

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

OSP1

Nature of
Impact
L-T, I, R, L

London-wide

OSP2

++

L-T, D, R,
M

OPDC area
and
surrounding
boroughs.

OSP3

++

L-T, D, R,
M

OPDC area
and
surrounding
boroughs.

OSP4

L-T, I, R, M

Town centres
within OPDC
area and
surrounding
boroughs.

The policy is likely to contribute to the enhancement of the built environment through
optimising the use of brownfield land and supporting the regeneration of the area as
well as the wider area.
The policy includes the support of proposals that will deliver a thriving new centre, to
accommodate a significant number of new homes and jobs, as well as protecting the
Park Royal industrial estate. This could contribute to the achievement of
enhancements to the built environment locally as well as encourage place-making
the policy also requires the delivery of a full mix of town centre uses and associated
infrastructure within a new town centre hierarchy. Supporting text indicates the types of
uses encouraged, which would include new shops, culture, sports and leisure
infrastructure such as new schools, health centres and community space. This could
lead to benefits against this objective in the long term.
The policy should help to deliver improvements to the existing built environment, which
could lead to significant positive benefits. The creation of a well-connected and legible
network of high quality and varied public, communal and private amenity spaces based
on the celebration of existing features, should help to create a sense of place and local
distinctiveness.
Focusing the highest densities of development in the centre of the area could also help
to develop a sense of place locally in the long term and ensure that the areas around
the stations and town centres are well connected.
However, the key issues as stated in the Local Plan text highlight that Well-designed
high density and tall building development can play a positive role in creating vibrancy
and a sense of place. To be successful, such buildings should be exemplar and ensure
the creation of a liveable place and avoid poor quality environments. Paragraph 3.22
states that Tall buildings must achieve the highest standards of design, be mindful of
their surrounding context and accord with the requirements set out in national
guidance, the London Plan and the draft preferred policy options of this Local Plan
The supporting text to the policy states that sensitive locations are considered to be
3

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

Page 508
3

OSP5

++

L-T, D, R,
M

OPDC area
and
surrounding
boroughs.

To optimise
the efficient
use of land
through
increased
development
densities and
building
heights, where
appropriate

OSP1

++

M, L-T, D,
R, M

OPDC area

OSP2

M, L-T, I, R,
L

OPDC area

OSP3
OSP4

0
+

M, L-T, D,
IR, M

OPDC area

OSP5

Maximise the
reuse of
previously
developed
land and
existing
buildings,
including the
remediation of
contaminated
land

OSP1

++

S, M, L-T,
D, R, M

OPDC area

OSP2

++

M, L-T, I, R,
L

OPDC area

OSP3

OSP4

++

M, L-T, D,
IR, M

OPDC area

OSP5

areas adjacent to designated heritage assets, existing public amenity spaces and
existing residential communities. Lower densities in these areas could help the design
of development to integrate into the local area and create a sense of place. See
recommendation under objective 12.
The policy states that OPDC will support proposals that create a series of attractive
and locally distinctive places and lifetime neighbourhoods. Proposals should also
clearly demonstrate early engagement with existing residents and business to inform
place-making. Small and large-scale catalyst uses will also be supported to drive
regeneration and help to generate a sense of place. These requirements should lead to
significant benefits against this objective.
The policy seeks to deliver a significant quantum of new homes, jobs and supporting
services on brownfield land, which could have direct significant benefits against this
objective.
The policy seeks to deliver a significant amount of development on brownfield land,
which could lead to benefits against this objective.
The policy is not related to the density of development specifically.
The policy specifically refers to the need for high density development in appropriate
locations across the plan area. This could lead to benefits against this objective.
The policy is not related to the density of development specifically.

The policy seeks to optimise the development of brownfield land, which could have
direct significant benefits against this objective. It is recommended that the policy
specifically refers to the use and remediation of contaminated land as that which
should be optimised, should there be an option within the site [NB this is now covered
in Policy EU12].
The policy seeks to deliver a significant quantum of development on brownfield land,
which could lead to benefits against this objective.
The policy promotes development on brownfield land and could lead to benefits against
this objective.
The policy specifically refers to the need for high density development in appropriate
locations across the plan area. This could lead to benefits against this objective.
The policy promotes development on brownfield land and could lead to benefits against
this objective.
4

IIA Objective

Page 509
5

Minimise the
need to travel,
improve
accessibility
for all users by
public and
non-motorised
transportation
methods and
mitigate
impacts on the
transport
network

Improve
access to well
designed,
well-located,
market,
affordable and
inclusive
housing of a

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

London-wide
and national

As explained in the policy supporting text, optimising development in this strategic

location could have London-wide benefits for accessibility by sustainable modes of
transport, with the potential for benefits to reach more widely.
The policy seeks to deliver a range of land uses within the area, including homes, jobs
and associated town centre infrastructure. This could help to reduce the need to travel
for both existing and incoming communities, which could have long term benefits
against this objective.
The development of an improvement to the existing street network connecting stations,
key destinations, neighbourhoods and the surrounding areas, that is well-connected
and legible, is likely to encourage walking and cycling as modes of transport, which
could have benefits against this objective.
The policy could specify that improvements will seek to prioritise non-motorised uses
within the street-scene, and encourage lower vehicle speeds through design [NB this is
now covered in Policy T1].
As set out in the supporting text, part of the rationale behind encouraging high density
development in this location is to optimise the areas excellent public transport
accessibility. This is reflected in the policy wording, which seeks that the highest
density development is focussed around Old Oak Common Station, with high density
development also focussed around other stations, with a mix of densities at key
destinations. These policy requirements could help to improve accessibility and
encourage a modal shift to more sustainable transport use in this area as well as more
widely.
The policy promotes the potential for large-scale catalyst uses to be located in the
OPDC area. These uses are likely to generate significant trip numbers and it is
appropriate that these sorts of uses are located in areas of high public transport access
such as the OPDC area.
As explained in the policy supporting text, optimising development in this location could
contribute to meeting Londons identified need for homes, thereby contributing to the
achievement of benefits against this objective. However, the types of homes are not
specified within this policy.
The policy specifies that the delivery of 24,000 homes will be supported in the Old Oak
area, with 1,500 new homes to be delivered in Park Royal. However, the types of
homes are not specified within this policy. Local Plan policies H4-H10 provide more
detail in relation to housing types and tenures.
The policy will not directly contribute to benefits against this objective.

OSP1

++

Nature of
Impact
L-T, I, R, M

OSP2

++

L-T, I, R, L

OPDC area

OSP3

++

L-T, D, R,
M

OPDC area

OSP4

++

L-T, I, R, M

London-wide
and national

OSP5

OSP1

M, L-T, I, R,
M

West London
and London
wide

OSP2

++

M, L-T, D,
R, M

West London
and London
wide

OSP3

IIA Objective

Page 510
7

Performance
of Policy

Temporal
Scale
Nature of
Impact
M, L-T, D,
R, M

Geographical
Extent

Commentary and Recommendations

West London
and London
wide

The policy seeks to deliver housing in appropriate locations, which could lead to
benefits against this objective. However, the types of homes are not specified within
this policy. Local Plan policies H4-H10 provide more detail in relation to housing types
and tenures.
The policy references the importance of delivering lifetime neighbourhoods, which
extols the importance of providing a range of housing types and tenures.
Optimising development in this brownfield location, which is largely at low risk of
flooding, could indirectly help to reduce the pressure for development in areas,
including greenbelt, which may be more susceptible to flood risk. However, some areas
within the OPDC area are at risk of flooding. If these areas are developed, this could
lead to negative effects, if not adequately mitigated. In addition, new large scale
development could increase areas of hardstanding and built development, which could
have negative effects in terms of surface water and sewer flooding, as well as
contributing to increased microclimatic temperatures, if not adequately mitigated.
However, this impact should be mitigated through the other policies of the Local Plan
such as Policy EU3.
A significant increase in development could lead to an increase in hardstanding and
built development, which could have negative effects in relation to surface water and
sewer flooding. This should be mitigated through the other policies of the Local Plan.

range of types
and tenures,
to meet
identified local
needs

OSP4

OSP5

Improve
climate
change
adaptation and
mitigation,
including
minimising the
risk of flooding
and
addressing the
heat island
effect

OSP1

M, L-T, D,
IR, L

OPDC area
and
surrounding
boroughs

OSP2

+/-

M, L-T, D,
IR, L

OPDC area
and
surrounding
boroughs

OSP3

M, L-T, D,
R, M

OOSP
4

+/-

M, L-T, D,
IR, L

OPDC area
and
surrounding
boroughs

OSP5
OSP1

?
+/-

S, M, L-T,
D, IR, L

OPDC area
and
surrounding
boroughs

To minimise
contributions
to climate
change
through

It is unclear what is meant by b) the highest standards of design for the public realm
that can positively accommodate change over time should this mean adapting to
climate change through the use of SuDS, this could be specified. The policy does refer
to the need to respond to environmental change, however.
A significant increase in the density of development could lead to an increase in
hardstanding and built development, which could have negative effects in relation to
surface water and sewer flooding. This should be mitigated through the other policies
of the Local Plan.
The policy will not directly contribute to benefits against this objective.
Optimising development in this location could help to create efficiencies in the potential
for improving energy efficiency through shared generation facilities, as well as
improving the viability of sustainable transport infrastructure. However, the increase in
the demand for energy may outweigh these potential benefits. Reducing the need for
energy should be encouraged through site layouts and sustainable design. This could
be referenced in the design policies of the Local Plan.
6

IIA Objective

Page 511

greater energy
efficiency,
generation
and storage;
and to reduce
reliance on
natural
resources
including fossil
fuels for
transport,
heating and
energy

To minimise
production of
waste across
all sectors in
the plan area,
maximise
efficiencies for
transporting
waste and
increasing
rates of reuse, recycling
and recovery
rates as well

Performance
of Policy

Temporal
Scale
Nature of
Impact
S, M, L-T,
D, IR, L

Geographical
Extent

Commentary and Recommendations

OPDC area
and
surrounding
boroughs

A significant increase in development in this location could increase pressure on the

need for resources, which could lead to negative effects against this objective.
However, the mix of uses may lead to potential efficiencies through reducing the need
to travel as well as the potential for shared energy generation and waste management
facilities.
The development of an improvement to the existing street network connecting stations,
key destinations, neighbourhoods and the surrounding areas, that is well-connected
and legible, is likely to encourage walking and cycling as modes of transport, which
could have benefits against this objective.
The policy could specify that improvements will seek to prioritise non-motorised uses
within the street-scene, and encourage lower vehicle speeds through design crossreference could be made to Policy T1.
Optimising development in this location could help to create efficiencies in the potential
for improving energy efficiency through shared generation facilities, as well as
improving the viability of sustainable transport infrastructure. However, the increase in
the demand for energy may outweigh these potential benefits. Reducing the need for
energy should be encouraged through site layouts and sustainable design. This could
be referenced in the design policies of the Local Plan.
The policy will not directly contribute to benefits against this objective.
Optimising development in this location could help to create efficiencies in the potential
for improving waste management through shared facilities and the creation of a circular
economy. However, the increase in the generation of waste through the extensive
construction period of the development and the potential displacement of waste to
neighbouring boroughs may outweigh these potential benefits. Sustainable design and
increasing the use of recycled materials during construction should be encouraged.
This could be cross-referenced to Policy Eu5.
A significant increase in development in this location could increase pressure on the
need for resources, which could lead to negative effects against this objective.
However, the mix of uses may lead to potential efficiencies through the potential for
shared waste management facilities and the creation of a circular economy. This could
be specified in the supporting text and cross-reference to Policy EU5.

OSP2

+/-

OSP3

++

L-T, D, R,
M

OPDC area

OSP4

+/-

S, M, L-T,
D, IR, L

OPDC area
and
surrounding
boroughs

OSP5
OSP1

?
+/-

S, M, L-T,
D, IR, L

OPDC area
and
surrounding
boroughs

OSP2

+/-

S, M, L-T,
D, IR, L

OPDC area
and
surrounding
boroughs

OSP3
OSP4

0
+/-

S, M, L-T,
D, IR, L

OPDC area
and

The policy will not directly contribute to benefits against this objective.
A significant increase in development in this location could increase pressure on the
need for resources, which could lead to negative effects against this objective.
7

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

surrounding
boroughs

However, the mix of uses may lead to potential efficiencies through the potential for
shared waste management facilities and the creation of a circular economy. This could
be specified in the supporting text and cross-referenced to Eu5.
The policy will not directly contribute to benefits against this objective.
The water quality in local area is currently low. Optimising development in this location
could have benefits for water quality in the long term, in that development could lead to
the remediation of contaminated land as well as replacing potentially contaminating
land uses with housing development and cleaner employment uses. This could
reduce the runoff of contaminated water entering the water environment. However, this
will be dependent on the efficiency of remediation and clean-up operations as well as
the infrastructure to be developed to support new development. Increased
development densities could also have negative effects on the water environment
through increased demand for resources.
The water quality in local area is currently low. Regeneration in this location could have
benefits for water quality in the long term, in that development could lead to the
remediation of contaminated land as well as replacing potentially contaminating land
uses with housing development and cleaner employment uses. This could reduce the
runoff of contaminated water entering the water environment. Increased development
densities could also have negative effects on the water environment through increased
demand for resources.
It is assumed that sustainability covers the water environment to a degree. However. It
is unclear what is meant by b) the highest standards of design for the public realm that
can positively accommodate change over time should this mean adapting to climate
change through the use of SuDS, this could be specified.
Increased development densities could have negative effects on the water environment
through increased demand for resources, if not adequately mitigated. It is
recommended that water efficiency measures are designed into developments from the
outset. This is addressed in Policy EU3 of the Local Plan.
The policy will not directly contribute to benefits against this objective. See
recommendation under Objective 7.
The area includes a Local Nature Reserve (Wormwood Scrubs) and a nature
conservation area of Metropolitan Importance adjacent to the Grand Union Canal.
Anecdotal evidence as part of the scoping workshop has suggested that some of the
brownfield areas within the site may have importance for biodiversity through the
presence of colonising species. Optimising development in this location could have

Nature of
Impact
as composting
of all green
waste
9

Improve the
quality of the
water
environment

Page 512
10

Create and
enhance
biodiversity
and the

OSP5
OSP1

0
+/-

OSP2

+/-

OSP3

OSP4

+/-

OSP5

OSP1

+/-

S, M, L-T,
D, R, L

OPDC area
and
surrounding
boroughs

S, M, L-T,
D, R, L

OPDC area
and
surrounding
boroughs

S, M, L-T,
D, IR, M

OPDC area
and
surrounding
boroughs

S, M, L-T,
D, IR, L

OPDC area
and
surrounding
boroughs

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
diversity of
habitats
across the
area and its
surroundings

+/-

OSP3

S, M, L-T,
D, IR, L

OPDC area
and
surrounding
boroughs

S, M, L-T, I,
R, L

OPDC area
and
surrounding
boroughs

Page 513

OSP2

OSP4

S, M, L-T,
D, IR, L

OPDC area
and
surrounding
boroughs

benefits for biodiversity in the long term, in that development could lead to the
remediation of contaminated land as well as replacing potentially contaminating land
uses which could improve soil quality. However, the density of development proposed
could reduce the potential for biodiversity through a decrease in the potential land
available for enhancement measures as well as increasing the local population, which
could increase disturbance. Certainty in the prediction of effects is considered to be
low. The construction period in the short and medium terms could have particularly
negative consequences, as existing biodiversity resources on brownfield sites could be
lost. This should be protected through Policy EU8.
The development proposed could reduce the potential for biodiversity through a
decrease in the potential land available for enhancement measures as well as
increasing the local population, which could increase disturbance. However, the
replacement of industrial land overall with green infrastructure would provide
opportunities. The construction period in the short and medium terms could have
particularly negative consequences, as existing biodiversity resources on brownfield
sites could be lost. This should be protected through Policy EU8. It is recommended
that a management plan or similar be developed, in order to guide development
proposals. This could link to a wider green infrastructure strategy (See policy EU8), to
ensure a holistic approach across the plan area. A Green Infrastructure strategy would
be beneficial.
The policy seeks to celebrate existing amenity spaces including the canalside nature
reserve, Wormwood Scrubs and the Grand Union Canal. This could lead to benefits
against this objective, should the celebration lead to enhancement and management
of the biodiversity of these assets.
Although hinted towards in the supporting text (including a reference to Policy EU8), It
is recommended that this policy set out, as part of the strategic connections, that multifunctional green infrastructure will form a key part of the overall strategic plan and
linkages. This could provide benefits for flood and surface water management,
biodiversity, micro-climate, alongside the existing requirements for human connectivity.
The area includes a Local Nature Reserve (Wormwood Scrubs) and a nature
conservation area of Metropolitan Importance adjacent to the Grand Union Canal.
Anecdotal evidence as part of the scoping workshop has suggested that some of the
brownfield areas within the site may have importance for biodiversity through the
presence of colonising species. Increased development densities could have negative
9

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

11

Page 514

To minimise
air, noise and
light pollution,
particularly for
vulnerable
groups

OSP5

S, M, L-T, I,
R, L
S, M, L-T,
D, IR, L

OPDC area

OSP1

+/-

OSP2

+/-

S, M, L-T,
D, IR, L

OPDC area
and
surrounding
boroughs

OSP3

L-T, D, R,
M

OPDC area

OSP4

+/-

L-T, D, R,
M

OPDC area

OPDC area
and
surrounding
boroughs

effects on the biodiversity through increased demand for land resources and
disturbance. Certainty in the prediction of effects is considered to be low although note
that EU8 requires no net loss of biodiversity. Recommendation: Need for biodiversity
policy to identify that there is also biodiversity in areas not identified as SINCs and that
this biodiversity should also be safeguarded or replaced to equal biodiversity value.
Also recommend a GI strategy.
The policy seeks to celebrate existing features of the Grand Union Canal, Wormwood
Scrubs which would benefit this SA Objective
Optimising development in this location could have benefits for air, noise and light
pollution in the long term, in that development could lead to the replacement of
potentially polluting industrial land uses in some areas. Further, the improvements in
transport infrastructure could reduce levels of pollution from this source. However, the
density of development proposed could reduce the potential for pollution through an
increase in the local population, which could increase traffic levels as well as built
development and its associated light and noise pollution in particular. The construction
period in the short and medium terms could have particularly negative consequences
through the generation of dust, night working and pollution related to traffic. This
should be minimised through the environment policies contained within the Local Plan.
Development in this location could have benefits for air, noise and light pollution in the
long term, in that development could lead to the replacement of potentially polluting
industrial land uses in some areas. However, the density of development proposed
could reduce the potential for pollution through an increase in the local population,
which could increase traffic levels as well as built development and its associated light
and noise pollution in particular. The construction period in the short and medium terms
could have particularly negative consequences through the generation of dust, night
working and pollution related to traffic. This should be minimised through the
environment policies contained within the Local Plan.
Insofar as the development could lead to an improvement to the existing street network
connecting stations, key destinations, neighbourhoods and the surrounding areas, that
is well-connected and legible, this is likely to encourage walking and cycling as modes
of transport, which could have benefits against this objective.
The policy could specify that the network will be accessible as well as legible, to
accommodate vulnerable groups.
Insofar as the development could lead to an improvement to the existing street network
connecting stations, key destinations, neighbourhoods and the surrounding areas, that
10

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

12

Page 515

To conserve
and enhance
the historic
environment,
heritage
assets and
their settings

OSP5
OSP1

0
+/-

OSP2

OSP3

S, M, L-T,
D, IR, L

OPDC area
and
surrounding
boroughs

+/-

S, M, L-T,
D, IR, L

OPDC area
and
surrounding
boroughs

++

S, M, L-T, I,
R, L

OPDC area
and
surrounding
boroughs

is well-connected and legible, this is likely to encourage walking and cycling as modes
of transport, which could have benefits against this objective. However, the density of
development proposed could reduce the potential for pollution through an increase in
the local population, which could increase traffic levels as well as built development
and its associated light and noise pollution in particular.
The policy will not directly contribute to benefits against this objective.
There are a number of undeclared heritage assets in the area. Therefore, optimising
development in this location could lead to negative effects should these assets not be
recognised as part of the regeneration of the area. However, the regeneration of the
area could also lead to benefits in the medium and long-term, through the potential for
improving the setting of the historic environment, as well as improving the assets
themselves through re-use. However, this is not specified in the policy. See Policy D6,
There are a number of undeclared heritage assets in the area. Therefore, development
in this location could lead to negative effects should these assets not be recognised as
part of the regeneration of the area. However, the regeneration of the area could also
lead to benefits in the medium and long-term, through the potential for improving the
setting of the historic environment, as well as improving the assets themselves through
re-use. However, this is not specified in the policy. However, this is not specified in the
policy. See Policy D6,
The policy specifically seeks to celebrate existing amenity spaces including the
heritage asset St Marys Cemetery. This could lead to benefits against this objective,
should the celebration lead to enhancement and management of this asset.
It is recommended that the policy could include reference to the celebrating the wider
historic environment across the area, including improving legibility and the setting of
other designated and undesignated heritage assets and conservation areas. This
would be complementary to improving the design of the public realm alongside the
development of a green infrastructure network.

11

IIA Objective

Performance
of Policy

Temporal
Scale

OOSP
4

+/-

Nature of
Impact
S, M, L-T,
D, IR, L

OSP5

++

S, M, L-T,
D, IR, L

Page 516
13

Increase
community
cohesion and
reduce social
exclusion to
encourage a
sense of
community
and welfare

Geographical
Extent

Commentary and Recommendations

OPDC area
and
surrounding
boroughs

There are a number of undeclared heritage assets in the area. Therefore, development
in this location could lead to negative effects should these assets not be recognised as
part of the regeneration of the area. However, the regeneration of the area could also
lead to benefits in the medium and long-term, through the potential for improving the
setting of the historic environment, as well as improving the assets themselves through
re-use. However, this is not specified in the policy. See Policy D6. The supporting text
to the policy states that sensitive locations are considered to be areas adjacent to
designated heritage assets, existing public amenity spaces and existing residential
communities. It is recommended that point e) of the policy is reworded to sensitive
locations as opposed to sensitive edges to be consistent with the definition in the
supporting text and to improve implementation.
The policy should lead to the enhancement of the historic environment through a focus
on creating a series of attractive and locally distinctive places. Heritage is specified in
the supporting text as a contributor to the identification of local distinctiveness.

OPDC area
and
surrounding
boroughs

OSP1

M, L-T, I, R,
L

West London
and London
wide

OSP2

M, L-T, I, R,
L

West London
and London
wide

OSP3

++

L-T, D, R,
M

OPDC area

It is recommended that background studies to inform the development of place-making

also include the development of a local historic environment study, to identify any
locally important heritage assets. These could form part of the identification of valued
buildings as set out in the supporting text to the policy.
As explained in the policy supporting text, optimising development in this location could
contribute to meting Londons identified need for homes, thereby contributing to the
achievement of benefits against this objective. The delivery of an improvement in
economic prosperity and the delivery of strategic infrastructure could have long term
benefits for community cohesion. This could be delivered through policy SI1.
The development of a new part of London could lead to an increased sense of
community cohesion over the existing situation, as they development would generate a
significant number of housing and jobs over the long term. The delivery of a full mix of
town centre uses, including schools, health centres and community space, could
ensure that a sense of community and welfare is created. The policy should specify
requirements in relation to the quantum of services and facilities to be provided in
relation to the incoming population. This should be delivered through the Social
Infrastructure policies of the Local Plan and the infrastructure table in the delivery and
implementation chapter.
The development of an improvement to the existing street network connecting stations,
key destinations, neighbourhoods and the surrounding areas, that is well-connected
12

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

14

Page 517

Improve safety
and reduce
crime and the
fear of crime

OSP4

M, L-T, D,
ID, R, M

West London
and London
wide

OSP5

++

S, M, L-T, I,
R, M

OSP1

M, L-T, I, R,
L

OSP2

L-T, I, R, L

OSP3

L-T, D, R,
M

OPDC area
and
surrounding
boroughs
West London
and London
wide
West London
and London
wide
OPDC area
and
surrounding
boroughs

OSP4

L-T, I, R, L

OSP5

S, M, L-T, I,
R, M

West London
and London
wide
OPDC area
and
surrounding
boroughs

and legible, is likely to encourage walking and cycling as modes of transport, which
could lead to benefits against this objective as increased community interaction could
lead to an increase in a sense of community.
The policy seeks to deliver high density development in areas close to public transport
nodes as well as key service areas such as Old Oak High Street. The development
supports the delivery of high quality housing, retail, employment space and social
infrastructure, which could lead to benefits against this objective through an increase in
facilities for direct benefits, and increased community interaction for indirect benefits.
The policy clearly states that proposals should demonstrate early engagement with
existing residents and businesses to inform place-making. This could lead to significant
benefits against this objective, creating a sense of community cohesion and ownership
locally.
The optimisation of development in this area, including strategic infrastructure that
could improve traffic management, could lead to benefits against this objective through
improved safety. See Policy D2.
The development of a mix of uses including housing, employment and community
facilities could increase a sense of community cohesion that, in turn, could lead to long
term benefits for crime and fear of crime.
The development of an improvement to the existing street network connecting stations,
key destinations, neighbourhoods and the surrounding areas, that is well-connected
and legible, is likely to encourage walking and cycling as modes of transport, which
could lead to benefits against this objective as increased community interaction could
lead to an increase in a sense of community and a reduction in the fear of crime.
The policy could include a requirement to improve natural surveillance through design
measures such as active frontages and open design (including lighting), which could
reduce the fear of crime within public spaces. See Policy D2.
The development of a mix of uses including housing, employment and community
facilities could increase a sense of community cohesion that, in turn, could lead to long
term benefits for crime and fear of crime.
The policy clearly states that proposals should demonstrate early engagement with
existing residents and businesses to inform place-making. This could lead to benefits
against this objective, creating a sense of community cohesion and ownership locally.
High quality design could also lead to benefits against this objective, depending on the
nature of design principles employed. Active frontages and the principles of Secured by
Design should be required cross-reference to Town Centres chapter.
13

IIA Objective

15

Maximise the
health and
wellbeing of
the population,
reduce
inequalities in
health and
promote
healthy living

Performance
of Policy

Temporal
Scale
Nature of
Impact
S, M, L-T, I,
R, L

Page 518

Geographical
Extent

Commentary and Recommendations

OPDC area
and
surrounding
boroughs.

As explained in the policy supporting text, optimising development in this location could
contribute to meting Londons identified need for homes, thereby contributing to the
achievement of benefits against this objective. The delivery of an improvement in
economic prosperity and the delivery of strategic infrastructure could also have benefits
for health. Strategic infrastructure may increase the use of sustainable transport in the
long term, which could have benefits for mental health as a result of community
interaction as well as physical benefits through physical activity, such as from walking
or cycling. There is potential, however, for short/medium term negative effects to arise
during the construction period, through effects such as stress as well as direct effects
from pollution including noise, air and light.
Development in this location could contribute to meeting Londons identified need for
homes as well as the provision of health centres, new schools and community spaces,
thereby contributing to the achievement of benefits against this objective. The delivery
of an improvement in economic prosperity and the delivery of strategic infrastructure
could also have benefits for health. There is potential, however, for short/medium term
negative effects to arise during the construction period, through effects such as stress
as well as direct effects from pollution including noise, air and light.
The development of an improvement to the existing street network connecting stations,
key destinations, neighbourhoods and the surrounding areas, that is well-connected
and legible, is likely to encourage walking and cycling as modes of transport, which
could lead to benefits against this objective as it could increase access to health care,
as well as providing indirect health benefits from physical activity and community
interaction.
See recommendations under objective 11.
Focusing development in accessible locations could have benefits for health in terms of
access to facilities as well as community interaction through the increase in the use of
public transport, which could have further benefits. High density housing development
in tall buildings, however, may lead to problems in accessibility for some members of
the community. Meeting the needs of these members of the community should be
considered.
The policy will not directly contribute to benefits against this objective. However, it is
considered that a multi-functional green infrastructure network, which could provide
benefits such as pollution sequestration and walking and cycling routes, could
contribute to the creation of place and local distinctiveness. This could be added to the
list in the supporting text.

OSP1

+/-

OSP2

S, M, L-T, I,
R, L

OPDC area
and
surrounding
boroughs.

OSP3

++

L-T, D, R,
M

OPDC area

OSP4

+/-

S, M, L-T,
D, R, L

West London
and London
wide

OSP5

14

IIA Objective

16

Page 519

17

18

To improve
the education
and skills
levels of all
members of
the population,
particularly
vulnerable
groups

Maximise the
social and
economic
wellbeing of
the local and
regional
population and
improve
access to
employment
and training

To encourage

Performance
of Policy

OSP1

OSP2

++

OSP3
OSP4

0
+

OSP5

OSP1

Temporal
Scale
Nature of
Impact
M, L-T, I, R,
L
S, M, L-T, I,
R, L

Geographical
Extent

Commentary and Recommendations

West London
and London
wide
OPDC area
and
surrounding
boroughs.

The optimisation of development in this area, including strategic infrastructure that

could lead to benefits against this objective. The social infrastructure policies of the
Local Plan should provide benefits against this objective.
Development in this location could contribute to meeting Londons identified need for
homes and jobs as well as the provision of new schools and community spaces,
thereby contributing to the achievement of benefits against this objective. The policy
promotes the provision of associated infrastructure to support the new development.
The policy will not directly contribute to benefits against this objective.
The development of a mix of uses including housing, employment and social
infrastructure could improve access to education facilities. Focusing development in
accessible locations could have further benefits for accessibility to education and
training opportunities in the surrounding areas and across London.
The policy identifies that catalyst uses could include educational institutions and this
would provide local residents with local opportunities to access higher education.
As explained in the policy supporting text, optimising development in this location could
contribute to driving forward the economic prosperity of the local area as well as the
surrounding boroughs. Short term benefits may arise from the generation of
employment during the construction period, although negative effects may also arise
through the loss of local employment lost through the regeneration activities.
As explained in the policy supporting text, the scale of development in the OPDC area
can have a profound impact on both the London and the UK economies, providing an
additional 65,000 jobs. However, locally, negative effects may also arise through the
loss of local industrial employment and businesses lost through the regeneration
activities.
The policy will not directly contribute to benefits against this objective.
The development of a mix of uses including housing, employment and social
infrastructure could improve access to employment and training opportunities.
Focusing development in accessible locations could have further benefits for
accessibility to opportunities in the surrounding areas and across London.
The policy clearly states that proposals should demonstrate early engagement with
existing residents and businesses to inform place-making. This could lead to benefits
against this objective. The policy identifies that catalyst uses could include educational
institutions and this would provide local residents with local opportunities to access
higher education, including training opportunities.
As explained in the policy supporting text, optimising development in this location could

S, M, L-T, I,
R, L

West London
and London
wide

+/-

S, M, L-T, I,
R, L

OPDC area,
West
London,
London wide

OSP2

S, M, L-T, I,
R, L

OPDC area,
West
London,
London wide

OSP3
OSP4

0
+

S, M, L-T, I,
R, L

West London
and London
wide

OSP5

++

S, M, L-T, I,
R, M

OPDC area
and
surrounding
boroughs

OSP1

M, L-T, I, R,

OPDC area,

15

IIA Objective

inward
investment
alongside
investment
within existing
communities,
to create
sustainable
economic
growth

Performance
of Policy

Temporal
Scale
Nature of
Impact
L

Page 520

OSP2

S, M, L-T, I,
R, L

OSP3

M, L-T, I, R,
L

OSP4

M, L-T, I, R,
L

OSP5

S, M, L-T, I,
R, M

Geographical
Extent

Commentary and Recommendations

West
London,
London wide
OPDC area,
West
London,
London wide
OPDC area,
West
London,
London wide
OPDC area,
West
London,
London wide
OPDC area
and
surrounding
boroughs

contribute to driving forward the economic prosperity of the local area as well as the
surrounding boroughs.
As explained in the policy supporting text, the scale of development in the OPDC area
can have a profound impact on both the London and the UK economies. This could
have benefits against this objective.
The policy could lead to indirect positive effects against this objective, as an
improvement in the local environment and connectivity could improve the
attractiveness of the area to inward investors.
The policy could lead to indirect positive effects against this objective, as an
improvement in connectivity and accessibility to public transport opportunities could
improve the attractiveness of the area to inward investors.
The policy clearly states that proposals should demonstrate early engagement with
existing residents and businesses to inform place-making. This could lead to benefits
against this objective.

16

Table G-2 Chapter 4: The Places

x P1: Old Oak South
x P2: Old Oak North
x P3: Old Oak High Street
x P4: Grand Union Canal
x P5: Park Royal
x P6: Park Royal Centre
x P7: North Acton
x P8: Scrubs Lane
x P9: Old Oak West
x P10: Wormwood Scrubs
IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

Page 521

To enhance the P1
built environment
and encourage
place-making

++ M, L-T, I, R,
M

P2

++ S, M-T, I, R,
M

P3

++ S, M, L-T, I,
R, L

Old Oak South As stated in the supporting text, the area specific policy should help to deliver a strong
and OPDC
sense of place through development, reflecting and building upon the areas existing
area
character.
The vision for the area highlights that Old Oak South will see a new commercial hub,
centred on the new Old Oak Common Station. The station, along with the a new London
Overground station, will be fully embedded into its surroundings, providing visitors,
employees and residents with easy access to west London and the OPDC regeneration
area. Wormwood Scrubs and the Grand Union Canal will be integral to the creation of a
unique sense of place. The land uses supported in the policy text should help to support
the creation of a sense of place, leading to the prediction of significant positive effects
against this objective. As the majority of Old Oak South is likely to come forward for
development post-2026, medium to long term effects are predicted.
Old Oak North The vision for the area highlights that Old Oak North will be redeveloped in the earlier
and OPDC
states of the regeneration. The development will be residential-led with a mix of town
area
centre uses. The future population will benefit from a new network of streets, open
spaces and associated community infrastructure embedded into new buildings and in
accessible locations. Early phases of development will be supported by a range of
meanwhile uses and employment space for SMEs that help support place-making, deliver
a mixed use place and act as a catalyst for wider regeneration. This could lead to
significant benefits against this objective.
Old Oak South The vision for the area states that the street will be a primary north-south route through
Old Oak, connecting Harlesden to Wormwood Scrubs and further south. The high street
and Old Oak
will be designed to the highest quality, materials and green infrastructure. The variation
North
17

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
in levels along the high street will create unique features and spaces that will play a
defining role in shaping Old Oaks sense of place.
The Vision for the area suggest that the character of the high streets will likely change
along its length, with a commercial focus in Old Oak South, providing services for the
large number of employees, and providing a mix of uses and spaces in Old Oak North to
support the areas future residential population. However, this differs from the description
of the three character areas in the policy wording. Positive effects are predicted.

Page 522

P4

++ S, M, L-T, I,
R, L

P5

++ S, M, L-T, I,
R, L

P6

++ M, L-T, I, R,
M

It is suggested that further clarity with regards to green infrastructure is provided

strategically, to which the requirement within the policy could refer to. It is also
recommended that it is referred to as multifunctional green infrastructure as, although
SuDS are referred to in the supporting text, green infrastructure has the potential to
provide greater benefits.
Old Oak North, The vision for the Grand Union Canal states that it will be central to creating a new part of
Old Oak South London in Old Oak and enhancing Park Royal as a thriving industrial area.
and Park Royal The policy states that the land along the canal will deliver housing and employment uses
along its length in Old Oak, and industrial uses and ancillary uses with active frontages at
ground floor level in Park Royal. This should help to create a sense of place.
It is recommended that clarity is provided in the supporting text as to the nature of new
and enhanced green and civic spaces as required through the policy wording in relation
to green infrastructure, and what their functions are intended to be.
Park Royal
The policy supports improvements to the road network to address congestion, as well as
improving the frequency, capacity and connectivity of the local bus network. In addition to
supporting the delivery of improvements to the walking and cycling network, the policy
could lead to an improvement in the sense of place. In addition, design measures and the
provision of public open spaces could help to reinforce a sense of local distinctiveness.
Park Royal and As stated in the Local Plan, the area currently lacks a defined character and its
OPDC area
environment is dominated by the road network. These streets are framed by inactive
building frontages and parking, creating a poor quality public realm. The vision for the
area seeks to enhance the range of services, shared services and amenities in the area,
to support local business, existing residential and medical communities. The public realm
will be improved to benefit from new public open spaces alongside active street
frontages. This is reflected in the policy wording and should lead to benefits against this
objective.
18

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
++ M, L-T, I, R,
M

P8

++ M, L-T, I, R,
M

P9

++ S, M, L-T, I,
R, M

P10

++ S, M, L-T, I,
R, M

Page 523

P7

To optimise the P1
efficient use of
land through
P2
increased
development
densities and
building heights, P3
where
appropriate
P4

++ M, L-T, I, R,
M
++ S, M-T, I, R,
M

++ S, M, L-T, I,
R, M
++ S, M, L-T, I,

The policy seeks to improve the public realm within the area, including supporting the
development of active frontages. Alongside the delivery of a new public civic square,
residential, employment, community infrastructure and improved connections across the
area, the policy could lead to the generation of significant positive benefits against this
objective.
Scrubs Lane The policy seeks to contribute to and/or deliver new and improved walking and cycling
routes, access to the Scrubs as well as a high quality coordinated public realm and street
and OPDC
greening. Alongside the overall approach to the area, which focusses development
area
around the important historic character of the area, these measures should lead to an
improvement in local distinctiveness locally.
OPDC area
Currently, the public realm along Old Oak Lane is dominated by vehicular transport
providing a poor walking and cycling experience. The vision for the area states that Old
Oak West will be a diverse area, reflecting its location between Old Oak and Park Royal,
centred on improving busy street environment and the industrial innovation area adjacent
to the Grand Union Canal. The HS2 construction sites are included in the industrial areas
north and south of the canal. The vision states that these sites will provide a space for
industrial innovation within a high quality environment, which integrates with Old Oak and
Harlesden. Public realm improvements may provide some benefits, although as a
connecting place with large construction sites, effects are unlikely to be significant.
OPDC area
Wormwood Scrubs is described in the Local Plan as a green lung that provides people
and wildlife with the opportunity to enjoy open space. The policy seeks to supports the
area as a public open space, alongside securing resources for its management, which
should help to enhance its function locally.
Old Oak South The policy specifies the areas where high densities will be encouraged across the area.
and OPDC
This could lead to benefits against this Objective.
area
Old Oak South The vision for the area highlights that densities in Old Oak North will include high density
development in areas with good public transport access and facilities, with lower density
and OPDC
development in sensitive areas such as the canal. This could lead to the efficient use of
area
land in this area.
Old Oak South The policy specifies the areas where high densities will be encouraged across the area.
This could lead to benefits against this Objective.
and Old Oak
North
Old Oak South The policy specifies the areas where high densities will be encouraged across the area.
North Acton
and OPDC
area

19

IIA Objective

Performance of Temporal
Policy
Scale
Nature of
Impact
R, M

Page 524
3

Geographical
Extent

Commentary and Recommendations

and Old Oak

North
Park Royal

This could lead to benefits against this Objective.

P5

++ S, M, L-T, I,
R, M

P6

++ M, L-T, I, R, L Park Royal

area

P7

++ S, M, L-T, I,
R, M

North Acton

P8

++ S, M, L-T, I,
R, M

North Acton

P9

++ S, M, L-T, I,
R, M

P10

Old Oak West The policy seek to intensify the use of sites within the SIL by requiring proposals to
demonstrate how they are maximising the use of sites, including the provision of smaller
unity, to support greater industrial employment densities. This could lead to benefits
against this Objective.
Wormwood
The continued protection of Wormwood Scrubs is considered to be an efficient use of
Scrubs
space appropriate to its relevant designations.
Old Oak South The policy specifies the areas where high densities will be encouraged across the area.
This would lead to benefits against this Objective.
and OPDC
area
Old Oak South The vision for the area highlights that densities in Old Oak North will include high density
and OPDC
development in areas with good public transport access and facilities, with lower density
area
development in sensitive areas such as the canal. This could lead to the efficient use of
land in this area, maximising the re-use of previously developed land.
Old Oak South The policy specifies the areas where high densities will be encouraged across the area.
This could lead to benefits against this Objective.
and Old Oak
North

P1
Maximise the
reuse of
previously
P2
developed land
and existing
buildings,
including the
P3
remediation of

S, M, L-T, I,
R, M
++ M, L-T, I, R,
M
++ S, M-T, I, R,
M

++ S, M, L-T, I,
R, M

The vision for the Park Royal area states that the design of industrial buildings is likely to
change, responding to the need for making optimum use of land as values rise and new
technologies support structural change. This should lead to the optimisation of land in this
location.
The policy seeks to centralise the provision of services, shared services and amenities to
support local businesses, residents and the medical community alongside providing
improved accessibility by walking and cycling modes within the area. It also states that
proposals will be required to demonstrate how they are optimising the use of land. This
would create some benefits against this objective through creating a more efficient use of
land.
The policy specifies the areas where high densities will be encouraged across the area.
This could lead to benefits against this Objective.
The policy specifies the areas where high densities will be encouraged across the area,
seeking to recognise sensitive historic assets as locations where lower densities would
be appropriate. This could lead to benefits against this Objective.

20

IIA Objective

contaminated
land

Page 525
4

Performance of Temporal
Policy
Scale

P4

Nature of
Impact
++ S, M, L-T, I,
R, M

Geographical
Extent

Commentary and Recommendations

Old Oak South The policy specifies the areas where high densities will be encouraged across the area.
This could lead to benefits against this Objective.
and Old Oak
North
Park Royal
The vision for the Park Royal area states that the design of industrial buildings is likely to
change, responding to the need for making optimum use of land as values rise and new
technologies support structural change. This should lead to benefits against this
objective.
Park Royal
The policy is likely to lead to the re-use and improved efficiency in the use of previously
Centre
developed land, which should generate benefits against this objective.

P5

++ S, M, L-T, I,
R, M

P6

++ S, M, L-T, I,
R, M

P7

++ S, M, L-T, I,
R, M

North Acton

The policy specifies the areas where high densities will be encouraged across the area.
This could lead to benefits against this Objective.

P8

++ S, M, L-T, I,
R, M

North Acton

The policy specifies the areas where high densities will be encouraged across the area,
seeking to recognise sensitive historic assets as locations where lower densities would
be appropriate. This could lead to benefits against this Objective.

P9

++ S, M, L-T, I,
R, M

P10
P1
Minimise the
need to travel,
improve
accessibility for
all users by
public and nonmotorised
transportation
methods and
mitigate impacts
on the transport

Old Oak West The policy seek to intensify the use of sites within the SIL by requiring proposals to
demonstrate how they are maximising the use of sites, including the provision of smaller
unity, to support greater industrial employment densities. This could lead to benefits
against this Objective.
0
The policy will not lead to the development of previously developed land.
Supporting text to the policy highlights that walking and cycling access within the area is
++ M, L-T, D, R, OPDC area,
M
London wide very constrained, which restricts movements to the north/south and east/west. The vision
and nationally for Old Oak South includes that the area will be focussed on a new Old Oak Common
station and a new London Overground station. In addition, a complete new network of
streets and bridges will integrate Old Oak South with its surroundings. The policy
wording states that the delivery of a network of unique and connected neighbourhoods
will be supported. This could lead to significant benefits against this objective through
encouraging the use of non-motorised transport across the area. Further significant
benefits may be realised from the supporting of new rail, bus, taxi and cycle infrastructure
and ensuring that these integrated with their surroundings, including the provision of
direct pedestrian and cycle access to Wormwood Scrubs. A direct vehicle connection
over the Grand Union Canal, improving existing streets and supporting better connections
to the Kensal Canalside Opportunity Area, could also lead to significant benefits against
21

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
this objective.

network

P2

Page 526

P3

P4

P5

It is suggested that the delivery and transport sections of the policy repeat the
supporting of transport infrastructure. These two sections could be merged, to avoid
repetition. It is also suggested that the streets section (o) repeats the need for the new
transport infrastructure to integrate with its surroundings. These two sections could be
streamlined to avoid repetition.
Willesden Junction station is situated in the northern part of Old Oak North and provides
++ M, L-T, D, R, OPDC area,
M
London wide access to both the Bakerloo London Underground Line and the London Overground.
and nationally However, at present, access from this station to the core development area is poor. The
core development area also doesnt include any east-west links.
The policy seeks to facilitate the delivery of a network of unique and connected
neighbourhoods, an enhanced Willesden Junction Station and a new Overground Station
on the West London line. Contributing to the new Old Oak High Street, providing better
connections across the area should improve accessibility significantly.
++ S, M, L-T, I, Old Oak South The policy seeks to provide legible connections to and from transport interchanges as
well as providing a high quality public realm that is attractive to both pedestrians and
R, M
and Old Oak
North, OPDC cyclists. Alongside the provision of services and facilities, this could lead to significant
benefits against this objective.
area and
surrounding
boroughs
++ S, M, L-T, I, OPDC area
The Local Plan outlines that the current character of the Grand Union Canal is
R, M
and
characterised by limited passive surveillance, which has a negative impact on the use of
surrounding
the tow path for walking, cycling and recreation. The canal itself is not currently
boroughs
extensively used for transport and is home to a community of residential moorings. The
vision sets out that development in this area will provide a safe and convenient walking
and cycling route enabling people to access the length of Old Oak, Park Royal and
beyond. New bridge crossings will support easier north/south movement while the canal
itself will be promoted and used for the transport of people and freight. This is reflected in
the policy wording, with the addition of the use of the canal for leisure uses. This could
lead to significant benefits against this objective.
++ S, M, L-T, I, OPDC area
As stated in the Local Plan, the Park Royal area currently suffers from high levels of road
R, M
and
congestion generated by industrial functions and a reliance on private vehicular transport.
surrounding
The vision states that residential pockets and open spaces will be better connected by
boroughs
safe and inviting routes to allow existing and future residents in these areas to access the
22

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

P6

P7

Page 527
P8

P9

P10

range of new services that will be available in old oak. The policy supports improvements
to the frequency, capacity and connectivity of the local bus network. In addition, the
delivery of improvements to the walking and cycling network could lead to significant
benefits against this objective.
++ S, M, L-T, I, Park Royal and The policy seeks to centralise services and amenities for the local business community,
residents and the medical community. The policy also supports improvements to the bus
R, M
OPDC area,
network, highway network and the legibility of streets, including the delivery of cycling and
and
walking infrastructure. This could lead to significant benefits against this objective.
surrounding
boroughs
The vision for the area supports new and improved connections to Old Oak Common
++ M, L-T, I, R, L North Acton
Station, and will ensure that North Action is integrated into the wider regeneration area.
and OPDC
The policy also has a significant focus on providing higher density development which is
area, and
focussed around the North Acton station. Highways improvements and active frontages
surrounding
along streets are proposed, alongside new and/or improved connections across the A40
boroughs
to West Acton. The policy also proposes new walking and cycling routes and significant
employment as well as residential, thereby bringing homes and jobs closer together.
These measures could lead to some benefits against this objective, although a focus on
highways improvements could reduce potential significance. It is also unclear what type
of connections across the A40 are supported by the policy.

++ M, L-T, I, R, L Scrubs Lane

and OPDC
area, and
surrounding
boroughs
++ S, M, L-T, I, OPDC area,
R, L
and
surrounding
boroughs
++ S, M, L-T, D, OPDC area,
R, M
and
surrounding
boroughs

It is suggested that the proposed connections across the A40 are explained more clearly
in the policy text.
The policy recognised the potential for high and medium densities to the north of the
canal and west of Scrubs Lane nearer to the proposed Hythe Road Station which should
lead to benefits against this objective. Further, the policy seeks to contribute towards
and/or deliver new and improved walking and cycling routes as well as vehicular routes
and connections. These measures could lead to some benefits against this objective.
The policy seeks to minimise the impacts of construction traffic on the street network,
existing residents and businesses, including through the use of consolidation centres.
Developments should improve connections across the area, including vehicle, walking
and cycling routes. These measures could lead to benefits against this objective.
The policy seeks to improve access to Wormwood Scrubs to and from Little Wormwood
Scrubs, North Kensington, Old Oak Common Estate and other areas to the south and Old
Oak. This could help to improve accessibility and help to connect communities within the
area.
23

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

Page 528

Improve access P1
to well designed,
well-located,
P2
market,
affordable and
inclusive housing
of a range of
P3
types and
tenures, to meet
identified local
needs

M, L-T, D, R,
M

S, M-T, D, R,
M

S, M, L-T, D,
R, M

P4

S, M, L-T, D,
R, M

P5

S, M, L-T, D,
R, M

The policy wording could specify that promoted access to Wormwood Scrubs would be
via walking and cycling modes, as set out in the supporting text to the policy.
OPDC area
The policy wording specifies that developments that deliver residential development
across the whole of Old Oak South will be supported, which could lead to positive effects
against this objective.
OPDC area
The vision for the area highlights that Old Oak North will be redeveloped in the earlier
states of the regeneration. The development will be residential-led with a mix of town
centre uses. Old Oak North will make a significant contribution to the areas housing
need.
Old Oak South The policy states that residential uses will be provided on the upper floors of the high
street. Alongside proposed policies for Old Oak South and Old Oak North, this will
and Old Oak
North, OPDC contribute to the achievement of this objective.
area and
surrounding
boroughs
Grand Union The canal itself is not currently extensively used for transport and is home to a community
Canal
of residential moorings. The vision sets out that new bridge crossings will support easier
north/south movement while the canal itself will be promoted and used for the transport of
people and freight. The policy states that new development will be supported where it
supports the delivery of residential and visitor moorings in appropriate locations that do
not adversely impact on the regeneration of the wider area or navigational function of the
canal. It also identifies that residential uses with front doors on to the canal edge will be
supported. This could lead to both positive and negative effects against this objective, as
some existing residential moorings may be lost, where they are not considered to be in
conformity with the regeneration proposals of the Local Plan. However, the overall net
delivery of housing supply will be higher.
Park Royal
The east of the area includes a Gypsy and Traveller site. The justification text directs
readers to policy H9 which provides guidance for Gypsy and Traveller Accommodation.
The First Central site will include a mix of uses including housing, which could deliver
some benefits against this objective.
The policy could provide further information following the completion of the OPDC Gypsy
and Traveller Accommodation Needs Assessment in light of emerging legislation.
24

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
P6

Page 529

P7

++ S, M, L-T, D, North Acton,

R, L
OPDC area
and
surrounding
boroughs

P8

P9

P10
P1
Improve climate
change
adaptation and
mitigation,
including
minimising the
risk of flooding
and addressing
the heat island
effect
P2

P3

0
+

S, M, L-T, D, Scrubs Lane

R, L
and OPDC
area
M, L-T, D, R, OPDC area
L

S, M, L-T, D, OPDC area

IR, L
and
surrounding
boroughs

S, M, L-T, D, OPDC area

IR, L
and
surrounding
boroughs

S, M, L-T, I,
R, M

The policy does not specifically propose housing within the area and so no effects are
predicted.
As stated in the Local Plan, the area is currently being regenerated with existing
developments of residential and student housing being included within the land uses. The
perfume factory sites is also expected to be redeveloped as a residential-led mixed use
development. The vision for the area seeks to build upon this, to provide a substantial
number of new homes in the area, which could lead to benefits against this objective.
However, this is not reflected in the policy wording.
The policy seeks to provide housing as part of mixed use developments within the area.
This could contribute to positive effects against this objective.
The policy states that housing densities should be mindful of the surrounding context.
Residential is supported outside the SIL.
The policy will not lead to the delivery of housing development.
A significant increase in the density of development could lead to an increase in
hardstanding and built development, which could have negative effects in relation to
surface water and sewer flooding if not adequately mitigated through flood management
and design as suggested in the Environment and Utilities Chapter. The policy specifies
that development should seek to overcome current surface water flooding issues to the
south of the canal and to the north of Wormwood Scrubs. This could lead to positive
effects against this objective. However, how this might be achieved is not specified,
although the issues are described as significant in the supporting text, leading to low
certainty in the prediction of effects.
See recommendation under Objective 10.
The policy specifies that development should seek to overcome current surface water
flooding issues to the north of the West London Line. This could lead to positive effects
against this objective. However, how this might be achieved is not specified, although the
issues are described as significant in the supporting text, leading to low certainty in the
prediction of effects.

See recommendation under Objective 10.

Old Oak South The policy seeks to support the delivery of green infrastructure along the length of the
and Old Oak
high street. This could create benefits against this objective, as the supporting text
25

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

P4

P5

North, OPDC
area and
surrounding
boroughs
S, M, L-T, D, OPDC area
IR, L
and
surrounding
boroughs

Page 530

S, M, L-T, D, OPDC area

IR, L
and
surrounding
boroughs

specifies that this could include SuDS. However, specific potential benefits of green
infrastructure, nor reference to a wider strategy to maximise the benefits is provided.
See recommendation under Objective 1 with regards to green infrastructure.
The policy specifies that development should seek to overcome current surface water
flooding issues. This could lead to positive effects against this objective. However, how
this might be achieved is not specified, leading to low certainty in the prediction of effects.
Supporting text could include a strategy for how surface water flood risk may be
overcome. This could help deliverability and reduce flood risk.
The policy specifies that development should seek to overcome current surface water
flooding issues. This could lead to positive effects against this objective. However, how
this might be achieved is not specified, leading to low certainty in the prediction of effects.
Supporting text could include a strategic for how surface water flood risk may be
overcome. This could help deliverability and reduce flood risk.

P6

P7

P8

P9

S, M, L-T, D, OPDC area

IR, L
and
surrounding
boroughs

Supporting text could include a strategy for how surface water flood risk may be
overcome. This could help deliverability and reduce flood risk.
No reference is made within the policy to improving the local environment in order to
adapt to the potential effects of climate change.

The policy specifies that development should seek to overcome current surface water
flooding issues. This could lead to positive effects against this objective. However, how
this might be achieved is not specified, leading to low certainty in the prediction of effects.

S, M, L-T, D, OPDC area

IR, L
and
surrounding
boroughs

S, M, L-T, D, OPDC area

A scheme of planting, connected to a wider green infrastructure network, which may also
include SuDS, could be included as a requirement in the Local Plan.
The policy specifies that development should seek to overcome current surface water
flooding issues. This could lead to positive effects against this objective. However, how
this might be achieved is not specified, leading to low certainty in the prediction of effects.
Supporting text could include a strategic for how surface water flood risk may be
overcome. This could help deliverability and reduce flood risk.
The policy specifies that development should seek to overcome current surface water
26

IIA Objective

Performance of Temporal
Policy
Scale
Nature of
Impact
IR, L

P10

Page 531

P1
To minimise
contributions to
climate change
through greater
energy
efficiency,
generation and P2
storage; and to
reduce reliance
on natural
resources
including fossil
fuels for
transport,
heating and
P3
energy

Geographical
Extent

Commentary and Recommendations

and
surrounding
boroughs

flooding issues. This could lead to positive effects against this objective. However, how
this might be achieved is not specified, leading to low certainty in the prediction of effects.

S, M, L-T, D, OPDC area

IR, L
and
surrounding
boroughs

Supporting text could include a strategic for how surface water flood risk may be
overcome. This could help deliverability and reduce flood risk.
The policy specifies that development should seek to overcome current surface water
flooding issues. This could lead to positive effects against this objective. However, how
this might be achieved is not specified, leading to low certainty in the prediction of effects.
However, it is noted that flooding in the common will not create as much risk to people
and property as it would elsewhere within the local plan area.

Supporting text could include a strategy for how surface water flood risk may be
overcome that further relates to the Water Policy. This could help deliverability and
reduce flood risk.
Minimising the need to travel and focussing development around new public transport
+/- M, L-T, D, R, OPDC area,
M
London wide infrastructure should help to reduce the reliance on fossil fuels in the long term. However,
and nationally the increase in new development could significantly increase the pressure on natural
resources from energy requirements during operation as well as through the construction
programme if renewable sources of energy supply arent secured.

+/- S, M-T, D, R, Old Oak North Minimising the need to travel and focussing development around new public transport
infrastructure should help to reduce the reliance on fossil fuels in the long term. However,
M
and OPDC
the increase in new development could significantly increase the pressure on natural
area
resources from energy requirements during operation as well as through the construction
programme if renewable sources of energy supply arent secured.
The introductory text indicates that an Old Oak Common Decentralised Energy Strategy
is currently in preparation. It is suggested that the findings of this study are reflected in
the supporting text, to provide more detail in relation to the supported energy centre.
How potential pollution from this facility might be managed could be explained.
+/- S, M, L-T, D, Old Oak South Minimising the need to travel and focussing development around new public transport
infrastructure should help to reduce the reliance on fossil fuels in the long term. However,
R, M
and Old Oak
North
the increase in new development could significantly increase the pressure on natural
resources from energy requirements during operation as well as through a lengthy
27

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
P4

P5

Page 532

P6

P7

construction programme if renewable sources of energy supply arent secured.

+/- S, M, L-T, D, Old Oak South Minimising the need to travel and focussing development around new public transport
infrastructure, walking and cycling, should help to reduce the reliance on fossil fuels in the
R, M
and Old Oak
long term. However, the increase in new development could significantly increase the
North
pressure on natural resources from energy requirements during operation as well as
through the construction programme if renewable sources of energy supply arent
secured.
+ S, M, L-T, D, Park Royal and The policy supports improvements to the road network to address congestion, as well as
improving the frequency, capacity and connectivity of the local bus network. In addition,
IR, M
surrounding
the delivery of improvements to the walking and cycling network, the policy could lead to
boroughs
an improvement local emissions levels. The vision for the Park Royal area states that the
design of industrial buildings is likely to change, responding to the need for making
optimum use of land as values rise and new technologies support structural change. This
could help to improve energy efficiency through improving the performance of buildings.
This may balance out a potential increase in demand for energy from new development,
although the exact mix of uses and potential energy balance is unknown, leading to
uncertainty in the prediction of effects.
+/- S, M, L-T, D, Park Royal and The policy seeks to centralise services and amenities for the local business community,
R, M
OPDC area
residents and the medical community. The policy also supports improvements to the bus
network and the legibility of streets, including the delivery of cycling and walking
infrastructure. This could lead to some benefits against this objective. Improvements to
the highway network could lead to some positive effects on local emissions, although
could also encourage the use of vehicular transport as a mode of travel unless
improvements to the public transport network are delivered in accordance with the
Transport Chapter.
The vision for the area supports new and improved connections to Old Oak Common
+/- S, M, L-T, D, North Acton
Station, and will ensure that North Acton is integrated into the wider regeneration area. It
R, M
and OPDC
also encourages walking and cycling and proposes employment and jobs in the same
area, and
area thereby reducing the possible distances travelled. Highways improvements and
surrounding
active frontages along streets are proposed, alongside new and/or improved connections
boroughs
across the A40 to West Acton. This could lead to some benefits against this objective,
although a focus on highways improvements could reduce potential significance. It is
currently unclear what type of connections across the A40 are supported by the policy.
The increase in new development could significantly increase the pressure on natural
resources from energy requirements during operation as well as through the construction
28

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
programme if renewable sources of energy supply arent secured.

+/- M, L-T, I, R, L Scrubs Lane

and OPDC
area, and
surrounding
boroughs

P9

+/- S, M, L-T, I,
R, L

Page 533

P8

P10

P1
To minimise
production of
waste across all
sectors in the
P2
plan area,

S, M, L-T, I,
R, L

OPDC area,
and
surrounding
boroughs

OPDC area,
and
surrounding
boroughs

M, L-T, D, R, OPDC area

M
and
surrounding
boroughs
+/- S, M-T, D, R, OPDC area
M
and

It is suggested that following the development of further work on the A40, additional detail
could be provided for the proposed connections across the A40 .
The policy seeks to focus development around public transport infrastructure, which
should lead to benefits against this objective. Further, the policy seeks to contribute
towards and/or deliver new and improved walking and cycling routes as well as vehicular
routes and connections. These measures could lead to some benefits against this
objective, although a focus on highways improvements could reduce potential
significance. The increase in new development could significantly increase the pressure
on natural resources from energy requirements during operation as well as through the
construction programme if renewable sources of energy supply arent secured.
The policy seeks to minimise the impacts of construction traffic on the street network,
existing residents and businesses, including through the use of consolidation centres.
Developments should improve connections across the area, including vehicle, walking
and cycling routes. These measures could lead to some benefits against this objective,
although a focus on highways improvements could reduce potential significance. The
increase in new development could significantly increase the pressure on natural
resources from energy requirements during operation as well as through the construction
programme if renewable sources of energy supply arent secured.
The management of Wormwood Scrubs has the potential to be sensitively enhanced to
improve its potential to enable the area to adapt to climate change, although this is not
specified within the policy it is referred to in the justification text and in the Water Policy.
The promotion of walking and cycling access to the park may reduce current emissions
from people accessing the park, leading to some positive benefits against this objective.
The policy or supporting text could state that management and sensitive enhancement
measures could be implemented to improve the parks potential to enable the local area
to reduce climate change emissions, such as through planting schemes.
The increase in new development could significantly increase the pressure on natural
resources and generation of waste during operation as well as through the construction
programme if not adequately mitigated and managed through the Waste Management
and Waste Minimisation policies.
The increase in new development could significantly increase the pressure on natural
resources and generation of waste during operation as well as through the construction
29

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

surrounding
boroughs

programme if not adequately mitigated and managed through the Waste Management
and Waste Minimisation policies. The Powerday waste site will be protected through this
policy, which could reduce the potential impact from the development on the surrounding
boroughs, which may otherwise have received the displacement of such as facility. The
delivery of an energy centre within the area may comprise an energy from waste facility,
which could help to reduce waste being displaced from the OPDC area.
The increase in new development could significantly increase the pressure on natural
resources and generation of waste during operation as well as through the construction
programme if not adequately mitigated and managed through the Waste Management
and Waste Minimisation policies..
The increase in new development could significantly increase the pressure on natural
resources and generation of waste during operation as well as through the construction
programme if not adequately mitigated and managed through the Waste Management
and Waste Minimisation policies.
The increase in new development could significantly increase the pressure on natural
resources and generation of waste during operation as well as through the construction
programme if not adequately mitigated and managed through the Waste Management
and Waste Minimisation policies. The Twyford Waste Transfer station will be protected
through this policy, which could reduce the potential impact from the development on the
surrounding boroughs, which may otherwise have received the displacement of such as
facility. Redevelopment of the facility is supported in the local plan, which may help to
address local capacity issues.
The intensification of new development could significantly increase the pressure on
natural resources and generation of waste during operation as well as through the
construction programme if not adequately mitigated and managed through the Waste
Management and Waste Minimisation policies..
The intensification of new development could significantly increase the pressure on
natural resources and generation of waste during operation as well as through the
construction programme if not adequately mitigated and managed through the Waste
Management and Waste Minimisation policies..
The intensification of new development could significantly increase the pressure on
natural resources and generation of waste during operation as well as through the
construction programme if not adequately mitigated and managed through the Waste
Management and Waste Minimisation policies..
The intensification of new development could significantly increase the pressure on

Nature of
Impact
maximise
efficiencies for
transporting
waste and
increasing rates
of re-use,
P3
recycling and
recovery rates
as well as
composting of all P4
green waste

Page 534

P5

S, M, L-T, D, OPDC area

R, M
and
surrounding
boroughs
- S, M, L-T, D, OPDC area
R, M
and
surrounding
boroughs
+/- S, M-T, D, R, OPDC area
M
and
surrounding
boroughs

P6

P7

P8

P9

S, M, L-T, D, OPDC area

R, M
and
surrounding
boroughs
S, M, L-T, D, OPDC area
R, M
and
surrounding
boroughs
S, M, L-T, D, OPDC area
R, M
and
surrounding
boroughs
S, M, L-T, D, OPDC area

30

IIA Objective

Performance of Temporal
Policy
Scale
Nature of
Impact
R, M

Improve the
quality of the
water
environment

P10
P1

Page 535

P2

P3

P4

Geographical
Extent

Commentary and Recommendations

and
surrounding
boroughs

natural resources and generation of waste during operation as well as through the
construction programme which includes the HS2 sites if not adequately mitigated and
managed through the Waste Management and Waste Minimisation policies.

0
+/- M, L-T, D, IR, OPDC area
M
and
surrounding
boroughs

Should further information be provided by HS2 regarding their waste management plans,
policies are alternative guidance should reflect this.
The policy is unlikely to have an effect when considered against this objective.
The policy seeks to celebrate the unique character of the Grand Union Canal and
associated nature reserve as well as providing a network of connected open spaces for
residents, employees and visitors. This could provide an opportunity for the positive
management of water quality in these areas. However, the new vehicle connection
across the Grand Union Canal could lead to some negative effects from pollution run off.

See recommendation under Objective 10.

The management of water quality in relation to the new vehicle connection across the
Grand Union Canal should be considered to ensure that no significant negative effects
arise from its development.
+ S, M-T, D, IR, OPDC area
Lower density development near to sensitive uses such as the Grand Union Canal, may
L
and
help to reduce the potential impact from development on water quality in this area. Flood
surrounding
risk management could also create benefits against this objective, as assessed under
boroughs
objective 6, through the potential management of increase in polluted surface water
runoff entering the water environment. However, the extent of predicted benefits is
uncertain.
+ S, M, L-T, I, Old Oak South The policy seeks to support the delivery of green infrastructure along the length of the
high street. This could create benefits against this objective, as the supporting text
R, M
and Old Oak
North, OPDC specifies that this could include SuDS. However, none of the other potential benefits of
green infrastructure, nor reference to a wider strategy to maximise the benefits is
area and
provided.
surrounding
boroughs
See recommendation under Objective 1 with regards to green infrastructure.
+/- S, M, L-T, I, OPDC area
The policy wording seeks to ensure that the use of the Grand Union Canal for passenger
R, M
and
and freight transport and leisure uses should take into account and impact on drainage
surrounding
functions. This could have some benefits against this objective. However, an increase in
boroughs
the use of the canal could increase the potential for negative effects on the water quality
of this resource.
31

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

S, M-T, D, IR, OPDC area

L
and
surrounding
boroughs

P6

S, M-T, D, IR, OPDC area

L
and
surrounding
boroughs

P7

S, M-T, D, IR, OPDC area

M
and
surrounding
boroughs

P8

S, M-T, D, IR, OPDC area

L
and
surrounding
boroughs

S, M-T, D, IR, OPDC area

L
and
surrounding
boroughs

Page 536

P5

P9

It is suggested that water quality issues are also included as a consideration when
considering the future use of the canal. See recommendation under Objective 10.
Supporting text to the policy states that there are utilities infrastructure issues within the
area and the policy seeks to support improvements to this. This could help to improve
local water quality through increased capacity. Improvements in the local road
infrastructure could help to reduce the runoff of pollutants. Flood risk management could
also create benefits against this objective, as assessed under objective 6, through the
potential management of increase in polluted surface water runoff entering the water
environment. However, the extent of predicted benefits is uncertain. See
recommendation under Objective 6.
Improvements in the local road infrastructure and potential increase in the use of more
sustainable modes of transport could help to reduce the runoff of pollutants. Flood risk
management could also create benefits against this objective, as assessed under
objective 6, through the potential management of increase in polluted surface water
runoff entering the water environment. However, the extent of predicted benefits is
uncertain.
See recommendation under Objective 6.
Improvements in the local road infrastructure and potential increase in the use of more
sustainable modes of transport could help to reduce the runoff of pollutants locally.
See recommendation under Objective 6.
Improvements in the local road infrastructure and potential increase in the use of more
sustainable modes of transport could help to reduce the runoff of pollutants. Flood risk
management could also create benefits against this objective, as assessed under
objective 6, through the potential management of increase in polluted surface water
runoff entering the water environment. However, the extent of predicted benefits is
uncertain.. Street greening could also create benefits to a certain degree, although it is
unclear what exactly these measures might comprise.
See recommendation under Objective 6.
Improvements in the local road infrastructure and potential increase in the use of more
sustainable modes of transport could help to reduce the runoff of pollutants. Flood risk
management could also create benefits against this objective, as assessed under
objective 6, through the potential management of increase in polluted surface water
32

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
runoff entering the water environment. However, the extent of predicted benefits is
uncertain.

P10

Page 537

10

P1
Create and
enhance
biodiversity and
the diversity of
habitats across
the area and its
surroundings

P2

S, M-T, D, IR, OPDC area

L
and
surrounding
boroughs

+/- M, L-T, D, IR, OPDC area

M

S, M, L-T, D, OPDC area

IR, M
and
surrounding
boroughs

See recommendation under Objective 6.

Improvements in the local road infrastructure and potential increase in the use of more
sustainable modes of transport could help to reduce the runoff of pollutants. Flood risk
management could also create benefits against this objective, as assessed under
objective 6, through the potential management of increase in polluted surface water
runoff entering the water environment. However, the extent of predicted benefits is
uncertain. The management of area in general could produce positive effects on water
quality through planting schemes and pollution sequestration, although effects are
uncertain due to the potential management measures being unknown.
See recommendation under Objective 6.
The area includes a designated nature reserve to the southern edge of the Grand Union
Canal. The policy seeks to celebrate the unique character of the Grand Union Canal and
associated nature reserve as well as providing a network of connected open spaces for
residents, employees and visitors. This could provide an opportunity for the positive
management of biodiversity in these areas. However, the new vehicle connection across
the Grand Union Canal could lead to some negative effects.
Improving connections could be tied to the development of an area-wide multi-functional
Green Infrastructure Strategy. The Local Plan text states that this is currently being
developed. It is suggested that, when this is available, relevant text is added explicitly to
the policy wording to improve deliverability.
The management of biodiversity in relation to the new vehicle connection across the
Grand Union Canal should be considered to ensure that no significant negative effects
arise from its development.
Lower density development near to sensitive uses such as the Grand Union Canal, may
help to reduce the potential impact from development on biodiversity in this area. The
policy specifies that development should be mindful of existing heritage and ecological
spaces such as the Grand Union Canal, St Marys Cemetery and Kensal Cemetery. This
could provide some benefits against this objective, although it is unclear what is meant by
mindful in this context. Open spaces to be provided may include enhancements for
biodiversity in the soft spaces to be provided.
33

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
The policy should provide further information in the supporting text relating to how
development should be mindful of these assets as well as how biodiversity may be
enhanced within open spaces.
Old Oak South The policy seeks to support the delivery of green infrastructure along the length of the
high street. This could create benefits against this objective, although reference to the
and Old Oak
North, OPDC potential biodiversity benefits of green infrastructure, nor reference to a wider strategy to
maximise the benefits is provided. Similarly, potential benefits at public open spaces for
area and
biodiversity are not referenced and could be specified, including the potential for these to
surrounding
be integrated into a green infrastructure strategy.
boroughs

S, M, L-T, I,
R, M

P4

S, M, L-T, I,
R, M

OPDC area
and
surrounding
boroughs

P5

++ S, M, L-T, I,
R, M

OPDC area
and
surrounding
boroughs

Page 538

P3

P6

See recommendation under Objective 1 with regards to green infrastructure.

The vision for the area states that the ecological role of the canal will be enhanced and
used to support the delivery of the green infrastructure network. The policy wording
seeks to ensure that the use of the Grand Union Canal for passenger and freight
transport and leisure uses should take into account and impact on biodiversity. The
delivery of towpath lighting should also consider the potential impact on biodiversity, as
set out in the policy wording. This could have some benefits against this objective.
Supporting text highlights that the canal is designated as a Nature Conservation Area of
Metropolitan Importance that will be integral to the OPDC green infrastructure network.
It is recommended that measures to enhance biodiversity are encouraged through the
policy wording and set out in the supporting text, including the rationale behind a specific
lighting strategy. This should help enable successful implementation. It is suggested that
some elements of the policy are re-ordered, so that impacts on the water environment
and biodiversity are set out under environment in connection with the green
infrastructure network.
The policy states that the Grand Union Canal and associated nature reserve becomes a
focal point for the area. Development proposals should enhance existing biodiversity
assets along railway corridors, within the First Central Site, the Grand Union Canal,
existing public open spaces and at the junction of Abbey Road and Premier Park Road.
This specificity could lead to significant positive effects locally.
The policy also does not make reference to biodiversity and relies on the Green
Infrastructure and Biodiversity Policy. It is assumed that biodiversity importance in the
area is low, and that the proposed development would not have a positive or negative
impact on this baseline.
34

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

P7

Page 539

P8

11

It is recommended that measures to improve local biodiversity, such as through the

extension of the green infrastructure network into the area, or through street
planting/landscaping schemes, could be promoted through the policy to improve both
biodiversity.
The policy also does not make reference to biodiversity and relies on the Green
Infrastructure and Biodiversity Policy. It is assumed that biodiversity importance in the
area is low, and that the proposed development would not have a positive or negative
impact on this baseline.

It is recommended that measures to improve local biodiversity, such as through the

extension of the green infrastructure network into the area, or through street
planting/landscaping schemes, could be promoted through the policy to improve both
biodiversity.
The policy also does not make reference to biodiversity and relies on the Green
Infrastructure and Biodiversity Policy. It is assumed that biodiversity importance in the
area is low, and that the proposed development would not have a positive or negative
impact on this baseline. Street greening could have the potential to improve local
biodiversity, although it is unclear what exactly these measures might comprise.

P9

P10

++ S, M, L-T, I,
R, M

To minimise air, P1

S, M, L-T, I,
R, M

OPDC area
and
surrounding
boroughs
OPDC area
and
surrounding
boroughs

+/- S, M, L-T, D, OPDC area

It is recommended that measures to improve local biodiversity, such as through the

extension of the green infrastructure network into the area, or through street
planting/landscaping schemes, could be promoted through the policy to improve both
biodiversity.
The policy states that development should enhance existing biodiversity assets along the
Grand Union Canal. This specifically could lead to positive effects locally.

The policy seeks to sustain the existing Local Nature Reserve and sites of borough
importance for nature conservation, which could lead to positive effects against this
objective.
The policy could seek to conserve and enhance the designations in order to allow
Wormwood Scrubs to be utilised for other functions as well as enhance its biodiversity
potential.
Minimising the need to travel and focussing development around new public transport
35

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Nature of
Impact
R, M

noise and light

pollution,
particularly for
vulnerable
groups
P2

+/- S, M, L-T, D, OPDC area

R, M

Page 540
P3

+/- S, M, L-T, D, OPDC area

R, M

P4

+/- S, M, L-T, D, OPDC area

R, M

P5

Commentary and Recommendations

infrastructure should help to reduce the pollution levels in the long term. However, the
increase in new development could significantly increase noise, air and light pollution,
particularly during the construction period if not adequately mitigated by policies D7,
EU11 EU12 and London Plan guidance.
See recommendations under Objectives 7 and 10.
Minimising the need to travel and focussing development around new public transport
infrastructure should help to reduce the pollution levels in the long term. However, the
increase in new development could significantly increase noise, air and light pollution,
particularly during the construction period if not adequately mitigated by policies D7,
EU11 EU12 and London Plan guidance. Supporting text highlights that air quality and
noise issues are generated from the Powerday waste facility and from rail uses and that
new development will need to clearly demonstrated how design has successfully
mitigated these issues. The development of a potential energy from waste facility within
the area as identified in the justification text may also increase air pollution locally if not
mitigated adequately.
See recommendation under objective 7. The requirement from the supporting text could
be referenced in light of policies EU11 EU12.
Minimising the need to travel and focussing development around new public transport
infrastructure should help to reduce the pollution levels in the long term. However, the
increase in new development could significantly increase noise, air and light pollution,
particularly during the construction period if not adequately mitigated by policies D7,
EU11 EU12 and London Plan guidance.

See recommendations under Objectives 7 and 10.

Minimising the need to travel and focussing development around new public transport
infrastructure, walking and cycling as well as the creation of green infrastructure should
help to reduce the pollution levels in the long term. However, the increase in new
development could significantly increase noise, air and light pollution, particularly during
the construction period if not adequately mitigated by policies D7, EU11 EU12 and
London Plan guidance.
S, M, L-T, D, Park Royal and The policy supports improvements to the road network to address congestion, as well as
IR, M
surrounding
improving the frequency, capacity and connectivity of the local bus network. In addition,
boroughs
the delivery of improvements to the walking and cycling network, the policy could lead to
36

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

+/- S, M, L-T, D, OPDC area

R, M

P7

+/- S, M, L-T, D, OPDC area

R, M

P8

+/- S, M, L-T, D, OPDC area

R, M

P9

+/- S, M, L-T, D, OPDC area

R, M

Page 541

P6

an improvement in air, noise and light pollution locally. However, the protection of
industrial uses may mean that pollution levels remain higher in the SIL compared with the
surrounding areas. This should be monitored and regulated by the regulatory control
system, which is outside the remit of the Local Plan.
Improvements in the local road infrastructure and potential increase in the use of more
sustainable modes of transport could help to reduce air, noise and light pollution locally.
However, the increase in new development could significantly increase noise, air and
light pollution, particularly during the construction period if not adequately mitigated by
policies D7, EU11 EU12 and London Plan guidance.
See recommendation under Objective 10.
Improvements in the local road infrastructure and potential increase in the use of more
sustainable modes of transport could help to reduce air, noise and light pollution locally.
However, the increase in new development could significantly increase noise, air and
light pollution, particularly during the construction period if not adequately mitigated by
policies D7, EU11 EU12 and London Plan guidance.
See recommendation under Objective 10.
The policy seeks to focus development around public transport infrastructure, which
should lead to benefits against this objective. Further, the policy seeks to contribute
towards and/or deliver new and improved walking and cycling routes as well as vehicular
routes and connections. These measures could lead to some benefits against this
objective, although a focus on highways improvements could reduce potential
significance. However, the increase in new development could significantly increase
noise, air and light pollution, particularly during the construction period if not adequately
mitigated by policies D7, EU11 EU12 and London Plan guidance.
See recommendation under Objective 10.
The policy seeks to minimise the impacts of construction traffic on the street network,
existing residents and businesses, including through the use of consolidation centres.
Developments should improve connections across the area, including vehicle, walking
and cycling routes. These measures could lead to some benefits against this objective,
although a focus on highways improvements could reduce potential significance. In
considering the potential impact from the HS2 construction programme, policies D7,
EU11, EU12 and London Plan guidance should be implemented to manage impacts. In
37

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
+

S, M, L-T, I,
R, L

OPDC area,
and
surrounding
boroughs

light of this, mixed effects are considered to be delivered.

The management of Wormwood Scrubs has the potential to address air and noise
pollution, although this is not specified within the policy. The promotion of walking and
cycling access to the park may reduce current pollution levels from people accessing the
park, leading to some positive benefits against this objective.

To conserve and P1
enhance the
historic
environment,
heritage assets
and their settings

S, M, L-T, D, OPDC area

IR, M
and
surrounding
boroughs

See recommendation under objective 7

Supporting text to the policy highlights that the Grand Union Canal is a designated
Conservation Area. The policy specifically states that supported developments will
celebrate the unique character of Grand Union Canal, and that it becomes an accessible
focal point for the area. This could provide some benefits against this objective.

P2

S, M, L-T, D, OPDC area

IR, M
and
surrounding
boroughs

P3

S, M, L-T, D, OPDC area

IR, M
and
surrounding
boroughs

P10

12

Page 542

It is suggested that further detail relating to how development should reflect the historic
character and appearance of the Old Oak area is reflected in the policy wording and
supporting text. This should include the identification and protection of local views and the
settings of historic assets. However, it is noted that the OPDC Heritage and Views Study
is yet to be completed.
Under the density subheading, the policy specifies that development should be mindful
of existing heritage and ecological spaces such as the Grand Union Canal, St Marys
Cemetery and Kensal Cemetery. This could provide some benefits against this objective,
although it is further information should be provided to describe what is meant by mindful
in this context.
Under open spaces the ecological and historical character of the Gran Union Canal is to
be celebrated.
The policy should seek to reduce repetition within the policy with regards to the ecological
and historical character of the Grand Union Canal as well as provide further information in
the supporting text relating to how development should be managed in relating to
enhancing nature conservation and heritage assets.
Supporting text to the policy states that building heights and massing on the high street
should vary, respond to local character and context and should not create a wall of
massing. Any development proposals will need to be sensitive to its surroundings such as
Wormwood Scrubs, the Grand Union Canal, Kensal Cemetery and nearby existing
residential areas. This could create some benefits against this objective.
38

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

P4

++ S, M, L-T, D, OPDC area

IR, M
and
surrounding
boroughs

It is recommended that this requirement from the supporting text is included in the policy
wording to improve implementation.
The vision states that behind the canal, a string of waterside spaces will complement the
canals historic character with many providing space for events, relaxation, socialising
and the night time economy along busier stretches. However, it is unclear how this will
complement the historic character of the canal.
The policy wording seeks that development proposals recognise the Grand Union Canal
Conservation Area as a sensitive area suitable for the lowest density development and
that the canal and its setting should be protected and/or enhanced. This could lead to
significant benefits against this objective.

Page 543

P5

S, M, L-T, D, OPDC area

IR, M
and
surrounding
boroughs

P6

S, M, L-T, D, OPDC area

IR, M

P7

P8

S, M, L-T, D, OPDC area

IR, M
and
surrounding
boroughs
++ M, L-T, D, IR, OPDC area
M
and
surrounding
boroughs

See recommendations for P1 how the waterside spaces would complement the canals
historic character could be specified. Any repetition between P1, P2 and P4 should be
sought to be removed.
The policy wording specifies that and proposed designated heritage assets and their
setting should be protected and/or enhanced as part of development. This could provide
some benefits against this objective.
Supporting text should set out the heritage assets to be considered as part of this
requirement. As stated, this will be included in the next iteration of the local plan.
As stated in the supporting text, Park Royal Centre lacks a defined character. The policy
should help to enhance the local built environment, which could lead to some benefits for
the historic environment in neighbouring places.
As stated in the supporting text, North Acton suffers from a poor quality public realm. The
policy should help to enhance the local built environment, which could lead to some
benefits for the historic environment in neighbouring places and surrounding boroughs
including Ealing.
The Cumberland Park Factory site is proposed as a Conservation area. Further, the area
north of the canal is bounded by St Marys cemetery conservation area to the east. The
current public realm along Scrubs Land is dominated by vehicular transport and a poor
walking and cycling environment. The Local Plan sets out that the Former Cumberland
Park Factory provides the opportunity to inform the development of local character within
Scrubs Lane and across Old Oak. The vision for the area seeks that Scrubs Lane is
transformed into a pleasant street, respectful of heritage assets within a high quality
public realm. The street will be framed by the active historic frontages of thriving micro,
39

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

P9

13

Page 544

P10
P1
Increase
community
cohesion and
reduce social
exclusion to
encourage a
P2
sense of
community and
welfare

small and medium sized employment uses within the Cumberland Park Factory alongside
a series of new mixed-use developments. Development will be designed to respond to
heritage assets and their settings. This is reflected in the policy wording, which should
lead to significant benefits against this objective.
+ M, L-T, D, IR, OPDC area
The policy specifically seeks to protect and/or enhance the Grand Union Canal and Old
M
and
Oak Land Conservation Areas and their settings. This could lead to benefits against this
surrounding
objective in the long term, although it is unclear how this would be implemented during
boroughs
the construction phases of development.
0
The policy is unlikely to have an effect when considered against this objective.
++ M,L-T, I, R, M Old Oak South The policy seeks that density considerations are mindful of existing residential
communities in the area. Alongside measures to ensure the delivery of a sense of place
and OPDC
and improve connectivity across the area, which could improve community interaction,
area
this could have positive benefits against this objective. Further benefits may also be
realised through the supporting of the creation of community space as part of the town
centre uses.
The policy seeks to deliver high quality, residential-led development alongside the
+ S, M, L-T, D, OPDC area
delivery of town centre uses. The policy also seeks that density considerations are
IR, M
and
mindful of existing residential communities in the area. This should deliver benefits
surrounding
against this objective, however, the types of town centre uses are not specified.
boroughs
Supporting text could provide a link to the glossary to define town centre uses.
The policy seeks to deliver a major new town centre of the highest quality design that will
contribute to delivering an excellent and accessible public realm. The types of town
centre uses are specified as including a significant quantum of A-class uses as well as a
range of culture, sports and leisure uses, visitor accommodation and social infrastructure.
This could provide significant benefits against this objective through improving
accessibility to services and facilities as well as increasing the potential for community
interaction.

P3

++ S, M, L-T, D, OPDC area

IR, M
and
surrounding
boroughs

P4

The policy seed to provide a range of green and civic spaces, that could contribute to
++ S, M, L-T, D, OPDC area
increasing a sense of community wellbeing locally, leading to positive effects against this
IR, M
and
objective.
surrounding
boroughs
+ S, M, L-T, I, Park Royal and The policy supports improvements to the road network to address congestion, as well as
R, M
surrounding
improving the frequency, capacity and connectivity of the local bus network and reducing

P5

40

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

areas

severance caused by the A40 and A406. In addition to supporting the delivery of
improvements to the walking and cycling network, the policy could lead to some
improvement in community cohesion locally.
Improvements in the local road infrastructure and potential increase in the use of more
sustainable modes of transport could help to the potential severance caused by the road
network locally. The policy seeks to centralise the provision of services, shared services
and amenities to support local businesses, residents and the medical community
alongside providing improved accessibility by walking and cycling modes within the area.
Alongside measures to improve the built environment within this area, including the
creation of more active frontages, which could encourage an increase in walking and
cycling, these could create significant benefits against this objective above the existing
baseline.
The policy specifically requires that supported development will be of a lower density in
more sensitive locations close to residential areas, as well as areas of open space such
as Acton Cemetery. Land uses supported will include a mix of small-scale retail, leisure
and community uses and eating and drinking establishments to serve local needs. The
policy also seeks to improve connections between features within the area such as the
station and the town centre uses, which should enable the achievement of significant
benefits against this objective.
The policy supports development as part of a mix of uses, which could help to create a
sense of community locally. The proposed improvements to walking and cycling links, as
well as reducing traffic congestion, could increase community interaction, resulting in
greater cohesion. Improvements to the public realm based on the enhancement of
historic assets could lead to a greater sense of place, which could have further benefits
for the local sense of community.
The policy specifically seeks that land uses do no negatively impact on the amenity of
existing residential communities, which could lead to some benefits against this objective.
However, as the area will be accommodating the HS2 construction site, it is considered
that, although long term benefits may be positive, short term impacts on local
communities could be negative, as a result of the significant construction impacts locally if
not appropriately managed.
The management of the facilities as a public open space for exercise and recreation
could have significant positive effects against this objective. Increasing accessibility to the
area through walking and cycling connections is likely to compound this effect.

Nature of
Impact

++ S, M, L-T, D, OPDC area

R, M
and
surrounding
boroughs

P7

++ S, M, L-T, D, OPDC area

R, M
and
surrounding
boroughs

P8

++ S, M, L-T, I,
R, M

P9

+/- S, M, L-T, D, OPDC area

R, M
and
surrounding
boroughs

P10

++ S, M, L-T, D, OPDC area

IR, M
and
surrounding
boroughs

Page 545

P6

OPDC area
and
surrounding
boroughs

41

IIA Objective

14

Improve safety
and reduce
crime and the
fear of crime

Performance of Temporal
Policy
Scale

P1

P2

P3

Page 546
P4

P5

P6

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
+ M,L-T, I, R, M Old Oak South The policy seeks that density considerations are mindful of existing residential
communities in the area. Alongside measures to ensure the delivery of a sense of place
and OPDC
and improve connectivity across the area, which could improve community interaction,
area
this could have positive benefits against this objective. Further benefits may also be
realised through the supporting of the creation of community space as part of the town
centre uses, which could reduce the potential for anti-social behaviour.
+ S, M, L-T, D, Old Oak South The Local Plan describes the existing pedestrian environment in the area as hostile, with
existing routes isolated from surrounding uses and suffering from a lack of natural
IR, M
and OPDC
surveillance. The creation of improved connections may reduce this effect alongside the
area
support for activation of the area within the Spatial Vision. Although specific measures to
improve natural surveillance have not been specified in the policy wording, these are
managed through London Plan policies.
The policy seeks to deliver a major new town centre of the highest quality design that will
++ S, M, L-T, D, OPDC area
contribute to delivering an excellent and accessible public realm. The types of town
IR, M
and
centre uses are specified as including a significant quantum of A-class uses as well as a
surrounding
range of culture, sports and leisure uses, visitor accommodation and social infrastructure.
boroughs
This could provide significant benefits against this objective through increasing the
potential for community interaction, active frontages and natural surveillance.
The Local Plan outlines that the current character of the Grand Union Canal is
++ S, M, L-T, D, OPDC area
characterised by limited passive surveillance, which has a negative impact on the use of
IR, M
and
the tow path for walking, cycling and recreation. The vision sets out that development in
surrounding
this area will provide a safe and convenient walking and cycling route enabling people to
boroughs
access the length of Old Oak, Park Royal and beyond including through the use of active
frontages. The policy also specifically sets out the need for tow path lighting, which could
reduce the fear of crime along the canal, leading to positive effects.
+ S, M, L-T, I, Park Royal and The policy supports improvements to the road network to address congestion, as well as
improving the frequency, capacity and connectivity of the local bus network and reducing
R, M
surrounding
severance caused by the A40 and A406. In addition to supporting the delivery of
areas
improvements to the walking and cycling network, the policy could lead to some
improvement in community cohesion locally which, in turn, could provide benefits for
crime and the fear of crim.
++ S, M, L-T, D, OPDC area
Improvements in the local road infrastructure and potential increase in the use of more
R, M
and
sustainable modes of transport could help to increase community interaction. Alongside
surrounding
measures to improve the built environment within this area, including the creation of more
boroughs
active frontages, which could encourage an increase in walking and cycling, further
42

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

P7

++ S, M, L-T, D, OPDC area

R, M
and
surrounding
boroughs

P8

Page 547
P9

P10

15

Maximise the

P1

S, M, L-T, i,
R, M

OPDC area
and
surrounding
boroughs

+/- S, M, L-T, D, OPDC area

R, M
and
surrounding
boroughs

S, M, L-T, D, OPDC area

IR, M
and
surrounding
boroughs

S, M,L-T, I, R, OPDC area

M
and

maximising natural surveillance, these measures could create significant benefits against
this objective above the existing baseline.
The policy specifically requires that supported development will be of a lower density in
more sensitive locations close to residential areas, as well as areas of open space such
as Acton Cemetery, as well as improve connections between features within the area
such as the station and the town centre uses, which should enable the achievement of
benefits against this objective in terms of community cohesion and interaction, leading to
a greater sense of wellbeing locally and an increase in natural surveillance. This effect
could be compounded through the provision of an increase in active frontages in areas
close to North Acton Station and along main streets.
The policy supports development as part of a mix of uses, which could help to create a
sense of community locally. The proposed improvements to walking and cycling links, as
well as reducing traffic congestion, could increase community interaction, resulting in
greater cohesion. Improvements to the public realm based on the enhancement of
historic assets could lead to a greater sense of place, which could have further benefits
for the local sense of community. In addition to an increase in the development of active
frontages, this could have positive effects for crime and the fear of crime.
Reference to active frontages, as included in the supporting text, should be specified in
the policy wording to improve deliverability.
The policy specifically seeks that land uses do no negatively impact on the amenity of
existing residential communities, which could lead to some benefits against this objective.
An improvement in connectivity across the area and active frontages could help to
improve community coherence and natural surveillance, leading to benefits against this
objective. However, as the site will be the impact of the HS2 construction site will need to
be mitigated.
The management of the facilities as a public open space for exercise and recreation
could have some positive effects against this objective. Increasing accessibility to the
area through walking and cycling connections could also provide benefits.
The management of the park could include measures to reduce crime and the fear of
crime when using or accessing the park, particularly if it would be open during the
evenings.
The policy seeks that density considerations are mindful of existing residential
communities in the area. Alongside measures to ensure the delivery of a sense of place
43

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

surrounding
boroughs

and improve connectivity across the area, which could improve community interaction,
this could have positive benefits against this objective. Further benefits may also be
realised through the supporting of the creation of community space as part of the town
centre uses. Accessibility to health services and physical activity may be improved
through the increased connectivity within and to the surrounding areas by sustainable
modes of transport, walking and cycling. Long term potential air quality benefits may also
have benefits for health. Access to green space could also provide both physical and
mental health benefits. Some negative effects on health during the construction period
may result from noise and air pollution if not adequately managed.

Nature of
Impact
health and
wellbeing of the
population,
reduce
inequalities in
health and
promote healthy
living

Page 548

P2

P3

See recommendation under objective 10 multifunctional green infrastructure could

improve the potential health benefits of connective routes through the increase in
pollution sequestration, improved micro-climate and a sense of wellbeing.
S, M, L-T, D, Old Oak South Measures to ensure the delivery of a sense of place and improve connectivity across the
area, which could improve community interaction, could have positive benefits against
IR, M
and OPDC
this objective. Further benefits may also be realised through the supporting of the
area
creation of community uses as part of the town centre uses. Accessibility to health
services and physical activity may be improved through the increased connectivity within
and to the surrounding areas by sustainable modes of transport, walking and cycling.
Long term potential air quality benefits may also have benefits for health. Access to
green space could also provide both physical and mental health benefits. Some negative
effects on health during the construction period may result from noise and air pollution if
not adequately managed. The Local Plan describes the existing pedestrian environment
in the area as hostile. The creation of improved connections may reduce this effect
alongside the support for activation of the area within the vision. Although specific
measures to improve natural surveillance have not been specified in the policy wording,
these are managed through London Plan policies.
See recommendation under Objective 14.
The policy seeks to deliver a major new town centre of the highest quality design that will
S, M, L-T, D, OPDC area
contribute to delivering an excellent and accessible public realm. The types of town
IR, M
and
centre uses are specified as including a significant quantum of A-class uses as well as a
surrounding
range of culture, sports and leisure uses, visitor accommodation and social infrastructure.
boroughs
This could provide benefits against this objective through increasing the potential for
community interaction. Further benefits may also be realised through the supporting of
the creation of social infrastructure as part of the town centre uses. Access to green
44

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
space could also provide both physical and mental health benefits. Some negative effects
on health during the construction period may result from noise and air pollution if not
adequately managed.

Page 549

P4

P5

P6

P7

See recommendation under objective 1 with regards to green infrastructure.

The Local Plan outlines that the current character of the Grand Union Canal is
characterised by limited passive surveillance, which has a negative impact on the use of
the tow path for walking, cycling and recreation. The vision sets out that development in
this area will provide a safe and convenient walking and cycling route enabling people to
access the length of Old Oak, Park Royal and beyond including through the use of active
frontages. This could have benefits for physical and mental health through physical
activity, increased community interaction and improved air quality in this area. The policy
also specifically sets out the need for tow path lighting, which could reduce the fear of
crime along the canal, leading to positive effects for health in this area.
S, M, L-T, D, Park Royal and The policy supports improvements to the road network to address congestion, as well as
improving the frequency, capacity and connectivity of the local bus network and reducing
R, M
surrounding
severance caused by the A40 and A406. In addition to supporting the delivery of
areas
improvements to the walking and cycling network, the policy could lead to some
improvement in community cohesion locally, which could have benefits for health. A
reduction in pollution and increase in connectivity via walking and cycling routes could
also lead to positive health effects in this location. However, due to the low proportion of
potential residents in this area and the retention of the area as an industrial location,
effects are unlikely to be significant.
S, M, L-T, I, Park Royal and Improvements in the local road infrastructure and potential increase in the use of more
R, M
surrounding
sustainable modes of transport could help to increase community interaction. Alongside
areas
measures to improve the built environment within this area, including the creation of more
active frontages, which could encourage an increase in walking and cycling, these
measures could create benefits against this objective above the existing baseline.
However, due to the low proportion of potential residents in this area and the retention of
the area as an industrial location, effects are unlikely to be significant.
S, M, L-T, D, OPDC area
IR, M
and
surrounding
boroughs

S, M, L-T, I,

North Acton

Health levels within the area could be improved through the extension of the green
infrastructure network through this area, to create more pleasant walking and cycling
routes.
Land uses supported will include a mix of small-scale retail, leisure and community uses
45

IIA Objective

Performance of Temporal
Policy
Scale
Nature of
Impact
R, M

P8

M, L-T, I, R,
M

Geographical
Extent

Commentary and Recommendations

and
surrounding
areas

and eating and drinking establishments to serve local needs. The policy also specifically
requires that supported development will be of a lower density in more sensitive locations
close to residential areas, as well as areas of open space such as Acton Cemetery, as
well as improve connections between features within the area such as the station and the
town centre uses, which should enable the achievement of benefits against this objective
in terms of community cohesion and interaction, as well as physical activity, leading to a
greater sense of wellbeing locally and an increase in natural surveillance. Potential
improvements in air, noise and light quality could further improve physical health. Walking
and cycling is also encouraged.
The policy supports development as part of a mix of uses, which could help to create a
sense of community locally. The proposed improvements to walking and cycling links,
access to recreational space at Wormwood Scrubs, as well as reducing traffic
congestion, could increase community interaction, resulting in greater cohesion as well as
physical activity and improved physical health over time, also resulting from potential long
term air quality improvements. Improvements to the public realm based on the
enhancement of historic assets could lead to a greater sense of place, which could have
further benefits for the local sense of community, leading to improvements in mental
health. In addition to an increase in the development of active frontages, this could have
positive effects for crime and the fear of crime, which could have benefits for health.
The policy specifically seeks that land uses do no negatively impact on the amenity of
existing residential communities, which could lead to some benefits against this objective.
An improvement in connectivity across the area and active frontages could help to
improve community coherence and natural surveillance, leading to benefits against this
objective. However, as the area will be accommodating the HS2 construction site, it is
considered that, although long term benefits may be positive, short term impacts on local
communities could be negative, as a result of the significant construction impacts locally.
The management of the facilities as a public open space for exercise and recreation
could have significant positive effects against this objective. Increasing accessibility to the
area through walking and cycling connections is likely to compound this effect.

Scrubs Lane
and
surrounding
areas

Page 550
16

P9

+/- S, M, L-T, D, OPDC area

R, M
and
surrounding
boroughs

P10

++ S, M, L-T, D, OPDC area

IR, M
and
surrounding
boroughs
+ M,L-T, I, R, M OPDC area
and
surrounding
boroughs

To improve the P1
education and
skills levels of all
members of the

Accessibility to education services may be improved through the increased connectivity

within and to the surrounding areas by sustainable modes of transport, walking and
cycling.
Town centre uses could be specified to include education facilities where necessary.
46

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

OPDC area
and
surrounding
boroughs

Accessibility to education services may be improved through the increased connectivity

within and to the surrounding areas by sustainable modes of transport, walking and
cycling.

Nature of
Impact
population,
particularly
vulnerable
groups

P2

S, M-T, I, R,
M

P3

S, M,L-T, I, R, OPDC area

M
and
surrounding
boroughs

Town centre uses could be specified to include education facilities where necessary
Accessibility to education services may be improved through the increased connectivity
within and to the surrounding areas by sustainable modes of transport, walking and
cycling. The provision of social infrastructure within the high street may include
educational facilities, although this isnt specified.
Town centre uses could be specified to include education facilities where necessary.

Page 551

P4

S, M-T, I, R,
M

OPDC area
and
surrounding
boroughs

P5

S, M-T, I, R,
M

P6

S, M-T, I, R,
M

P7

++ S, M-T, I, R,
M

OPDC area
and
surrounding
boroughs
OPDC area
and
surrounding
boroughs
OPDC area
and
surrounding
boroughs

P8

S, M-T, I, R,
M

OPDC area
and
surrounding
boroughs

Accessibility to education services may be improved through the increased connectivity

within and to the surrounding areas by sustainable modes of transport, walking and
cycling.
Town centre uses could be specified to include education facilities where necessary
Accessibility to education services may be improved through the increased connectivity
within and to the surrounding areas by sustainable modes of transport, walking and
cycling.
Accessibility to education services may be improved through the increased connectivity
within and to the surrounding areas by sustainable modes of transport, walking and
cycling.
Accessibility to education services may be improved through the increased connectivity
within and to the surrounding areas by sustainable modes of transport, walking and
cycling. The policy specifically supports the delivery of education uses close to North
Acton station, which could lead to significant benefits against this objective.
Accessibility to education services may be improved through the increased connectivity
within and to the surrounding areas by sustainable modes of transport, walking and
cycling.
47

IIA Objective

17

Performance of Temporal
Policy
Scale

P9

P10
P1

0
+

Page 552

Maximise the
social and
economic
wellbeing of the
local and
regional
P2
population and
improve access
to employment
and training
P3

P4

P5

P6

Nature of
Impact
M, L-T, I, R,
M

Geographical
Extent

Commentary and Recommendations

OPDC area
and
surrounding
boroughs

Accessibility to education services may be improved through the increased connectivity

within and to the surrounding areas by sustainable modes of transport, walking and
cycling.

M,L-T, I, R, M OPDC area

and
surrounding
boroughs

M,L-T, I, R, M OPDC area

and
surrounding
boroughs

S, M,L-T, I, R, OPDC area

M
and
surrounding
boroughs

S, M,L-T, I, R, OPDC area

M
and
surrounding
boroughs
S, M,L-T, I, R, OPDC area
M
and
surrounding
boroughs
S, M,L-T, I, R, OPDC area
M
and
surrounding

The policy is unlikely to have an effect when considered against this objective.
The Policy seeks to deliver commercial space, including a range of flexible workspaces in
accessible locations, as well as new retail and other town centre uses, including
community space. This could lead to positive effects against this Objective.
The provision of training facilities could be specified as a requirement in this area in
addition to the guidance set out in policy E5.
The Policy seeks to deliver a range of meanwhile uses and employment space for SMEs
that help support place-making, deliver a mixed use place and act as a catalyst for wider
regeneration, as well as new town centre uses. This could lead to positive effects against
this Objective.
The provision of training facilities could be specified as a requirement in this area in
addition to the guidance set out in policy E5.
The Policy seeks to provide a significant quantum of A-class uses as well as a range of
culture, sports and leisure uses, visitor accommodation and social infrastructure. This
could lead to positive effects against this objective.
The provision of training facilities could be specified as a requirement in this area in
addition to the guidance set out in policy E5.
The Policy seeks to support the economic functions of Old Oak and Park Royal, which
could lead to some positive benefits against this objective arising from the implementation
of this policy.
The Policy seeks to support the economic functions of the industrial location of Park
Royal, which could lead to some positive benefits against this objective arising from the
implementation of this policy.
The Policy seeks to support the economic functions of the industrial location of Park
Royal, which could lead to some positive benefits against this objective arising from the
implementation of this policy.
48

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
P7

Page 553

18

P8

P9

P10
P1
To encourage
inward
investment
alongside
investment
within existing
communities, to
create
P2
sustainable
economic growth

0
++

++

boroughs
S, M,L-T, I, R, OPDC area
M
and
surrounding
boroughs

The Policy seeks to support the economic functions of Old Oak and Park Royal as well as
the surrounding boroughs including Ealing, which could lead to some positive benefits
against this objective arising from the implementation of this policy.
It is unclear from the policy text under b) what exactly the policy is supportive of. This
could be made clearer in the policy wording.
The Policy seeks to support the economic functions of Old Oak and Park Royal as well as
the surrounding boroughs, which could lead to some positive benefits against this
objective arising from the implementation of this policy.

S, M,L-T, I, R, OPDC area

M
and
surrounding
boroughs
S, M, L-T, I, Old Oak West The policy seek to intensify the use of sites within the SIL by requiring proposals to
R, M
demonstrate how they are maximising the use of sites, including the provision of smaller
unity, to support greater industrial employment densities. This could lead to benefits
against this Objective through maximising local employment levels.

M, L-T, I, R, OPDC area

L
and
surrounding
boroughs

M, L-T, I, R, OPDC area

L
and
surrounding
boroughs

The policy is unlikely to have an effect when considered against this objective.
The Policy seeks to support small and large scale catalyst uses as well as delivering
commercial space and new retail and other town centre uses. This could encourage
inward investment in the area. It is unclear as to whether the uses proposed would impact
on neighbouring town centres.
The policy also supports the redevelopment of all existing infrastructure, rail and industrial
uses, which could have significant benefits against this objective.
It is recommended that this is a consideration, and measures to reduce the impact on
neighbouring town centres be included within the policy or highlighted to ensure that the
intention behind measures is made clear.
The existing land uses are characterised by a large second hand car dealership
(Cargiant), rail infrastructure and a large waste recycling and processing plant (Powerday
and European Metal Recycling). There are also a substantial number of SMEs in the
area. New development will be residential-led with a mix of town centre uses including
small and large scale catalyst uses. New employment spaces will cater mainly for SME
and micro-businesses as part of new mixed-use buildings. Early phases will be supported
by a range of meanwhile uses and employment space for SMEs that help support placemaking, deliver a mixed use place and act as a catalyst for wider regeneration. The type
of workspaces will differ from the large commercial spaces in Old Oak South. The policy
49

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
wording encourages flexible workspace typologies at locations adjacent to transport or
utilities infrastructure. This should help to provide benefits against this objective. Further
benefits in terms of connections to Harlesden town centre, could further compound
sustainability benefits.
The Policy seeks to provide a significant quantum of A-class uses as well as a range of
culture, sports and leisure uses, visitor accommodation and social infrastructure. This
vision specifies that the Old Oak South area of the high street will be focussed on
providing services for the large number of employees in the area. This could increase the
attractiveness of the location to inward investors. However, this is not reflected in the
policy wording.

Page 554

P3

S, M,L-T, I, R, OPDC area

M
and
surrounding
boroughs

P4

S, M,L-T, I, R, OPDC area

M
and
surrounding
boroughs

P5

++

M, L-T, I, R, London-wide The Park Royal industrial estate is protected by a SIL designation. The policy supports
L
and nationally this designation and seeks to deliver broad industrial type uses within the SIL. Mixed use
development is encouraged on the First Central Site, including non-industrial employment
and housing that supports walking, cycling and public transport access to Park Royal
London Underground Station. The delivery of a range of walking and cycling
infrastructural improvements are also set out in the policy. This clarity of land uses and
potential improvement in the local environment and connectivity could improve the
attractiveness of the area to inward investors.

P6

++

See recommendation under Objective 1.

The policy could increase the connectivity of the employment and residential areas
across the plan area, as well as improving the local environment. This could be attractive
to inward investors, leading to potential benefits against this objective.

P7

M, L-T, I, R, London-wide The policy supports a range of industrial types alongside affordable open workspaces
L
and nationally and supporting services and amenities within a centralised, accessible, area. This should
help to generate significant benefits against this objective.
++ M, L-T, I, R, London-wide The policy seeks to provide a range of flexible workspaces and a significant quantum of
L
and nationally new jobs and SME space, focussed on the station and major thoroughfares. Visitor
accommodation will also be provided. This should help to deliver significant benefits
against this objective.

P8

++

M, L-T, I, R, London-wide

See recommendation under Objective 17.

The policy seeks to provide a range of flexible workspaces as part of the development of
50

IIA Objective

Performance of Temporal
Policy
Scale
Nature of
Impact
L

P9

++

P10

Geographical
Extent

Commentary and Recommendations

and nationally the Cumberland Park Factory and new mixed use developments. This should help to
deliver significant benefits against this objective.

Page 555

See recommendation under Objective 17.

M, L-T, I, R, London-wide The policy seeks to deliver development uses of broad industrial types appropriate for a
L
and nationally SIL on the HS2 construction sites, once they are no longer in use. The policy also seeks
to deliver employment and commercial uses. The policy seeks to intensify the use of sites
within the SIL by requiring proposals to demonstrate how they are maximising the use of
sites, including the provision of smaller unity, to support greater industrial employment
densities. Together, along with public realm improvements, these measures could help to
encourage inward investment into the area in the medium to long term.
The protection of this green open space could encourage inward investment to some
S, M,L-T, I, R, OPDC area
degree, through increasing the attractiveness of the area as a place to live and work.
M
and
surrounding
boroughs

Table G-3 Chapter 5: Sustainable development

x SD1: Sustainable development
IIA Objective

Performance of Temporal
Policy
Scale

To enhance the SD1

built environment
and encourage
place-making

Nature of
Impact
L-T, I, R, M

To optimise the SD1

L-T, I, R, M

Geographical
Extent

Commentary and Recommendations

OPDC area
and Londonwide

Policy SD1 seeks to encourage the implementation of sustainable development through

seeking to proactively work with applicants to jointly find solutions to ensure that
development will improve the economic, social and environmental conditions in the area
in accordance with Local Plan policies, the London Plan and the NPPF.
This should help to realise benefits against this objective, although the specific benefits
and potential negative effects of the policies have been assessed elsewhere in this IIA
and will form the overall assessment of the effects of this policy.
See assessment under Objective 1. The policy should lead to positive effects against this
objective, through the implementation of the other policies within the Local Plan, the

OPDC area
and London-

51

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

wide

London Plan and the NPPF.

Nature of
Impact
efficient use of
land through
increased
development
densities and
building heights,
where
appropriate
SD1
Maximise the
reuse of
previously
developed land
and existing
buildings,
including the
remediation of
contaminated
land

L-T, I, R, M

OPDC area
and Londonwide

See assessment under Objective 1. The policy should lead to positive effects against this
objective, through the implementation of the other policies within the Local Plan, the
London Plan and the NPPF.

SD1
Minimise the
need to travel,
improve
accessibility for
all users by
public and nonmotorised
transportation
methods and
mitigate impacts
on the transport
network

L-T, I, R, M

OPDC area
and Londonwide

See assessment under Objective 1. The policy should lead to positive effects against this
objective, through the implementation of the other policies within the Local Plan, the
London Plan and the NPPF.

Page 556

52

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

OPDC area
and Londonwide

See assessment under Objective 1. The policy should lead to positive effects against this
objective, through the implementation of the other policies within the Local Plan, the
London Plan and the NPPF.

Page 557

Improve access SD1

to well designed,
well-located,
market,
affordable and
inclusive housing
of a range of
types and
tenures, to meet
identified local
needs

Nature of
Impact
L-T, I, R, M

Improve climate SD1

change
adaptation and
mitigation,
including
minimising the
risk of flooding
and addressing
the heat island
effect

L-T, I, R, M

OPDC area
and Londonwide

See assessment under Objective 1. The policy should lead to positive effects against this
objective, through the implementation of the other policies within the Local Plan, the
London Plan and the NPPF.

SD1
To minimise
contributions to
climate change
through greater
energy
efficiency,
generation and
storage; and to
reduce reliance

L-T, I, R, M

OPDC area
and Londonwide

See assessment under Objective 1. The policy should lead to positive effects against this
objective, through the implementation of the other policies within the Local Plan, the
London Plan and the NPPF.

53

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
on natural
resources
including fossil
fuels for
transport,
heating and
energy
SD1
To minimise
production of
waste across all
sectors in the
plan area,
maximise
efficiencies for
transporting
waste and
increasing rates
of re-use,
recycling and
recovery rates
as well as
composting of all
green waste

L-T, I, R, M

OPDC area
and Londonwide

See assessment under Objective 1. The policy should lead to positive effects against this
objective, through the implementation of the other policies within the Local Plan, the
London Plan and the NPPF.

Improve the
quality of the
water
environment

SD1

L-T, I, R, M

OPDC area
and Londonwide

See assessment under Objective 1. The policy should lead to positive effects against this
objective, through the implementation of the other policies within the Local Plan, the
London Plan and the NPPF.

10

SD1
Create and
enhance
biodiversity and

L-T, I, R, M

OPDC area
and Londonwide

See assessment under Objective 1. The policy should lead to positive effects against this
objective, through the implementation of the other policies within the Local Plan, the
London Plan and the NPPF.

Page 558

54

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
the diversity of
habitats across
the area and its
surroundings

Page 559

11

To minimise air, SD1

noise and light
pollution,
particularly for
vulnerable
groups

L-T, I, R, M

OPDC area
and Londonwide

See assessment under Objective 1. The policy should lead to positive effects against this
objective, through the implementation of the other policies within the Local Plan, the
London Plan and the NPPF.

12

To conserve and SD1

enhance the
historic
environment,
heritage assets
and their settings

L-T, I, R, M

OPDC area
and Londonwide

See assessment under Objective 1. The policy should lead to positive effects against this
objective, through the implementation of the other policies within the Local Plan, the
London Plan and the NPPF.

13

SD1
Increase
community
cohesion and
reduce social
exclusion to
encourage a
sense of
community and
welfare

L-T, I, R, M

OPDC area
and Londonwide

See assessment under Objective 1. The policy should lead to positive effects against this
objective, through the implementation of the other policies within the Local Plan, the
London Plan and the NPPF.

14

Improve safety
and reduce
crime and the
fear of crime

SD1

L-T, I, R, M

OPDC area
and Londonwide

See assessment under Objective 1. The policy should lead to positive effects against this
objective, through the implementation of the other policies within the Local Plan, the
London Plan and the NPPF.

55

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

OPDC area
and Londonwide

See assessment under Objective 1. The policy should lead to positive effects against this
objective, through the implementation of the other policies within the Local Plan, the
London Plan and the NPPF.

SD1
Maximise the
health and
wellbeing of the
population,
reduce
inequalities in
health and
promote healthy
living

16

To improve the SD1

education and
skills levels of all
members of the
population,
particularly
vulnerable
groups

L-T, I, R, M

OPDC area
and Londonwide

See assessment under Objective 1. The policy should lead to positive effects against this
objective, through the implementation of the other policies within the Local Plan, the
London Plan and the NPPF.

17

SD1
Maximise the
social and
economic
wellbeing of the
local and
regional
population and
improve access
to employment
and training

L-T, I, R, M

OPDC area
and Londonwide

See assessment under Objective 1. The policy should lead to positive effects against this
objective, through the implementation of the other policies within the Local Plan, the
London Plan and the NPPF.

18

To encourage
inward
investment

++ L-T, I, R, M

OPDC area
and Londonwide

See assessment under Objective 1. The policy should lead to positive effects against this
objective, through the implementation of the other policies within the Local Plan, the
London Plan and the NPPF. A positive approach to working with developers should

Page 560

15

Nature of
Impact
L-T, I, R, M

SD1

56

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
alongside
investment
within existing
communities, to
create
sustainable
economic growth

encourage an increase in inward investment in the local area.

Page 561
57

Table G-4 Chapter 6: Design

x D1: Strategic Policy: For Design
x D2: Streets and public realm
x D3: Open space
x D4: New buildings
x D5: Alterations & extensions
x D6: Heritage
x D7: Amenity
x D8: Inclusive design
IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
1

Page 562

To enhance the D1
built environment
and encourage
place-making

++

M, L-T, D, R, OPDC area

H

D2

++

M, L-T, D, R, OPDC area

H

D3

M, L-T, D, R, OPDC area

M

D4

D5

M, L-T, D, R, OPDC area

M
M, L-T, D, R, OPDC area
M

D5
Option 1

+/- M, L-T, I, R,

OPDC area

D6

D7

S, M, L-T, I,
R, M
S, M, L-T, I,

OPDC area
OPDC area

The policy seeks to contribute towards creating new character areas for places and
neighbourhoods and enhancing positive elements of existing local character and context
through the delivery of exemplar world class architectural and landscape design which
would enable the enhancement of local distinctiveness and character and would directly
support the IIA Objective.
The policy seeks to deliver exemplarily designed, welcoming, safe, resilient, flexible,
inclusive and sustainable public realm network through supporting proposals that
contribute to improving the quality of existing public realm and creating new public realm;
improving local character areas or contributing to the delivery of new local character
areas which would directly support the IIA Objective.
The protection and enhancement of existing public open spaces as well as contribution to
the delivery of new public open spaces will support local distinctiveness and help to
encourage place-making.
The policy seeks to deliver world class exemplary designed buildings which would
contribute towards encouraging place-making.
Alterations and extensions would contribute to the IIA Objective through improving the
architectural quality and character of existing building, as well as the provision of open
and active frontages to the public realm.
The policy would seek the development of a streamlined local planning framework,
however, this approach could result in negative impacts on the local character and
context through an accumulation of unmanaged amendments to existing buildings.
The conservation and enhancement of the historic environment, heritage assets and their
setting would contribute towards creating a sense of place.
The provision of a high level of amenity and quality environment for building users would
58

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

Page 563
3

To optimise the
efficient use of
land through
increased
development
densities and
building heights,
where
appropriate

R, M
S, M, L-T, I,
R, M
S, M, L-T, I,
R, M
S, M, L-T, I,
R, M

help to support place-making.

The use of the London Plan policy to manage amenity would partially contribute towards
achieving the IIA Objective.
The provision of an inclusive designed environment for Old Oak, Park Royal, and
Wormwood Scrubs would support place-making.
The creation of new character areas and enhancement of positive existing elements
would inform optimising of development densities and location and/or range of building
heights.
The delivery of exemplarily designed, welcoming, safe, resilient, flexible, inclusive and
sustainable public realm network will contribute to optimising densities in helping to
support the functioning of buildings and quality of life of building users.
The delivery of a network of public open spaces will contribute to optimising densities in
helping to support the quality of life of building users.
The policy seeks to deliver world class exemplary designed buildings and supports the
delivery of densities within development that support those identified in the Overarching
Spatial Policies and Places chapter of the Plan.

D7
Option 1
D8

D1

D2

S, M, L-T, I,
R, M

OPDC area

D3

OPDC area

D4

S, M, L-T, I,
R, M
S, M, L-T, I,
R, M

D5
D5
Option 1
D6

0
0

N/A
N/A

N/A
N/A

There is no clear link between the policy and the IIA Objective.
There is no clear link between the policy and the IIA Objective.

OPDC area

D7

D7
Option 1

S, M, L-T, I,
R, M
S, M, L-T, I,
R, M
S, M, L-T, I,
R, M

0
0

N/A
N/A

N/A
N/A

N/A

N/A

The need to conserve and / or enhance heritage assets will contribute to inform
development densities and building heights.
Ensuring that development delivers a high level of amenity and high quality environment
for building users will inform development densities and buildings.
Using London Plan policy to ensuring that development delivers a high level of amenity
and high quality environment for building users will inform development densities and
buildings may not deliver the sufficient amount of amenity specific to Old Oak and Park
Royal.
There is no clear link between the Policy and IIA Objective.
Development within the OPDC area would be on previously developed land however this
is not the specific focus of the policy therefore effects against the Objective would be
neutral. This is considered in the OSPs.
Development within the OPDC area would be on previously developed land however this
is not the specific focus of the policy therefore effects against the Objective would be

D8
D1
Maximise the
reuse of
previously
D2
developed land

OPDC area
OPDC area
OPDC area

OPDC area

OPDC area
OPDC area

59

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
and existing
buildings,
including the
remediation of
contaminated
land

Page 564
4

Minimise the
need to travel,
improve
accessibility for
all users by
public and nonmotorised

D3

N/A

N/A

D4

S, M, L-T, I,
R, M

OPDC area

D5

N/A

N/A

D5
Option 1

N/A

D6

N/A

D7

N/A

D7
Option 1

N/A

D8

N/A

D1

D2

S, M, L-T, I,
R, M
S, M, L-T, I,
R, M

D3

D4

S, M, L-T, I,
R, L
S, M, L-T, I,

neutral. This is considered in the OSPs.

Development within the OPDC area would be on previously developed land however this
is not the specific focus of the policy therefore effects against the Objective would be
neutral. This is considered in the OSPs.
The policy seeks to deliver world class exemplary designed buildings and supports the
delivery of densities within development that support those identified in the Overarching
Spatial Policies and Places chapter of the Plan.

Development within the OPDC area would be on previously developed land however this
is not the specific focus of the policy therefore effects against the Objective would be
neutral.
N/ADevelopment within the OPDC area would be on previously developed land however this
is not the specific focus of the policy therefore effects against the Objective would be
neutral.
N/A
Development within the OPDC area would be on previously developed land however this
is not the specific focus of the policy therefore effects against the Objective would be
neutral.
N/A
Development within the OPDC area would be on previously developed land however this
is not the specific focus of the policy therefore effects against the Objective would be
neutral.
N/A
Development within the OPDC area would be on previously developed land however this
is not the specific focus of the policy therefore effects against the Objective would be
neutral.
N/A
Development within the OPDC area would be on previously developed land however this
is not the specific focus of the policy therefore effects against the Objective would be
neutral.
OPDC area
The delivery of exemplar design quality would involve good levels of accessibility which
would support the IIA Objective.
OPDC area
The policy seeks to contribute to or improve the network of streets and to contribute to
connecting places together as well as breaking down severance which would support the
improvement of accessibility and may contribute towards minimising the need to travel.
OPDC area
The provision of public open space would make partial contributions towards improving
accessibility.
OPDC area
The policy would include the delivery of development densities that accord with guidance
60

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
transportation
methods and
mitigate impacts D5
D5
on the transport
Option 1
network
D6
D7
D7
Option 1
D8

Page 565

Improve access D1
to well designed,
well-located,
D2
market,
affordable and
D3
inclusive housing
of a range of
D4
types and
tenures, to meet
identified local D5
needs
D5
Option 1
D6
D7
D7
Option 1
D8

R, L
0
0

N/A
N/A

N/A
N/A

set out in the OSP Chapter, thereby higher densities at stations would contribute to
minimising the need to travel.
There is no clear link between the policy and the IIA Objective.
There is no clear link between the policy and the IIA Objective.

0
0
0

N/A
N/A
N/A

N/A
N/A
N/A

There is no clear link between the policy and the IIA Objective.
There is no clear link between the policy and the IIA Objective.
There is no clear link between the policy and the IIA Objective.

S, M, L-T, D, Old Oak, Park

I, R, M
Royal, and
Wormwood
Scrubs
++ S, M, L-T, I, OPDC area
R, L
0
0
+

0
0
0
0
0
+

The policy specifically seeks to deliver inclusive and accessible designed environment for
Old Oak, Park Royal, and Wormwood Scrubs and to reduce existing barriers.

The policy seeks to create new and enhance existing character areas for places and
neighbourhoods. Across Old Oak and within non-industrial areas of Park Royal, this
would include significant levels of housing.
N/A
N/A
The policy seeks the delivery of public realm and therefore has no direct link to the IIA
Objective.
N/A
N/A
The policy addresses the delivery of open space and therefore has no direct link to the
IIA Objective.
S, M, L-T, I, OPDC area
The policy addresses the delivery of new buildings and development densities in
R, L
accordance with the OSP Chapter which would deliver significant levels of new housing,
thereby supporting the IIA Objective.
N/A
N/A
The policy addresses alterations and extensions however ultimately does not directly
relate to housing provision.
N/A
N/A
The policy addresses alterations and extensions however ultimately does not directly
relate to housing provision.
N/A
N/A
There is no direct link between the policy and the IIA Objective.
N/A
N/A
The policy primarily addresses amenity provision and has no direct link between the IIA
Objective.
N/A
N/A
The policy primarily addresses amenity provision and has no direct link between the IIA
Objective.
S, M, L-T, D, Old Oak, Park The policy seeks inclusive design and it is noted that policy 3.8 of the London Plan
I, R, M
Royal, and
requires development to deliver 10% of new housing to be designed to be wheelchair
61

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

Page 566

Improve climate D1
change
adaptation and
mitigation,
including
minimising the
risk of flooding D2
and addressing
the heat island
effect
D3

Wormwood
Scrubs
S, M, L-T, D, OPDC area
I, R, L

S, M, L-T, D, OPDC area

I, R, L

S, M, L-T, D, OPDC area

I, R, L

D4

N/A

D5

S, M, L-T, D, OPDC area

I, R
L

D5
Option 1

S, M, L-T, D, OPDC area

I,R, L

N/A

accessible or easily adaptable for residents who are wheelchair users.

New development has the potential to increase flood risk however this would only be
associated with development within flood zones associated with the River Brent. However
the provision of exemplar design would incorporate flood avoidance or adaptation
measures. This should also be considered alongside the Environment and Utilities
Chapter water proposed policy which sets out the suggested approach to flood risk.
Where necessary, appropriate mitigation measures should be incorporated into
development.
The nature of the policy itself to deliver an exemplarily designed, welcoming, safe,
resilient, flexible, inclusive and sustainable public realm network may offer benefits
towards the IIA Objectives through measures such as street greening
There is no clear link between the policy and the IIA Objective.
The provision of open space has the potential to act as flood storage which could prevent
adverse risk to housing areas and delivering green infrastructure to help address the
urban heat island effect.
Where necessary and appropriate, flood risk mitigation measures and measures
supporting climate change adaptation should be incorporated into the design of open
space in accordance with the proposed water policy in the Environment and Utilities
Chapter..
New exemplarily designed and sustainable buildings would potentially incorporate flood
alleviance or flood avoidance measures. This should also be considered alongside the
Environment and Utilities Chapter water proposed policy which sets out the suggested
approach to flood risk.
The extent of extensions could potentially have an effect on flood risk, however, this
would only be associated with development within flood zones associated with the River
Brent.
Where necessary and appropriate, flood risk mitigation measures and measures
supporting climate change adaptation should be incorporated into the design of open
space in accordance with the proposed water policy in the Environment and Utilities
Chapter.
The policy states that guidance is not provided for alterations, extensions or shopfronts
and could potentially have an effect on flood risk however this would only be associated
with development within flood zones associated with the River Brent.
Where necessary and appropriate, flood risk mitigation measures and measures
62

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

Page 567
8

To minimise
contributions to
climate change
through greater
energy
efficiency,
generation and
storage; and to
reduce reliance
on natural
resources
including fossil
fuels for
transport,
heating and
energy

To minimise

D6
D7
D7
Option 1
D8
D1

0
0
0

N/A
N/A
N/A

N/A
N/A
N/A

0
0

N/A
N/A

N/A
N/A

D2
D3
D4

0
0
+

N/A
N/A
N/A
N/A
S, M, L-T, D, OPDC area
I, R, M

D5

S, M, L-T, D, OPDC area

I, R, M

D5
Option 1

D6
D7
D7
Option 1
D8
D1
D2

+/- S, M, L-T, D, OPDC area

I, R, M

0
0
0

N/A
N/A
N/A

N/A
N/A
N/A

0
0
+

N/A
N/A
N/A
N/A
S, M, L-T, D, Old Oak and

supporting climate change adaptation should be incorporated into the design of open
space in accordance with the proposed water policy in the Environment and Utilities
Chapter.
There is no direct link between the policy and the IIA Objective.
There is no direct link between the policy and the IIA Objective.
There is no direct link between the policy and the IIA Objective.
There is no direct link between the policy and the IIA Objective.
The nature of the policy itself to demonstrate exemplar world class architectural and
landscape design quality and may offer benefits towards the IIA Objectives through
measures such as energy efficiency and reducing reliance on natural resources though
not to a significant degree.
There is no direct link between the policy and the IIA Objective.
There is no direct link between the policy and the IIA Objective.
The policy seeks the development of world class exemplarily designed and sustainable
buildings which would likely support the minimisation of contributions to climate change
through high standards of sustainable design and the incorporation of incorporated
measures for energy efficiency.
Alterations and extensions would require the use of materials and transportation during
construction though appropriate measures could support climate change adaptation.
Development should seek to incorporate sustainability measures during construction and
operation.
The policy does not provide guidance for alterations, extensions and shopfronts instead
seeking the development through a streamlined planning framework approach. Lack of
guidance could reduce the likelihood of meeting the IIA Objective
Development should seek to incorporate sustainability measures during construction and
operation.
There is no direct link between the policy and the IIA Objective.
There is no direct link between the policy and the IIA Objective.
There is no direct link between the policy and the IIA Objective.
There is no direct link between the policy and the IIA Objective.
There is no direct link between the policy and the IIA Objective.
The policy seeks to coordinate the delivery of utilities infrastructure within the public realm
63

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Park Royal

which could include sub-surface waste transfer. This would help to support the IIA
Objective.
The provision of open space is not likely to result in significant effects to waste.
Development of new buildings could have negative effects resulting in increased waste
particularly during construction if not adequately mitigated through policies in the waste
management policy in the Environment and Utilities Chapter.
Where appropriate waste and recycling facilities should be incorporated and waste
minimisation techniques should be encouraged.
Alterations and extensions could have negative effects resulting in increased waste
particularly during construction if not adequately mitigated through policies in the waste
management policy in the Environment and Utilities Chapter..
Where appropriate waste and recycling facilities should be incorporated and waste
minimisation techniques should be encouraged.
Alterations and extensions through a streamlined planning framework approach could
have negative effects resulting in increased waste particularly during construction if not
adequately mitigated through policies in the waste management policy in the
Environment and Utilities Chapter..
Where appropriate waste and recycling facilities should be incorporated and waste
minimisation techniques should be encouraged.
There is no direct link between the policy and the IIA Objective.
There is no direct link between the policy and the IIA Objective.
There is no direct link between the policy and the IIA Objective.

Nature of
Impact

Page 568

production of
waste across all
D3
sectors in the
D4
plan area,
maximise
efficiencies for
transporting
waste and
D5
increasing rates
of re-use,
recycling and
recovery rates
D5
as well as
Option 1
composting of all
green waste

Improve the
quality of the
water
environment

I, R, M

0 N/A
N/A
+/- S, M, L-T, D, OPDC area
I, R, M

+/- S, M, L-T D, I, OPDC area

R, M

+/- S, M, L-T, D, OPDC area

I, R, M

D6
D7
D7
Option 1
D8
D1

0
0
0

N/A
N/A
N/A

N/A
N/A
N/A

0
+

N/A
N/A
S, M, L-T, D, OPDC area
I, R, M

There is no direct link between the policy and the IIA Objective.
The delivery of exemplar world class landscape design quality could include water
efficiency measures such as SuDS which would contribute to improving the water
environment.

D2
D3

0
+

N/A
N/A
S, M, L-T, D, OPDC area
I, R, M

D4

S, M, L-T, D, OPDC area

I, R, M

There is no direct link between the policy and the IIA Objective.
New and existing open space could support the IIA Objective through providing
opportunities for Sustainable Urban Drainage Systems (SuDS).
Sustainable water measures should be adopted where appropriate.
The policy seeks to deliver exemplary design and sustainable buildings which could
include water efficiency measures such as SuDS which would contribute to improving the
64

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

D5

D5
Option 1

Page 569

10

11

D6
D7
D7
Option 1
D8
D1

Create and
enhance
biodiversity and
D2
the diversity of
habitats across
the area and its D3
surroundings

D4
D5
D5
Option 1
D6
D7
D7
Option 1
D8
To minimise air, D1

S, M, L-T,D, I, OPDC area

R, M

+/- S, M, L-T, D, OPDC area

I, R, M

N/A
N/A
N/A

water environment.
Sustainable water measures should be adopted where appropriate.
The delivery of alterations and extensions could include water efficiency measures such
as SuDS which would contribute to improving the water environment.
Sustainable water measures should be adopted where appropriate.
The delivery of alterations, extensions and shopfronts could include water efficiency
measures such as SuDS. However a lack of guidance for delivery could have implications
for achieving the IIA Objective. Sustainable water measures should be adopted where
appropriate.
There is no direct link between the policy and the IIA Objective.
There is no direct link between the policy and the IIA Objective.
There is no direct link between the policy and the IIA Objective.

0
0
0

N/A
N/A
N/A

0
+

N/A
N/A
S, M, L-T, D, OPDC area
I, R, M

S, M, L-T, D, OPDC area

I, R, M

S, M, L-T, D, OPDC area

I, R, M

0
0
0

N/A
N/A
N/A

N/A
N/A
N/A

There is no direct link between the policy and the IIA Objective.
The delivery of world class architectural and landscape quality design could contribute
towards including landscape features which may support the IIA Objective though to a
limited degree.
The delivery of a sustainable public realm network could help to support biodiversity
where spaces may include provision for street greening.
Where possible, green corridors should be encouraged within development.
The delivery of open space could help to support biodiversity where spaces may include
provision for green corridors.
Where possible, green corridors should be encouraged within development.
There is no direct link between the policy and the IIA Objective.
There is no direct link between the policy and the IIA Objective.
There is no direct link between the policy and the IIA Objective.

0
0
0

N/A
N/A
N/A

N/A
N/A
N/A

There is no direct link between the policy and the IIA Objective.
There is no direct link between the policy and the IIA Objective.
There is no direct link between the policy and the IIA Objective.

0
+

N/A
N/A
S, M, L-T, D, OPDC area
I, R, M

There is no direct link between the policy and the IIA Objective.
The delivery of exemplar world class architectural and landscape design quality could
include measures to minimise air, noise and light pollution.
65

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

OPDC area

The provision of open space could bring about positive effects to air quality through the
provision of street greening.
The provision of open space could bring about positive effects to air quality through the
provision of vegetation.
There is no direct link between the policy and the IIA Objective.
There is no direct link between the policy and the IIA Objective.
There is no direct link between the policy and the IIA Objective.

Nature of
Impact
noise and light
pollution,
particularly for
vulnerable
groups

D2

D3

D4
D5
D5
Option 1
D6
D7

0
0
0

Page 570

D7
Option 1

12

S, M, L-T, D,
I, R, L
S, M, L-T, D,
I, R, L
N/A
N/A
N/A

OPDC area
N/A
N/A
N/A

N/A N/A
N/A
+ S, M, L-T, D, OPDC area
I, R, L
+/- S, M, L-T, D, OPDC area
I, R, L

D8

N/A

N/A

To conserve and D1
enhance the
historic
environment,
heritage assets D2
and their settings

S, M, L-T, I,
R, M

OPDC area

S, M, L-T, I,
R, M

OPDC area

D3

S, M, L-T, I,
R, M

OPDC area

D4

S, M, L-T, I,
R, M

OPDC area

There is no direct link between the policy and the IIA Objective.
The need for development to deliver a high level of amenity would directly minimise air,
noise and light pollution.
The need for development to deliver a high level of amenity would directly minimise air,
noise and light pollution. Relying on London Plan policy may not address Old Oak and
Park Royal specific issues in relation to daylight/sunlight.
There is no direct link between the policy and the IIA Objective.

The creation of new places within the plan area would support the IIA Objective as design
would seek to enhance existing elements of local character and context ensuring a
positive response to the surrounding environment. This would help to ensure that the
setting of assets would be protected and enhanced as well helping to conserve the
historic environment.
The policy seeks to deliver a public realm network that responds to the surrounding
character. This would support the IIA Objective through the provision of public realm that
respects and complements its existing surroundings including heritage assets and their
setting.
The policy seeks to deliver open space that contributes to the character and activation of
an area. This would support the IIA Objective through the provision of open space that
respects and complements its existing surroundings including heritage assets and their
setting.
The delivery of exemplary buildings would support the IIA Objective through careful
design that respects its surroundings and conserves the historic environment, heritage
assets and their setting.
66

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

S, M, L-T, I,
R, M

OPDC area

D5
Option 1

+/- S, M, L-T, I,

OPDC area

The policy states that proposals for alterations and extensions would be supported where
they relate sympathetically to any other sensitive sites that would be affected which would
contribute to conserving heritage assets and their setting as well as protecting the historic
environment.
The policy also supports the IIA Objective however without guidance provided for
alterations, extensions and shopfronts, unmanaged amendments to existing buildings
could result in negative impacts on local character and potentially heritage assets.

D6

++

S, M, L-T, D, OPDC area

R, H

D7

S, M, L-T, I,
R, M

OPDC area

D7
Option 1

S, M, L-T, I,
R, M

OPDC area

D8

N/A

N/A

D1
Increase
community
D2
cohesion and
reduce social
exclusion to
encourage a
D3
sense of
community and
welfare
D4

S, M, L-T, I,
R, L
S, M, L-T, I,
R, L

OPDC area

S, M, L-T, I,
R, L

OPDC area

S, M, L-T, I,
R, L

OPDC area

Nature of
Impact
D5

Page 571
13

R, L

OPDC area

The policy would directly support the IIA Objective as it seeks to identify, conserve,
enhance and improve access to the historic environment, heritage assets and their
setting. The policy also seeks to ensure heritage assets contribute to improving and
creating a sense of place where appropriate and address Heritage at Risk.
The policy seeks to provide high level amenity and quality environment for building users
and surrounding areas which would enable an approach to development that would be
sensitive to the existing local area and would respect and complement features including
heritage assets and their setting.
A London-wide standardised approach to the delivery of amenity would help to contribute
to delivering the objective, however OPDC would not be able to manage specific amenity
issues in relation to higher density development.
The policy seeks to deliver exemplary inclusive and accessible design that could support
sensitive development however would not make significant contributions towards
achieving the IIA Objective.
The provision of new character areas and improvements to existing character areas
would support a sense of place and would help to increase community cohesion.
The policy seeks provision of public realm that facilitates the use and enjoyment of
spaces and to improve the network of streets, to connect places together and breakdown
severance all of which would contribute towards increasing community cohesion and
reducing social exclusion.
The provision of open space, the protection of existing spaces and the delivery of
temporary spaces that contribute to the vitality character and activation of an area
supporting the development of permanent development would help to increase
community cohesion and encourage a sense of community welfare.
The delivery of new buildings would contribute to creating a sense of place and would
partially support the IIA Objective.
67

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

Page 572

14

Improve safety
and reduce
crime and the
fear of crime

D5

N/A N/A

D5
Option 1
D6

N/A N/A
+

S, M, L-T, I,
R, L
S, M, L-T, I,
R, L
S, M, L-T, I,
R, L

N/A

Alterations and extensions would not contribute significantly towards the achievement of
the IIA Objective.
N/A
Alterations and extensions would not contribute significantly towards the achievement of
the IIA Objective.
OPDC area
The improvement and enhancement of the historic environment and heritage features
within the area may contribute partially towards supporting community cohesion.
OPDC area
The provision of a high level of amenity and quality environment would help to support
community cohesion and welfare.
OPDC area
A London-wide standardised approach to the delivery of amenity would help to contribute
to delivering the objective, however OPDC would not be able to manage specific amenity
issues in relation to higher density development
Old Oak, Park The development of inclusive design that is safe and accessible and addresses existing
barriers would contribute towards community cohesion.
Royal, and
Wormwood
Scrubs
OPDC area
The policy primarily focuses on place-making through the provision of architectural and
landscape design quality which incorporates safety and could make contributions towards
reducing fear of crime.

D7

D7
Option 1

D8

S, M, L-T, I,
R, L

D1

++

S, M, L-T, I,
R, L

D2

S, M, L-T, I,
R, L

OPDC area

D3

OPDC area

D4

S, M, L-T, I,
R, L
S, M, L-T, I,
R, L

D5
D5
Option 1
D6
D7

0
0

N/A
N/A

N/A
N/A

The delivery of world-class exemplary and sustainable building design would likely
incorporate safety into its design which would support the IIA Objective however this is
not explicitly stated within the policy.
There is no direct link between the policy and the IIA Objective.
There is no direct link between the policy and the IIA Objective.

N/A
S, M, L-T, I,
R, L

N/A
OPDC area

There is no direct link between the policy and the IIA Objective.
The design of open space could support the reduction of crime and could improve safety.

OPDC area

The policy seeks to provide safe public realm and improving the network of streets which
would help to improve safety.
Development design should seek to optimise natural surveillance and ensure that new
spaces and routes are safe.
The design of open space could support the reduction of crime and could improve safety.

68

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

15

Page 573

D7
Option 1

S, M, L-T, I,
R, L

D8

S, M, L-T, I,
R, L

D1
Maximise the
health and
wellbeing of the
D2
population,
reduce
inequalities in
health and
promote healthy
D3
living

S, M, L-T, I,
R, M

S, M, L-T, I,
R, M

S, M, L-T, I,
R, M

D4

D5
D5
Option 1
D6
D7

0
0

S, M, L-T, I,
R, M
N/A
N/A

D7
Option 1

S, M, L-T, I,
R, M

D8

S, M, L-T, I,
R, L

0
+

N/A
S, M, L-T, I,
R, M

OPDC area

A London-wide standardised approach to the delivery of amenity would help to contribute

to delivering the objective, however OPDC would not be able to manage specific amenity
issues in relation to higher density development
Old Oak, Park Safety could be improved through development design.
Royal, and
Wormwood
Scrubs
OPDC area
The policy seeks to enhance existing local character and context and contribute towards
creating new character areas for places and neighbourhoods for locations within Old Oak
this would contribute to place-making and maximising the wellbeing of the population.
OPDC area
The policy seeks to provide welcoming and safe public realm network that facilitates the
use and enjoyment of spaces while responding to local character and integrating with
surroundings. This would contribute towards maximising the wellbeing of the population
through enabling safety, enhancing community spirit all of which would support
community cohesion. It would also contribute to promoting healthy living giving greater
opportunities for walking and cycling which would promote health benefits.
OPDC area
The policy seeks to protect and enhance existing public open spaces, create and connect
new public open spaces to meet needs identified and deliver private and communal open
space to support the needs of residents which would contribute to maximising health and
wellbeing as well as helping to promote healthy living.
OPDC area
The policy seeks to deliver world class exemplarily designed and sustainable new
buildings that would contribute to maximising the wellbeing of the population.
N/A
There is no direct link between the policy and the IIA Objective.
N/A
There is no direct link between the policy and the IIA Objective.
N/A
OPDC area

There is no direct link between the policy and the IIA Objective.
The delivery of a high level of amenity and quality environment for building users that
would not negatively impact upon the amenity of existing local communities would
contribute towards maximising the health and wellbeing of the population.
OPDC area
A London-wide standardised approach to the delivery of amenity would help to maximise
health and wellbeing of the population however OPDC would not be able to manage
specific amenity issues in relation to higher density development.
Old Oak, Park The delivery of inclusive design which is accessible and addresses existing barriers of the
Royal, and
physical environment would make contributions towards maximising wellbeing of the
69

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

population.

Nature of
Impact

16

To improve the
education and
skills levels of all
members of the
population,
particularly
vulnerable
groups

Page 574
17

Maximise the
social and
economic
wellbeing of the
local and
regional
population and
improve access
to employment
and training

D1

N/A

Wormwood
Scrubs
N/A

D2

N/A

N/A

D3

N/A

N/A

D4

M, L-T, I, R, L OPDC area

D5
D5
Option 1
D6
D7
D7
Option 1
D8
D1

0
0

N/A
N/A

N/A
N/A

The policy primarily addresses place-making and has no direct link to improving
education and skills.
The policy primarily addresses streets and public realm and has no direct link to
improving education and skills.
The policy primarily addresses open space and has no direct link to improving education
and skills.
The policy primarily addresses new building design, including social infrastructure which
could include the integration of schools which would support the improvement of
education.
There is no direct link between the policy and improving education and skills.
There is no direct link between the policy and improving education and skills.

0
0
0

N/A
N/A
N/A

N/A
N/A
N/A

There is no direct link between the policy and improving education and skills.
There is no direct link between the policy and improving education and skills.
There is no direct link between the policy and improving education and skills.

N/A
S, M, L-T, I,
R, L

N/A
OPDC area

D2

OPDC area

D3

D4

D5
D5
Option 1
D6

0
0

S, M, L-T, I,
R, L
S, M, L-T, I,
R, L
S, M, L-T, I,
R, L
N/A
N/A

There is no direct link between the policy and improving education and skills.
The policy seeks to provide new character areas and enhance the positive elements of
existing character areas which would partially support the IIA Objective in helping to
maximise social and economic wellbeing of the local and regional population.
Social and economic wellbeing could be partly supported through improvements to public
realm and street network.
The provision of public open space would partly support the IIA Objective by contributing
to maximising social wellbeing.
The delivery of exemplary designed buildings could help to support social and economic
wellbeing.
There is no direct link between the policy and the IIA Objective.
There is no direct link between the policy and the IIA Objective.

S, M, L-T, I,
R, M

OPDC area
OPDC area
N/A
N/A
OPDC area

The conservation, enhancement and improvement of the historic environment and

heritage assets help to generate social and economic benefits for Old Oak and Park
Royal and would therefore partially support the IIA Objective.
70

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

OPDC area

The delivery of a high level amenity and quality environment for building users and
surrounding areas would help to support social and economic wellbeing.
There is no direct link between the policy and the IIA Objective.

N/A

Nature of
Impact

18

D7

D7
Option 1
D8

S, M, L-T, I,
R, M
N/A

N/A

S, M, L-T, I,
R, L

S, M, L-T, I,
R, L
N/A

Page 575

D1
To encourage
inward
investment
D2
alongside
investment
D3
within existing
communities, to D4
create
sustainable
economic growth D5

0
+

S, M, L-T, I,
R, M

S, M, L-T, I,
R, L

D5
Option 1

S, M, L-T, I,
R, L

D6

D7

S, M, L-T, I,
R, L
S, M, L-T, I,
R, M

D7
Option 1

S, M, L-T, I,
R, L

D8

S, M, L-T, I,

N/A

Social and economic wellbeing could be partly supported by delivering an exemplarily

inclusive and accessible designed environment for all.
OPDC area
An increase in exemplar design that contributes to enhancing character and creating new
character areas would contribute towards encouraging inward investment alongside
investment within existing communities.
OPDC area
Inward investment would be encouraged through the delivery of public realm that
facilitates the use and enjoyment of spaces.
N/A
Whilst the provision of open space would not significantly contribute towards achieving
the IIA Objective, it would help to increase attractiveness of the local area.
OPDC area
The delivery of exemplary and sustainable buildings would enable the creation of
attractive areas which would help to encourage inward investment alongside investment
within existing communities.
OPDC area
Alterations and extensions would provide for improvements to the architectural quality
and character of buildings which would make partial contributions towards achieving the
IIA Objective.
OPDC area
Alterations and extensions would provide for improvements to the architectural quality
and character of buildings which would make partial contributions towards achieving the
IIA Objective.
OPDC area
Conserving and enhancing the historic environment and heritage assets would make
partial contributions towards achieving the IIA Objective.
OPDC area
The delivery of a high level amenity and quality environment for building users and
surrounding areas would help to promote the attractiveness of the local area as a place to
live and work which would help to attract inward investment and would support the
creation of economic growth.
OPDC area
The management of amenity through a London wide plan similarly with the preferred
option would help to promote the attractiveness of the local area as a place to live and
work which would help to attract inward investment however the policy would not enable
the management of specific amenity issues relevant to Old Oak and Park Royal and
therefore would support the IIA Objective to a lesser extent than the preferred option.
Old Oak, Park The delivery of an inclusive and accessible design environment within Old Oak, Park
71

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Royal, and
Wormwood
Scrubs

Royal and Wormwood Scrub would increase attractiveness within these areas and would
help to encourage inward investment.

Nature of
Impact
R, M

Page 576
72

Table G-5 Chapter 7: Housing Policies and Policy Options

x H1: Strategic Policy for Housing
x H2: Housing Supply
x H3: Housing Mix
x H4: Affordable Housing
x H5: Existing Housing
x H6: Housing in the Private Rented Sector
x H7: Housing with shared facilities
x H8: Specialist housing for older people and / or vulnerable people
x H9: Gypsy and Travellers Accommodation
x H10: Student housing
IIA Objective

Page 577

To enhance
the built
environment
and
encourage
place-making

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

The policy seeks to deliver housing to contribute to meeting the housing needs
identified in the London Plan. The requirement for high quality design and lifetime
neighbourhoods should lead to significant benefits against this objective.
The policy could have some benefits against this objective in that it seeks to bring
vacant dwellings back into use, which could improve sense of place locally.
The policy option relates to housing numbers, which is unlikely to noticeably affect the
predicted effect of this policy compared to the preferred option. However, the
implication of a higher provision of housing within the plan period could have
implications for infrastructure provision and increased construction impacts, which
could lead to negative effects against this objective.
The policy could lead to the generation of some benefits against this objective, in that it
will deliver a mix of housing to meet local needs, which could lead to the generation of
mixed, balanced and sustainable neighbourhoods.

H1

++

Nature of
Impact
L-T, I, R, M

H2

L-T, I, R, L

OPDC area
and Londonwide
OPDC area

+/-

L-T, I, R, L

OPDC area

L-T, I, R, L

OPDC area

H2
Option
1

H3

H3
Option
1
H4
H4
Option
1

L-T, I, R, L

OPDC area

It is suggested that bullet point 3 of the policy is unnecessary and provides repetition
that could be excluded.
The policy option relates to alternatives in the provision of housing types, which is
unlikely to significantly affect the predicted effect of this policy compared to the
preferred option.
No preferred policy is provided for affordable housing in this iteration of the Local Plan.
See assessment of strategic options Table F-1 Affordable Housing Approaches

73

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
H4
Option
2
H4
Option
3
H4
Option
4
H5

Page 578

H5
Option
1
H5
Option
2
H6

H6
Option
1

H7

See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

M, L-T, I, R,
L

OPDC area

M, L-T, I, R,
L

OPDC area

M, L-T, I, R,
L

OPDC area

S, M, L-T, I,
R, L

OPDC area
and Londonwide

+/-

S, M, L-T, I,
R, L

OPDC area
and Londonwide

S, M, L-T, I,
R, L

OPDC area
and Londonwide

The policy could have some benefits against this objective in that it seeks to bring
vacant dwellings back into use, as well as resist the loss of existing housing stock, with
the exception of land within the SIL, which could improve sense of place locally.
The policy option relates to the conversion of buildings to other uses and the potential
loss of existing housing stock, which could have a negative effect in relation to the
creation of a sense of place adhering to the principles of lifetime neighbourhoods.
The policy option would include a lower percentage of family sized accommodation,
which could reduce the potential for the creation of mixed communities locally.
However, effects would still be positive overall.
The policy could lead to some benefits against this objective as it seeks to support an
identified housing need in London. A requirement to ensure that developments are of a
high standard of design, which is managed, should seek to benefit this objective to
some degree.
In addition to the above, the policy option could have benefits for the creation of more
sustainable communities through leading to positive impacts for the residents.
However, the requirements for all PRS proposals to sign up to the London Rental
Scheme could have impacts on deliverability, which could affect the overall housing
mix, which could lead to negative effects against this objective.
The policy could lead to some benefits against this objective as it seeks to support an
identified housing need in London. A requirement to ensure that developments meet
relevant quality standards are located in areas with good public transport accessibility
and facilities, could lead to some benefits against this objective. Supporting text
indicates that where quality concerns exist about existing shared housing, their loss to
an alternative housing uses will not be resisted or proposals to improve standards will
be considered.
74

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
The policy could seek to enhance the creation of local communities as opposed to only
seeking that shared housing do not give rise to unacceptable impacts on local amenity.

Page 579
2

To optimise

H7
Option
1

S, M, L-T, I,
R, L

OPDC area
and Londonwide

H8

S, M, L-T, I,
R, L

OPDC area
and Londonwide

H9

S, M, L-T, I,
R, L

H10

S, M, L-T, I,
R, L

OPDC area
and Londonwide
OPDC area
and Londonwide

H10
Option
1
H1

S, M, L-T, I,
R, L

S, M, L-T,
D, R, M

OPDC area
and Londonwide
OPDC area
and London-

The policy could include a requirement relating to existing shared housing, similar to
that included within the supporting text, within the policy wording.
This option could have a negative effect on the objective. The conversion or loss of
shared housing would remove this type of housing from supply and would not help
meet Londons housing demand.
The policy could lead to some benefits against this objective as it seeks to support an
identified housing need in London. A requirement to ensure that developments are of a
high standard of design, and are accessible to public transport, shops, services,
community facilities and social networks, should seek to benefit this objective to some
degree.
The policy could lead to some benefits against this objective as it seeks to support an
identified housing need in London.
The policy could lead to some benefits against this objective as it seeks to support an
identified housing need in London. The policy seeks to ensure that the development of
student accommodation does not lead to an over-concentration of student
accommodation in a particular location. In addition, proposals should not have an
unacceptable impact on the immediate and surrounding areas, including residential
amenity. Sites should be in accessible locations and not lead to the net loss of other
forms of housing. These measures should ensure that a sense of place and community
is maintained, although will not necessarily contribute towards the creation of
communities.
Measures that could be included to create places within the local communities as a
result of student housing could be suggested to enhance their presence within the built
environment.
The policy option is unlikely to noticeably affect the predicted effect of this policy
compared to the preferred option.
The policy seeks to deliver a significant number of houses within London, which is
likely to lead to the optimisation in the use of land.
75

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
the efficient
use of land
through
increased
development
densities and
building
heights, where
appropriate

wide
H2

H2
Option
1
H3

Page 580

H3
Option
1
H4
H4
Option
1
H4
Option
2
H4
Option
3
H4
Option
4
H5

H5
Option
1
H5
Option
2
H6

The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option is unlikely to have an effect against achievements against this
objective directly.

The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option relates to alternatives in the provision of housing types, which is
unlikely to noticeably affect the predicted effect of this policy compared to the preferred
option.
No preferred policy is provided for affordable housing in this iteration of the Local Plan.
See assessment of strategic options Table 5-2 Affordable Housing Approaches

See assessment of strategic options Table 5-2 Affordable Housing Approaches

See assessment of strategic options Table 5-2 Affordable Housing Approaches

See assessment of strategic options Table 5-2 Affordable Housing Approaches

M, L-T, I, R,
M

OPDC area

M, L-T, I, R,
M

OPDC area

M, L-T, I, R,
M

OPDC area

The policy could have some benefits against this objective in that it seeks to optimise
existing housing stock through the conversion of existing dwellings to two or more
dwellings.
The policy option could have some benefits against this objective in that it seeks to
optimise development through the conversion of existing dwellings for other uses.
The policy option could have some benefits against this objective in that it seeks to
optimise development through the conversion of existing dwellings for other uses.
The policy is unlikely to have an effect against achievements against this objective
directly.
76

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
H6
Option
1
H7

H7
Option
1
H8

Page 581
3

Maximise the
reuse of
previously
developed
land and
existing
buildings,
including the

The policy option is unlikely to have an effect against achievements against this
objective directly.

S, M, L-T, I,
R, L

S, M, L-T, I,
R, L

S, M, L-T, I,
R, L

OPDC area
and Londonwide
OPDC area
and Londonwide
OPDC area
and Londonwide

H9

+/-

S, M, L-T, I,
R, L

OPDC area
and Londonwide

H10

S, M, L-T, I,
R, L

H10
Option
1
H1

S, M, L-T, I,
R, L

S, M, L-T,
D, R, M

H2

L-T, I, R, M

OPDC area
and Londonwide
OPDC area
and Londonwide
OPDC area
and Londonwide
OPDC area

H2
Option
1
H3

L-T, I, R, L

OPDC area

Meeting an identified need for shared housing within the plan area is considered to be
an efficient use of land.
The option seeks to encourage the loss of shared housing which is not a way to
optimise the efficient use of land
The key issues to within the Local Plan in relation to this policy highlight that new
specialist need housing should be provided in new high density buildings. However,
this is not reflected in the policy wording.
The policy wording could usefully identify the need for developments to be high
density, if this is appropriate.
Gypsy and traveller sites are likely to be characterised by low density development,
which could lead to negative effects against this objective. However, there is only site
in the OPDC area. Any future site identified would need to meet the required number of
pitches, which would be in line with the regulations/guidance.
.
Student accommodation could be considered to be an efficient use of land as it is likely
to be high density.
The policy option is unlikely to noticeably affect the predicted effect of this policy
compared to the preferred option.
The policy seeks to deliver a significant number of houses within London, which is
likely to maximise the use of previously developed land and buildings, through the
implementation of this strategic policy.
The policy could have some benefits against this objective in that it seeks to bring
vacant dwellings back into use.
The policy option relates to housing numbers, which is unlikely to noticeably affect the
predicted effect of this policy compared to the preferred option.
The policy is unlikely to have an effect against achievements against this objective
77

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
remediation of
contaminated
land

Page 582

H3
Option
1
H4
H4
Option
1
H4
Option
2
H4
Option
3
H4
Option
4
H5

See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

H5
Option
1
H5
Option
2
H6

H6
Option
1
H7

H7
Option

directly.
The policy option relates to alternatives in the provision of housing types, which is
unlikely to noticeably affect the predicted effect of this policy compared to the preferred
option.
No preferred policy is provided for affordable housing in this iteration of the Local Plan.
See assessment of strategic options Table F-1 Affordable Housing Approaches

M, L-T, I, R,
M
M, L-T, I, R,
M
M, L-T, I, R,
M

OPDC area
OPDC area

OPDC area

The policy could have some benefits against this objective in that it seeks to bring
vacant dwellings back into use.
The policy option could have some benefits against this objective in that it seeks to
optimise development through the conversion of existing dwellings for other uses.
The policy option could have some benefits against this objective in that it seeks to
optimise development through the conversion of existing dwellings for other uses.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option is unlikely to have an effect against achievements against this
objective directly.

S, M, L-T, I,
R, L

S, M, L-T, I,
R, L

OPDC area
and Londonwide
OPDC area
and London-

Meeting an identified need for shared housing within the plan area is considered to be
an efficient use of land.
The option seeks to encourage the loss of shared housing which is not a way to
optimise the efficient use of land.
78

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

Page 583
9

Minimise the
need to travel,
improve
accessibility
for all users by
public and
non-motorised
transportation
methods and
mitigate
impacts on the
transport
network

1
H8

H9

S, M, L-T, I,
R, L

H10

S, M, L-T, I,
R, L

H10
Option
1
H1

S, M, L-T, I,
R, L

M, L-T, I, R,
M

H2

H2
Option
1

wide

+/-

H3

H3
Option
1

L-T, I, R, L

OPDC area
and Londonwide
OPDC area
and Londonwide
OPDC area
and Londonwide
OPDC area

OPDC area

The policy is unlikely to have an effect against achievements against this objective
directly.
Gypsy and traveller sites are likely to be characterised by low density development,
which could lead to negative effects against this objective. .
Student accommodation could be considered to be an efficient use of land as it is likely
to be high density.
The policy option is unlikely to noticeably affect the predicted effect of this policy
compared to the preferred option.
The policy specifically seeks the delivery of Lifetime Neighbourhoods. The principles
of Lifetime Neighbourhoods include the creation of walkable communities and
sustaining a diverse range of methods of transportation that enable people to get
around, especially by using public transport, or by other means if they cannot use this
9
type of service The implementation of this policy should lead to benefits against this
objective locally.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option relates to housing numbers, which is unlikely to noticeably affect the
predicted effect of this policy compared to the preferred option. However, the
implication of a higher provision of housing within the plan period could have
implications for infrastructure provision and increased construction impacts, which
could lead to negative effects against this objective. Nevertheless, construction traffic
impacts, unless not mitigated, will be managed and policies relating to this are
contained in the transport chapter.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option relates to alternatives in the provision of housing types, which is
unlikely to noticeably affect the predicted effect of this policy compared to the preferred
option.

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6248/2044122.pdf
79

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

Page 584

H4
H4
Option
1
H4
Option
2
H4
Option
3
H4
Option
4
H5

No preferred policy is provided for affordable housing in this iteration of the Local Plan.
See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

H5
Option
1
H5
Option
2
H6

+/-

M, L-T, I, R,
M

OPDC area

+/-

M, L-T, I, R,
M

OPDC area

H6
Option
1
H7

M, L-T, I, R,
M

OPDC area

S, M, L-T, I,
R, L

OPDC area
and Londonwide

H7
Option
1

The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option relates to alternatives in the provision of development types, which is
unlikely to noticeably affect the predicted effect of this policy compared to the preferred
option.
The policy option relates to alternatives in the provision of development types, which is
unlikely to noticeably affect the predicted effect of this policy compared to the preferred
option.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option is unlikely to have an effect against achievements against this
objective directly.
The policy seeks that new shared houses should be located in areas with high public
transport access and facilities and services. This could help to create benefits against
this objective.
This option could have a negative effect on the objective. The conversion or loss of
shared housing would remove this type of housing from supply and would not help
meet Londons housing demand. Despite the change in nature of accommodation type
this should not have an effect on public transport accessibility therefore the option
could lead to some benefits.
80

IIA Objective

Page 585

Improve
access to well
designed,
well-located,
market,
affordable and
inclusive
housing of a
range of types
and tenures,
to meet
identified local
needs

Performance
of Policy

Temporal
Scale
Nature of
Impact
M, L-T, I, R,
M

Geographical
Extent

Commentary and Recommendations

OPDC area

The policy seeks that new specialist housing should be located in areas with high
public transport access and facilities and services. This could help to create benefits
against this objective.
The policy seeks that any new gypsy and traveller sites should be accessible to
transport, services and facilities. This could help to create benefits against this
objective.
The policy requires that new student housing should be in accessible locations, which
could lead to some benefits against this objective.
The policy option is unlikely to noticeably affect the predicted effect of this policy
compared to the preferred option.

H8

H9

M, L-T, I, R,
M

OPDC area

H10

OPDC area

H10
Option
1
H1

M, L-T, I, R,
M
M, L-T, I, R,
M

++

L-T, D, R, L

OPDC area

OPDC area
and Londonwide

The delivery of a significant number of high quality dwellings, to meet Londons

housing needs, should lead to significant positive benefits against this objective. The
policy specifically requires a mix of housing types to meet a wide variety of needs,
whilst specifying that 90% of units must be accessible and adaptable and 10% of units
must be accessible to wheelchair users.
Details pertaining to what the housing needs will be within the area, in order to identify
whether these needs are being met within the housing policies, could be provided in
the supporting text. This may be implemented in the next stage of the Local Plan, once
the evidence-base studies are complete.

H2

++

L-T, D, R,
M

OPDC area
and Londonwide

H2
Option
1

+/-

M, L-T, D,
R, M

OPDC area
and Londonwide

It is unclear where the 10% of housing to meet building regulation M4(3) wheelchair
user dwellings has come from. Reference to the evidence-base for this proportion
could be usefully provided in the supporting text. If this is a standard requirement within
the building regulations, it is suggested that it need not be included within the policy
wording.
The policy should help the delivery of housing within the area, through the creation of
targets, promotion of development opportunities and conversion of existing buildings,
as well as through monitoring. The supporting text highlights that the conversion of
larger dwellings to smaller, more affordable dwellings, will contribute to the supply of
housing. This could create significant benefits against this objective.
Delivering a higher proportion of housing units within the plan period could lead to
housing needs being met at an earlier stage. However, potential impacts on viability
could lead to negative effects in deliverability, leading to the prediction of both positive
81

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
H3

H3
Option
1

Page 586

H4
H4
Option
1
H4
Option
2
H4
Option
3
H4
Option
4
H5

++

L-T, I, R, L

L-T, D, R, L

OPDC area

OPDC area
and Londonwide

and negative effects against this objective.

The policy could lead to the generation of significant benefits against this objective, in
that if will deliver a mix of housing to meet local needs, which could lead to the
generation of mixed, balanced and sustainable neighbourhoods.
It is suggested that bullet point 3 of the policy is unnecessary and provides repetition
that could be excluded.
The policy option would have similar effects to that assessed for the preferred option,
although effects may be less significant as, although the option could deliver a more
flexible range of unit types, these would not be designed to meet lifetime needs, and
thus may not meet all of the housing needs in the area.

No preferred policy is provided for affordable housing in this iteration of the Local Plan.
See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

M, L-T, I, R,
L

OPDC area

The policy could generate positive effects against this objective through the creation of
additional housing through the conversion of existing dwellings and other types of
buildings. However, the policy seeks to provide at least one family sized unit within
conversions. This should help to maintain a mix of housing, however, it is unclear
whether or not this proportion would meet local needs or not. As stated in the
supporting text for policy H3, housing mix and needs will be identified more clearly in
the next iteration of the local plan.
See recommendation under Objective 1. It is further recommended that repetition with
regards to housing mix is removed between housing policies H3 and H5. The policy
82

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

Page 587

H5
Option
1

+/-

M, L-T, I, R,
L

OPDC area

H5
Option
2
H6

+/-

M, L-T, I, R,
L

OPDC area

S, M, L-T, I,
R, L

H6
Option
1
H7

+/-

S, M, L-T, I,
R, L

S, M, L-T, I,
R, L

OPDC area
and Londonwide
OPDC area
and Londonwide
OPDC area
and Londonwide

H7
Option
1

S, M, L-T, I,
R, L

OPDC area
and Londonwide

H8

S, M, L-T, I,
R, L

OPDC area
and Londonwide

could seek to require that conversions of existing and vacant buildings include
provision for ensuring that the accessibility of buildings is brought up to the standard
required for new developments.
The policy option would allow the conversion of existing residential uses for nonresidential uses, which could lead to the loss of housing stock. This could lead to
negative effects against this objective. However, existing stock may be of
unsatisfactory standards; in inappropriate locations or of lower density. The loss of
such accommodation will only be negative if it is not replaced, and in instances where it
is replaced at higher density, it will have a positive impact.
The policy option may lead to negative effects against the provision of a mix of housing
to meet local needs through the loss of family accommodation. However, the loss of
smaller family homes could be to provide a single large family home.
The policy could lead to benefits against this objective as it seeks to support an
identified housing need in London.
In addition to the above, the requirements for all PRS proposals to sign up to the
London Rental Scheme could have impacts on deliverability, which could affect the
overall housing mix, which could lead to negative effects against this objective.
The policy could lead to some benefits against this objective as it seeks to support an
identified housing need in London. Supporting text indicates that where quality
concerns exist about existing shared houses, their loss to an alternative housing uses
will not be resisted or proposals to improve standards will be considered. This could
help to increase quality locally over time.
See second recommendation under Objective 1.
This option could have a negative effect on the objective. The conversion or loss of
shared housing would remove this type of housing from supply and would not help
meet Londons housing demand. The option could result in particular households being
unable to this form of affordable housing.
The policy could lead to benefits against this objective as it seeks to support an
identified housing need in London. Affordable housing is also sought within the policy,
for developments that include market led development aimed at older or vulnerable
people.
83

IIA Objective

Page 588

Improve
climate
change
adaptation and
mitigation,
including
minimising the
risk of flooding
and
addressing the
heat island
effect

Performance
of Policy

Temporal
Scale
Nature of
Impact
S, M, L-T, I,
R, L

H9

H10

S, M, L-T, I,
R, L

H10
Option
1
H1

S, M, L-T, I,
R, L

M, L-T, I, R,
L

H2

H2
Option
1

H3

H3
Option
1
H4
H4
Option
1
H4

L-T, I, R, L

Geographical
Extent

Commentary and Recommendations

OPDC area
and Londonwide

The policy could lead to benefits against this objective as it seeks to support an
identified housing need in London. The extent of how significant the potential benefits
will be will be dependent on the outcomes of the study, which will be included in the
next stage of the Local Plan. This may include the need to identify new sites for the
accommodation of gypsies and travellers.
The policy could lead to benefits against this objective as it seeks to support an
identified housing need in London. Specific requirements with regard to design are not
included within the policy.
The policy option is likely to have similar effects against the objective compared with
the preferred option, although these effects may be slightly less positive, as the option
does not allow for the flexible future use of the student accommodation.
The policy specifically refers to the need for developments to be flexible and adaptable
to accommodate future need, innovation and smart technologies. The supporting text
doesnt specify what these measures may include, but goes on to state that
development will need to cater for a wide variety of needs promoting consideration of
aspects such as natural lighting, ventilation and the efficient use of space. This could
lead to indirect benefits against this objective in terms of sustainable design.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option relates to housing numbers, which is unlikely to noticeably affect the
predicted effect of this policy compared to the preferred option. However, the
implication of a higher provision of housing within the plan period could have
implications for infrastructure provision and increased construction impacts, which
could lead to negative effects against this objective. Note that the Environment and
Utilities policies contain some measures to mitigate this.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option relates to alternatives in the provision of housing types, which is
unlikely to noticeably affect the predicted effect of this policy compared to the preferred
option.
No preferred policy is provided for affordable housing in this iteration of the Local Plan.
See assessment of strategic options Table F-1 Affordable Housing Approaches

OPDC area
and Londonwide
OPDC area
and Londonwide
OPDC area

OPDC area

See assessment of strategic options Table F-1 Affordable Housing Approaches

84

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
Option
2
H4
Option
3
H4
Option
4
H5

Page 589

H5
Option
1
H5
Option
2
H6
H6
Option
1
H7

See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

0
0

The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option is unlikely to have an effect against achievements against this
objective directly.

The policy option is unlikely to have an effect against achievements against this
objective directly.

The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option is unlikely to have an effect against achievements against this
objective directly.

H7
Option
1
H8

H9

H10

H10
Option

The policy is unlikely to have an effect against achievements against this objective
directly.
The option is unlikely to have an effect against this objective.

The policy is unlikely to have an effect against achievements against this objective
directly.
The policy is unlikely to have an effect against achievements against this objective
directly. Should new sites be proposed, the policy should seek that flood risk
minimisation measures are incorporated into the site.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy is unlikely to have an effect against achievements against this objective
directly.
85

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

The policy specifically refers to the need for developments to be flexible and adaptable
to accommodate future need, innovation and smart technologies. The supporting text
doesnt specify what these measures may include, but goes on to state that
development will need to cater for a wide variety of needs promoting consideration of
aspects such as natural lighting, ventilation and the efficient use of space. This could
lead to indirect benefits against this objective in terms of sustainable design.
The policy could lead to the increased delivery of housing which could have negative
effects against this objective, through an increase in the need for energy and transport.
However, design objectives could minimise this effect. However, the delivery phasing
and design of schemes will mitigate for the impact on climate change as will the use of
sustainable construction methods.
The policy option relates to housing numbers, which is unlikely to noticeably affect the
predicted effect of this policy compared to the preferred option. However, the
implication of a higher provision of housing within the plan period could have
implications for infrastructure provision and increased construction impacts, which
could lead to negative effects against this objective. However, be aware that the
policies in the transport chapter will require mitigation of construction impact.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option relates to alternatives in the provision of housing types, which is
unlikely to noticeably affect the predicted effect of this policy compared to the preferred
option.
No preferred policy is provided for affordable housing in this iteration of the Local Plan.
See assessment of strategic options Table F-1 Affordable Housing Approaches

Nature of
Impact
7

Page 590

To minimise
contributions
to climate
change
through
greater energy
efficiency,
generation
and storage;
and to reduce
reliance on
natural
resources
including fossil
fuels for
transport,
heating and
energy

1
H1

M, L-T, I, R,
L

OPDC area

H2

+/-

L-T, I, R, L

OPDC area

H2
Option
1

L-T, I, R, L

OPDC area

H3

H3
Option
1
H4
H4
Option
1
H4
Option
2
H4
Option
3
H4
Option

See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

86

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

OPDC area

The policy could have some benefits against this objective in that it seeks to optimise
existing housing stock through the conversion of existing dwellings to two or more
dwellings, which could reduce the embodied energy required compared with the
creation of new dwellings to meet the entire housing need. However, increased
pressure on local infrastructure through an intensification of the population, could lead
to negative effects on resource requirements. However, the policy seeks to minimise
this effect through requiring that conversions do not result in cumulative stress on
services and would not result in an adverse impact on parking or other local amenities.

Nature of
Impact
4
H5

+/-

M, L-T, I, R,
M

Page 591

The policy could seek to require that conversions of existing and vacant buildings
include provision for ensuring that the energy efficiency of buildings is brought up to the
standard required for new developments.
The policy option relates to alternatives in the provision of development types, which is
unlikely to noticeably affect the predicted effect of this policy compared to the preferred
option.
The policy option relates to alternatives in the provision of development types, which is
unlikely to noticeably affect the predicted effect of this policy compared to the preferred
option.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option is unlikely to have an effect against achievements against this
objective directly.

H5
Option
1
H5
Option
2
H6

+/-

M, L-T, I, R,
M

OPDC area

+/-

M, L-T, I, R,
M

OPDC area

H6
Option
1
H7

L-T, I, IR, L

OPDC area
and Londonwide

The policy seeks that new shared houses are located in areas with good access to
public transport and services and facilities, which could help to provide some benefits
against this objective in relation to reducing the need to travel and thus reducing the
impacts from new development on the emissions of greenhouse gases.
The option is unlikely to have an effect against this objective.

L-T, I, IR, L

OPDC area
and Londonwide

The policy seeks that new specialist housing is located in areas with good access to
public transport and services and facilities, which could help to provide some benefits
against this objective in relation to reducing the need to travel and thus reducing the
impacts from new development on the emissions of greenhouse gases.

H7
Option
1
H8

87

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

Page 592

To minimise
production of
waste across
all sectors in
the plan area,
maximise
efficiencies for
transporting
waste and
increasing
rates of reuse, recycling
and recovery
rates as well
as composting
of all green
waste

H9

M, L-T, I, R,
M

OPDC area

H10

OPDC area

H10
Option
1
H1

M, L-T, I, R,
M
M, L-T, I, R,
M

+/-

L-T, I, R, L

OPDC area

H2

+/-

L-T, I, R, L

OPDC area

H2
Option
1

+/-

L-T, I, R, L

OPDC area

H3

H3
Option
1
H4
H4
Option
1
H4
Option

OPDC area

It is recommended that high quality design aspects also specify the need for energy
efficient design, which should help to reduce the cost of living for older people and
improve their health.
The policy seeks that any new gypsy and traveller sites should be accessible to
transport, services and facilities. This could help to create benefits against this
objective.
The policy requires that new student housing should be in accessible locations, which
could lead to some benefits against this objective.
The policy option is unlikely to noticeably affect the predicted effect of this policy
compared to the preferred option.
The delivery of a significant number of houses within the area is likely to have negative
implications for the creation of waste. This may be partly mitigated by the policies
encouraging recycling.
The policy could lead to the increased delivery of housing which could have negative
effects against this objective, through an increase in the need for natural resources and
the creation of waste. However, design objectives could minimise this effect.
The policy option relates to housing numbers, which is unlikely to noticeably affect the
predicted effect of this policy compared to the preferred option. However, the
implication of a higher provision of housing within the plan period could have
implications for infrastructure provision and increased construction impacts, which
could lead to negative effects against this objective. Note that other policies in the
construction sections of the plan could help to mitigate this.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option is unlikely to have an effect against achievements against this
objective directly.
No preferred policy is provided for affordable housing in this iteration of the Local Plan.
See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

88

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
2
H4
Option
3
H4
Option
4
H5

See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

+/-

M, L-T, I, R,
M

OPDC area

Page 593
H5
Option
1
H5
Option
2
H6

+/-

M, L-T, I, R,
M

OPDC area

+/-

M, L-T, I, R,
M

OPDC area

H6
Option
1
H7

H7
Option
1
H8

The policy could have some benefits against this objective in that it seeks to optimise
existing housing stock through the conversion of existing dwellings to two or more
dwellings, which could reduce the waste generated during construction activities.
However, increased pressure on local infrastructure through an intensification of the
population, could lead to negative effects on resource requirements. The policy seeks
to minimise this effect through requiring that conversions do not result in cumulative
stress on services and would not result in an adverse impact local amenities.
The policy could add a requirement that conversions do not result in cumulative stress
on the local environment, including pollution levels such as air, noise and light pollution
as well as the potential impact on biodiversity, land quality and water quality.
The policy option relates to alternatives in the provision of development types, which is
unlikely to noticeably affect the predicted effect of this policy compared to the preferred
option.
The policy option relates to alternatives in the provision of development types, which is
unlikely to noticeably affect the predicted effect of this policy compared to the preferred
option.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option is unlikely to have an effect against achievements against this
objective directly.

The policy is unlikely to have an effect against achievements against this objective
directly.
The option is unlikely to have an effect against this objective.

The policy is unlikely to have an effect against achievements against this objective
89

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

Improve the
quality of the
water
environment

directly.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option is unlikely to have an effect against achievements against this
objective directly.

Page 594

H9

H10

H10
Option
1
H1

+/-

L-T, I, R, L

OPDC area

H2

+/-

L-T, I, R, L

OPDC area

H2
Option
1

M, L-T, I, R,
L

OPDC area

H3

H3
Option
1
H4
H4
Option
1
H4
Option
2
H4
Option

The delivery of a significant number of houses within the area is likely to have negative
implications for the natural environment through a potential increase in polluted runoff
and increase demand for natural resources. However, design objectives could
minimise this effect see water management policies.
The policy could lead to the increased delivery of housing which could have negative
effects against this objective, through an increase in the need for natural resources.
However, design objectives could minimise this effect see water management
policies.
The policy option relates to housing numbers, which is unlikely to noticeably affect the
predicted effect of this policy compared to the preferred option. However, the
implication of a higher provision of housing within the plan period could have
implications for infrastructure provision and increased construction impacts, which
could lead to negative effects against this objective.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option is unlikely to have an effect against achievements against this
objective directly.
No preferred policy is provided for affordable housing in this iteration of the Local Plan.
See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

90

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
3
H4
Option
4
H5

See assessment of strategic options Table F-1 Affordable Housing Approaches

Page 595

+/-

M, L-T, I, R,
M

OPDC area

H5
Option
1
H5
Option
2
H6

+/-

M, L-T, I, R,
M

OPDC area

+/-

M, L-T, I, R,
M

OPDC area

H6
Option
1
H7

H7
Option
1
H8
H9

The policy could have some benefits against this objective in that it seeks to optimise
existing housing stock through the conversion of existing dwellings to two or more
dwellings, which could reduce the pollution generated during construction activities.
However, increased pressure on local infrastructure through an intensification of the
population, could lead to negative effects on resource requirements and potential
pollution. The policy seeks to minimise this effect through requiring that conversions do
not result in cumulative stress on services and would not result in an adverse impact
local amenities.
See recommendation under Objective 8.
The policy option relates to alternatives in the provision of development types, which is
unlikely to noticeably affect the predicted effect of this policy compared to the preferred
option.
The policy option relates to alternatives in the provision of development types, which is
unlikely to noticeably affect the predicted effect of this policy compared to the preferred
option.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option is unlikely to have an effect against achievements against this
objective directly.

The policy is unlikely to have an effect against achievements against this objective
directly.
The option is unlikely to have an effect against this objective.

The policy is unlikely to have an effect against achievements against this objective
directly.
The policy seeks that any new gypsy and traveller sites should be capable of
connecting to utilities infrastructure and services. This could help to create benefits
against this objective. Access to utilities at the current site in Ealing is unknown.

M, L-T, I, R,
M

OPDC area

91

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

10

Page 596

Create and
enhance
biodiversity
and the
diversity of
habitats
across the
area and its
surroundings

The policy could include a requirement for the improvement of connections to services
and facilities including utilities to the existing site, should this be necessary. Detail
relating to this could be included in the supporting text.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option is unlikely to have an effect against achievements against this
objective directly.

H10

H10
Option
1
H1

L-T, I, R, L

OPDC area

H2

L-T, I, R, L

OPDC area

H2
Option
1

M, L-T, I, R,
L

OPDC area

H3

H3
Option
1
H4
H4
Option
1
H4
Option
2
H4
Option

The delivery of a significant number of houses within the area is likely to have negative
implications for the natural environment through a potential increase in polluted runoff
and increase demand for natural resources. However, design objectives could
minimise this effect.
The policy could lead to the increased delivery of housing which could have negative
effects against this objective, through an increase in the need for natural resources.
However, design objectives could minimise this effect.
The policy option relates to housing numbers, which is unlikely to noticeably affect the
predicted effect of this policy compared to the preferred option. However, the
implication of a higher provision of housing within the plan period could have
implications for infrastructure provision and increased construction impacts, which
could lead to negative effects against this objective. Note that the GI policies in the
Environment and Utilities chapter may help to mitigate this.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option is unlikely to have an effect against achievements against this
objective directly.
No preferred policy is provided for affordable housing in this iteration of the Local Plan.
See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

92

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
3
H4
Option
4
H5

Page 597
11

To minimise
air, noise and
light pollution,

See assessment of strategic options Table F-1 Affordable Housing Approaches

H5
Option
1
H5
Option
2
H6

+/-

M, L-T, I, R,
M

OPDC area

+/-

M, L-T, I, R,
M

OPDC area

H6
Option
1
H7

H7
Option
1
H8

H9

H10

H10
Option
1
H1

The policy is unlikely to have an effect against achievements against this objective
directly.
The option is unlikely to have an effect against this objective.

+/-

The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option relates to alternatives in the provision of development types, which is
unlikely to noticeably affect the predicted effect of this policy compared to the preferred
option.
The policy option relates to alternatives in the provision of development types, which is
unlikely to noticeably affect the predicted effect of this policy compared to the preferred
option.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option is unlikely to have an effect against achievements against this
objective directly.

The policy is unlikely to have an effect against achievements against this objective
directly.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option is unlikely to have an effect against achievements against this
objective directly.
M, L-T, I, R,
M

OPDC area

The delivery of a significant number of houses within the area is likely to have negative
implications for the natural environment through a potential increase in polluted runoff
and increase demand for natural resources. However, design objectives could
minimise this effect. The policy specifically seeks the delivery of Lifetime
93

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
particularly for
vulnerable
groups

Page 598
10

H2

L-T, I, R, L

OPDC area

H2
Option
1

L-T, I, R, L

OPDC area

H3

H3
Option
1
H4
H4
Option
1
H4
Option
2
H4
Option
3
H4
Option
4

Neighbourhoods. The principles of Lifetime Neighbourhoods include the creation of

walkable communities and sustaining a diverse range of methods of transportation that
enable people to get around, especially by using public transport, or by other means if
10
they cannot use this type of service The implementation of this policy should lead to
benefits against this objective locally. In addition, some indirect effects through high
quality design measures, may also lead to some benefits.
The policy could lead to the increased delivery of housing which could have negative
effects against this objective, through an increase in noise and pollution. However,
design objectives could minimise this effect including via policies in other chapters.
The policy option relates to housing numbers, which is unlikely to noticeably affect the
predicted effect of this policy compared to the preferred option. However, the
implication of a higher provision of housing within the plan period could have
implications for infrastructure provision and increased construction impacts, which
could lead to negative effects against this objective.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option relates to alternatives in the provision of housing types, which is
unlikely to noticeably affect the predicted effect of this policy compared to the preferred
option.
No preferred policy is provided for affordable housing in this iteration of the Local Plan.
See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6248/2044122.pdf
94

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
H5

The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option relates to alternatives in the provision of development types, which is
unlikely to noticeably affect the predicted effect of this policy compared to the preferred
option.
The policy option relates to alternatives in the provision of development types, which is
unlikely to noticeably affect the predicted effect of this policy compared to the preferred
option.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option is unlikely to have an effect against achievements against this
objective directly.

Page 599

H5
Option
1
H5
Option
2
H6

+/-

M, L-T, I, R,
M

OPDC area

+/-

M, L-T, I, R,
M

OPDC area

H6
Option
1
H7

L-T, I, IR, L

OPDC area
and Londonwide

The policy seeks that new shared houses are located in areas with good access to
public transport and services and facilities, which could help to provide some benefits
against this objective in relation to reducing the need to travel and thus reducing the
impacts from new development on local pollution levels.
The option is unlikely to have an effect against this objective.

The policy seeks that new specialist housing is located in areas with good access to
public transport and services and facilities, which could help to provide some benefits
against this objective in relation to reducing the need to travel and thus reducing the
impacts from new development on local pollution levels.
The policy seeks that any new gypsy and traveller sites should be accessible to
transport, services and facilities. This could help to create benefits against this
objective.

H7
Option
1
H8

L-T, I, IR, L

OPDC area
and Londonwide

H9

M, L-T, I, R,
M

OPDC area

H10

M, L-T, I, R,
M

OPDC area

H10

M, L-T, I, R,

OPDC area

The policy requires that new student housing should be in accessible locations, which
could lead to some benefits against this objective through a potential reduction in an
increase in vehicular transport. Further, the requirement for consideration of the
potential impact on the immediate and surrounding area and residential amenity, could
help to reduce potential impacts from noise, air and light pollution.
The policy option is unlikely to noticeably affect the predicted effect of this policy
95

IIA Objective

12

To conserve
and enhance
the historic
environment,
heritage
assets and
their settings

Performance
of Policy

Option
1
H1

Temporal
Scale

Geographical
Extent

Nature of
Impact
M

compared to the preferred option.

Page 600

+/-

L-T, I, R, L

OPDC area

H2

L-T, I, R, L

OPDC area

H2
Option
1
H3

M, L-T, I,
IR, L

M, L-T, I,
IR, L

OPDC area
and
surrounding
boroughs
OPDC area
and
surrounding
boroughs

H3
Option
1
H4
H4
Option
1
H4
Option
2
H4
Option
3
H4
Option
4
H5

Commentary and Recommendations

The delivery of a significant number of houses within the area is likely to have negative
implications for the historic environment through a significant change in the setting of
the local area. However, the design and heritage policies could minimise this effect.
The policy could lead to the increased delivery of housing which could have negative
implications for the historic environment through a significant change in the setting of
the local area. However, the design and heritage policies could minimise this effect.
The policy option is unlikely to have an effect against achievements against this
objective directly.
The policy could lead to benefits against this objective, in that new housing will need to
take into consideration the local character of the site and its ability to accommodate a
mix of housing types and sizes.
The policy option is likely to generate similar effects to the preferred option.

No preferred policy is provided for affordable housing in this iteration of the Local Plan.
See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

M, L-T, I,
IR, L

OPDC area
and
surrounding

The policy seeks to ensure that conversions of existing buildings maintain the general
character of the surrounding area. This could help to ensure that effects on the historic
environment are minimised.
96

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

Page 601
13

Increase
community
cohesion and
reduce social

H5
Option
1
H5
Option
2
H6

+/-

M, L-T, I, R,
M

+/-

M, L-T, I, R,
M

H6
Option
1
H7

boroughs
OPDC area

OPDC area

H7
Option
1
H8

H9

H10

H10
Option
1
H1

The policy is unlikely to have an effect against achievements against this objective
directly.
The option is unlikely to have an effect against this objective.

++

The policy option relates to alternatives in the provision of development types, which is
unlikely to noticeably affect the predicted effect of this policy compared to the preferred
option.
The policy option relates to alternatives in the provision of development types, which is
unlikely to noticeably affect the predicted effect of this policy compared to the preferred
option.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option is unlikely to have an effect against achievements against this
objective directly.

M, L-T, I,
IR, L

OPDC area
and
surrounding
boroughs

The policy is unlikely to have an effect against achievements against this objective
directly. Supporting text indicates that new development should take into account the
location and character of the area. However, this is not reflected in the policy wording.
Proposals for new gypsy and traveller sites could impact on the local historic
environment. However, whether there is a need for new sites is currently unknown until
the outcomes of the study are published. This could be included in the policy wording
as a consideration.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option is unlikely to have an effect against achievements against this
objective directly.

M, L-T, I, R,
M

OPDC area

The policy specifically seeks the delivery of Lifetime Neighbourhoods. The principles
of Lifetime Neighbourhoods include the creation of a number of features, which could
have significant positive effects in relation to this objective. These measures includes
requirements relating to: resident empowerment; access; the provision of a range of
services and amenities; accessible greenspace; opportunities to enhance social
97

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
exclusion to
encourage a
sense of
community
and welfare

Page 602
11

H2

M, L-T, I, R,
L

OPDC area

H2
Option
1

L-T, I, R, L

OPDC area

H3

++

L-T, I, R, L

OPDC area

H3
Option
1
H4
H4
Option
1
H4
Option
2
H4
Option

M, L-T, I, R,
M

OPDC area

networks and wellbeing; and the meeting of inclusive design principles. Specific
requirements relating to social networks include: Informal/formal opportunities and
activities (social, learning/training, volunteering), where people feel safe and confident
and which respect and reflect the needs of different ages, cultures and ethnicities. 11
Adherence to these principles should ensure that the provision of opportunities reflects
the diversity of the local area and the incoming population.
The policy may lead to the generation of benefits against this objective, as it seeks to
promote the re-use of vacant dwellings. This could help to enhance sense of
community wellbeing as vacant dwellings could engender a sense of local decline and
anti-social behaviour through reduced sense of community ownership.
The policy option relates to housing numbers, which is unlikely to noticeably affect the
predicted effect of this policy compared to the preferred option. However, the
implication of a higher provision of housing within the plan period could have
implications for infrastructure provision and increased construction impacts, which
could lead to negative effects against this objective.
The policy could lead to the generation of benefits against this objective, in that if will
deliver a mix of housing to meet local needs, which could lead to the generation of
mixed, balanced and sustainable neighbourhoods. This could generated significant
benefits against this objective, through the potential creation of greater social equity
through reducing geographical inequalities.
The policy option relates to alternatives in the provision of housing types, which,
although could offer a more flexible range of unit types compared with the preferred
policy option, is unlikely to meet local needs as significantly.
No preferred policy is provided for affordable housing in this iteration of the Local Plan.
See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6248/2044122.pdf
98

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
3
H4
Option
4
H5

See assessment of strategic options Table F-1 Affordable Housing Approaches

M, L-T, I,
IR, L

OPDC area

Page 603

H5
Option
1
H5
Option
2

M, L-T, I, R,
L

OPDC area

M, L-T, I, R,
L

OPDC area

H6

S, M, L-T, I,
R, L

OPDC area
and Londonwide

+/-

S, M, L-T, I,
R, L

OPDC area
and Londonwide

S, M, L-T, I,
R, L

OPDC area
and Londonwide

H6
Option
1

H7

The policy may lead to the generation of benefits against this objective, as it seeks to
promote the re-use of vacant dwellings. This could help to enhance sense of
community wellbeing as vacant dwellings could engender a sense of local decline and
anti-social behaviour through reduced sense of community ownership. Further, the
policy seeks that conversions of existing dwellings maintain the amenity of neighbours,
the general character of the surrounding area, and do not result in the cumulative
stress on services.
The policy could be reworded to seek that the conversion of existing dwellings and
vacant buildings seeks to enhance the amenity of the local community, as opposed to
seeking a minimal effect.
The policy option would allow the conversion of existing residential uses for nonresidential uses, which could lead to the loss of housing stock. This could lead to
negative effects against this objective.
The policy option may lead to negative effects against the provision of a mix of housing
to meet local needs through the loss of family accommodation. This could also lead to
negative effects against this objective through a reduction in the mix of the community
and resulting potential negative effects to the generation of inequalities.
The policy could lead to some benefits against this objective as it seeks to support an
identified housing need in London, which could help to reduce inequalities and provide
benefits against this objective to some degree. A requirement to ensure that
developments are of a high standard of design, which is managed, should also seek to
benefit this objective to some degree.
In addition to the above, the policy option could have benefits for the creation of more
sustainable communities through leading to positive impacts for the residents.
However, the requirements for all PRS proposals to sign up to the London Rental
Scheme could have impacts on deliverability, which could affect the overall housing
mix, which could lead to negative effects against this objective.
The policy could lead to some benefits against this objective as it seeks to support an
identified housing need in London. A requirement to ensure that developments meet
relevant quality standards are located in areas with good public transport accessibility
99

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
and facilities, could also lead to benefits against this objective. Further, new shared
houses should not give rise to unacceptable impacts on amenity.

H7
Option
1

Page 604

S, M, L-T, I,
R, L

OPDC area
and Londonwide

H8

++

S, M, L-T, I,
R, L

OPDC area
and Londonwide

H9

S, M, L-T, I,
R, L

OPDC area
and
surrounding
boroughs

H10

S, M, L-T, I,
R, L

OPDC area
and Londonwide

H10
Option
1

S, M, L-T, I,
R, L

OPDC area
and Londonwide

See first recommendation under Objective 1.

This option could have a negative effect on the objective. The conversion or loss of
shared housing would remove this type of housing from supply and would not help
meet Londons housing demand. The shortage of available affordable housing and
more non-affordable self-contained accommodation may alienate certain groups and
create unrest in the community.
The policy could lead to some benefits against this objective as it seeks to support an
identified housing need in London. A requirement to ensure that developments meet
relevant quality standards are located in areas with good public transport accessibility
and facilities, could also lead to benefits against this objective. Significant positive
effects may be achieved through a requirement that accessible social networks are
appropriate to the needs of the intended occupiers.
The policy seeks to ensure that any new sites are accessible to services and facilities,
and local social infrastructure. This could provide some benefits against this objective.
The policy could usefully consider the potential integration of new sites within the
surrounding community, as part of the assessment of impacts.
The policy could lead to some benefits against this objective as it seeks to support an
identified housing need in London. The policy seeks to ensure that the development of
student accommodation does not lead to an over-concentration of student
accommodation in a particular location. In addition, proposals should not have an
unacceptable impact on the immediate and surrounding areas, including residential
amenity. Sites should be in accessible locations and not lead to the net loss of other
forms of housing. These measures should ensure that a sense of place and community
is maintained, although will not necessarily contribute towards the creation of more
cohesive communities.
See recommendations under objective 1.
The policy option is unlikely to noticeably affect the predicted effect of this policy
compared to the preferred option.
100

IIA Objective

14

Improve safety
and reduce
crime and the
fear of crime

Performance
of Policy

Temporal
Scale
Nature of
Impact
M, L-T, I, R,
M

Geographical
Extent

Commentary and Recommendations

OPDC area

The policy specifically seeks the delivery of Lifetime Neighbourhoods. The principles
of Lifetime Neighbourhoods include the creation of a number of features. These
measures includes requirements relating to: resident empowerment; access; the
provision of a range of services and amenities; accessible greenspace; opportunities to
enhance social networks and wellbeing; and the meeting of inclusive design principles.
These measures could lead to an increase in natural surveillance and general feeling
of community, which could create positive indirect benefits against this objective.
The policy may lead to the generation of benefits against this objective, as it seeks to
promote the re-use of vacant dwellings. This could help to enhance sense of
community wellbeing as vacant dwellings could engender a sense of local decline and
anti-social behaviour through reduced sense of community ownership.
Secure by design policies implemented for housing development will mitigate for the
fear of crime and improve safety.

Page 605

H1

H2

M, L-T, I, R,
L

OPDC area

H2
Option
1
H3

L-T, I, R, L

OPDC area

L-T, I, R, L

OPDC area

H3
Option
1

M, L-T, I, R,
L

OPDC area

H4
H4
Option
1
H4
Option
2
H4
Option
3
H4
Option

The policy could lead to the generation of some benefits against this objective, in that if
will deliver a mix of housing to meet local needs, which could lead to the generation of
mixed, balanced and sustainable neighbourhoods. This could generate benefits
against this objective, through the potential creation of greater social equity through
reducing geographical inequalities.
The policy option relates to alternatives in the provision of housing types, which,
although could offer a more flexible range of unit types compared with the preferred
policy option, is unlikely to meet local needs as significantly, which may lead to less
benefits in relation to social equity.
No preferred policy is provided for affordable housing in this iteration of the Local Plan.
See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

101

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

The policy may lead to the generation of benefits against this objective, as it seeks to
promote the re-use of vacant dwellings. This could help to enhance sense of
community wellbeing as vacant dwellings could engender a sense of local decline and
anti-social behaviour through reduced sense of community ownership. Further, the
policy seeks that conversions of existing dwellings maintain the amenity of neighbours,
which could have some benefits.

Nature of
Impact
4
H5

Page 606

M, L-T, I,
IR, L

OPDC area

H5
Option
1
H5
Option
2
H6

M, L-T, I,
IR, L

OPDC area

M, L-T, I,
IR, L

OPDC area

S, M, L-T, I,
R, L

H6
Option
1

+/-

S, M, L-T, I,
R, L

OPDC area
and Londonwide
OPDC area
and Londonwide

H7

S, M, L-T, I,
R, L

OPDC area
and Londonwide

H7
Option
1

S, M, L-T, I,
R, L

OPDC area
and Londonwide

H8

See recommendation under objective 13.

The policy option relates to alternatives in the provision of development types, which is
unlikely to noticeably affect the predicted effect of this policy compared to the preferred
option.
The policy option relates to alternatives in the provision of development types, which is
unlikely to noticeably affect the predicted effect of this policy compared to the preferred
option.
The policy could lead to some benefits against this objective as it seeks to support an
identified housing need in London, which could help to reduce inequalities and provide
benefits against this objective to some degree.
In addition to the above, the policy option could have benefits for the creation of more
sustainable communities through leading to positive impacts for the residents.
However, the requirements for all PRS proposals to sign up to the London Rental
Scheme could have impacts on deliverability, which could affect the overall housing
mix, which could lead to negative effects against this objective.
The policy could lead to some benefits against this objective as it seeks to support an
identified housing need in London. A requirement to ensure that developments meet
relevant quality standards and are located in areas with good public transport
accessibility and facilities, could also lead to benefits against this objective. Further,
new shared houses should not give rise to unacceptable impacts on amenity, which
should help to reduce potential impacts on crime.
This option could have a negative effect on the objective. The conversion or loss of
shared housing to non-affordable accommodation may increase the possibility of
crime.
The policy is unlikely to have an effect against achievements against this objective
directly.
102

IIA Objective

Performance
of Policy

H9

Page 607

15

Maximise the
health and
wellbeing of
the population,
reduce
inequalities in
health and
promote
healthy living

Temporal
Scale
Nature of
Impact
S, M, L-T, I,
R, L

H10

+/-

S, M, L-T, I,
R, L

H10
Option
1

+/-

S, M, L-T, I,
R, L

H1

++

M, L-T, I, R,
M

H2

M, L-T, I, R,
L

Geographical
Extent

Commentary and Recommendations

OPDC area
and
surrounding
boroughs

The policy seeks to ensure that any new sites are accessible to services and facilities,
and local social infrastructure. This could provide some benefits against this objective
through potentially reducing the potential for anti-social behaviour.

OPDC area
and
surrounding
boroughs
OPDC area
and
surrounding
boroughs
OPDC area

OPDC area

The policy could usefully consider the potential integration of new sites within the
surrounding community, as part of the assessment of impacts. This could help to
reduce a possible perception of fear of crime.
The introduction of student housing into the area could increase the potential for local
crime, as students can be targets for crime, as well as causing potential anti-social
behaviour. Ensuring a mix of housing in student areas could lead to the minimisation of
this potentially negative effect see supporting policy text.
The policy option is unlikely to noticeably affect the predicted effect of this policy
compared to the preferred option.

The policy specifically seeks the delivery of Lifetime Neighbourhoods. The principles
of Lifetime Neighbourhoods include the creation of a number of features, which could
have significant positive effects in relation to this objective. These measures includes
requirements relating to: resident empowerment; access; the provision of a range of
services and amenities; accessible greenspace; opportunities to enhance social
networks and wellbeing; and the meeting of inclusive design principles. In addition, the
supporting text to the policy indicates that the policy requirement for developments to
be flexible and adaptable to accommodate future need, innovation and smart
technologies refers to the need for developments to be reflective of the health impacts
of new housing. The supporting text refers to aspects such as natural lighting,
ventilation and the efficient use of space to be considered specifically, whilst
encouraging developers to consider positively the impact on mental and physical
health through the quality of housing provision.
The policy wording could specifically refer to the need for developments to be designed
with the health and wellbeing of residents in mind. Design measures might also include
measures such as high levels of thermal insulation and the provision of outside
space/green roofs for all residents.
The policy could lead to the generation of benefits against this objective, as it seeks to
promote the re-use of vacant dwellings. This could help to enhance sense of
103

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

H2
Option
1

L-T, I, R, L

OPDC area

H3

L-T, I, R, L

OPDC area

Page 608
H3
Option
1
H4
H4
Option
1
H4
Option

M, L-T, I, R,
L

OPDC area

community wellbeing and thus improvements in mental health, as vacant dwellings

could engender a sense of local decline and anti-social behaviour through reduced
sense of community ownership.
The policy option relates to housing numbers, which is unlikely to noticeably affect the
predicted effect of this policy compared to the preferred option. However, the
implication of a higher provision of housing within the plan period could have
implications for infrastructure provision and increased construction impacts, which
could lead to negative effects against this objective. Note construction policy in
transport chapter for mitigation measures. And environment chapter policies relation to
air quality.
The policy could lead to the generation of some benefits against this objective, in that if
will deliver a mix of housing to meet local needs, which could lead to the generation of
mixed, balanced and sustainable neighbourhoods. This could generate benefits
against this objective, through the potential creation of greater social equity through
reducing geographical inequalities, leading to potential benefits for mental health as
well as physical heath, through the provision of appropriate housing types. It is noted
that more details relating to housing mix will be provided at the next stage of the Local
Plans development, which could lead to more significant effects being generated
against this objective.
It is recommended that the next iteration of the Local Plan considers human health as
part of the mix of housing provision, through the consideration of design principles
alluded to in the supporting text provided for policy H1. It is suggested that the
requirements relating to housing mix within policies H1 and H3 are consolidated into
the same policy.
The policy option relates to alternatives in the provision of housing types, which,
although could offer a more flexible range of unit types compared with the preferred
policy option, is unlikely to meet local needs as significantly, which may lead to less
benefits in relation to social equity.
No preferred policy is provided for affordable housing in this iteration of the Local Plan.
See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

104

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
2
H4
Option
3
H4
Option
4
H5

See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

M, L-T, I, R,
L

OPDC area

Page 609
H5
Option
1
H5
Option
2
H6

M, L-T, I, R,
L

OPDC area

M, L-T, I, R,
L

OPDC area

S, M, L-T, I,
R, L

H6
Option
1

+/-

S, M, L-T, I,
R, L

OPDC area
and Londonwide
OPDC area
and Londonwide

S, M, L-T, I,
R, L

H7

OPDC area
and London-

The policy could lead to the generation of benefits against this objective, as it seeks to
promote the re-use of vacant dwellings. This could help to enhance sense of
community wellbeing and thus improvements in mental health, as vacant dwellings
could engender a sense of local decline and anti-social behaviour through reduced
sense of community ownership. Further, the policy seeks that conversions of existing
dwellings maintain the amenity of neighbours, and do not result in the cumulative
stress on services. This could help to maintain existing health levels.
See recommendation under objective 13. The requirements for new development in
terms of requirements for improving mental and physical health should also be applied
to the conversion of existing and vacant dwellings, to seek that inequalities are not
exacerbated.
The policy option relates to alternatives in the provision of development types, which is
unlikely to noticeably affect the predicted effect of this policy compared to the preferred
option.
The policy option relates to alternatives in the provision of development types, which is
unlikely to noticeably affect the predicted effect of this policy compared to the preferred
option.
The policy could lead to some benefits against this objective as it seeks to support an
identified housing need in London, which could help to reduce inequalities and provide
benefits against this objective to some degree.
In addition to the above, the policy option could have benefits for the creation of more
sustainable communities through leading to positive impacts for the residents.
However, the requirements for all PRS proposals to sign up to the London Rental
Scheme could have impacts on deliverability, which could affect the overall housing
mix, which could lead to some negative effects against this objective.
The policy could lead to some benefits against this objective as it seeks to support an
identified housing need in London. A requirement to ensure that developments meet
105

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

wide

relevant quality standards are located in areas with good public transport accessibility
and facilities, could also lead to benefits against this objective. Further, new shared
houses should not give rise to unacceptable impacts on amenity, which could have
some benefits against this objective.

Nature of
Impact

H7
Option
1

S, M, L-T, I,
R, L

OPDC area
and Londonwide

S, M, L-T, I,
R, L

OPDC area
and Londonwide

H9

+/-

S, M, L-T, I,
R, L

OPDC area
and
surrounding
boroughs

H10

S, M, L-T, I,
R, L

OPDC area
and Londonwide

Page 610

H8

See first recommendation under Objective 1.

This option could have a negative effect on the objective. The conversion or loss of
shared housing would remove this type of housing from supply and would not help
meet Londons housing demand. Despite the change in nature of accommodation type
this should not have an effect on social infrastructure or public transport accessibility
therefore the option could lead to some benefits.
The policy could lead to some benefits against this objective as it seeks to support an
identified housing need in London. A requirement to ensure that developments are of a
high standard of design, and are accessible to public transport, shops, services,
community facilities and social networks, should seek to also benefit this objective to
some degree through a potential increase in walking to services and facilities, as well
as reduction in air pollution, which could provide health benefits.
See recommendation under Objective 7.
The policy could lead to the generation of health benefits for potential communities on
new sites, as the policy requires that new sites are supported by appropriate facilities,
layout and design quality to support health and wellbeing. However, the continued use
of the existing site could lead to long term health implications, as access improvements
to health facilities are described as limited in the supporting text.
The policy could lead to some benefits against this objective as it seeks to support
sites which are in accessible locations to public transport. However, the policy also
seeks to ensure the new student housing does not have an unacceptable impact on
residential amenity, which doesnt necessarily ensure the health and wellbeing of the
student communities.
It is recommended that the policy ensures that new student accommodation is
supported by an appropriate level of services and facilities, to meet the needs of the
students. This could also help to reduce impacts on residential amenity in a positive
way. The creation of new facilities and services might include sports facilities, which
106

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

16

Page 611
12

To improve
the education
and skills
levels of all
members of
the population,
particularly
vulnerable
groups

H10
Option
1
H1

S, M, L-T, I,
R, L

M, L-T, I, R,
L

H2

H2
Option
1

H3

H3
Option
1
H4
H4
Option
1
H4
Option
2

L-T, I, R, L

OPDC area
and Londonwide
OPDC area

OPDC area

could be shared locally.

The policy option is unlikely to noticeably affect the predicted effect of this policy
compared to the preferred option.
The policy specifically seeks the delivery of Lifetime Neighbourhoods. The principles
of Lifetime Neighbourhoods include the creation of a number of features. These
measures includes requirements relating to: resident empowerment; access; the
provision of a range of services and amenities; accessible greenspace; opportunities to
enhance social networks and wellbeing; and the meeting of inclusive design principles.
Specific requirements include: Informal/formal opportunities and activities (social,
learning/training, volunteering) 12 These measures may lead to some benefits against
this objectives in relation to learning opportunities.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option relates to housing numbers, which is unlikely to noticeably affect the
predicted effect of this policy compared to the preferred option. However, the
implication of a higher provision of housing within the plan period could have
implications for infrastructure provision and increased construction impacts, which
could lead to negative effects against this objective. However, the social infrastructure
policies may help mitigate this.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option relates to alternatives in the provision of housing types, which is
unlikely to noticeably affect the predicted effect of this policy compared to the preferred
option.
No preferred policy is provided for affordable housing in this iteration of the Local Plan.
See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6248/2044122.pdf
107

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
H4
Option
3
H4
Option
4
H5

Page 612
17

Maximise the

See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

H5
Option
1
H5
Option
2
H6

+/-

M, L-T, I, R,
M

OPDC area

+/-

M, L-T, I, R,
M

OPDC area

H6
Option
1
H7

H7
Option
1
H8

H9

H10

H10
Option
1
H1

The policy is unlikely to have an effect against achievements against this objective
directly.
The option is unlikely to have an effect against this objective.

The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option relates to alternatives in the provision of development types, which is
unlikely to noticeably affect the predicted effect of this policy compared to the preferred
option.
The policy option relates to alternatives in the provision of development types, which is
unlikely to noticeably affect the predicted effect of this policy compared to the preferred
option.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option is unlikely to have an effect against achievements against this
objective directly.

M, L-T, I, R,
L

OPDC area

M, L-T, I, R,

OPDC area

The policy is unlikely to have an effect against achievements against this objective
directly.
The policy requires that new gypsy and traveller site should be capable of support by
local social infrastructure. This could include education facilities, leading to potential
benefits against this objective.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option is unlikely to have an effect against achievements against this
objective directly.
The policy specifically seeks the delivery of Lifetime Neighbourhoods. The principles
108

IIA Objective

social and
economic
wellbeing of
the local and
regional
population and
improve
access to
employment
and training

Page 613
13

Performance
of Policy

Temporal
Scale

Geographical
Extent

Nature of
Impact
L

H2

H2
Option
1

H3

H3
Option
1
H4
H4
Option
1
H4
Option
2
H4
Option
3
H4
Option

L-T, I, R, L

OPDC area

Commentary and Recommendations

of Lifetime Neighbourhoods include the creation of a number of features. These

measures includes requirements relating to: resident empowerment; access; the
provision of a range of services and amenities; accessible greenspace; opportunities to
enhance social networks and wellbeing; and the meeting of inclusive design principles.
Specific requirements include: Informal/formal opportunities and activities (social,
learning/training, volunteering) 13 These measures may lead to some benefits against
this objectives in relation to learning opportunities.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option relates to housing numbers, which is unlikely to noticeably affect the
predicted effect of this policy compared to the preferred option. However, the
implication of a higher provision of housing within the plan period could have
implications for infrastructure provision and increased construction impacts, which
could lead to negative effects against this objective. Also, a larger number of homes
could increase the number of opportunities to employment and training.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy is unlikely to have an effect against achievements against this objective
directly.
No preferred policy is provided for affordable housing in this iteration of the Local Plan.
See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6248/2044122.pdf
109

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
4
H5
H5
Option
1
H5
Option
2
H6

Page 614

H6
Option
1
H7

18

To encourage
inward
investment
alongside
investment
within existing

The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option is unlikely to have an effect against achievements against this
objective directly.

The policy option is unlikely to have an effect against achievements against this
objective directly.

The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option is unlikely to have an effect against achievements against this
objective directly.

The policy is unlikely to have an effect against achievements against this objective
directly.
The option is unlikely to have an effect against this objective.

H7
Option
1
H8

H9

H10

H10
Option
1
H1

L-T, I, R, L

H2

L-T, I, R, L

The policy is unlikely to have an effect against achievements against this objective
directly.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option is unlikely to have an effect against achievements against this
objective directly.
OPDC area,
London-wide
and
nationally
OPDC area,
London-wide
and

The creation of high quality design and the meeting of housing needs may encourage
inward investment into the area indirectly through the attraction of a diverse workforce
through the creation of an area where people want to live.
The policy could increase the potential deliverability of housing in the area, which could
increase the attractiveness of the area to inward investors.
110

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
communities,
to create
sustainable
economic
growth

nationally
H2
Option
1
H3

Page 615

H3
Option
1
H4
H4
Option
1
H4
Option
2
H4
Option
3
H4
Option
4
H5
H5
Option
1
H5
Option
2
H6
H6
Option
1

The policy option is unlikely to have an effect against achievements against this
objective directly.

The policy is unlikely to have an effect against achievements against this objective
directly.
The policy is unlikely to have an effect against achievements against this objective
directly.

No preferred policy is provided for affordable housing in this iteration of the Local Plan.
See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

See assessment of strategic options Table F-1 Affordable Housing Approaches

0
0

The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option is unlikely to have an effect against achievements against this
objective directly.

The policy option is unlikely to have an effect against achievements against this
objective directly.

The policy is unlikely to have an effect against achievements against this objective
directly.
The policy option is unlikely to have an effect against achievements against this
objective directly.

111

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

Page 616

H7

H7
Option
1
H8

H9

H10

H10
Option
1

The policy is unlikely to have an effect against achievements against this objective
directly.
The option is unlikely to have an effect against this objective.

M, L-T, I, R,
L
M, L-T, I, R,
L

OPDC area,
London-wide
OPDC area,
London-wide

The policy is unlikely to have an effect against achievements against this objective
directly.
The policy is unlikely to have an effect against achievements against this objective
directly.
An increase in students in the area may attract local investment through the potential
for a highly skilled and potentially flexible workforce.
The policy option relates to alternatives in the provision of development types, which is
unlikely to noticeably affect the predicted effect of this policy compared to the preferred
option.

112

Table G-6 Chapter 8: Employment Policies and Policy Options

x E1: Strategic Policy: Delivering a diverse economy
x E2: Old Oak
x E3: Park Royal
x E4: Open workspaces
x E5: Local access to employment and training
IIA Objective

Performance of Temporal
Policy
Scale
Nature of
Impact
S, M, L-T, I,
R, M

Page 617

Geographical
Extent

Commentary and Recommendations

Old Oak and

Park Royal

The policy seeks to promote Old Oak and Park Royal as a place for enterprise and
innovation. The area possesses a diverse economic profile and the delivery of economic
growth through contribution to the delivery of a range of employment uses in areas
outside Strategic Industrial Locations (SIL) and a range of industrial uses within Park
Royal SIL would help to enhance the built environment and encourage place making.
The policy states that Old Oak would become a mixed employment hub through requiring
a range of flexible workspace typologies from proposals and town centre uses which
generate employment along the High Street, in and around Old Oak Common Station and
in other accessible locations. Supporting Old Oak to become a mixed employment hub
would help towards enhancing the built environment and encouraging placemaking.
The policy would not support focus on B1(a) uses around Old Oak Common Station
which would provide for a flexible approach to office distribution across Old Oak. This
would not greatly affect place-making compared to the preferred option.
The benefit of not focussing support on B1(b) and B1(c) uses in Old Oak north would be
that additional floorspace for non-industrial uses would be provided which would benefit
the built environment. However locations not suited to retail, office, leisure or residential
uses could remain vacant and could negatively impact upon the amenity of the public
realm which could also negatively impact upon placemaking.
The protection and enhancement of SIL and the support of adjacent uses and provision
for smaller units to support greater employment densities would make contributions
towards enhancing the built environment.
The option states that the SIL boundary would not be extended which would benefit the
delivery of non-industrial uses however not designating SIL appropriate sites could be
considered a lost opportunity to help support the continued success of Park Royal. The
policy would support the enhancement of the built environment though to a lesser extent
than the preferred option.
The option states that additional land would be released to accommodate other forms of
development which could help to support the enhancement of the built environment.
However, there would be increased pressure on industrial land capacity.

To enhance the E1
built environment
and encourage
place-making

E2

S, M, L-T, I,
R, M

Old Oak

E2
Option 1

S, M, L-T, I,
R, L

Old Oak

+/- S, M, L-T, I,
R, M

Old Oak

E2
Option 2

E3

S, M, L-T, I,
R, M

Park Royal

E3
Option 1

S, M, L-T, I,
R, M

Park Royal

+/- S, M, L-T, I,
R, M

Park Royal

E3
Option 2

113

IIA Objective

Performance of Temporal
Policy
Scale

E4

Page 618

To optimise the
efficient use of
land through
increased
development
densities and
building heights,
where
appropriate

Nature of
Impact
S, M, L-T, I,
R, M

Geographical
Extent

Commentary and Recommendations

OPDC area

E5

S, M, L-T, I,
R, L

OPDC area

E1

S, M, L-T, I,
R, L

Old Oak and

Park Royal

E2

Old Oak

E2
Option 1
E2
Option 2
E3

S, M, L-T, I,
R, L
N/A

The policy supports placemaking and the enhancement of the built environment as it
seeks to support proposals for affordable workspaces and open workspaces that protect
existing viable open workspace typologies and contribute to the wider regeneration of the
OPDC area.
Delivery of onsite open workspaces for residential and or/ commercial proposals would
provide a large range of employment workspace to support a diverse local economy
which in turn would also contribute towards placemaking. However, providing these
spaces without appropriate market assessment may result in them remaining vacant.
Delivery of small scale workspaces would contribute towards placemaking and the built
environment though on a slightly different scale compared to policies E4 and E4 Option 1.
There is a risk that if the employment or housing unit is vacant, then the joined unit would
also be vacant.
The policy primarily focuses on improving access to employment and training and it
seeks to provide physical access to jobs for local people which would help the area
become more defined and would contribute to placemaking.
Policy supports the establishment of new commercial hub and the consolidation and
intensification of Park Royal SIL, both of which aim to make the most efficient use the use
of land.
The policy seeks to provide a new commercial area and town centre uses.

Old Oak

There is no direct link with the policy and SA Objective.

N/A

Old Oak

There is no direct link with the policy and SA Objective.

Park Royal

S, M, L-T, I,
R, L
N/A

Park Royal

The policy requires proposals to demonstrate how they are maximising the use of sites in
Park Royal. This would support the objective.
There is no direct link with the policy and SA Objective.

N/A

Park Royal

There is no direct link with the policy and SA Objective.

S, M, L-T, I,
R, L

OPDC area

The policy focus is on the support of open workspace typologies and it seeks to support
proposals that make maximum use of their site and are appropriately located and
designed. This would support the objective.

E4
Option 1

+/- S, M, L-T, I,
R, M

OPDC area

E4
Option 2

+/- S, M, L-T, I,
R, M

OPDC area

E3
Option 1
E3
Option 2
E4

114

IIA Objective

Page 619
4

Maximise the
reuse of
previously
developed land
and existing
buildings,
including the
remediation of
contaminated
land

Minimise the
need to travel,

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
N/A

N/A

There is no direct link with the policy and SA Objective.

E4
Option 1
E4
Option 2
E5

N/A

N/A

There is no direct link with the policy and SA Objective.

N/A

N/A

There is no direct link with the policy and SA Objective.

E1

N/A

N/A

E2

N/A

N/A

E2
Option 1
E2
Option 2
E3

N/A

N/A

N/A

N/A

OPDC area

S, M, L-T, I,
R, L
N/A

N/A

N/A

S, M, L-T, I,
R, L

OPDC area

N/A

N/A

Development would be on previously developed land however this is not the focus of the
policy therefore effects against the SA Objective would be neutral.
Development would be on previously developed land however this is not the focus of the
policy therefore effects against the SA Objective would be neutral.
Development would be on previously developed land however this is not the focus of the
policy therefore effects against the SA Objective would be neutral.
Development would be on previously developed land however this is not the focus of the
policy therefore effects against the SA Objective would be neutral.
Part d requires proposals to demonstrate how they are maximising the use of the site.
This would support the objective.
Development would be on previously developed land however this is not the focus of the
policy therefore effects against the SA Objective would be neutral.
Development would be on previously developed land however this is not the focus of the
policy therefore effects against the SA Objective would be neutral.
The policy focus is on the support of open workspace typologies and it seeks to support
proposals that make maximum use of their site and are appropriately located and
designed. This would support the objective.
Development would be on previously developed land however this is not the focus of the
policy therefore effects against the SA Objective would be neutral.
Development would be on previously developed land however this is not the focus of the
policy therefore effects against the SA Objective would be neutral.
Development would be on previously developed land however this is not the focus of the
policy therefore effects against the SA Objective would be neutral.
The delivery of a range of employment uses in areas outside of the SIL and the delivery
of a range of industrial uses within Park Royals SIL would improve accessibility to jobs
and encourage transport links into the area.

E3
Option 1
E3
Option 2
E4

N/A

E4
Option 1
E4
Option 2
E5

N/A

N/A

N/A

N/A

E1

M, L-T, I, R, L Old Oak and

Park Royal

115

IIA Objective

improve
accessibility for
all users by
public and nonmotorised
transportation
methods and
mitigate impacts
on the transport
network

Page 620
5

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

E2

Nature of
Impact
M, L-T, I, R, L Old Oak

E2
Option 1

M, L-T, I, R, L Old Oak

E2
Option 2

M, L-T, I, R, L Old Oak

E3

M, L-T, I, R, L Park Royal

E3
Option 1
E3
Option 2
E4

N/A

N/A

The policy states that Old Oak will become a mixed employment hub and would require
proposals to provide town centre uses generating employment along the High Street, in
and around Old Oak Common Station and in other accessible locations. This would
contribute towards achieving the SA Objective through helping to improve accessibility to
employment.
The policy would not provide support for focussing B1(a) uses in and around Old Oak
Common Station and would contribute towards improving accessibility though to a lesser
extent than the preferred policy.
The policy would not provide support for B1(b) and B1(c) uses in Old Oak north and
would contribute towards improving accessibility though to a lesser extent than the
preferred policy.
The focus of the policy is the enhancement of SIL and it designates five new SIL sites
and in the long term this would improve accessibility to jobs and encourage transport
links into the area.
The policy does not directly link with the SA Objective.

N/A

N/A

The policy does not directly link with the SA Objective.

S, M, L-T, I, OPDC area

R, L
M, L-T, I, R, L OPDC area

E4
Option 1

E4
Option 2

M, L-T, I, R,
M

OPDC area

E5

OPDC area

Improve access E1
to well designed,
E2
well-located,

S, M, L-T, I,
R, L
N/A

N/A

N/A

N/A

Appropriate location of open workspace may make partial contributions to improving

accessibility though to a limited extent.
The delivery of onsite open workspace for residential and/or commercial proposals may
bring employment opportunities closer to residential areas and would make partial
contributions towards minimising the need to travel.
The delivery of small scale workspaces supported with coordinated delivery of rented
small scale residential units outside of the SIL would in the long term enable improve
accessibility. The delivery of workspaces that link with residential units would also help to
support the mitigation of impacts on the transport network with linked sites promoting
more sustainable travel.
The policy seeks to maximise access to employment and skills for local people and which
would indirectly support improved accessibility.
The focus of the policy is to deliver employment and industrial uses which will support
economic growth and therefore has no link with the SA Objective.
The policy seeks to enhance SIL and therefore has no link with the SA Objective.
116

IIA Objective

Performance of Temporal
Policy
Scale

E2
market,
affordable and Option 1
inclusive housing E2
Option 2
of a range of
E3
types and
tenures, to meet
identified local E3
Option 1
needs
E3
Option 2
E4

Page 621

E4
Option 1
E4
Option 2

Improve climate
change
adaptation and
mitigation,
including
minimising the
risk of flooding
and addressing
the heat island
effect

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
N/A

N/A

There is no direct link between the policy and the SA Objective.

N/A

N/A

There is no direct link between the policy and the SA Objective.

N/A

N/A

There is no direct link between the policy and the SA Objective.

N/A

N/A

There is no direct link between the policy and the SA Objective.

N/A

N/A

There is no direct link between the policy and the SA Objective.

N/A

N/A

There is no direct link between the policy and the SA Objective.

N/A

N/A

There is no direct link between the policy and the SA Objective.

+/- M, L-T, D, R, OPDC area

M

The policy would partly support the SA Objective as it seeks to deliver small scale
workspace with coordinated delivery of rented small residential units outside the SIL. The
policy would enable the delivery of a range of housing typologies which could help to
meet local needs. However, the disadvantage would be the risk that if one of the
employment or housing units is vacant, the related joined unit would also be vacant.
There is no direct link between the policy and the SA Objective.

E5

N/A

N/A

E1

N/A

N/A

The policy focuses on establishing Old Oak as a recognised employment hub,

consolidating SILs at Park Royal and supporting the delivery of economic growth. These
aims do not link with the SA Objective. It is also noted that there are no flood zones in Old
Oak.

E2

N/A

N/A

The primary focus of the policy has no direct link to the SA Objective.

E2
Option 1
E2
Option 2

N/A

N/A

The primary focus of the policy has no direct link to the SA Objective.

N/A

N/A

The primary focus of the policy has no direct link to the SA Objective.

117

IIA Objective

Performance of Temporal
Policy
Scale

Page 622
To minimise
contributions to
climate change
through greater
energy
efficiency,
generation and
storage; and to
reduce reliance
on natural
resources
including fossil
fuels for

Commentary and Recommendations

E3

Nature of
Impact
M, L-T, I, R, L Park Royal

E3
Option 1
E3
Option 2
E4

N/A

N/A

The policy focuses on enhancing SIL through demonstrating the use and design of sites
and will support the integrity and effectiveness of industrial sites. Flood zones in the
OPDC area and risk of flooding is associated with the river Brent. Elements of site
design, where located in a flood zones could also include adaptation measures which
could minimise flood risk.
Appropriate climate change mitigation and adaptation measures should be incorporated
where possible - as per Preferred Policy Option EU3:Water
The primary focus of the policy has no direct link to the SA Objective.

N/A

N/A

The primary focus of the policy has no direct link to the SA Objective.

N/A

N/A

The primary focus of the policy has no direct link to the SA Objective.

N/A

N/A

The primary focus of the policy has no direct link to the SA Objective.

N/A

N/A

The primary focus of the policy has no direct link to the SA Objective.

N/A

N/A

The primary focus of the policy has no direct link to the SA Objective.

E4
Option 1
E4
Option 2
E5
7

Geographical
Extent

E1

+/- M, L-T, I, R,
M

Old Oak and

Park Royal

E2

+/- M, L-T, I, R,
M

Old Oak

E2
Option 1
E2
Option 2

N/A

N/A

The consolidation of SIL at Park Royal and support of economic growth has the potential
to impact upon climate change through increased industrial activity in the long term
contribute to effects upon natural resources and fossil fuels use linked to industrial
activities if not managed through London Plan Policy and guidance within the
Environment and Utilities Chapter. Elements of site design could incorporate measures
such as energy efficiency which would help to minimise contributions to climate change.
The policy states that Old Oak will become a mixed employment hub which may
contribute to climate change if not managed through London Plan Policy and guidance
within the Environment and Utilities Chapter. .. Elements of site design could incorporate
measures such as energy efficiency which would help to minimise contributions to climate
change.
The primary focus of the policy has no direct link to the SA Objective.

N/A

N/A

The primary focus of the policy has no direct link to the SA Objective.
118

IIA Objective

transport,
heating and
energy

Performance of Temporal
Policy
Scale

E3

E3
Option 1
E3
Option 2
E4

Page 623

E4
Option 1
E4
Option 2
E5

E1
To minimise
production of
waste across all
sectors in the
plan area,
maximise
E2
efficiencies for
transporting
waste and
increasing rates
E2
of re-use,
Option 1

Nature of
Impact
+/- M, L-T, I, R,
M

Geographical
Extent

Commentary and Recommendations

Park Royal

N/A

N/A

The policy focuses on enhancing SIL through demonstrating the use and design of sites
which will support the integrity and effectiveness of industrial sites. Elements of site
design could incorporate measures such as energy efficiency which would help to
minimise contributions to climate change. The development of industry would however in
the long term contribute to effects upon natural resources and fossil fuels linked to
industrial activities if not managed through London Plan Policy and guidance within the
Environment and Utilities Chapter.
The primary focus of the policy has no direct link to the SA Objective.

N/A

N/A

The primary focus of the policy has no direct link to the SA Objective.

N/A

N/A

The primary focus of the policy has no direct link to the SA Objective.

N/A

N/A

The primary focus of the policy has no direct link to the SA Objective.

N/A

N/A

The primary focus of the policy has no direct link to the SA Objective.

M, L-T, I, R, L OPDC area

M, L-T, I, R, L OPDC area

M, L-T, I, R, L OPDC area

N/A

N/A

The primary focus of the policy is to improve access to employment and skills for local
people and improved accessibility could contribute towards reducing journey times thus
helping to minimise contributions to climate change.
The policy focuses on the promotion of Old Oak and Royal Park as a place for enterprise
and innovation and the focus on employment development could have implications for
increase in waste as well as opportunities for waste facilities and recycling. This would be
linked to building design and methods for transporting waste which are considered as per
Preferred Policy Option on Waste Minimisation and Preferred Strategic Policy for
Transport. However, this is uncertain.
The focus on the provision of workspaces and town centre uses could have implications
for increase in waste as well as opportunities for waste facilities and recycling. This would
be linked to building design and methods for transporting waste which are considered as
per Preferred Policy Option on Waste Minimisation and Preferred Strategic Policy for
Transport. However, this is uncertain.
There is no direct link between the policy and achieving the SA Objective.

119

IIA Objective

Performance of Temporal
Policy
Scale

E2
recycling and
recovery rates Option 2
E3
as well as
composting of all
green waste
E3
Option 1
E3
Option 2
E4

Page 624
9

Improve the
quality of the
water
environment

Geographical
Extent

Commentary and Recommendations

N/A

There is no direct link between the policy and achieving the SA Objective.

Nature of
Impact
N/A

M, L-T, I, R, L OPDC area

N/A

N/A

The policy focuses on enhancing SIL through demonstrating the use and design of sites
will support the integrity and effectiveness of industrial sites. Elements of site design
could incorporate waste or recycling facilities which would help to increase recycling rates
and waste recovery.
There is no direct link between the policy and achieving the SA Objective.

N/A

N/A

There is no direct link between the policy and achieving the SA Objective.

N/A

N/A

There is no direct link between the policy and achieving the SA Objective.

N/A

N/A

There is no direct link between the policy and achieving the SA Objective.

E4
Option 1
E4
Option 2
E5

N/A

N/A

There is no direct link between the policy and achieving the SA Objective.

N/A

N/A

There is no direct link between the policy and achieving the SA Objective.

E1

M, L-T, I, R, L Old Oak and

Park Royal

E2

M, L-T, I, R, L Old Oak

E2
Option 1
E2
Option 2
E3

N/A

N/A

N/A

N/A

M, L-T, I, R, L Park Royal

The primary focus on employment and industrial development could have implications for
increased water usage as well as opportunities to incorporate measures such as
Sustainable Urban Drainage Systems (SuDS). This would be linked to building design,
which is considered as part of Preferred Policy on Water. However, this is uncertain.
The primary focus on the provision of workspaces and town centre uses could have
implications for increased water usage as well as opportunities to incorporate measures
such as SuDS. Waste facilities and recycling. This would be linked to building design
however this is uncertain.
The principle of the policy has no direct link with improving the water quality of the
environment.
The principle of the policy has no direct link with improving the water quality of the
environment.
The policy focuses on enhancing SIL through demonstrating the use and design of sites
will support the integrity and effectiveness of industrial sites. Elements of site design
could potentially include design that incorporates measures such as SuDS.
120

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

E3
Option 1
E3
Option 2
E4

Page 625

10

Create and
enhance
biodiversity and
the diversity of
habitats across
the area and its
surroundings

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

E4
Option 1
E4
Option 2
E5

N/A

N/A

N/A

N/A

E1

M, L-T, I, R, L Old Oak and

Park Royal

E2

M, L-T, I, R, L Old Oak

E2
Option 1
E2
Option 2
E3

N/A

N/A

N/A

N/A

M, L-T, I, R, L Park Royal

N/A

N/A

N/A

N/A

N/A

N/A

E3
Option 1
E3
Option 2
E4

Sustainable water measures should be adopted where appropriate as per Preferred

Policy on Water.
The principle of the policy has no direct link with improving the water quality of the
environment.
The principle of the policy has no direct link with improving the water quality of the
environment.
There is no direct link between the policy and achieving the SA Objective.
The principle of the policy has no direct link with improving the water quality of the
environment.
The principle of the policy has no direct link with improving the water quality of the
environment.
The principle of the policy has no direct link with improving the water quality of the
environment.
The delivery of employment and industrial uses has the potential to positively impact
upon enhancing the diversity of habitats through landscape design though this would be
to a limited extent.
The provision of workspaces and town centre uses within Old Oak has the potential to
positively impact upon enhancing the diversity of habitats through landscape design
though this would be to a limited extent.
The principle of the policy has no direct link with creating and enhancing biodiversity and
the diversity of habitats.
The principle of the policy has no direct link with creating and enhancing biodiversity and
the diversity of habitats.
The delivery of SIL has the potential to positively impact upon enhancing the diversity of
habitats through landscape design though this would be to a limited extent.
The principle of the policy has no direct link with creating and enhancing biodiversity and
the diversity of habitats.
The principle of the policy has no direct link with creating and enhancing biodiversity and
the diversity of habitats.
The principle of the policy has no direct link with creating and enhancing biodiversity and
the diversity of habitats.
121

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
N/A

N/A

N/A

N/A

N/A

N/A

To minimise air, E1
noise and light
pollution,
E2
particularly for
vulnerable
groups
E2
Option 1
E2
Option 2
E3

M, L-T, I, R, L Old Oak and

Park Royal

M, L-T, I, R, L Old Oak

N/A

N/A

N/A

N/A

M, L-T, I, R, L Park Royal

E3
Option 1
E3
Option 2
E4

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

M, L-T, I, R, L Old Oak and

Park Royal

The principle of the policy has no direct link with creating and enhancing biodiversity and
the diversity of habitats.
The principle of the policy has no direct link with creating and enhancing biodiversity and
the diversity of habitats.
The principle of the policy has no direct link with creating and enhancing biodiversity and
the diversity of habitats.
The delivery of employment and industrial uses has the potential to minimise air, noise
and light pollution however this would be dependent upon appropriate design, which is
considered as part of Preferred Policy Options on Air Quality and Noise.
The provision of workspaces and town centre uses within Old Oak has the potential to
minimise air, noise and light pollution however this would be dependent upon appropriate
design, which is considered as part of Preferred Policy Options on Air Quality and Noise..
There is no direct link between the primary focus of the policy and minimising air, noise
and light pollution.
There is no direct link between the primary focus of the policy and minimising air, noise
and light pollution.
The delivery of SIL has the potential to minimise air, noise and light pollution however
this would be dependent upon appropriate design and implementation of Environment
and Utilities policies.
There is no direct link between the primary focus of the policy and minimising air, noise
and light pollution.
There is no direct link between the primary focus of the policy and minimising air, noise
and light pollution.
There is no direct link between the primary focus of the policy and minimising air, noise
and light pollution.
There is no direct link between the primary focus of the policy and minimising air, noise
and light pollution.
There is no direct link between the primary focus of the policy and minimising air, noise
and light pollution.
There is no direct link between the primary focus of the policy and minimising air, noise
and light pollution.
The delivery of employment and industrial uses has the potential to contribute towards
conserving the historic environment and protecting heritage assets and their setting

E4
Option 1
E4
Option 2
E5
11

Page 626

E4
Option 1
E4
Option 2
E5
12

To conserve and E1

122

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
enhance the
E2
historic
environment,
heritage assets
and their settings E2

M, L-T, I, R, L Old Oak

N/A

N/A

N/A

N/A

M, L-T, I, R, L Park Royal

N/A

N/A

N/A

N/A

S, M, L-T, I,
R, L

OPDC area

E4
Option 1

N/A

N/A

E4
Option 2

N/A

N/A

E5

N/A

N/A

E1

S, M, L-T, I,
R, L

OPDC area

Option 1
E2
Option 2
E3

Page 627

E3
Option 1
E3
Option 2
E4

13

Increase
community

through appropriate design in accordance with Preferred Policy Option for Heritage.
The provision of workspaces and town centre uses within Old Oak has the potential to
contribute towards conserving the historic environment and protecting heritage assets
and their setting through appropriate design in accordance with Preferred Policy Option
for Heritage, but this is uncertain at this stage.
The policy does not have direct links to conserving and enhancing the historic
environment, heritage assets and their settings.
The policy does not have direct links to conserving and enhancing the historic
environment, heritage assets and their settings.
The delivery of SIL has the potential to contribute towards conserving the historic
environment and protecting heritage assets and their setting through appropriate design
in accordance with Preferred Policy Option for Heritage, but this is uncertain at this
stage.
The policy seeks to enhance SIL and does have direct links to conserving and enhancing
the historic environment, heritage assets and their settings.
The policy seeks to enhance SIL and does have direct links to conserving and enhancing
the historic environment, heritage assets and their settings.
The policy seeks to support open workspace typologies that are appropriately located
and designed which could support the SA Objective through appropriate design that
respects its surrounding environment, helping to conserve heritage assets and their
setting.
The policy seeks to deliver onsite open workspaces for residential and/or commercial
though unlike the preferred option does not explicitly reference appropriate location and
design and therefore effects against the SA Objective would be uncertain.
The policy seeks to deliver small scale workplaces with coordinated delivery of rented
small-scale residential units outside of the SIL though unlike the preferred option does not
explicitly reference appropriate location and design and therefore effects against the SA
Objective would be uncertain.
The primary focus of the policy is to maximise access to employment and training
therefore it does not directly link with the SA Objective.
The policy principally seeks to establish Old Oak as a recognised employment hub and
seeks the delivery of a diverse economy that supports growth. This is considered to to
help achieve the SA Objective.
123

IIA Objective

cohesion and
reduce social
exclusion to
encourage a
sense of
community and
welfare

Page 628
14

Improve safety
and reduce
crime and the
fear of crime

Performance of Temporal
Policy
Scale
Nature of
Impact
S, M, L-T, I,
R, L

Geographical
Extent

Commentary and Recommendations

Old Oak

The policy states that Old Oak would become a mixed development hub with town centre
uses generating employment in accessible locations. In light of OPDC regeneration
programmes the policy would make partial contributions towards increasing community
cohesion.
The policy focus is a more flexible approach to office distribution across and would not
significantly contribute towards achieving the SA Objective.
The policy focus is on the provision of additional floor space not for industrial use which
would not significantly contribute towards achieving the SA Objective.
There is no direct link between the policy and increasing community cohesion, reducing
social exclusion or encouraging a sense of community and welfare.
There is no direct link between the policy and increasing community cohesion, reducing
social exclusion or encouraging a sense of community and welfare.
The policy would release additional land within Park Royal to accommodate other forms
of development which could have the potential to benefit community cohesion but this is
uncertain.
The policy focus is on the provision of open workspaces which doesnt not directly link
with the SA Objective.
The policy focus is on the provision of onsite workspaces which doesnt not directly link
with the SA Objective.
The policy focus is on the provision of small scale workspaces which doesnt not directly
link with the SA Objective.
The policy focus is on maximising access to employment, skills training, apprenticeships
and pre-employment support and the opportunity to provide pathways to employment
could indirectly support the SA Objective by encouraging community cohesion and
welfare.
Establishing Old Oak as a recognised employment hub would not directly link with
improving safety or reducing crime.
There is no direct link between the policy and improving safety, reducing crime and fear
of crime.
There is no direct link between the policy and improving safety, reducing crime and fear
of crime.
There is no direct link between the policy and improving safety, reducing crime and fear
of crime.

E2

E2
Option 1
E2
Option 2
E3

N/A

N/A

N/A

N/A

N/A

N/A

E3
Option 1
E3
Option 2

N/A

N/A

Park Royal

E4

S, M, L-T, I
R
L
N/A

N/A

E4
Option 1
E4
Option 2
E5

N/A

N/A

N/A

N/A

S, M, L-T, I,
R, L

OPDC area

E1

N/A

N/A

E2

N/A

N/A

E2
Option 1
E2
Option 2

N/A

N/A

N/A

N/A

124

IIA Objective

Page 629

15

Maximise the
health and
wellbeing of the
population,
reduce
inequalities in
health and
promote healthy
living

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

N/A

E3

Nature of
Impact
N/A

E3
Option 1
E3
Option 2
E4

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

E4
Option 1
E4
Option 2
E5

N/A

N/A

N/A

N/A

E1

S, M, L-T, I,
R, L

Old Oak and

Park Royal

E2

Old Oak

E2
Option 1
E2
Option 2
E3

S, M, L-T, I,
R, L
S, M, L-T, I,
R, L
S, M, L-T, I,
R, L
N/A

N/A

There is no direct link between the policy and improving safety, reducing crime and fear
of crime.
There is no direct link between the policy and improving safety, reducing crime and fear
of crime.
There is no direct link between the policy and improving safety, reducing crime and fear
of crime.
There is no direct link between the policy and improving safety, reducing crime and fear
of crime.
There is no direct link between the policy and improving safety, reducing crime and fear
of crime.
There is no direct link between the policy and improving safety, reducing crime and fear
of crime.
There is no direct link between the policy and improving safety, reducing crime and fear
of crime.
Whilst delivery of a diverse economy would not directly relate to health, the provision of
employment uses would ultimately secure jobs which would help contribute towards
maximising wellbeing.
Old Oak as a mixed use employment hub will ultimately provide employment and will
contribute towards maximising wellbeing.
The policy would ultimately secure employment which would contribute towards achieving
a sense of wellbeing among the population.
The policy would ultimately secure employment which would contribute towards achieving
a sense of wellbeing among the population.
There is no direct link between the policy and the SA Objective.

E3
Option 1
E3
Option 2
E4

N/A

N/A

There is no direct link between the policy and the SA Objective.

N/A

N/A

There is no direct link between the policy and the SA Objective.

S, M, L-T, I,
R, L

OPDC area

The provision of workspace typologies would not directly relate to health but would
ultimately create jobs and maximise wellbeing.

Old Oak
Old Oak

125

IIA Objective

16

Page 630

To improve the
education and
skills levels of all
members of the
population,
particularly
vulnerable
groups

Performance of Temporal
Policy
Scale

OPDC area

E4
Option 1
E4
Option 2
E5

E1

E2

N/A

N/A

There is no direct link between the policy and the SA Objective.

E2
Option 1
E2
Option 2
E3

N/A

N/A

There is no direct link between the policy and the SA Objective.

N/A

N/A

There is no direct link between the policy and the SA Objective.

N/A

N/A

There is no direct link between the policy and the SA Objective.

N/A

N/A

There is no direct link between the policy and the SA Objective.

N/A

N/A

There is no direct link between the policy and the SA Objective.

N/A

N/A

There is no direct link between the policy and the SA Objective.

N/A

N/A

There is no direct link between the policy and the SA Objective.

N/A

N/A

There is no direct link between the policy and the SA Objective.

++ S, M, L-T, I,
R, M

OPDC area

++ S, M, L-T, I,
R, M

Old Oak and

Park Royal

The policy seeks to maximise access to skills training, apprenticeships and preemployment support all of which would contribute towards improving the skills level of the
population.
The policy seeks to deliver a diverse economy through promoting Old Oak and Park
Royal as a place for enterprise and innovation which would contribute partially towards
achieving the SA Objective by maximising economic wellbeing.

E4
Option 1
E4
Option 2
E5

Maximise the
social and

Commentary and Recommendations

Nature of
Impact
S, M, L-T, I,
R, L
S, M, L-T, I,
R, L
S, M, L-T, I,
R, L
N/A

E3
Option 1
E3
Option 2
E4

17

Geographical
Extent

E1

+
+

N/A

The provision of onsite open workspace typologies would not directly relate to health but
would ultimately create jobs and maximise wellbeing.
The provision of small scale workspace typologies would not directly relate to health but
would ultimately create jobs and maximise wellbeing.
Maximising access to employment and training could have a positive effect on the
wellbeing of the population.
There is no direct link between the policy and the SA Objective.

OPDC area
OPDC area

126

IIA Objective

economic
wellbeing of the
local and
regional
population and
improve access
to employment
and training

Page 631
18

To encourage
inward
investment
alongside
investment

Performance of Temporal
Policy
Scale

E2

Nature of
Impact
++ M, L-T, I, R,
M

Geographical
Extent

Commentary and Recommendations

Old Oak

The policy states that Old Oak will become a mixed employment hub with a range of
flexible workspace typologies and town centre uses generating employment along High
Street, in and around Old Oak Common Station and in other accessible locations which
would support the improvement of access to employment and maximising economic
wellbeing.
The policy would give a more flexible approach to office distribution around Old Oak
which could contribute towards improving access to employment in the long term.
The policy would not support B1(b) and B1(a) uses in Old Oak north which would provide
for additional floorspace for non-industrial uses however may result in locations unsuited
to uses such as retail and office use would remain vacant.
The enhancement of SIL through intensifying use of land including the provision of
smaller units to support greater employment densities will help to facilitate employment
opportunities which in the long term would contribute towards improving access to
employment.
The delivery of non-industrial uses to support the functioning of SIL may in the long term
contribute towards improving employment access.
Additional land release in Park Royal may in the long term contribute towards improving
employment access, if it is accommodates appropriate development.
The policy seeks to support affordable workspaces and open workspaces which are
appropriately located and do no result in net loss of employment land or floorspace.
Delivery of onsite open workspaces for commercial proposals would help to support a
diverse local economy and support social and economic wellbeing.
The policy could help to support employment access improvements through delivery of
small scale workspaces supported with coordinate delivery of rented small scale
residential units outside of the SIL.
The policy seeks to maximise employment, skills training, apprenticeships and preemployment as well as delivering OPDC projects all of which would directly support the
SA Objective.
The policy seeks to deliver a strong, sustainable, robust local economy that promotes Old
Oak and Park Royal as a place for enterprise and innovation which contributes to
Londons economic growth all of which would help to encourage inward investment
alongside investment within existing communities.
Old Oak would become a mixed employment hub providing town centre uses which
generate employment along High Street, in and around Old Oak Common Station and in

E2
Option 1
E2
Option 2

M, L-T, I, R,
M
+/- M, L-T, I, R,
M

Old Oak

E3

++ M, L-T, I, R,
M

Park Royal

E3
Option 1
E3
Option 2
E4

M, L-T, I, R, L Park Royal

M, L-T, I, R, L Park Royal

OPDC area

E4
Option 1
E4
Option 2

M, L-T, I, R,
M
M, L-T, I, R,
M
M, L-T, I, R,
M

E5

++ S, M, L-T, I,
R, M

OPDC area

E1

++ M, L-T, I, R,
M

Old Oak and

Park Royal

E2

++ M, L-T, I, R, L Old Oak

Old Oak

OPDC area
OPDC area

127

IIA Objective

Performance of Temporal
Policy
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
within existing
communities, to E2
Option 1
create
sustainable
economic growth

M, L-T, I, R, L Old Oak

Page 632

E2
Option 2

+/- M, L-T, I, R, L OId Oak

E3

++ M, L-T, I, R,
M
+ M, L-T, I, R,
M

E3
Option 1
E3
Option 2

Park Royal
Park Royal

+/- M, L-T, I, R, L Park Royal

E4

M, L-T, I, R,
M

OPDC area

E4
Option 1
E4
Option 2

M, L-T, I, R,
M
M, L-T, I, R,
M

OPDC area

E5

M, L-T, I, R,
M

OPDC area

OPDC area

other accessible areas, supporting this SA Objective.

The policy would not focus B1(a) uses in and around Old Oak Common Station though
the flexible approach to office distribution could support sustainable growth of the
economy. The policy would however mean that the commercial centre around Old Oak
Common Station could become less defined so it is considered that the preferred option
performs more strongly against this SA Objective.
The policy would not support B1(b) and B1(c) and this approach would provide for
additional floorspace for non-industrial uses which would offer benefits to the SA
Objective. The disadvantage of the policy however, would be that locations not suited to
retail, office, leisure or residential uses could remain vacant which could negatively
impact on the amenity of the public realm and may have a negative effect with regards to
encouraging inward investment and creating sustainable growth.
The policy seeks to protect SIL and support adjacent uses. It also designates five new
SIL sites and this in the long term could help to encourage inward investment.
The policy proposes not to extend the SIL boundary which could deliver non-industrial
uses which support the functioning of SIL and would contribute to encouraging
investment.
Inward investment would be encouraged through the release of additional land in Park
Royal to accommodate other forms of development, however, this could put pressure on
industrial land capacity and threaten the economic growth of Park Royal.
The policy would contribute to supporting inward investment as it seeks to support open
workspace typologies and temporary workspaces contributing to establishing and/or
growing an existing new business sector that would positively contribute to economic and
social regeneration of the area.
The delivery of onsite open workspaces for residential or commercial proposals could
help to support a diverse local economy and could help to attract inward investment.
The delivery of small scale workspaces coordinated with delivery of rented small-scale
residential units outside SIL could partially contribute to attracting investment as
development would support start-up businesses.
The policy principally seeks to maximise access to employment and training for local
people which could contribute towards attracting inward investment

Table G-7 Chapter 9: Town Centre Uses

128

x
x
x
x
x
x
x
IIA Objective

TC1: Strategic Policy: Town Centre uses

TC2: Town centre hierarchy
TC3: Vibrancy
TC4: Retail and eating and drinking establishment needs
TC5: Culture, Sports and Leisure Facilities
TC6: Visitor Accommodation
TC7: Hours of operation for night time economy uses
Performance of Temporal
Policy
Scale
Nature of
Impact

To enhance the TC1

built environment
and encourage
place-making
TC2

Page 633
TC2
Option 1

TC2
Option 2
TC2
Option 3

Geographical
Extent

Commentary and Recommendations

++ S,M,L-T,
D,R,H

Old Oak and

Park Royal

The policy states that Town centre uses can play a critical role in place-making, adding
vibrancy to buildings and the public realm and helping to attract people to live, work and
visit the area.

++ S,M,L-T,
D,R,H

Old Oak High

Street, Park
Royal and
North Acton.

The policy demands that the centres should be of a sufficient size that they meet needs,
promote sustainability and assist with place-making. A new major town centre in Old Oak
would have significant benefits to place-making in the area, providing opportunities for the
provision of a range of culture, sports and leisure facilities which as well as meeting local
need, could make a significant contribution to strategic provision and help to promote
London as the worlds cultural capital, as set out in the Mayors Cultural Strategy.

+/- S,M,L-T,
D,R,H

OPDC area

This option would have benefits in terms of making Old Oak a destination that people will
be attracted to and could have benefits for place-making by attracting higher footfall.
However, this option could impact on the vitality and viability of the surrounding town
centre hierarchy and the neighbouring town centres of Ealing, Shepherds Bush and
Kingston.
Two new centres at Old Oak and Old Oak Common Station would have benefits to placemaking in the area meeting local need. However, this option does not directly support the
delivery of catalyst uses around Old Oak Common Station.
The designation of a district centre to the south of the canal would better capture the
scale of need for town centre uses arising from the population living, working and visiting
the area than in option 2. However, to the north of the canal, the designation of a
neighbourhood centre would not be capable of providing sufficient town centre uses to
meet the areas need. This could be met to a certain degree by the District Centre at Old
Oak Common station and the District Centre at Harlesden, but there would also be a risk
that premises in this area would struggle and the limited quantum of town centre uses
may impact on place-making.

S,M,L-T, I,R,L OPDC area

and Old Oak
High Street
+/- S,M,L-T,
OPDC and
D,R,H
surrounding
area

129

IIA Objective

Performance of Temporal
Geographical
Policy
Scale
Extent
Nature of
Impact
TC2
+/- S,M,L-T, I,R,L OPDC area
Option 4

Page 634

TC3

++ S,M,L-T,
D,R,H

OPDC and
surrounding
area

TC3
Option 1

S,M,L-T,
D,R,H

OPDC and
surrounding
area

TC4

++ S,M,L-T,
D,R,H

OPDC and
surrounding
area

TC4
Option 1

+/- S,M,L-T,
D,R,H

OPDC and
surrounding
area

TC5

S,M,L-T,
D,R,H

OPDC and
surrounding
area

TC5
Option 1

S,M,L-T,
D,R,M

OPDC and
surrounding
area

TC6

S,M,L-T, I,R,L OPDC and

Commentary and Recommendations

This option would have benefits for delivering new employment space within Park Royal.
However, the potential dispersal of town centre walk-to uses may have negative impacts
on accessibility of these uses and, in turn, impacts on road congestion.
Town centre uses play an important role in place-making, by attracting people to an area
and helping to enliven it. Town centre uses within the OPDC area, particularly in Old Oak,
will help to play a critical role in the approach to place-making. An important way of
achieving this is through activating and overlooking the public realm, by providing outdoor
uses such as event space, outdoor seating associated with eating and drinking
establishments and through the provision of street markets.
The choice of land use may affect the ability to create a sense of place. The option
maintains that Town centre uses within the OPDC area will help to play a critical role in
the approach to place-making with flexibility around uses such as betting shops, pay-day
loan shops and takeaways.
The policy states that if there is not enough A-class floorspace, people will be required to
travel further for their needs, putting increased pressures on the transport network and
undermining the place-making benefits that A-class floorspace could bring to the OPDC
area. The policy seeks to deliver the necessary place-making benefits for the OPDC
area.
This option would have potential benefits in terms of place-making, by creating a greater
retail draw and providing more opportunities for active uses. However, this option could
impact on the vitality and viability of surrounding retail centres outside of the OPDC area
and as a consequence, this policy approach has not been identified as the preferred
option.
The policy states that culture, sports and leisure facilities make an important contribution
to place-making, could be important catalyst uses and could help to define and shape the
place and add to vibrancy and activity by attracting visitors to an area. It can also help
and support place-making and/or act as a catalyst for regeneration.
This option would provide a clearer indication of the acceptable quantum of floorspace for
other town centre uses, providing greater certainty to stakeholders, but this approach
would constrain the ability for these sorts of uses to aid with place-making and could
potential prevent a major cultural, sports or leisure use from locating the area that could
act as a catalyst for regeneration and provide a strategic cultural or leisure destination.
Visitor accommodation is an element that contributes to creating a place. The policy
130

IIA Objective

Page 635

To optimise the
efficient use of
land through
increased
development
densities and
building heights,
where
appropriate

Performance of Temporal
Policy
Scale
Nature of
Impact

Geographical
Extent

Commentary and Recommendations

surrounding
area
OPDC and
surrounding
area

highlights the importance of hotels for leisure and business that could help the tourism
sector in the area.
Night-time economy uses play an important role in place-making, by attracting people to
an area and helping to enliven it. Eating and drinking establishments and culture, sports
and entertainment uses should create a sense of place for local residents and visitors to
the area. Limits have been imposed to ensure activity is kept within sensible hours.

TC7

++ S,M,L-T,
D,R,M

TC1

TC2

TC2
Option 1

S,M,L-T, I,R,L Old Oak High

Street

TC2
Option 2

S,M,L-T, I,R,L Old Oak

TC2
Option 3

S,M,L-T, I,R,L Old Oak

TC2
Option 4
TC3

S,M,L-T, I,R,L Park Royal

TC3
Option 1
TC4

S,M,L-T, I,R,L OPDC area

and London
wide
S,M,L-T,
OPDC area
I,R,M

S,M,L-T, I,R,L OPDC area

The policy relates to focussing development i higher density town centre locations such
as Old Oak and Park Royal.
The policy states the centres should be of sufficient size to accommodate residents and
users. The aim is for higher densities in appropriate areas trying to seek the best balance
of efficient land use. This must take into account the use of land within the centre
boundary.
The option to concentrate town centre development in this area should optimise the
efficient use of land at Old Oak High Street. The delivery of a Metropolitan Centre would
enable the delivery of greater amounts of town centre uses representing a potential
greater optimisation of the use of land.
The option to concentrate town centre development in this area should optimise the
efficient use of land at Old Oak. The delivery of smaller town centre typologies would not
enable the delivery of the same amount of retail uses compared to the preferred policy
option.
The option to concentrate town centre development in this area should optimise the
efficient use of land at Old Oak. The delivery of smaller town centre typologies would not
enable the delivery of the same amount of retail uses compared to the preferred policy
option.
The option to use Park Royal Centre for other uses may enable more employment
floorspace to be delivered thereby affecting the areas density and building heights.
The policy seeks to optimise the development of brownfield land, which could have direct
significant benefits against this objective. Measures to improve vibrancy would not affect
efficient land use.
This option would not affect efficient land use.
The preferred policy to deliver A classes that serve the needs of the development and
complement nearby centres would support the efficient use of land.
131

IIA Objective

Page 636

Maximise the
reuse of
previously
developed land
and existing
buildings,
including the
remediation of
contaminated
land

Performance of Temporal
Geographical
Policy
Scale
Extent
Nature of
Impact
TC4
++ S,M,L-T, I,R,L OPDC area
Option 1
TC5
+ S,M,L-T, I,R,L Old Oak
TC5
Option 1
TC6

TC7
TC1

0
+

TC2

TC2
Option 1
TC2
Option 2
TC2
Option 3
TC2
Option 4
TC3

TC3
Option 1
TC4
TC4
Option 1
TC5

0
S,M,L-T, I,R,L OPDC area

S,M,L-T, I,R,L OPDC area

and London
wide
++ S,M,L-T,
OPDC area
I,R,M

S,M,L-T, I,R,L OPDC area

S,M,L-T, I,R,L OPDC area

S,M,L-T, I,R,L OPDC area

+/- S,M,L-T, I,R,L OPDC area

0

0
+

S,M,L-T, I,R,L OPDC area

++ S,M,L-T, I,R,L OPDC area

+

S,M,L-T, I,R,L Old Oak

Commentary and Recommendations

The preferred policy option to deliver a higher amounts of A classes would enable greater
optimisation of the efficient use of land.
The preferred policy option to deliver culture, sports and leisure facilities would support
the efficient use of land.
This option would not affect efficient land use.
The preferred policy option to deliver visitor accommodation would support the efficient
use of land.
The policy would not affect efficient land use.
Any new development within the town centre would be built on brownfield sites.

The policy states the centres should be of sufficient size to accommodate residents and
users. Town Centre regeneration in this location could have benefits in that development
could lead to the remediation of contaminated land as well as replacing potentially
contaminating land uses with other developments.
The option to concentrate town centre development in this area should maximise the
reuse of brownfield land at Old Oak High Street.
The option to concentrate town centre development in this area should maximise the
reuse of brownfield land at Old Oak.
The option to concentrate town centre development in this area should maximise the
reuse of brownfield land at Old Oak.
The option to use Park Royal for other uses may affect the choice of land for
development.
The policy seeks to optimise the development of brownfield land, which could have direct
significant benefits against this objective. Measures to improve vibrancy would not affect
efficient land use.
This option would not affect efficient land use.
The preferred policy option to deliver A classes that serve the needs of the development
and complement nearby centres would support the maximum reuse of brownfield land..
The preferred policy option to deliver a higher amounts of A classes would enable greater
optimisation of the efficient use of land.
The preferred policy option to deliver culture, sports and leisure facilities would support
the maximum reuse of brownfield of land.
132

IIA Objective

Performance of Temporal
Geographical
Policy
Scale
Extent
Nature of
Impact
TC5
0
Option 1
TC6
+ S,M,L-T, I,R,L OPDC area

Page 637

TC7
Minimise the
TC1
need to travel,
improve
accessibility for
all users by
TC2
public and nonmotorised
transportation
methods and
mitigate impacts
on the transport
network

0
+

S,M,L-T, I,R,L OPDC area

and London
wide

++ S,M,L-T,
D,R,H

OPDC area
and London
wide

TC2
Option 1

S,M,L-T,
D,R,M

OPDC area

TC2
Option 2

S,M,L-T,
D,R,M

OPDC area

TC2
Option 3

S,M,L-T,
D,R,M

OPDC area

+/- S,M,LT,D,R,M

OPDC and
surrounding
area

TC2
Option 4

Commentary and Recommendations

This option would not affect efficient land use.

The preferred policy option to deliver visitor accommodation would support the maximum
reuse of brownfield land.
The policy would not maximise the use of previously developed land.
The policy states the need to develop a network of new town and local centres that are
the focus for town centre uses and which complement and enhance Londons wider
network of centres. This can indirectly minimise the excessive need for travel with a wellconnected transport network.
Reduce the need to travel by car and do not have an adverse impact on the operation of
the road network. The public transport accessibility that will be afforded to the area,
making Old Oak a highly sustainable location for town centre uses, reducing the need for
people in the surrounding area to travel to these uses by private vehicle. Retail and other
town centre uses should be focussed within the designated town centres and
neighbourhood centres. However, in accordance with the sequential test, if there are no
suitable sites within these designated centres there may be the potential for town centre
uses in edge of centre or out of centre locations. This would be supported where it
addresses a specific deficiency in need, such as in areas further away from the
designated centres or where they provide local convenience retail that reduces the need
to travel. The proposed hierarchy could work well in terms of maximising sustainable
transport use by focussing key services and attractions in the largest accessible locations
with smaller amounts in more local areas for local needs.
This option focuses on high public transport accessibility to promote Old Oak High Street
as a major metropolitan centre destination. Access to the town centre typologies in this
option would rely on the same transport network as the preferred policy option.
New district and neighbourhood centres would require sufficient transport networks to
and from the sites Access to the town centre typologies in this option would rely on the
same transport network as the preferred policy option.
New district and neighbourhood centres would require sufficient transport networks to
and from the sites. Access to the town centre typologies in this option would rely on the
same transport network as the preferred policy option.
An approach to minimise this impact might be to de-designate the centre and allow for its
gradual erosion to other uses such as employment and residential including local walk to
services. However, this approach could also result in worse impacts on the highway
network as if the town centre uses were diminished, workers and residents in Park Royal
133

IIA Objective

Performance of Temporal
Policy
Scale
Nature of
Impact

TC3

++ L-T, I, R, L

OPDC area

TC3
Option 1

++ M-T, D,R,M

OPDC area

TC4

++ M-T, D,R,M

OPDC area

TC4
Option 1

+/- S,M,L-T,
D,R,M

OPDC and
wider area

Page 638

TC5

M-T, D,R,M

OPDC area

TC5
Option 1

S,M,L-T,
D,R,M

OPDC area

TC6

++ S,M,LT,D,R,M

OPDC and
surrounding
area

TC7

Geographical
Extent

Improve access TC1

to well designed, TC2
well-located,
TC2
market,
Option 1

0
0
0

Commentary and Recommendations

would have to travel further for their services. It would also see the loss of well used
existing local services over time.
The policy seeks to deliver a range of land uses and associated town centre
infrastructure. This could help to reduce the need to travel for both existing and incoming
communities, which could have long term benefits against this objective.
This option could help to reduce the need to travel and would not look to resist these
uses and would instead consider proposals for such uses on their merits, having regard
to their impact on amenity, transport and other Local Plan considerations.
The policy seeks to deliver A Use Class land uses which could help to reduce the need to
travel for both existing and incoming communities and could have long term benefits
against this objective
The option for OPDC to be a greater retail destination with a higher quantum of retail over
and above that required to serve the needs of the development. This would impose
greater demand on the transport network and generate more trips from a wider area but
could also be used to inform public transport services business planning to inform the
delivery of additional infrastructure. However, should this not be undertaken, higher
amounts of town centre uses may cause disruption and highway pressure on the area.
The policy clarifies that OPDC will be supportive of the provision of new facilities, where
they demonstrably address either a local or strategic need and do not give rise to an
unacceptable impact on the amenity of existing and future residents, businesses or on
the transport network.
This approach could potentially prevent a major cultural, sports or leisure use from
locating the area that could act as a catalyst for regeneration and provide a strategic
cultural or leisure destination. This more reserved option should limit the impact on the
transport network.
The policy states that hotels are well suited to areas of high public transport access and
therefore, parts of the OPDC area and particularly the Old Oak area would be appropriate
locations to consider promoting visitor accommodation.
The policy proposes closing times of establishments. This may relieve pressure to
provider late night public transport services. This may have an indirect effect on the
transport network.
The policy would not have any significant effects for the objective.
The policy would not have any significant effects for the objective.
The option would not have any significant effects for the objective.

134

IIA Objective

Page 639

Performance of Temporal
Geographical
Policy
Scale
Extent
Nature of
Impact
affordable and TC2
0
inclusive housing Option 2
of a range of
TC2
0
types and
Option 3
tenures, to meet TC2
0
identified local Option 4
needs
TC3
0
TC3
0
Option 1
TC4
0
TC4
0
Option 1
TC5
0
TC5
0
Option 1
TC6
0
TC7
0
Improve climate TC1
0 S,M,L-T, I,R,L Old Oak High
Street, Park
change
adaptation and
Royal Centre,
North Acton
mitigation,
including
TC2
- M, L-T, D, IR, OPDC area
minimising the
L
and
risk of flooding
surrounding
and addressing
boroughs
the heat island TC2
- M, L-T, D, IR, OPDC area
effect
Option 1
L
and
surrounding
boroughs
TC2
- M, L-T, D, IR, OPDC area
Option 2
L
and
surrounding
boroughs
TC2
- M, L-T, D, IR, OPDC area
Option 3
L
and

Commentary and Recommendations

The option would not have any significant effects for the objective
The option would not have any significant effects for the objective
The option would not have any significant effects for the objective
The policy would not have any significant effects for the objective.
The option would not bring any benefits for the objective
The policy would not have any significant effects for the objective.
The option would not have any significant effects for the objective
The policy would not have any significant effects for the objective.
The option would not have any significant effects for the objective
The policy would not have any significant effects the objective.
The policy would not have any significant effects the objective.
The policy does not specifically address climate change issues as it relates to town
centre uses such issues are addressed in Policy EU1.

An increase in development at Old Oak High Street, North Acton and Park Royal could
lead to an increase in built development. This could have negative effects in relation to
surface water and flooding if not adequately mitigated through the implementation of
policies within the Environment and Utilities Chapter.
Development at Old Oak High Street could lead to an increase in built development. This
could have negative effects in relation to surface water and flooding if not adequately
mitigated through the implementation of policies within the Environment and Utilities
Chapter.
Development at Old Oak could lead to an increase in built development. This could have
negative effects in relation to surface water and flooding if not adequately mitigated
through the implementation of policies within the Environment and Utilities Chapter.
Development at Old Oak could lead to an increase in built development. This could have
negative effects in relation to surface water and flooding if not adequately mitigated
135

IIA Objective

Performance of Temporal
Policy
Scale
Nature of
Impact

TC2
Option 4

Geographical
Extent

surrounding
boroughs
M, L-T, D, IR, OPDC area
L
and
surrounding
boroughs

TC3

Page 640
7

To minimise
contributions to
climate change
through greater
energy
efficiency,
generation and
storage; and to
reduce reliance
on natural
resources
including fossil
fuels for
transport,
heating and
energy

Commentary and Recommendations

through the implementation of policies within the Environment and Utilities Chapter.
Development at Park Royal could lead to an increase in built development. This could
have negative effects in relation to surface water and flooding if not adequately mitigated
through the implementation of policies within the Environment and Utilities Chapter.
The policy would not have any significant effects for the objective.

0
0

The option would not have any significant effects for the objective.

0
0

The policy would not have any significant effects for the objective.
The option would not have any significant effects for the objective.

TC3
Option 1
TC4
TC4
Option 1
TC5
TC5
Option 1
TC6
TC7
TC1

0
0

The policy would not have any significant effects for the objective.
The option would not have any significant effects for the objective.

0
0
+

S,M,L-T, I,R,L Nationwide

TC2

S,M,L-T, I,R,L Nationwide

TC2
Option 1

S,M,L-T, I,R,L Nationwide

TC2
Option 2

S,M,L-T, I,R,L Nationwide

TC2
Option 3

S,M,L-T, I,R,L Nationwide

TC2
Option 4

S,M,L-T, I,R,L Nationwide

The policy would not have any significant effects for the objective.
The policy would not have any significant effects for the objective.
Town centres provide clusters and higher densities which may make it easier for shared
power and heating. This would also make travel by sustainable means to the key uses
proposed more viable.
Town centres provide clusters and higher densities which may make it easier for shared
power and heating. This would also make travel by sustainable means to the key uses
proposed more viable.
Town centres provide clusters and higher densities which may make it easier for shared
power and heating. This would also make travel by sustainable means to the key uses
proposed more viable.
Town centres provide clusters and higher densities which may make it easier for shared
power and heating. This would also make travel by sustainable means to the key uses
proposed more viable.
Town centres provide clusters and higher densities which may make it easier for shared
power and heating. This would also make travel by sustainable means to the key uses
proposed more viable.
Town centres provide clusters and higher densities which may make it easier for shared
power and heating. This would also make travel by sustainable means to the key uses
136

IIA Objective

Performance of Temporal
Policy
Scale
Nature of
Impact
TC3
TC3
Option 1
TC4
TC4
Option 1
TC5
TC5
Option 1
TC6
TC7
TC1

Page 641

To minimise
production of
waste across all
sectors in the
TC2
plan area,
maximise
efficiencies for TC2
transporting
Option 1
waste and
increasing rates
of re-use,
recycling and
TC2
recovery rates Option 2
as well as
composting of all TC2
green waste
Option 3
TC2
Option 4
TC3

Geographical
Extent

Commentary and Recommendations

0
0

proposed more viable.

The policy would not have any significant effects for the objective.
This option would not have any significant effects for the objective.

0
0

The policy would not have any significant effects for the objective.
This option would not have any significant effects for the objective.

0
0

The policy would not have any significant effects for the objective.
This option would not have any significant effects for the objective.

0
0
+

S,M,L-T, I,R,L OPDC area

S,M,L-T, I,R,L OPDC area

The policy would not have any significant effects for the objective.
The policy would not have any significant effects for the objective.
The principle of focusing retail and leisure uses in town centres can benefit construction
and operational waste collection and the provision of recycling facilities through spatial
proximity.
The principle of focusing retail and leisure uses in town centres can benefit construction
and operational waste collection and the provision of recycling facilities through spatial
proximity.
The principle of focusing retail and leisure uses in town centres can benefit construction
and operational waste collection and the provision of recycling facilities through spatial
proximity. This option would deliver greater amounts of town centre uses which may
result in higher levels of operational waste generated if not adequately managed by
waste policies in the Environment and Utilities Chapter.
The principle of focusing retail and leisure uses in town centres can benefit construction
and operational waste collection and the provision of recycling facilities through spatial
proximity.
The principle of focusing retail and leisure uses in town centres can benefit construction
and operational waste collection and the provision of recycling facilities through spatial
proximity.
This option would potentially see town centre walk to uses dispersed across Park Royal
which may result in less efficient collection of operational waste if not adequately
managed by waste policies in the Environment and Utilities Chapter.
The policy will not directly contribute to benefits against this objective However, the
emphasis on high quality places should contribute to the use of visibly aesthetic
recyclable materials and aim to minimise transporting waste.

+/- S,M,L-T,
I,R,M

OPDC area

S,M,L-T, I,R,L OPDC area

S,M,L-T, I,R,L OPDC area

+/- S,M,L-T,
I,R,M
?

OPDC area

137

IIA Objective

Page 642

Improve the
quality of the
water
environment

Performance of Temporal
Policy
Scale
Nature of
Impact
TC3
+ S,M,L-T,
Option 1
I,R,M
TC4
+/- S,M,L-T,
I,R,M
TC4
+/- S,M,L-T,
Option 1
I,R,M
TC5
+/- S,M,L-T,
I,R,M
TC5
0
Option 1
TC6
+/- S,M,L-T,
I,R,M
TC7
0

TC1

TC2

TC2
Option 1

TC2
Option 2

TC2
Option 3

TC2
Option 4

TC3

Geographical
Extent

Commentary and Recommendations

OPDC area

Managing the number of takeaways and fast food outlets could have a positive impact on
managing operational waste created by these uses.
Delivery of A Use Classes will need to be supported by the implementation of
Environment and Utilities policies to manage operational waste.
Delivery of A Use Classes will need to be supported by the implementation of
Environment and Utilities policies to manage operational waste.
Delivery of culture, leisure and sports facilities will need to be supported by the
implementation of Environment and Utilities policies to manage operational waste.
The option would not have any significant effects for the objective.

OPDC area
OPDC area
OPDC area

OPDC area

Delivery of visitor accommodation will need to be supported by the implementation of

Environment and Utilities policies to manage operational waste.
Existing or new night-time economy uses should not have a significant effect on the
production of waste. Waste generated by the facility will be dealt with the same as any
other use.
The policy would not have any significant effects for the objective. Any development
would need to ensure that water infrastructural capacity is sufficient to accommodate new
development ahead of occupation.
The policy would not have any significant effects for the objective. Any development
would need to ensure that water infrastructural capacity is sufficient to accommodate new
development ahead of occupation.
The policy would not have any significant effects for the objective. Any development
would need to ensure that water infrastructural capacity is sufficient to accommodate new
development ahead of occupation.
The policy would not have any significant effects for the objective. Any development
would need to ensure that water infrastructural capacity is sufficient to accommodate new
development ahead of occupation.
The policy would not have any significant effects for the objective. Any development
would need to ensure that water infrastructural capacity is sufficient to accommodate new
development ahead of occupation.
The policy would not have any significant effects for the objective. Any development
would need to ensure that water infrastructural capacity is sufficient to accommodate new
development ahead of occupation.
The policy would not have any significant effects for the objective. Any development
would need to ensure that water infrastructural capacity is sufficient to accommodate new
138

IIA Objective

Page 643
10

Create and
enhance
biodiversity and
the diversity of
habitats across
the area and its
surroundings

Performance of Temporal
Policy
Scale
Nature of
Impact

Geographical
Extent

Commentary and Recommendations

TC3
Option 1

TC4

TC4
Option 1

TC5

TC5
Option 1

TC6

TC7

TC1
TC2
TC2
Option 1
TC2
Option 2
TC2
Option 3
TC2
Option 4
TC3
TC3
Option 1

0
0
0

development ahead of occupation.

The policy would not have any significant effects for the objective. Any development
would need to ensure that water infrastructural capacity is sufficient to accommodate new
development ahead of occupation.
The policy would not have any significant effects for the objective. Any development
would need to ensure that water infrastructural capacity is sufficient to accommodate new
development ahead of occupation.
The policy would not have any significant effects for the objective. Any development
would need to ensure that water infrastructural capacity is sufficient to accommodate new
development ahead of occupation.
The policy would not have any significant effects for the objective. Any development
would need to ensure that water infrastructural capacity is sufficient to accommodate new
development ahead of occupation.
The policy would not have any significant effects for the objective. Any development
would need to ensure that water infrastructural capacity is sufficient to accommodate new
development ahead of occupation.
The policy would not have any significant effects for the objective. Any development
would need to ensure that water infrastructural capacity is sufficient to accommodate new
development ahead of occupation.
The policy would not have any significant effects for the objective. Any development
would need to ensure that water infrastructural capacity is sufficient to accommodate new
development ahead of occupation.
. The policy would not have any significant effects for the objective.
. The policy would not have any significant effects for the objective.
This option would not have any significant effects for the objective.

This option would not have any significant effects for the objective.

This option would not have any significant effects for the objective.

This option would not have any significant effects for the objective.

0
0

. The policy would not have any significant effects for the objective.
The policy would not have any significant effects for the objective.
139

IIA Objective

11

Performance of Temporal
Policy
Scale
Nature of
Impact

Page 644

TC4
TC4
Option 1
TC5
TC5
Option 1
TC6
TC7
To minimise air, TC1
noise and light
pollution,
particularly for
vulnerable
groups
TC2

Geographical
Extent

Commentary and Recommendations

0
0

The policy would not have any significant effects for the objective.
The option would not have any significant effects for the objective.

0
0

The policy would not have any significant effects for the objective.
The option would not have any significant effects for the objective.

0
0
+/- S,M,L-T, I,R,L OPDC area

+/- S, M, L-T, D, OPDC area

IR, L
and
surrounding
boroughs

TC2
Option 1

+/- S, M, L-T, D, OPDC area

IR, L
and
surrounding
boroughs

TC2
Option 2

+/- S, M, L-T, D, OPDC area

IR, L
and
surrounding
boroughs

TC2
Option 3

+/- S, M, L-T, D, OPDC area

IR, L
and
surrounding
boroughs

TC2
Option 4

+/- S, M, L-T, I,
R, M

OPDC area
and

The policy would not have any significant effects for the objective.
The policy would not have any significant effects for the objective.
There is no direct relationship between objective and policy. However, focussing retail
and leisure uses within town centres will encourage people to use sustainable public
transport. \ Impacts on air, noise and light pollution generated by town centre uses will
need to be managed by London Plan policy and policies in the Environment and Utilities
Chapter.
There is no direct relationship between objective and policy. However, focussing retail
and leisure uses within town centres will encourage people to use sustainable public
transport. \ Impacts on air, noise and light pollution generated by town centre uses will
need to be managed by London Plan policy and policies in the Environment and Utilities
Chapter.
There is no direct relationship between objective and policy. However, focussing retail
and leisure uses within town centres will encourage people to use sustainable public
transport. \ Impacts on air, noise and light pollution generated by town centre uses will
need to be managed by London Plan policy and policies in the Environment and Utilities
Chapter.
There is no direct relationship between objective and policy. However, focussing retail
and leisure uses within town centres will encourage people to use sustainable public
transport. \ Impacts on air, noise and light pollution generated by town centre uses will
need to be managed by London Plan policy and policies in the Environment and Utilities
Chapter.
There is no direct relationship between objective and policy. However, focussing retail
and leisure uses within town centres will encourage people to use sustainable public
transport. \ Impacts on air, noise and light pollution generated by town centre uses will
need to be managed by London Plan policy and policies in the Environment and Utilities
Chapter.
This option could result in town centre walk-to uses being dispersed across Park Royal
which may result in additional use of private transport and impacts on air quality.
140

IIA Objective

Performance of Temporal
Policy
Scale
Nature of
Impact

Geographical
Extent

Commentary and Recommendations

surrounding
boroughs
TC3

TC3
Option 1
TC4

TC4
Option 1

Page 645

TC5
TC5
Option 1
TC6

TC7

12

To conserve and TC1

enhance the
historic
environment,
heritage assets
and their settings TC2

Minimisation of air, noise and light pollution caused by traffic and commercial uses during
the construction and operation of development on existing town centres and communities
will help maintain the vibrancy of the area.
The policy would not have any significant effects for the objective.

+/- S, M, L-T, D, OPDC area

IR, L
and
surrounding
boroughs
+/- S, M, L-T, D, OPDC area
IR, M
and
surrounding
boroughs
0
0
-

S, M, L-T, I,
IR, L

S, M, L-T, I,
IR, L

OPDC area
and
surrounding
boroughs
OPDC area

+/- S, M, L-T, D, OPDC area

IR, L
and
surrounding
boroughs
+/- S, M, L-T, D, OPDC area
IR, L
and
surrounding

There is no direct relationship between objective and policy. However, focussing A use
classes within town centres will encourage people to use sustainable public transport. \
Impacts on air, noise and light pollution generated by town centre uses will need to be
managed by London Plan policy and policies in the Environment and Utilities Chapter.
There is no direct relationship between objective and policy. However, a greater amount
of retail floorspace will need to be managed by London Plan policy and policies in the
Environment and Utilities Chapter.
The policy would not have any significant effects for the objective.
The policy would not have any significant effects for the objective.
Greater volumes of tourists to the area may result in higher amounts of vehicular
transport and resultant air pollution if the area is not supported by appropriate public
transport infrastructure.
The policy states that proposals for late licenses will be assessed in terms of the uses
impact on residential amenity and will consider issues such as noise within the premises,
smells, light pollution and the impact of those going to and from the facility, considering
issues such as traffic and car parking and anti-social behaviour. As such this would
benefit the objective.
New town centre development could lead to benefits, through the potential for improving
the setting of the historic environment, as well as improving the assets themselves
through re-use. Development in Old Oak and Park Royal could also have a detrimental
effect on any existing heritage assets unless adequately managed by Policy D6 and
London Plan policy.
New town centre development could lead to benefits, through the potential for improving
the setting of the historic environment, as well as improving the assets themselves
through re-use. Development in Old Oak and Park Royal could also have a detrimental
141

IIA Objective

Performance of Temporal
Policy
Scale
Nature of
Impact

Page 646

Geographical
Extent

Commentary and Recommendations

boroughs

effect on any existing heritage assets unless adequately managed by Policy D6 and
London Plan policy..
New town centre development could lead to benefits, through the potential for improving
the setting of the historic environment, as well as improving the assets themselves
through re-use. Development in Old Oak and Park Royal could also have a detrimental
effect on any existing heritage assets unless adequately managed by Policy D6 and
London Plan policy.
New town centre development could lead to benefits, through the potential for improving
the setting of the historic environment, as well as improving the assets themselves
through re-use. Development in Old Oak and Park Royal could also have a detrimental
effect on any existing heritage assets unless adequately managed by Policy D6 and
London Plan policy.
New town centre development could lead to benefits, through the potential for improving
the setting of the historic environment, as well as improving the assets themselves
through re-use. Development in Old Oak and Park Royal could also have a detrimental
effect on any existing heritage assets unless adequately managed by Policy D6 and
London Plan policy.
New town centre development could lead to benefits, through the potential for improving
the setting of the historic environment, as well as improving the assets themselves
through re-use. Development in Old Oak and Park Royal could also have a detrimental
effect on any existing heritage assets unless adequately managed by Policy D6 and
London Plan policy.
The policy could lead to the preservation of the historic environment through a focus on
creating an attractive, locally distinctive, vibrant town centre. Regeneration and
intensification must recognise the importance of heritage and historic environment as
referred to in Policy D6.

TC2
Option 1

+/- S, M, L-T, D, OPDC area

IR, L
and
surrounding
boroughs

TC2
Option 2

+/- S, M, L-T, D, OPDC area

IR, L
and
surrounding
boroughs

TC2
Option 3

+/- S, M, L-T, D, OPDC area

IR, L
and
surrounding
boroughs

TC2
Option 4

+/- S, M, L-T, D, OPDC area

IR, L
and
surrounding
boroughs

TC3

S, M, L-T, D, OPDC area

IR, L
and
surrounding
boroughs

TC3
Option 1

TC4

S, M, L-T, D, OPDC area

IR, L
and
surrounding
boroughs
S, M, L-T, D, OPDC area
IR, L
and
surrounding
boroughs

TC4

This option could lead to the preservation of the historic environment due to the more
flexible approach of OPDC over proposals.

The policy could lead to the preservation of the historic environment through a focus on
not adversely affecting the vitality and viability of nearby centres in the development of
any new A-class uses.
This option may have a detrimental effect on the objective due to a lesser importance
142

IIA Objective

Performance of Temporal
Policy
Scale
Nature of
Impact
Option 1
TC5
+/- S, M, L-T, D,
IR, L

TC5
Option 1
TC6

TC7

Page 647

13

Increase
community
cohesion and
reduce social
exclusion to
encourage a
sense of
community and
welfare

Geographical
Extent

OPDC area
and
surrounding
boroughs

Commentary and Recommendations

placed on the vitality and viability of the town centre.

The policy could lead to the preservation of the historic environment depending on the
nature of the cultural, sports and leisure uses.

The policy would not have any significant effects for the objective.

+/- S, M, L-T, I,
R, M

OPDC and
London wide

TC1

++ S,M,L-T,
D,R,H

TC2

Nationwide

M, L-T, I, R, L OPDC area

TC2
Option 1

+/- M, L-T, D, R, OPDC area

M

TC2
Option 2

+/- M, L-T, D, R, OPDC area

M

TC2

+/- M, L-T, D, R, OPDC area

The policy could lead to the preservation of the historic environment but the potential
design of proposals may have a detrimental effect on the character of the area if not
adequately managed by design policies within the Design Chapter and London Plan.
As explained in the policy London Plan policy 4.6 requires local planning authorities in
their Local Plans to minimise the impact of night time economy uses on other land uses
taking account of the cumulative effects of night time uses and saturation levels beyond
which they have unacceptable impacts on the environmental standards befitting a world
city and quality of life for local residents. This statement should protect the historic
environment and any heritage assets.
The policy states that the NPPF promotes the role that town centre uses can play in
supporting the needs of those living, working and visiting an area and that town centres
should sit as the heart of communities. This encompasses all of the community and
increases cohesion.
The development of new town centres could lead to an increased sense of community
cohesion over the existing situation, as the development would generate a significant
number of housing, jobs and a mix of other community focused uses.
The development of a new metropolitan centre at Old Oak Street could lead to an
increased sense of community cohesion and this option would have benefits in terms of
making Old Oak a destination that people will be attracted to and could improve the
community. However, this could have a detrimental effect on the other town centres in
the OPDC area.
The development of a new district centre and neighbourhood centre in Old Oak could
lead to an increased sense of community cohesion and minimise impacts on nearby town
centres such as Harlesden, Ealing and Shepherds Bush. However, the designation
would be likely to only provide sufficient floorspace to provide for retail needs and would
not allow for the provision of a significant quantum of culture, sports or leisure uses within
these centres.
The development of a new district centre and neighbourhood centre in Old Oak could
143

IIA Objective

Performance of Temporal
Policy
Scale
Nature of
Impact
Option 3
LM

TC2
Option 4

TC3

TC3
Option 1

Page 648

TC4

TC4
Option 1

TC5

Geographical
Extent

Commentary and Recommendations

lead to an increased sense of community cohesion and minimise impacts on nearby town
centres. There would also be a risk that premises in this area would struggle and the
limited quantum of town centre uses may impact on the community.

M, L-T, D, R, OPDC area

M

++ M, L-T, D, R, OPDC area

M
and London
wide
+/- M, L-T, D, R, OPDC area
LM
and
surrounding
boroughs
++ S,M,L-T,
OPDC area
D,R,H

+/- S,M, L-T, D, OPDC area

R, LM
and
surrounding
boroughs
+ S,M,L-T,
OPDC area
D,R,H

TC5
Option 1

S,M,L-T,
I,R,M

OPDC area

TC6

S,M,L-T,
D,R,H

OPDC and
surrounding
area

This option could result in negative impacts on the highway network as the town centre
uses were diminished or dispersed, workers and residents in Park Royal would have to
travel further for their services. It would also see the loss of well used existing local
services over time which would have a negative effect on the community.
Vibrant town centre uses, regeneration links with London and a healthy mix of retailers in
the area should benefit the community cohesion through entertainment, employment and
social infrastructure.
This option would take careful consideration over the uses in the area and the impact it
would have on the existing services and the community. This would allow the OPDC to
be more responsive to market demands, thereby, satisfying the local people. However,
the option could result in a spread of these uses away from the OPDC area
It is important that an appropriate quantum of A-class uses are provided to support the
needs of those living, working and visiting Old Oak and Park Royal. It will be important to
achieve the right balance and consider how OPDC can be flexible and respond to future
changing market conditions and local need.
The option would potential benefits by creating more retail opportunities but this could
impact on the surrounding retail centres meaning the effects on the community would be
mixed. However, most people would travel from outside the area to use the shops.
The policy states that OPDC is keen to ensure that there is access to all new sports
facilities for local communities and OPDC will seek to secure a proportion of affordable
sports and leisure provision. This should improve community cohesion and reduce social
exclusion.
The quantum threshold for culture, sports and leisure uses could constrain the ability for
these sorts of uses to help the community and could potential prevent a major cultural,
sports or leisure use from locating the area that could act as a catalyst for regeneration
and provide a strategic cultural or leisure destination.
More high quality visitor accommodation will improve the tourism sector in the area,
thereby, improving the local economy with community benefits. A more prosperous local
economy should create more community cohesion.
144

IIA Objective

14

Improve safety
and reduce
crime and the
fear of crime

Page 649

Performance of Temporal
Policy
Scale
Nature of
Impact

Geographical
Extent

Commentary and Recommendations

TC7

OPDC area

Night time entertainment should play an important role in the vibrancy of the area,
thereby, improving community cohesion and adding activity to the public realm and
supporting the local economy. This is supported as the policy seeks to impose sensible
limits on hours.
Supporting the area with new cultural destinations and town centres should enhance
security and surveillance in the area. However, it will also create more opportunity for
crime if not adequately managed through London Plan policy and other mechanisms.
Supporting the area with new cultural destinations and town centres should enhance
security and surveillance in the area. However, it will also create more opportunity for
crime if not adequately managed through London Plan policy and other mechanisms.
Supporting the area with a metropolitan town centre should enhance security and
surveillance in the area. However, it will also create more opportunity for crime if not
adequately managed through London Plan policy and other mechanisms.
Supporting the area with a district and neighbourhood town centre should enhance
security and surveillance in the area. However, it will also create more opportunity for
crime if not adequately managed through London Plan policy and other mechanisms.
Supporting the area with a district and neighbourhood town centre should enhance
security and surveillance in the area. However, it will also create more opportunity for
crime if not adequately managed through London Plan policy and other mechanisms.
This option may see town centre uses dispersed across Park Royal. If not supported to
by public realm and building design improvements set out in the Places Chapter, this may
have a negative impact on safety and fear of crime.
The optimisation of development in the town centres, including facility security and
strategic infrastructure that could improve traffic management, could lead to benefits
against this objective through improved safety.
The optimisation of development in the town centres, including facility security and
strategic infrastructure that could improve traffic management, could lead to benefits
against this objective through improved safety.
The optimisation of A-class development, including facility/customer security and
strategic infrastructure that could improve traffic management, could lead to benefits
against this objective through improved safety.
The optimisation of A-class development, including facility/customer security and
strategic infrastructure that could improve traffic management, as there will be more
incoming traffic due to increased retail use. This could lead to benefits against this
objective through improved safety.

S,M,L-T,
D,R,H

TC1

+/- S,M,L-T,
I,R,M

OPDC and
surrounding
area
M.L-T, I, R, L OPDC and
surrounding
area
M,L-T, I, R, M OPDC and
surrounding
area
M,L-T, I, R, M OPDC and
surrounding
area
M,L-T, I, R, M OPDC and
surrounding
area
S,M,L-T,
OPDC area
I,R,M

TC2

+/-

TC2
Option 1

+/-

TC2
Option 2

+/-

TC2
Option 3

+/-

TC2
Option 4

TC3

M, L-T, I, R, L London wide

TC3
Option 1

M, L-T, I, R, L London wide

TC4

M, L-T, I, R, L London wide

TC4
Option 1

M, L-T, I, R, L London wide

145

IIA Objective

Performance of Temporal
Policy
Scale
Nature of
Impact

Geographical
Extent

Commentary and Recommendations

TC5

London wide

TC5
Option 1
TC6

A new leisure facility should provide high level security and natural surveillance to
increase the safety of the users.
A new leisure facility should provide high level security and natural surveillance to
increase the safety of the users.
Visitor accommodation should provide high level security and natural surveillance to
increase the safety of their guests. The accommodation will attract more visitors with
uncertain effects on crime.
Security is an important aspect of night-time uses. The safety and wellbeing of local
residents and users at drinking establishments must have high security and surveillance
in place during and after operating hours. Imposing hours for trade may help prevent
crime but the certainty is low.
The policy makes it clear that OPDC will support proposals for town centres uses that
promote social and economic regeneration and healthy lifestyles. Town centre uses can
also promote healthy lifestyles and OPDCs role as a Healthy New Town.

TC7

15

Page 650

Maximise the
TC1
health and
wellbeing of the
population,
reduce
TC2
inequalities in
health and
promote healthy
living
TC2
Option 1
TC2
Option 2
TC2
Option 3
TC2
Option 4

M, L-T, I, R,
M
M, L-T, I, R,
M

London wide

+/- S,M,L-T, I,R,L OPDC area

S,M,L-T,
I,R,M

OPDC area

S, M, L-T, I,
R, L

S, M, L-T, I,
R, M
S, M, L-T, I,
R, M
S, M, L-T, I,
R, M
S, M, L-T, I,
R, M

OPDC area
and
surrounding
boroughs.
OPDC area

+
+
-

New town centre development and maintenance of existing centres could contribute to
meeting the need for homes as well as the provision of health centres contributing to the
achievement of benefits against this objective.

OPDC are

Old Oak High Street as a metropolitan centre could provide and attract additional social
infrastructure such as health centres.
Old Oak District Centre could provide social infrastructure such as health centres.

OPDC area

Old Oak District Centre could provide social infrastructure such as health centres.

OPDC and
surrounding
area.

Not using Park Royal as a Neighbourhood Centre may mean employees and residents
would have to travel further for their health services. It would also see the loss of well
used existing local services over time.

TC3

S, M, L-T, D, London wide

R, H

TC3
Option 1

S, M, L-T, D, OPDC area

R, L

As explained in the policy the London Plan (2015) policies 2.15 and 4.8 support
proposals that sustain and enhance the viability of a town centre, promote healthy living,
support and enhance the competitiveness, quality and diversity of town centre uses and
that contribute towards enhancing the public realm.
The option would have perceptual significant negatives as it could result in the
proliferation of these uses and would not promote OPDCs role as a healthy new part of
146

IIA Objective

Page 651
16

Performance of Temporal
Policy
Scale
Nature of
Impact

Geographical
Extent

TC4

S, M, L-T, I,
R, M

OPDC area

TC4
Option 1

S, M, L-T, I,
R, M

OPDC area

TC5

++ S, M, L-T, D, OPDC and

R, H
London wide

TC5
Option 1

TC6
TC7

0
+

To improve the TC1

education and
skills levels of all
members of the
population,
TC2
particularly
vulnerable
groups
TC2
Option 1

S, M, L-T, D, OPDC and

R, M
London wide

S, M, L-T, I,
R, M

OPDC area

S, M, L-T, I,
R, L

S, M, L-T, I,
R, L

S, M, L-T, I,
R, L

OPDC area
and
surrounding
boroughs.
OPDC area
and
surrounding
boroughs.
OPDC area
and
surrounding
boroughs.

Commentary and Recommendations

London.
The policy seeks to facilitate the supply of local food through the provision of space for
uses such as allotments or farmers markets and reduce the potential for an overconcentration of hot food takeaways in the local area. This should contribute to benefits
against the objective.
.A strong retail focus with accompanying eating establishments would not have a direct
effect on the health of the community but a facility that supports the need of the user
should improve healthy living. From a retail perspective, this would be more likely to be
achieved through greater active uses.
Culture, sports and leisure facilities will be expected to cater for a range of incomes,
particularly those in low incomes who are often excluded from access to such facilities or
whose choice is often limited. This will be especially important for access to sports
facilities. There is a direct correlation between income deprivation and obesity and as a
healthy new London quarter, OPDC is keen to ensure that there is access for all to new
sports facilities for local communities and OPDC will seek to secure a proportion of
affordable sports and leisure provision.
OPDC is keen to ensure that there is access for all to new sports facilities for local
communities and OPDC will seek to secure a proportion of affordable sports and leisure
provision. However, the option imposes a limit on these uses.
The option will not directly contribute to benefits against this objective.
Seeking to manage the hours of operation of evening and night time economy uses
would help to manage the impact on building user amenity and users health and wellbeing.
New town centre development and maintenance of existing centres could contribute to
meeting the need for homes as well as the provision of new schools contributing to the
achievement of benefits against this objective.
The provision of retail space will help to generate new job and skills development
opportunities that will benefit local people.

The provision of a greater amount of retail space within a metropolitan centre will help to
generate new job and skills development opportunities that will benefit local people.

147

IIA Objective

Performance of Temporal
Policy
Scale
Nature of
Impact
TC2
+ S, M, L-T, I,
Option 2
R, L

Commentary and Recommendations

OPDC area
and
surrounding
boroughs.
OPDC area
and
surrounding
boroughs.

The provision of retail space will help to generate new job and skills development
opportunities that will benefit local people.

Page 652

TC2
Option 3

TC2
Option 4
TC3
TC3
Option 1
TC4

The option will not directly contribute to benefits against this objective.

0
0

The policy will not directly contribute to benefits against this objective.
The option will not directly contribute to benefits against this objective.

TC4
Option 1
TC5

TC5
Option 1
TC6

17

Geographical
Extent

TC7
Maximise the
TC1
social and
economic
wellbeing of the

S, M, L-T, I,
R, L

S, M, L-T, I,
R, L

OPDC area
and
surrounding
boroughs.

The delivery of new A Use Class development will help to generate new job and skills
development opportunities that will benefit local people.

The option will not directly contribute to benefits against this objective.

++ S, M, L-T, D, London wide

R, H

The provision of retail space will help to generate new job and skills development
opportunities that will benefit local people.

S, M, L-T, D,
R, H
S, M, L-T, I,
R, L

0
++ S,M,L-T,
I,R,M

OPDC and
London wide
OPDC area
and
surrounding
boroughs.
OPDC area

The Mayors Cultural Strategy promotes London as the worlds cultural capital and how
this role can help widen the reach of and access to culture, support education skills and
careers and enhance the physical environment. The delivery of new cultural, sports and
leisure facilities will help to generate new job and skills development opportunities that
will benefit local people.
The option will offer leisure and sports education in the area.
The delivery of new visitor accommodation will help to generate new job and skills
development opportunities that will benefit local people.

The option will not directly contribute to benefits against this objective.
Town centre uses can also add to the economic prosperity of an area, helping to provide
a range of employment opportunities over a wide range of sectors and skill levels. Town
centre uses will play a critical role in achieving this, providing new employment and
services and adding vibrancy and activity. To support these centres, employment and
148

IIA Objective

Performance of Temporal
Policy
Scale
Nature of
Impact

Geographical
Extent

local and
regional
population and
improve access
to employment
and training

Commentary and Recommendations

residential uses will also be supported as part of the mix of uses, which can help to
increase footfall and add to vibrancy and vitality. New town centre uses will also play a
critical role in overcoming the socio-economic deprivation experienced in and around the
OPDC area by providing a range of new opportunities for employment and training across
a breadth of sectors.

Page 653

TC2

++ S,M,L-T,
I,R,H

OPDC area

TC2
Option 1

++ S,M,L-T,
I,R,H

OPDC area

TC2
Option 2

S,M,L-T,
I,R,H

OPDC area

TC2
Option 3

S,M,L-T,
I,R,H

OPDC area

TC2
Option 4
TC3

+/- S,M,L-T,I,R,L OPDC area

TC3
Option 1
TC4

+/- S,M,L-T,I,R,M OPDC area

S,M,L-T,I,R,M OPDC area

S, M, L-T, I,
R, L

OPDC area
and
surrounding
boroughs.

As explained in the policy the London Plan Policy 2.15 promotes the designation of new
town centres, giving priority to areas with a need for regeneration and better access to
services, facilities and employment, which is true for both Old Oak and Park Royal which
are identified as Opportunity Areas (Policy 2.13).
As explained in the policy the London Plan Policy 2.15 promotes the designation of new
town centres, giving priority to areas with a need for regeneration and better access to
services, facilities and employment, which is true for both Old Oak and Park Royal which
are identified as Opportunity Areas (Policy 2.13). The delivery of a metropolitan centre
will help to further deliver this guidance.
As explained in the policy the London Plan Policy 2.15 promotes the designation of new
town centres, giving priority to areas with a need for regeneration and better access to
services, facilities and employment, which is true for both Old Oak and Park Royal which
are identified as Opportunity Areas (Policy 2.13). The delivery of a district and
neighbourhoods centre may not deliver the same level of benefits as a major centre.
As explained in the policy the London Plan Policy 2.15 promotes the designation of new
town centres, giving priority to areas with a need for regeneration and better access to
services, facilities and employment, which is true for both Old Oak and Park Royal which
are identified as Opportunity Areas (Policy 2.13). The delivery of a district and
neighbourhoods centre may not deliver the same level of benefits as a major centre.
This option could see the dispersal of services across Park Royal limiting their access.
The policy promotes vibrancy that can attract inward investment which is a positive for
socio-economic wellbeing.
The option states that the vibrancy will attract investment but the proliferation of these
types of business may detract potential investors.
The delivery of new A Use Class development will help to generate new job and skills
development opportunities that will benefit local people.

149

IIA Objective

Performance of Temporal
Geographical
Policy
Scale
Extent
Nature of
Impact
TC4
0
Option 1
TC5
++ S, M, L-T, D, London wide
R, H

TC5
Option 1
TC6

Page 654

TC7

18

To encourage
TC1
inward
investment
alongside
investment
TC2
within existing
communities, to
create
sustainable
economic growth TC2
Option 1

+
+

S, M, L-T, D,
R, H
S, M, L-T, I,
R, L

+/- S,M,L-T,
I,R,M

OPDC and
London wide
OPDC area
and
surrounding
boroughs.
OPDC area

Commentary and Recommendations

The option will not directly contribute to benefits against this objective.
The Mayors Cultural Strategy promotes London as the worlds cultural capital and how
this role can help widen the reach of and access to culture, support education skills and
careers and enhance the physical environment. The delivery of new cultural, sports and
leisure facilities will help to generate new job and skills development opportunities that
will benefit local people.
The option will offer leisure and sports education in the area.
The delivery of new visitor accommodation will help to generate new job and skills
development opportunities that will benefit local people.

Operational hours may have an effect on employment resource required at the venues. A
new facility could create employment opportunities for the local people. The policy also
ensures proposals would not result in harmful cumulative impacts in association with
other late licensed properties leading to loss of employment.

++ S,M,L-T,
I,R,M

London wide

The policy emphasises Londons growing needs and the role that these town centre
facilities can play in promoting economic prosperity and maintaining Londons status as
one of the worlds greatest cities.

Nationwide

As explained in the policy the NPPF should consider the impact of the proposal on
existing, committed and planned investment in nearby centres within its catchment and
the impact of the proposal on the vitality and viability of nearby centres. The NPPF
requires local authorities to define a network and hierarchy of centres that is resilient to
anticipated future economic changes. This options meets this requirement.
This option could impact on the vitality and viability of the surrounding town centre
hierarchy. It may also dilute investment in other centres and could also impact on a wider
catchment and a greater number of town centres in West London. However, Old Oak
High Street should see direct investment opportunities which may act as a catalyst for the
OPDC area.

S,M,L-T,
I,R,H

+/- S,M,L-T,
I,R,M

London wide

150

IIA Objective

Performance of Temporal
Policy
Scale
Nature of
Impact
TC2
+/- S,M,L-T,
Option 2
D,R,H

Geographical
Extent

Commentary and Recommendations

OPDC and
surrounding
areas

TC2
Option 3

OPDC area

There is a significant opportunity for the land uses around the Old Oak Common station
to attract interchangers into the surrounding hinterland and to help activate the place and
capture economic benefits for the area and its hinterland. This opportunity would be
limited through the designation of a Neighbourhood Centre here, rather than a Major
Centre.
Old Oak and the station should see direct investment opportunities which may act as a
catalyst for the OPDC area. The designation of a Neighbourhood Centre may limit
opportunity.
Park Royal should see direct investment opportunities which may act as a catalyst for
the OPDC area.
The policy could lead to indirect positive effects against this objective, as an improvement
to the aesthetics and vibrancy could improve the attractiveness of the town centres to
inward investors.
The vibrancy of the location could lead to positive effects against this objective but the
proliferation of the use may detract potential investment.

TC2
Option 4
TC3

Page 655

TC3
Option 1
TC4

+/- S,M,L-T,
D,R,H
+

S,M,L-T,
Park Royal
D,R,H
+ M, L-T, I, R, L OPDC area
and London
wide
+/- M, L-T, I, R, L OPDC area
and London
wide
+/- S,M,L-T,
OPDC and
I,R,M
surrounding
areas

TC4
Option 1
TC5

TC5
Option 1

S,M,L-T,
D,R,M

TC6

S,M,L-T,
D,R,H

TC7

++ S,M,L-T,
D,R,H

S,M,L-T,
I,R,M
S,M,L-T,
D,R,M

OPDC area
OPDC and
surrounding
areas
OPDC and
surrounding
areas
OPDC and
surrounding
area
OPDC and
surrounding
area

The policy states that if you provide too much A-class floorspace, units could remain
vacant or the uses could start to draw significant levels of trade away from the
surrounding retail hierarchy and existing community. This could have a detrimental effect
on the local economy. However, more a-class uses in the town centres will bring
investment and incentives for businesses to move into the area.
More a-class uses, especially retail, in OPDC will bring investment and incentives for
businesses to move into the area.
More facilities may provide inward investment and community benefits for the area.

More facilities may provide inward investment and community benefits for the area.

More high quality visitor accommodation businesses will attract investment into the area
which help create and build sustainable economic growth in the OPDC and surrounding
area.
The policy supports the role that eating and drinking establishments and culture, sports
and leisure uses can play in contributing to the vibrancy and vitality of the OPDC area
and adding activity to the public realm and supporting the local economy. The operating
151

IIA Objective

Performance of Temporal
Policy
Scale
Nature of
Impact

Geographical
Extent

Commentary and Recommendations

hours should benefit the local community and develop economic growth in the area.

Page 656
152

Table G-8 Chapter 10: Social Infrastructure

x SI1: Strategic Policy: Social infrastructure
x SI2: Educational
x SI3: Health
x SI4: Community facilities
x SI5: Public houses
IIA Objective

Performance of Temporal
Policy
Scale
Nature of
Impact

To enhance the SI1

built environment
and encourage
place-making SI1
Option 1

Page 657

Commentary and Recommendations

OPDC area

The policy seeks to improve social infrastructure and upgrade existing facilities. The scale
of development in Old Oak and Park Royal should enhance the built environment in the
area.
The policy states that new place-making would be enhanced by new social infrastructure
delivering a range of community facilities on-site in earlier development phases.
However, the early provision may be isolated from existing communities.
The scale of the development and higher education facilities in the area may promote
OPDC as an appropriate location and may act as a catalyst for regeneration and creating
a greater sense of place.
The option does not promote OPDC as an appropriate location for an educational facility
and therefore does not recognise this potential catalyst for regeneration and creating a
greater sense of place.
The policy seeks to support development in Old Oak and Park Royal as a Healthy New
Town which could contribute to enhancing the built environment and encouraging place
making.
The policy emphasises the importance of community facilities in place-making specifically
in the OPDC area creating key hubs of activity and focal points for the neighbourhood.
As a place of social, community focused and entertainment, protection of public houses
can be seen as a crucial aspect of maintaining and contributing towards place-making.
Vacant pubs could be more likely to be lost to other uses if there is no policy to protect
their retention for community uses.
The policy promotes the co-location and multifunctionality of social infrastructure which
will to make the most efficient use of land and optimise the development of brownfield
land, which could have direct significant benefits against this objective.
On-site development rather than expanding to surrounding existing facilities may increase
building densities.
There is no direct link to this IIA Objective.
There is no direct link to this IIA Objective.

S-T,I,R,L

S, M, L-T, D, OPDC area

R, L

SI2

M-T, I, IR, L

OPDC area

SI2
Option 1

M-T, I, IR, L

OPDC area

SI3

S,M,LT,D,R,M

OPDC area

SI4

++ S, M, L-T, D, OPDC area

R, M
++ S-T, D, R, M OPDC area

SI5

Geographical
Extent

SI5
Option 1
To optimise the SI1
efficient use of
land through
increased
SI1
development
Option 1
densities and
SI2
building heights, SI2

S-T, D, R, M OPDC area

++ S, M, L-T, D, OPDC area

R, M
++ S, M, L-T, D, OPDC area
R, M
0 N/A
OPDC area
0 N/A
OPDC area

153

IIA Objective

Page 658
4

Performance of Temporal
Geographical
Policy
Scale
Extent
Nature of
Impact
Option 1
where
appropriate
SI3
++ S,M,L-T,
OPDC area
D,R,M
SI4
+ S,M,LOPDC area
T,D,R.L
SI5
0
SI5
0
Option 1
SI1
Maximise the
++ S, M, L-T, D, OPDC area
reuse of
R, M
previously
SI1
+ S, M, L-T, D, OPDC area
developed land Option 1
R, M
and existing
SI2
+ S-T, D,IR,M OPDC area
buildings,
including the
remediation of SI2
+ S-T, D,IR,M OPDC area
contaminated
Option 1
land
SI3
+ S,M,L-T,I,IR,L OPDC and
surrounding
area
SI4
+ S,M,L-T,I,IR,L OPDC and
surrounding
area
SI5
+ S,M,L-T,I,R,L London wide
and national
SI5
+ S,M,LOPDC area
Option 1
T,D,IR,L
SI1
Minimise the
+ L-T, I, R, M London-wide
need to travel,
and national
improve
SI1
+ S, M, L-T, D, OPDC area
accessibility for Option 1
R, L
all users by
public and non- SI2
++ S,M,LOPDC and
motorised
T,D,R,M
surrounding
transportation
area.

Commentary and Recommendations

Co-location of health facilities with other uses will increase development densities.
Co-location of community facilities with other uses will increase development densities.
This option would not bring any benefits for the objective.
This option would not bring any benefits for the objective.
The policy objectives enhance existing educational provision and promote co-location
which could have direct significant benefits against this objective.
Providing new social infrastructure on-site would help meet this objective if the land is
previously developed.
The policy seeks to look at existing schools for expansion opportunities as well as
securing new sites for schools. These objectives will likely result in re-use of previously
developed land and of existing buildings.
The option does not promote OPDC as an appropriate location for an educational facility.
There is no direct link to this SA Objective.
Colocation of health facilities with other users with prevent the use of greenfield space
and increase the use of previously developed land.
Colocation of community facilities with other users with prevent the use of greenfield
space and increase the use of previously developed land.
The policy clearly states that National, regional and local planning authorities seek to
safeguard valued community assets. This would help maintain the use of these buildings.
This option could lead to the re-use of vacant buildings for other uses, however, these
uses may not offer the same benefit in terms of a community asset.
Development in OPDC and London could provide improved accessibility to new and
improved social infrastructure.
The policy demonstrates benefits on the transport network as new residents would not
have to travel as far to access community uses. However, the early provision may be
isolated from existing communities.
The policy seeks to increase the co-location of education services and facilities as part of
developments therefore improving accessibility and mitigating impacts on the transport
network in the area.
154

IIA Objective

Performance of Temporal
Policy
Scale
Nature of
Impact
SI2
methods and
++ S,M,Lmitigate impacts Option 1
T,D,R,M
on the transport SI3
++ S,M,L-T,
network
SI4

Page 659
6

SI5
SI5
Option 1
Improve access SI1
to well designed, SI1
well-located,
Option 1
market,
SI2
affordable and SI2
inclusive housing Option 1
of a range of
SI3
types and
SI4
tenures, to meet SI5
identified local SI5
needs
Option 1
Improve climate SI1
change
adaptation and
mitigation,
including
SI1
minimising the Option 1
risk of flooding
and addressing
the heat island SI2
effect
SI2
Option 1
SI3

Geographical
Extent

Commentary and Recommendations

OPDC area

0
0

The option does not promote OPDC as an appropriate location for an educational facility.
There is no direct link to this SA Objective.
Facilities should be located in designated town centres and close to areas of high public
transport access, as well as providing facilities with multiple uses, which would be easily
accessible and visible for members of the public.
OPDC will secure a range of new high quality community facilities that are located at key
destination points within the OPDC area, close to destinations of high footfall and high
public transport access, leading to benefits against this objective.
There is no direct relationship between objective and policy.
There is no direct relationship between objective and policy.

0
0

The policy does not directly affect the objective.

The policy does not directly affect the objective.

0
0

The provision of education does not affect access to housing.

There is no direct relationship between the access to housing objective and the provision
of education.
The policy does not directly affect the objective.
The policy does not directly affect the objective.
The use of public houses does not directly support access to different housing types.
There is no direct relationship between objective and policy.

++ S,M,L-T,

OPDC area

OPDC area

0
0
0
0
+

L-T, I, R, L

L-T, I, R, L

0
0
0

OPDC area
and
surrounding
boroughs
OPDC area
and
surrounding
boroughs

High quality design of social infrastructure may enable buildings to adapt to the changing
climate including natural ventilation, temperature adaptation and minimise the risk of
flooding on site.
High quality design of social infrastructure may enable buildings to adapt to the changing
climate including natural ventilation, temperature adaptation and minimise the risk of
flooding on site.
The choice of land use for education will not have an effect on the objective surrounding
climate change issues.
The choice of land use for education will not have an effect on the objective surrounding
climate change issues.
The policy does not directly affect the objective.
155

IIA Objective

Page 660
8

To minimise
contributions to
climate change
through greater
energy
efficiency,
generation and
storage; and to
reduce reliance
on natural
resources
including fossil
fuels for
transport,
heating and
energy

To minimise
production of
waste across all
sectors in the
plan area,

Performance of Temporal
Policy
Scale
Nature of
Impact
SI4

SI5
SI5
Option 1
SI1

0
0

S,M,L-T, I, IR, OPDC area

L

OPDC area

S, M, L-T, I,
IR, L

SI1
Option 1

S, M, L-T, I,
IR, L

SI2

S, M, L-T, I,
IR, L

SI2
Option 1
SI3

0
+

SI4

SI5
SI5
Option 1
SI1

0
0
+

Geographical
Extent

OPDC area
and
surrounding
boroughs
OPDC area
and
surrounding
boroughs
OPDC area
and
surrounding
boroughs

Commentary and Recommendations

Design measures may include improvements to energy efficiency, which could lead to
further benefits against this objective in accordance with Preferred Policy Options for the
Environment and Utilities policies.
There is no direct relationship between objective and policy.
There is no direct relationship between objective and policy.
A lesser need to travel to community facilities should reduce carbon emissions and make
a contribution to tackling climate change. High quality design could also provide benefits
in relation to this objective.
A lesser need to travel to community facilities should reduce carbon emissions and make
a contribution to tackling climate change. High quality design could also provide benefits
in relation to this objective.
A lesser need to travel to education facilities should reduce carbon emissions and make a
contribution to tackling climate change. High quality design could also provide benefits in
relation to this objective.
The policy does not directly affect the objective.

S,M,L-T, I, IR, OPDC area

L
S,M,L-T, I, IR, OPDC area
L

The provision and co-location of facilities could reduce the need to travel leading to
benefits against this objective.
The provision and co-location of facilities in areas with high footfall and public transport
access could reduce the need to travel leading to benefits against this objective. Design
measures may include improvements to energy efficiency, which could lead to further
benefits against this objective, although these measures are not specified in the policy or
supporting text.
There is no direct relationship between objective and policy.
There is no direct relationship between objective and option.

S,M,L-T, D,
IR, L

High quality design with the selection of sustainable materials for new buildings could
contribute to higher recovery rates and minimise the production of waste. The expansion
of existing facilities and the use of facilities for multiple uses could create efficiencies in
the use of construction resources.

OPDC area

156

IIA Objective

Performance of Temporal
Policy
Scale
Nature of
Impact

Page 661

maximise
efficiencies for
transporting
waste and
SI1
increasing rates Option 1
of re-use,
SI2
recycling and
recovery rates
as well as
composting of all
green waste
SI2
Option 1
SI3
SI4

Improve the
quality of the
water
environment

Geographical
Extent

New development should promote the consideration of recycled materials for the
construction of the building can help minimise waste as considered in Preferred Policy
Options on Waste.
There is no direct relationship between the policy and the objective surrounding waste
minimisation.
High quality design with the selection of sustainable materials for new buildings could
contribute to higher recovery rates and minimise the production of waste.

0
0

0
0
+

SI5

SI5
Option 1
SI1

SI1
Option 1
SI2
SI2
Option 1
SI3
SI4
SI5
SI5

Commentary and Recommendations

S,M,L-T, D,
IR, L

S,M,L-T, D,
IR, L
S,M,L-T, D,
IR, L

OPDC area

New development should promote the consideration of recycled materials for the
construction of the building can help minimise waste as considered in Preferred Policy
Option on Waste.
There is no direct relationship between the policy and the objective surrounding waste
minimisation.
There is no direct relationship between objective and policy.
High quality design with the selection of sustainable materials for new buildings could
contribute to higher recovery rates and minimise the production of waste.

OPDC area

New development should promote the consideration of recycled materials for the
construction of the building can help minimise waste as considered in Preferred Policy
Option on Waste.
The re-use of vacant pubs could reduce the need for materials in new development.

OPDC area

The re-use of vacant pubs could reduce the need for materials in new development.

0
0

There is no direct relationship between the option and the objective surrounding the
quality of the water environment.
There is no direct relationship between the option and the objective surrounding the
quality of the water environment.
There is no direct relationship between the objective and policy.
There is no direct relationship between the objective and policy.

0
0
0
0

There is no direct relationship between objective and policy.

There is no direct relationship between objective and policy.
There is no direct relationship between objective and policy.
There is no direct relationship between objective and policy.
157

IIA Objective

10

Page 662

11

Create and
enhance
biodiversity and
the diversity of
habitats across
the area and its
surroundings

Performance of Temporal
Policy
Scale
Nature of
Impact
Option 1
SI1
0
SI1
Option 1
SI2

SI2
Option 1
SI3

SI4

SI5

SI5
Option 1
To minimise air, SI1
noise and light
pollution,
particularly for
vulnerable
SI1
groups
Option 1

Geographical
Extent

OPDC area

There is no direct relationship between the option and the objective surrounding
biodiversity issues.
There is no direct relationship between the option and the objective surrounding
biodiversity issues.
There is no direct relationship between the option and the objective surrounding
biodiversity issues.
There is no direct relationship between the option and the objective surrounding
biodiversity issues.
There is no direct relationship between objective and policy.

OPDC area

There is no direct relationship between objective and policy.

OPDC area

There is no direct relationship between objective and policy.

OPDC area

There is no direct relationship between objective and policy.

0
+

S,M,L-T,
D,R,L
S,M,L-T,
D,R,L
S,M,L-T,
D,R,L
S,M,L-T,
D,R,L
S, M, L-T, D,
IR, L

Commentary and Recommendations

OPDC area
and
surrounding
boroughs
S, M, L-T, D, OPDC area
IR, L
and
surrounding
boroughs
S, M, L-T, D, OPDC area
IR, L

SI2

SI2
Option 1
SI3

N/A

S, M, L-T, D, OPDC area

IR, L

SI4

S,M,L-T,

N/A

OPDC area

High public transport access and the co-location of facilities may minimise air, noise and
light pollution through the use of more sustainable modes of transport.

High public transport access and the co-location of facilities may minimise air, noise and
light pollution through the use of more sustainable modes of transport.

The policy seeks to increase the co-location of education services and facilities as part of
developments therefore improving accessibility and mitigating impacts on the transport
network in the area, which could improve pollution impacts
There is no direct relationship between objective and policy.
Facilities should be located in accessible locations as well as providing facilities with
multiple uses, which would be easily accessible and visible for members of the public.
This could help to reduce potential pollution impacts.
OPDC will secure a range of new high quality community facilities that are located at key
destination points within the OPDC area, close to destinations of high footfall and high
158

IIA Objective

12

Performance of Temporal
Policy
Scale
Nature of
Impact

Geographical
Extent

SI5

OPDC area

public transport access, leading to benefits against this objective.

There is no direct relationship between objective and policy.

OPDC area

There is no direct relationship between objective and policy.

OPDC area
and
surrounding
boroughs

The promotion of high quality design could provide some benefits against this objective.

SI5
Option 1
To conserve and SI1
enhance the
historic
environment,
heritage assets
and their settings SI1
Option 1

Page 663
Increase
community
cohesion and
reduce social
exclusion to

0
+

S,M,LT,D,R,L
S,M,L-T,
D,R,L
S, M, L-T, D,
IR, L

S, M, L-T, D, OPDC area

IR, L
and
surrounding
boroughs
S, M, L-T, D, OPDC area
IR, L
and
surrounding
boroughs

New community uses and the provision of social infrastructure in Old Oak and Park Royal
should seek to preserve any historic features and heritage assets in the area as
considered in Preferred Policy Option on Heritage.
The promotion of high quality design could provide some benefits against this objective.
.

SI2

SI2
Option 1
SI3
SI4

There is no direct relationship between objective and policy.

+
+

The promotion of high quality design could provide some benefits against this objective.
The promotion of high quality design could provide some benefits against this objective.

SI5

13

Commentary and Recommendations

S,M,L-T,I,R,M OPDC area

S,M,LOPDC area
T,D,R,M
++ S-T, D, R, M London wide

SI5
Option 1

+/- S-T, D, R, M OPDC area

SI1

++ S, M, L-T, I,
R, L

West London
and London
wide

The promotion of high quality design could provide some benefits against this objective.

OPDC considers that pubs can act as hubs for community life bringing activity to high
streets and can provide heritage value. The preservation of existing and creation of new
public houses in Old Oak and Park Royal should seek to preserve any historic features
and heritage assets in the area as considered in Preferred Policy Option on Heritage...
This policy allows for optimisation of development of sites occupied by public houses.
This may have an effect on the historic environment adjacent and surrounding the site,
although design measures elsewhere in the Local Plan could seek to reduce this effect.
The policy has the potential to increase community cohesion, unite diverse groups and
support the community and welfare through its approach to safeguarding existing
infrastructure and creating new community facilities to meet the needs of the local
residents and all members of the community and in particular the protected
characteristics. Management of the construction process to reduce the impact of a
159

IIA Objective

Performance of Temporal
Policy
Scale
Nature of
Impact

encourage a
sense of
community and SI1
welfare
Option 1
SI2

Page 664

SI2
Option 1
SI3

14

Improve safety
and reduce
crime and the
fear of crime

S,M,L-T,
D,R,M

++ S,M,L-T, D,
R, H

Geographical
Extent

OPDC area

OPDC area

0
S,M,L-T,
D,R,H

OPDC area

SI4

++ S,M,L-T,
D,R,H

OPDC area

SI5

++ S,M,L-T,
OPDC area
D,R,H
- S,M,L-T,
OPDC area
D,R,M
+ M, L-T, I, R, L London wide

SI5
Option 1
SI1
SI1
Option 1
SI2
SI2
Option 1
SI3
SI4
SI5

Commentary and Recommendations

potentially large transitory construction workforce on the local community, specifically in

relation to social infrastructure may have a positive effect on the community
This option would not help to knit the residents, diverse groups and employees on early
sites with the existing community and may leave these sites feeling isolated in early
years.
The policy seeks to promote OPDC as a location for education whilst helping the area
and the wider economy. This will have many benefits to the community, increase
cohesion, bring diverse groups together and takes into account the increase in
population. Physically, the policy should look to improve the quality of the public realm,
open spaces and the connectivity to the development as considered in Preferred Policy
Options for Design.
The policy does not promote OPDC as a location for education. There is no direct
relationship between objective and policy.
The policy seeks to secure adequate health provision. This will have many benefits to the
community, increase cohesion, bring diverse groups together and takes into account the
increase in population.
The policy seeks to ensure that development in Old Oak and Park Royal is supported by
adequate community facilities to cater for all resident groups, such as libraries, places of
worship, halls for hire, youth space and training and meeting space. These facilities will
increase community cohesion, consider people with a protected characteristic and
encourage a sense of welfare.
OPDC considers that pubs can act as hubs for community life. They provide a social
space for entertainment purposes and promote community cohesion
This option may result in the loss of pubs that provide a valued community facility.

0
0

The provision of social infrastructure and services (i.e. police, fire and health) may help
prevent crime and create safer communities.
The provision of community facilities and services may help prevent crime and create
safer communities.
There is no direct relationship between objective and policy.
There is no direct relationship between objective and policy.

0
0
0

There is no direct relationship between objective and policy.

There is no direct relationship between objective and policy.
There is no direct relationship between objective and policy.

M, L-T, I, R, L OPDC area

160

IIA Objective

15

Performance of Temporal
Policy
Scale
Nature of
Impact
SI5
0
Option 1
SI1
++ S, M, L-T, I,
R, L

Maximise the
health and
wellbeing of the
population,
reduce
inequalities in
health and
promote healthy SI1
living
Option 1
SI2

Page 665

SI2
Option 1
SI3

16

To improve the
education and
skills levels of all
members of the
population,

++ S, M, L-T, I,
R, L
+ S,M,L-T,
D,R,M
0

Geographical
Extent

Commentary and Recommendations

There is no direct relationship between objective and policy.

OPDC area
and
surrounding
boroughs.

OPDC area
OPDC area

The future population in the OPDC area will need to be supported by adequate provision
of social infrastructure to meet the requirements of the community. This will also increase
the capacity of local social infrastructure.
The scale of development in Old Oak and Park Royal provides substantial opportunities
to upgrade existing facilities and to provide new state of the art facilities demonstrating
best-practice in terms of the provision of social infrastructure. This policy could have
benefits for health.
Closer healthcare facilities may help reduce inequalities in health and promote healthy
living.
Educational facilities could help the health and wellbeing of the community through
increased knowledge and accessibility by sustainable modes of transport.
There is no direct relationship between objective and policy.

++ S,M,L-T,
D,R,L

OPDC and
surrounding
area.

The future population in the OPDC area will need to be supported by adequate provision
of healthcare. Healthcare facilities and social care will protect the health and wellbeing of
the local community. As a Healthy New Town there will be an integrated approach to
encouraging healthy living.

SI4

S,M,L-T,
D,R,M

OPDC area

The policy seeks to deliver community facilities that are collocated where feasible and
encourage opportunities for buildings with a shared community use and the co-location of
services. This could have benefits for health and wellbeing.

SI5

S,M,L-T,
D,R,H

OPDC area

SI5
Option 1

S,M,L-T,
D,R,H

OPDC area

SI1

The policy states that OPDC consider that pubs can act as hubs for community life, which
is important for mental health and wellbeing. As a Healthy New Town OPDC proposes
that the Local Plan looks to protect its public houses, subject to their continuing viability.
The policy states that OPDC consider that pubs can act as hubs for community life, which
is important for mental health and wellbeing. The loss of such facilities could have
negative effects on health.
There is no direct relationship between objective and policy.

SI1
Option 1
SI2

M, L-T, I, R, L OPDC area

++ S,M,L-T,

OPDC area

There is no direct relationship between objective and policy.

Closer educational facilities within the existing community may increase the availability of
161

IIA Objective

particularly
vulnerable
groups

Performance of Temporal
Policy
Scale
Nature of
Impact
D,R,H
SI2
Option 1
SI3
SI4

17

Page 666
18

Maximise the
social and
economic
wellbeing of the
local and
regional
population and
improve access
to employment
and training

To encourage
inward
investment
alongside
investment

Geographical
Extent

SI5
SI5
Option 1
SI1

formal education for all age groups and adults from all equality groups.

S,M,L-T,
D,R,H
++ S,M,L-T,
D,R,H
+ S,M,L-T,
D,R,L
0
0

OPDC area

Social Infrastructure may provide access to a range of high quality local employment
OPDC area,
West London, opportunities and community services.
London wide
OPDC area
On-site social infrastructure may provide easier access to a range of high quality local
employment opportunities and community services.
OPDC area
The opportunity to promote OPDC as a location for new and enhanced education
facilities will improve the social wellbeing of the community by providing employment and
training opportunities.
OPDC area
The policy option would not directly promote higher education uses, but does not
preclude them so this may not improve the social wellbeing of the community by
providing employment and training opportunities.
OPDC area
Any new healthcare facility will provide an opportunity for local employment during
construction or operation of the development.
OPDC area
Any new community facility will provide an opportunity for local employment during
construction or operation of the development
OPDC area
The policy states that OPDC considers that pubs can act as hubs for community life and
provide economic benefits by providing jobs.
This policy could result in the loss in viable existing businesses.

S, M, L-T, I,
R, L

SI1
Option 1
SI2

++ S, M, L-T, I,
R, L
++ S,M,L-T,
D,R,H

SI2
Option 1

S,M,L-T,
D,R,L

SI3

SI4

SI5

S,M,L-T,
D,R,M
S,M,L-T,
D,R,M
S,M,L-T,
D,R,H

SI5
Option 1
SI1

SI1
Option 1

Commentary and Recommendations

OPDC area
OPDC area

The policy option would not directly promote higher education uses, but does not
preclude them so this may not improve employment and skills opportunities.
The policy supports the provision of health facilities. There is no direct relationship
between objective and policy.
There is no direct relationship between the objective and the policy.
There is no direct relationship between the objective and the policy.
There is no direct relationship between the objective and the policy.

M, L-T, I, R, L OPDC area,

West London,
London wide
M, L-T, I, R, L OPDC area

An increase in social infrastructure will increase infrastructure and utilities capacity which
may contribute to the community and inward investment with a greater flow of businesses
moving into the area.
An increase in social infrastructure will increase infrastructure and utilities capacity which
may contribute to the community and inward investment with a greater flow of businesses
162

IIA Objective

Performance of Temporal
Policy
Scale
Nature of
Impact

within existing
communities, to SI2
create
sustainable
SI2
economic growth Option 1
SI3
SI4
SI5

Page 667

SI5
Option 1

+
+
+

S,M,L-T,
D,R,M
S,M,L-T,
D,R,M
L-T, I, IR, M

++ S,M,L-T,
D,R,H
++ S,M,L-T,
D,R,H
-

S,M,L-T,
D,R,L

Geographical
Extent

OPDC area
OPDC area
OPDC area
OPDC area
OPDC area

OPDC area

Commentary and Recommendations

moving into the area.

An education facility in the OPDC will encourage further investment as the OPDC will be
seen as a desirable location for business and academia.
An education facility in the OPDC will encourage further investment as the OPDC will be
seen as a desirable location for business and academia.
National and International health institutions in the OPDC area could encourage further
inward investment from associated sectors.
An increase in community facilities may contribute to the community and inward
investment due to their ability to provide jobs and attract footfall into an area.
The policy states that OPDC consider that pubs can act as hubs for community life. They
provide economic benefits by providing jobs, supporting local food suppliers and bring
activity to high streets. Public houses must be seen as a viable business.
This policy could result in the loss in viable existing businesses.

163

Table G-9 Chapter 11: Transport

x T1: Strategic Policy: Transport
x T2: Walking
x T3: Cycling
x T4: Rail
x T5: Buses
x T6: Roads
x T7: Parking
x T8: Freight, servicing and deliveries
x T9: Construction
x T10: Transport Assessments and Travel Plans

Page 668

IIA Objective

Performance
of Policy

Temporal
Scale
Nature of
Impact

Geographical
Extent

Commentary and Recommendations

T1

S,M,LT,I,R,M

OPDC area

T1
Option
1

S,M,LT,I,R,L

OPDC area

T2

S,M,LT,I,R,M

OPDC and
surrounding
area

T3

S,M,LT,I,R,M

OPDC and
surrounding
area

T4

S,M,LT,I,R,M

OPDC and
surrounding
area

T5

S,M,LT,I,R,L

T6

S,M,L-

OPDC and
surrounding
area
OPDC and

The policy seeks to deliver state of the art, safe and accessible transport systems, by
providing infrastructure that connects communities and helps facilitate growth and this
would support accessibility and would help to encourage place making.
The policy seeks to give priority to car travel which would result in effects to vehicle
congestion, people making fewer journeys by foot and other sustainable means
including cycling and public transport and this would impact upon health and wellbeing
and which could negatively impact upon local amenity.
Walking is the most sustainable form of transport and encouraging increased walking
will have many advantages including more connected neighbourhoods. Increasing the
connection of the public realm and internal routes to neighbouring areas alongside
local and strategic cycle and walking networks including via green infrastructure
networks and the canal would all support placemaking.
Placemaking would be encouraged through the provision of state of the art cycling
infrastructure, improved cycle wayfinding and signage and the enhancement of existing
cycle connections to ensure they are safe, convenient, direct but not detrimental to
pedestrians.
The policy seeks to support a number of rail improvements including the delivery of
state of the art rail station at Old Oak Common and at links between stations as well as
improved services on existing rail infrastructure these features would all contribute
towards enhancing the built environment and improving accessibility.
The policy seeks the delivery of increased bus frequencies on existing and extended
bus routes; to provide bus journey time reliability and to provide clear and legible
signage. This would help to encourage placemaking.
The policy seeks to deliver high quality streets that integrate effectively with the wider

To enhance
the built
environment
and
encourage
place-making

164

IIA Objective

Performance
of Policy

Temporal
Scale
Nature of
Impact

Geographical
Extent

Commentary and Recommendations

T,I,R,M

surrounding
area
OPDC and
surrounding
area
OPDC area

public realm which would help to support placemaking.

The policy seeks to promote modal shift towards more sustainable modes. This would
help to support the street scene, public realm and placemaking.

Page 669

T7

S,M,LT,I,R,L

T7
Option
1

S,M,LT,I,R,L

T7
Option
2
T8

S,M,LT,I,R,L

N/A

OPDC and
surrounding
area
N/A

T8
Option
1
T8
Option
2
T9

N/A

N/A

Setting less stringent car parking standards would offer greater choice however would
place unacceptable impacts on the surrounding road network and would discourage
modal shift towards the use of more sustainable transport odes and would increase
emissions. This would potentially lead to more congestion and would not support
placemaking.
This policy, similarly to the preferred option, would enable a mode shift towards the use
of sustainable transport and reduce traffic flow and congestion through limited parking
which would support the street scene, public realm and placemaking.
The policy primarily addresses freight, servicing and deliveries and does not have a
direct link to the SA Objective.
The nature of the policy does not directly link with the SA Objective.

N/A

N/A

The nature of the policy does not directly link with the SA Objective.

S,M,LT,I,R,L

T9
Option
1
T9
Option
2
T10

S,M,LT,I,R,L

OPDC and
surrounding
area
OPDC area

The policy seeks to provide support to reduce freight and construction trips which may
have an indirect effect on amenity through reduced frequency of heavy goods vehicles
(HGVs) on roads.
A lack of coordination over construction transport could lead to increased volumes of
construction vehicles on the road network which could have an effect on amenity.

S,M,LT,I,R,L

The policy seeks to move all freight moved by rail or water which could have a positive
effect on amenity.

N/A

OPDC and
surrounding
area
N/A

T10
Option
1

N/A

N/A

The policy primarily addresses transport assessments and travel plans and does not
have a direct link to the SA Objective.
There is no link between the policy and the SA Objective.

165

IIA Objective

To optimise
the efficient
use of land
through
increased
development
densities and
building
heights, where
appropriate

Page 670

Performance
of Policy

Temporal
Scale
Nature of
Impact

Geographical
Extent

Commentary and Recommendations

T10
Option
2
T1

N/A

N/A

There is no link between the policy and the SA Objective.

S,M,LT,I,R,L

OPDC and
surrounding
area
N/A

The policy primarily seeks to provide transport infrastructure and to facilitate growth
and the development of state of the art infrastructure could help to optimise efficient
use of land.
The primary focus of the policy is to give priority to car travel which directly link with
efficient land use.
The efficient use of land would be demonstrated through the provision of high quality,
safe and accessible walking networks.

There is no direct link between the primary focus of the policy and the SA Objective.
There is no direct link between the primary focus of the policy and the SA Objective.
There is no direct link between the primary focus of the policy and the SA Objective.
There is no direct link between the primary focus of the policy and the SA Objective.
There is no direct link between the primary focus of the policy and the SA Objective.

T1
Option
1
T2

N/A

S,M,LT,I,R,L

T3

S,M,LT,I,R,L

T4
T5
T6
T7
T7
Option
1
T7
Option
2
T8

0
0
0
0
0

N/A
N/A
N/A
N/A
N/A

OPDC and
surrounding
area
OPDC and
surrounding
area
N/A
N/A
N/A
N/A
N/A

N/A

N/A

There is no direct link between the primary focus of the policy and the SA Objective.

S,M,LT,I,R,L

OPDC and
surrounding
area

N/A

N/A

The policy supports freight, servicing and deliveries and it seeks to identify potential
sites for consolidation centres and lorry holding areas and the provision of facilities for
home deliveries within residential development. The delivery of facilities for home
deliveries within residential development would help to optimise the efficient use of
land.
The policy option seeks no controls over deliveries and servicing which does not have
direct link to the SA Objective.

N/A

N/A

T8
Option
1
T8
Option

The provision of state of the art cycling infrastructure through this policy would
contribute towards optimising efficient land use.

The policy option seeks to ban deliveries and servicing by larger vehicles which does
not have direct link to the SA Objective.
166

IIA Objective

Performance
of Policy

2
T9

Page 671

Maximise the
reuse of
previously
developed
land and
existing
buildings,
including the
remediation of
contaminated
land

T9
Option
1
T9
Option
2
T10
T10
Option
1
T10
Option
2
T1

Temporal
Scale
Nature of
Impact

Geographical
Extent

Commentary and Recommendations

N/A

N/A

N/A

N/A

The policy focuses on reducing freight and construction trips which does not directly
link with the SA Objective.
There is no direct link between the primary focus of the policy and the SA Objective.

N/A

N/A

There is no direct link between the primary focus of the policy and the SA Objective.

0
0

N/A
N/A

N/A
N/A

There is no direct link between the primary focus of the policy and the SA Objective.
There is no direct link between the primary focus of the policy and the SA Objective.

N/A

N/A

There is no direct link between the primary focus of the policy and the SA Objective.

S,M,LT,I,R,L

OPDC and
surrounding
area

The policy primarily seeks to provide transport infrastructure and to facilitate growth
and the development of state of the art infrastructure could help to optimise reuse of
previously developed land.
The primary focus of the option is to give priority to car travel which does not directly
link with use of previously developed land.

OPDC and
surrounding
area
OPDC and
surrounding
area

As a sustainable form of travel, walking routes and infrastructure will be more likely to
be in place in previously developed areas therefore encouraging brownfield
development.
As a sustainable form of travel, cycle routes and infrastructure will be more likely to be
in place in previously developed areas therefore encouraging brownfield development.

T1
Option
1
T2

S,M,LT,I,R,L

T3

S,M,LT,I,R,L

T4
T5
T6

0
0
+

T7
T7

0
0

S,M,LT,D,R,M

OPDC and
surrounding
area

There is no direct link between the primary focus of the policy and the objective.
There is no direct link between the primary focus of the policy and the objective.
The strategic road network, particularly the A40 and A406, is vital to the successful
operation of Park Royal and will be in the future to Old Oak. Road schemes should
contribute to strategic land remediation.
There is no direct link between the primary focus of the policy and the objective.
There is no direct link between the primary focus of the policy and the objective.
167

IIA Objective

Performance
of Policy

Option
1
T7
Option
2
T8

Page 672
4

Minimise the
need to travel,
improve
accessibility

Temporal
Scale
Nature of
Impact

Geographical
Extent

T8
Option
1
T8
Option
2
T9

T9
Option
1
T9
Option
2
T10
T10
Option
1
T10
Option
2
T1

Commentary and Recommendations

There is no direct link between the primary focus of the policy and the objective.

S,M,LT,I,R,L

OPDC and
surrounding
area

The policy supports freight, servicing and deliveries and it seeks to identify potential
sites for consolidation centres and lorry holding areas and the provision of facilities for
home deliveries within residential development. The delivery of facilities for home
deliveries within residential development would help to optimise the efficient use of
land.
This option seeks no controls over deliveries and servicing which does not have direct
link to the objective.

This option seeks to ban deliveries and servicing by larger vehicles which does not
have direct link to the objective.

0
0

The policy focuses on reducing freight and construction trips which does not directly
link with the objective.
There is no direct link between the primary focus of the policy and the objective.

There is no direct link between the primary focus of the policy and the objective.

0
0

There is no direct link between the primary focus of the policy and the objective.
There is no direct link between the primary focus of the policy and the objective.

There is no direct link between the primary focus of the policy and the objective.

++

S,M,L-T, D,
R, H

OPDC and
surrounding
area

The policy seeks to deliver state of the art, safe and accessible transport systems by
providing infrastructure that connects communities and facilitates growth. It also seeks
to prioritise sustainable transport modes and support modal shift from private cars all of
which would directly support the SA Objective.
168

IIA Objective

for all users by

public and
non-motorised
transportation
methods and
mitigate
impacts on the
transport
network

Page 673

Performance
of Policy

Temporal
Scale
Nature of
Impact

Geographical
Extent

Commentary and Recommendations

T1
Option
1

+/-

S,M,LT,D,R,M

OPDC and
surrounding
area

T2

S,M,LT,D,R,M

T3

S,M,LT,D,R,M

T4

++

S,M,LT,D,R,H

OPDC and
surrounding
area
OPDC and
surrounding
area
OPDC and
surrounding
area

T5

S,M,LT,D,R,M

T6

S,M,LT,D,R,M

T7

S,M,LT,D,R,M

OPDC area

T7
Option
1
T7
Option
2
T8

S,M,LT,D,R,M

OPDC area

This policy gives priority to car travel above sustainable modes which could impact
upon journey times through increased vehicle congestion though the policy may benefit
some businesses and residents. However, by facilitating the use of private vehicles
congestion, noise and emissions would increase and fewer people would make
journeys by foot, bike or public transport.
The policy seeks to support walking through the provision of high quality, safe and
accessible walking networks. This would help to minimise the need to travel through
improving accessibility by walking.
The policy seeks to support and encourage cycling through the provision of state of the
art infrastructure and enhanced connections which would help to minimise the need to
travel through improving accessibility by cycling.
The policy would deliver a new state of the art rail station at Old Oak and would provide
quality links between stations as well as improving services on existing infrastructure
all of which would directly serve to improve accessibility. The delivery of two new
overground stations would also help to manage capacity.
The policy would deliver and contribute to the delivery of infrastructure to improve bus
journey time reliability and priority measures as well as improved bus frequencies on
new and extended routes which would help to improve accessibility.
The policy primarily seeks to provide roads and streets that overcome severance and
optimise connectivity. It also seeks to ensure that streets give priority to pedestrians,
cyclists and buses which would improve accessibility.
The policy primarily seeks to promote modal shift towards more sustainable modes
through car parking limitations. This may contribute to minimising the need to travel
and limited car parking in areas may also lead to increased use of sustainable
transport modes such as public transport.
The policy seeks to set less stringent car parking standards which could discourage the
use of more sustainable transport modes.

S,M,LT,D,R,M

OPDC area

S,M,LT,D,R,M

OPDC and
surrounding
area

OPDC and
surrounding
area
OPDC area

The car free approach would enable a mode shift towards the use of more sustainable
transport modes which would have a positive effect on accessibility across nonmotorised transportation methods.
The policy addresses freight, servicing and deliveries and does not directly link to
minimising the need to travel and improving improve accessibility for all users.

169

IIA Objective

Performance
of Policy

Temporal
Scale
Nature of
Impact

Geographical
Extent

Commentary and Recommendations

T8
Option
1
T8
Option
2
T9

N/A

N/A

The primary focus of the policy does not have a direct link to the SA Objective.

N/A

N/A

The primary focus of the policy does not have a direct link to the SA Objective.

S,M,L-T,D,
I, R M

OPDC and
surrounding
area

S,M,LT,D,R,M

OPDC area

S,M,L-T,D,
I, R M

S,M,LT,D,I,R,M

OPDC and
surrounding
area
OPDC and
surrounding
area

The policy seeks to provide for measures to reduce freight and construction trips, make
use of rail and water transportation and to coordinate and phase construction projects
to enable effective mitigation of transport impacts all of which would help to mitigate
impacts on the transport network.
No control or coordination of construction transport would lead to high volumes of
construction vehicles on the road network which would put a strain on the transport
network.
The policy would have improved impacts upon the transport network compared to
Option 1.

T10
Option
1
T10
Option
2
T1

S,M,LT,D,I,R,M

S,M,LT,D,I,R,M

T1
Option
1
T2

Page 674

T9
Option
1
T9
Option
2
T10

Improve
access to well
designed,
well-located,
market,
affordable and
inclusive
housing of a
range of types

OPDC and
surrounding
area
OPDC and
surrounding
area

Transport assessments and travel plans will help to deliver sustainable transport
objectives and will seek to address congestion and impacts upon bus routes and on
the primary route network and will ultimately support the mitigation of impacts upon the
transport network.
Requiring a transport assessment for all development would enable more control over
cumulative impacts of developments on the transport network which would support the
mitigation of impacts on the transport network.
Increasing the threshold for schemes that require a transport assessment could lead to
a congested road network.
The significant general background growth and the increase in travel demand resulting
from additional homes within the development area will add to the existing travel
demand, both at the strategic and local level. The policy may have an indirect effect on
the range of housing types in the local area.
This option support for the use of car travel may benefit the local residents.

S,M,LT,D,R,L

OPDC area

Redevelopment presents an opportunity to enhance existing and provide new

pedestrian environments across Old Oak and Park Royal. High quality pedestrian
170

IIA Objective

and tenures,
to meet
identified local
needs

Performance
of Policy

Temporal
Scale
Nature of
Impact

Geographical
Extent

Page 675

T3

S,M,LT,D,R,L

OPDC area

T4

S,M,LT,I,R,L

T5

S,M,LT,D,R,L

OPDC area
and London
wide
OPDC area

T6

T7

T7
Option
1
T7
Option
2
T8

T8
Option

S,M,LT,D,R,H

OPDC area

+/-

S,M LT,D,R,H

OPDC area

S,M LT,I,R,M

OPDC area

Commentary and Recommendations

walking routes to Old Oak Common station from all areas will be vital to ensure
residents can benefit from this new transport superhub. This should improve access to
housing developments through sustainable travel.
Private cycle parking for residents and provision for visitors should meet local needs
and encourage cycling. Adequate cycle storage and infrastructure may increase the
suitability of homes for potential residents.
High quality rail infrastructure and a frequent rail service may help meet local needs.
HS2 and Crossrail could benefit the area and support sustainable travel to surrounding
residential areas.
Increased bus services and frequencies would provide improved connections to homes
in Old Oak and Park Royal reducing dependence on the private car. This policy may
have an indirect effect on housing locations.
A high quality road network could contribute to the provision of a variety of homes in
the area.
The policy seeks to control the level of parking. In Old Oak, limiting car parking to 0.2
spaces for residential developments, promotion of car free development close to public
transport hubs and securing zero car parking for non-residential developments. In Park
Royal, limiting car parking to 0.2 spaces for residential developments and allowing
limited car parking for non-residential development taking into account access to public
transport and operational or business needs. Limited car parking should encourage
sustainable travel and provide greater flexibility in improving access and providing
different types of homes.
This option would offer greater choice. However, this is likely to place unacceptable
impacts on the surrounding road network, discourage a mode shift towards the use of
more sustainable transport modes and effect access to housing developments.
This option would enable a mode shift towards the use of more sustainable transport
modes and would reduce traffic flow and congestion. This should have a positive effect
on access to housing developments.
OPDC will work collaboratively with stakeholders to ensure that freight movements are
conducted in a safe, efficient and sustainable manner by encouraging the provision of
facilities for home deliveries within residential developments. This will require sufficient
access to housing areas.
There is no direct link between the primary focus of the policy and the objective.

171

IIA Objective

Performance
of Policy

1
T8
Option
2
T9

Page 676

T9
Option
1
T9
Option
2
T10

Improve
climate
change
adaptation and
mitigation,
including
minimising the
risk of flooding
and
addressing the

T10
Option
1
T10
Option
2
T1

Temporal
Scale
Nature of
Impact

Geographical
Extent

Commentary and Recommendations

There is no direct link between the primary focus of the policy and the objective.

There is no direct link between the primary focus of the policy and the objective.
However, a Construction Logistics Strategy will be developed by TfL and OPDC to
ensure a coordinated approach which will minimise the disruption to surrounding
residents.

There is no direct link between the primary focus of the option and the objective.

There is no direct link between the primary focus of the option and the objective.

Workplace and/or residential travel plans should be provided for planning applications
exceeding the thresholds in, and produced in accordance with, the relevant TfL
guidance. This requirement may indirectly affect housing provision, access and
locations.
There is no direct link between the primary focus of the policy and the objective.

There is no direct link between the primary focus of the policy and the objective.

S,M,LT,D,I,R,M

OPDC area

T1
Option
1
T2

N/A

N/A

S,M,LT,D,I,R,M

OPDC area

T3

N/A

N/A

The delivery of state of the art road infrastructure could include the provision for
Sustainable Urban Drainage Systems (SuDS) which would contribute towards climate
change adaptation and minimising flood risk.
Giving priority to car travel does not directly link to minimising flood risk.

The policy primarily focuses on supporting walking networks and connectivity and the
provision of SuDS within walking infrastructure could contribute towards achieving the
SA Objective.
The policy primarily focuses on supporting and encouraging cycling which would help
172

IIA Objective

Performance
of Policy

Temporal
Scale
Nature of
Impact

Geographical
Extent

heat island
effect

Commentary and Recommendations

Page 677

to encourage more people to cycle however would not have a direct effect in achieving
the SA Objective.
Climate change adaptation could be achieved through provisions including a state of
the art rail links and a state of the art rail station at old common as well as future
proofing station design to enable smart technology to be implemented.
The policy primarily focuses on delivery and contributions to bus improvements and
infrastructure for buses and has no direct link to the SA Objective though it is noted
that provisions for roads in connection with the policy could contribute towards
achieving the SA Objective.
Climate change adaptation and flood minimisation would be supported through the
provision of high quality roads with robust and coordinated materials.
The policy seeks to ensure that development is an exemplar of low carbon
development and it seeks to promote a modal shift towards more sustainable modes
by imposing car parking limits which will help to support climate change adaptation.
The policy focuses setting less stringent car parking standards which does not directly
link with flood risk minimisation.

T4

S,M,LT,D,I,R,M

OPDC area

T5

N/A

N/A

T6

OPDC area

T7

S,M,LT,D,I,R,M
S,M,LT,D,I,R,M

T7
Option
1
T7
Option
2
T8
T8
Option
1
T8
Option
2
T9
T9
Option
1
T9
Option
2
T10

N/A

N/A

N/A

N/A

The policy encourages a shift to sustainable transport use however this does not
directly link with flood risk minimisation.

0
0

N/A
N/A

N/A
N/A

The policy does not directly link with the SA Objective.

The policy does not directly link with the SA Objective.

N/A

N/A

0
0

N/A
N/A

N/A
N/A

Banning deliveries and servicing by larger vehicles would help to reduce local
congestion however would have a limited effect in supporting climate change and flood
risk minimisation.
The policy does not directly link with the SA Objective.
The policy does not directly link with the SA Objective.

N/A

N/A

The policy does not directly link with the SA Objective.

N/A

N/A

The policy does not directly link with the SA Objective.

OPDC area

173

IIA Objective

Page 678

To minimise
contributions
to climate
change
through
greater energy
efficiency,
generation
and storage;
and to reduce
reliance on
natural
resources
including fossil
fuels for
transport,
heating and
energy

Performance
of Policy

Temporal
Scale
Nature of
Impact

Geographical
Extent

Commentary and Recommendations

T10
Option
1
T10
Option
2
T1

N/A

N/A

The policy does not directly link with the SA Objective.

N/A

N/A

The policy does not directly link with the SA Objective.

S,M,LT,D,I,R,M

OPDC area

The policy seeks to deliver state of the art road infrastructure and to prioritise
sustainable transport modes and to support modal shift from private cars which would
support adaptation to climate change.
Giving priority to car travel would go against the climate change adaptation initiative
and would facilitate the use of private vehicles, would increase congestion and lead to
increased emissions.
The policy primarily focuses on supporting walking networks and connectivity which
would help to support the increase of journeys made by non-motorised transport and
would contribute towards achieving the SA Objective.
The policy primarily focuses on supporting and encouraging cycling which would help
to encourage more people to cycle helping to increase non-motorised journeys and
may help to reduce car reliance and emissions which would support climate change
adaptation.
Climate change adaptation could be achieved through provisions including a state of
the art rail links and a state of the art rail station at old common helping to increase
energy efficiency. Future proofing station design would also enable smart technology to
be implemented.
The policy primarily focuses on delivery and contributions to bus improvements and
infrastructure for buses and has no direct link to the SA Objective.
Climate change adaptation would be supported through the provision of high quality
roads with robust and coordinated materials. The policy also seeks to mitigate impacts
of development on surrounding local and strategic road networks as well as ensuring
that streets prioritise pedestrians, cyclists and buses which would help to encourage
sustainable movements.
The policy seeks to ensure that development is an exemplar of low carbon
development and it seeks to promote a modal shift towards more sustainable modes
by imposing car parking limits which will help to support climate change adaptation.
The policy also seeks to incorporate electric charging points for electric vehicles at all
new parking spaces which would help to promote and encourage the use of electric

T1
Option
1
T2

S,M,LT,D,I,R,M

OPDC area

S,M,LT,D,I,R,M

OPDC area

T3

S,M,LT,D,I,R,M

OPDC area

T4

S,M,LT,D,I,R,M

OPDC area

T5

N/A

N/A

T6

S,M,LT,D,I,R,M

OPDC area

T7

S,M,LT,D,I,R,M

OPDC area

174

IIA Objective

Page 679

Performance
of Policy

Temporal
Scale
Nature of
Impact

Geographical
Extent

T7
Option
1
T7
Option
2
T8

S,M,LT,D,I,R,M

OPDC area

S,M,LT,D,I,R,M

OPDC area

S,M,LT,D,I,R,M

OPDC area

S,M,LT,D,I,R,M

OPDC area

N/A

N/A

S,M,LT,D,I,R,M

OPDC area

S,M,LT,D,I,R,M

OPDC area

S,M,LT,D,I,R,M

OPDC area

M,LT,D,I,R,M

OPDC area

M,LT,D,I,R,M

OPDC area

M,LT,D,I,R,M

OPDC area

T8
Option
1
T8
Option
2
T9

T9
Option
1
T9
Option
2
T10

T10
Option
1
T10
Option

Commentary and Recommendations

cars, further supporting the SA Objective.

The policy focuses setting less stringent car parking standards which could
discourages a mode shift towards more sustainable modes and would impact upon the
surrounding road network and would also lead to increased emissions.
The policy encourages a shift to sustainable transport use which would help to reduce
traffic and contribute to reducing emissions which would support climate change
adaptation.
The policy seeks to identify more efficient and sustainable ways of delivering goods
including the use of cargo bikes as well as seeking to ensure that operators of all
freight vehicles have attained the Gold Fleet Operator Recognition Scheme (FORS)
accreditation demonstrating efforts to reduce emissions all of which supports climate
change adaptation.
The policy would not place controls over deliveries and servicing which would mean
that the flow of HGVs and LGVs would increase drastically, exacerbating congestion
issues and resulting in negative environmental impacts including increased emissions.
Banning deliveries and servicing by larger vehicles would help to reduce local
congestion however would have a limited effect in supporting climate change mitigation
and adaptation.
The policy seeks to reduce freight and construction trips and to make maximum use of
rail and water transport for construction and freight which would help to support
reducing transportation by road.
The policy states that there would be no control or coordination of construction
transport which could lead to high volumes of construction vehicles on the road
network increasing congestion and contributing to increased emissions.
The policy seeks to make transport all freight by rail or water which would reduce
transportation by road and help to reduce impacts to the road network and emissions.
Travel plans provide a long term strategy to deliver sustainable transport objectives
through an action plan and would ultimately contribute towards increasing energy
efficiency, reducing congestion and emissions.
Requiring a transport assessment for all development would help to reduce impacts on
the road network and emissions.
Increasing the threshold for schemes that require a transport assessment could lead to
a congested road network which could lead to increased emissions.
175

IIA Objective

Page 680

To minimise
production of
waste across
all sectors in
the plan area,
maximise
efficiencies for
transporting
waste and
increasing
rates of reuse, recycling
and recovery
rates as well
as composting
of all green
waste

Performance
of Policy

2
T1
T1
Option
1
T2
T3
T4
T5
T6

T7
T7
Option
1
T7
Option
2
T8

T8
Option
1
T8
Option
2
T9

Temporal
Scale
Nature of
Impact

Geographical
Extent

Commentary and Recommendations

M,LT,D,I,R,M
N/A

OPDC area

The policy seeks to deliver state of the art transport systems and has no direct link to
the SA Objective.
The primary focus of the policy has no direct link to the SA Objective.

0
0
0
0
?

N/A
N/A
N/A
N/A
S,M,LT,D,I,R,M

N/A
N/A
N/A
N/A
OPDC area

0
0

N/A
N/A

N/A
N/A

The primary focus of the policy has no direct link to the SA Objective.
The primary focus of the policy has no direct link to the SA Objective.
The primary focus of the policy has no direct link to the SA Objective.
The primary focus of the policy has no direct link to the SA Objective.
The policy seeks to deliver high quality streets with robust and coordinated materials
and has the potential to partially support the SA Objective through the use of recycled
materials for infrastructure.
The primary focus of the policy has no direct link to the SA Objective.
The primary focus of the policy has no direct link to the SA Objective.

N/A

N/A

The primary focus of the policy has no direct link to the SA Objective.

S,M,LT,D,I,R,M

OPDC area

N/A

N/A

The policy explains rail freight activity within the wider Park Royal area utilising the
Great Western Main Line and West Coast Main Line routes (including at various sites
around Willesden such as the Euro Freight Terminal) which handle inbound flows of
aggregates and cement and outbound flows of waste and scrap metal. The policy
would contribute to the SA through maximising transportation of waste by making less
trips and potential segregation of waste types.
The primary focus of the policy has no direct link to the SA Objective.

N/A

N/A

The primary focus of the policy has no direct link to the SA Objective.

S,M,LT,D,R,H

OPDC area

The policy addresses freight and construction transport may enable benefits through
minimisation techniques. Maximum re-use and recycling of waste and construction
materials within the area will reduce transport demands. For residual movements, there

+
0

++

N/A

176

IIA Objective

Performance
of Policy

T9
Option
1
T9
Option
2
T10

Page 681

Improve the
quality of the
water
environment

Temporal
Scale
Nature of
Impact

Geographical
Extent

Commentary and Recommendations

is potential for bulk construction materials and/or waste to be transported by rail and
canal although issues of local environmental impact and commercial viability will need
to be addressed.
The primary focus of the policy has no direct link to the SA Objective.

N/A

N/A

N/A

N/A

The primary focus of the policy is the movement of freight by rail or water and has no
direct link to the SA Objective.

S,M,LT,D,R,M

OPDC area

T10
Option
1
T10
Option
2
T1

S,M,LT,D,R,M

OPDC area

S,M,LT,D,R,M

OPDC area

OPDC area

T1
Option
1
T2

S,M,LT,I,R,L
N/A

Transport assessments and travel plans would enable sustainable objectives which
could include efficient transportation of waste materials from development sites which
would partially support the SA Objective.
Requiring a transport assessment for all development would enable more scrutiny over
developments to ensure best practice compliance which would also likely include
efficient waste transportation.
Increasing the threshold for schemes requiring a transport assessment contrary to the
preferred option may result in efficient transportation techniques for waste not being
explored.
The delivery of state of the art road infrastructure could include the provision for SuDS
which would contribute towards improving the quality of the water environment.
The policy seeks to give priority to car travel and has no direct link to the SA Objective.

S,M,LT,I,R,L

OPDC area

T3

N/A

N/A

T4

M,L-T,I,R,L

OPDC area

T5

N/A

N/A

N/A

The policy primarily focuses on supporting walking networks and connectivity and the
provision of SuDS within walking infrastructure could contribute towards achieving the
SA Objective.
The policy primarily focuses on supporting and encouraging cycling and has no direct
link to the SA Objective.
The provision of state of the art rail links and a state of the art rail station at old
common could help to support the SA Objective through incorporating SuDS into
design.
The policy primarily focuses on delivery and contributions to bus improvements and
infrastructure for buses and has no direct link to the SA Objective though it is noted
that provisions for roads in connection with the policy could contribute towards
achieving the SA Objective.
177

IIA Objective

Page 682

Performance
of Policy

Temporal
Scale
Nature of
Impact

Geographical
Extent

Commentary and Recommendations

T6

OPDC area

T7

S,M,LT,I,R,L
N/A

N/A

T7
Option
1
T7
Option
2
T8
T8
Option
1
T8
Option
2
T9

N/A

N/A

The provision of high quality roads with robust and coordinated materials would
support the SA Objective through incorporating SuDS into design.
The policy primarily focuses on car parking provision and has no direct link to the SA
Objective.
The policy focuses setting less stringent car parking standards and has no direct link to
the SA Objective.

N/A

N/A

The policy focuses on having residential parking and has no direct link to the SA
Objective.

0
0

N/A
N/A

N/A
N/A

The primary focus of the policy has no direct link to the SA Objective.
The primary focus of the policy has no direct link to the SA Objective.

N/A

N/A

The primary focus of the policy has no direct link to the SA Objective.

S,M,LT,D,R,M

OPDC area

T9
Option
1
T9
Option
2

N/A

N/A

S,M,LT,D,R,M

OPDC area

T10
T10
Option
1
T10
Option

0
0

N/A
N/A

N/A
N/A

The policy seeks to make maximum use of rail and water transport for construction and
freight. Transportation for construction and freight across water has the potential to
result in pollution of the water environment if not adequately mitigated.
Appropriate pollution prevention would need to be considered where water
transportation is concerned.
The policy states that there would be no control or coordination of construction
transport which could lead to high volumes of construction vehicles on the road
network however there would be no direct link to improving the water environment.
The policy seeks to make transport all freight by rail or water which would have more of
a potential negative effect upon the water environment than the preferred option.
Appropriate pollution prevention would need to be considered where water
transportation is concerned.
The primary focus of the policy has no direct link to the SA Objective.
The primary focus of the policy has no direct link to the SA Objective.

N/A

N/A

The primary focus of the policy has no direct link to the SA Objective.
178

IIA Objective

10

Create and
enhance
biodiversity
and the
diversity of
habitats
across the
area and its
surroundings

Performance
of Policy

2
T1

Temporal
Scale
Nature of
Impact

Geographical
Extent

Commentary and Recommendations

S,M,LT,D,R,M

OPDC and
London wide

The policy would not have any significant effects for the objective. Promoting
sustainable transport over cars could benefit biodiversity by reducing emissions, run-off
and noise. Whilst there is benefits in areas close to the LNR, in general biodiversity
levels in the area are limited due to existing uses and the wider development proposals
so the benefits of this may not be significant.
The option would be detrimental to biodiversity due to the encouragement of car travel
and associated increase in emissions and disturbance effects.

Page 683

T1
Option
1
T2

S,M,LT,D,R,M

OPDC and
London wide

T3

T4

+/-

S,M,LT,D,R,M
S,M,LT,D,R,M
S,M,LT,D,R,M

OPDC and
London wide
OPDC and
London wide
OPDC and
London wide

T5
T6

0
?

T7
T7
Option
1
T7
Option
2
T8
T8
Option
1
T8
Option
2
T9

0
0

The policy would not have any significant effects for the objective.
The option would not have any significant effects for the objective.

The option would not have any significant effects for the objective.

0
0

The policy would not have any significant effects for the objective.
The option would not have any significant effects for the objective.

The option would not have any significant effects for the objective.

The policy would not have any significant effects for the objective.

This policy offers opportunities to tie in walking routes with GI and improve wildlife
connectivity
This policy offers opportunities to tie in cycling routes with GI and improve wildlife
connectivity
Whilst the construction of new stations and infrastructure may adversely affect
biodiversity present, this is unknown at this stage. New stations could include planting
schemes and biodiversity enhancements.
The policy would not have any significant effects for the objective.
The value of the policy to the objective would be uncertain but new streets, if allied with
suitable green infrastructure provision may act as green corridors.

179

IIA Objective

Page 684

11

To minimise
air, noise and
light pollution,
particularly for
vulnerable
groups

Performance
of Policy

T9
Option
1
T9
Option
2
T10
T10
Option
1
T10
Option
2
T1

Temporal
Scale
Nature of
Impact

Geographical
Extent

Commentary and Recommendations

The option would not have any significant effects for the objective.

The option would not have any significant effects for the objective.

0
0

The policy would not have any significant effects for the objective.
The option would not have any significant effects for the objective.

The option would not have any significant effects for the objective.

++

M,LT,D,R,M

OPDC area
and London
wide

T1
Option
1
T2

M,LT,D,R,M

OPDC area

OPDC area

T3

M,LT,D,R,M
M,LT,D,R,M

T4
T5

0
+/-

S,M,LT,D,R,L

OPDC area

T6

+/-

S,M,LT,D,R,L

OPDC area

T7

S,M,L-

OPDC area

OPDC area

The policy explains that an uptake of low carbon vehicle technologies and fuels, lower
emission buses, taxis and HGVs and infrastructure to support electric vehicles will
facilitate significant reductions in CO2 and NOx emissions across all modes and
contribute towards a cleaner and healthier development area.
However, by facilitating the use of private vehicles congestion, noise and emissions
would increase and fewer people would make journeys by foot, bike or public transport.
The policy would benefit the minimisation of pollution as walking provides an
alternative to the private car.
The policy would benefit the minimisation of pollution as cycling provides an alternative
to the private car.
The policy would not have any significant effects for the objective.
The policy would not have any significant effects for the objective. The policy would
benefit the minimisation of pollution as buses provide a sustainable alternative to the
private car However, buses can cause pollution.
Recommendation to encourage use of low carbon buses and work with TfL.
The policy would not have any significant effects for the objective. However, new
streets may bring pollution closer to residents in those areas, or it may help relieve
congestion elsewhere and hence have benefits.
OPDC will ensure the development area is an exemplar of low carbon development
180

IIA Objective

Performance
of Policy

Temporal
Scale
Nature of
Impact

Geographical
Extent

T,D,R,M

T7
Option
1
T7
Option
2
T8

Page 685

S,M,LT,I,R,M

S,M,LT,I,R,M

+/-

S,M,LT,D,R,H

T8
Option
1

--

S,M,LT,D,R,M

T8
Option
2
T9

S,M,LT,I,R,M

+/-

S,M,LT,D,R,M

OPDC and
surrounding
area
OPDC and
surrounding
area
OPDC and
surrounding
area
London wide

OPDC and
surrounding
area
London wide

T9
Option
1
T9
Option
2
T10

S,M,LT,D,R,M

London wide

S,M,LT,D,R,M

London wide

S,M,LT,D,R,M

London wide

T10

S,M,L-

London wide

Commentary and Recommendations

and will promote a modal shift towards more sustainable modes. This will have a
positive effect on pollution levels. Limiting spaces will deter people from using cars and
provides charging points to encourage electric vehicles.
Less stringent car parking standards may encourage private car use therefore
increasing pollution levels.
This option would enable a mode shift towards the use of more sustainable transport
modes reducing traffic flow and congestion. This could have a positive effect on
pollution levels.
The significant HGV activity in the development area can have negative impacts on the
environment in terms of noise and air quality and causes congestion, particularly on
Scrubs Lane. However, there is an attempt to limit and control the congestion.
If no measures are put in place to control servicing and deliveries, HGVs and LGVs
flow would increase drastically, exacerbating the congestion issues in the development
area, as well as having noise and environmental impacts, affecting the public realm
and using up road space.
This option would ban the larger vehicles, thereby, potentially reducing congestion and
pollution levels.
Construction traffic will increase the volume of HGVs and other construction vehicles
on the local and strategic road network and may increase pollution levels. However,
the freight consolidation centre described in policy T8 could be used to reduce the
number of construction vehicles required and the number of construction vehicle
movements on the road network. Maximum re-use and recycling of waste and
construction materials within the area will reduce transport demands.
The option to programme construction works without any coordination with other
projects would lead to very high volumes of construction vehicles on the road network
which would also have noise pollution implications.
This option would reduce the impacts of construction on the road network due to the
alternative use of rail or water for all freight. This would have a positive effect on
minimising noise.
Transport Statement or Transport Assessment which assesses the extent to which the
development will support opportunities for sustainable travel that should minimise air,
noise and light pollution.
This option would enable more scrutiny over developments to ensure they comply with
181

IIA Objective

12

Page 686

To conserve
and enhance
the historic
environment,
heritage
assets and
their settings

Performance
of Policy

Temporal
Scale
Nature of
Impact

Option
1

T,D,R,M

T10
Option
2
T1

Geographical
Extent

S,M,LT,I,R,M
S,M,LT,I,R,M

OPDC area

Commentary and Recommendations

best practice. In addition it would enable more control over the cumulative impact of
developments on the transport network. More control over development and the
network should help to reduce carbon emissions and subsequently minimise pollution
from private vehicles.
If the threshold was increased developments could be planned without assessing the
impact of the development on the transport system. This could have a detrimental
effect on pollution levels.
Fewer cars will cause less disturbance and pollution which could affect heritage assets
or their settings.
The option would cause more cars which will cause more disturbance and pollution,
which in turn could affect heritage assets or their setting.

T1
Option
1
T2

T3

T4

T5
T6

0
?

T7
T7
Option
1
T7
Option
2
T8

0
0

The policy would not have any significant effects for the objective.
The policy may not have any significant effects for the objective although it depends on
the relative location of heritage assets.
The policy would not have any significant effects for the objective.
The option would not have any significant effects for the objective.

The option would not have any significant effects for the objective.

T8
Option
1
T8

The policy may not have any significant effects for the objective although it depends on
the relative location of heritage assets.
The option would not have any significant effects for the objective.

The option would not have any significant effects for the objective.

S,M,LT,I,R,M
S,M,LT,I,R,M
S,M,LT,I,R,L

OPDC area

OPDC area
OPDC area
OPDC and
surrounding
area

Fewer cars will cause less disturbance and pollution which could affect heritage assets
or their settings.
Fewer cars will cause less disturbance and pollution which could affect heritage assets
or their settings.
The policy would not have any significant effects for the objective. However, a focus on
really high quality design should complement any existing heritage assets.

182

IIA Objective

Performance
of Policy

Option
2
T9

Page 687

13

Increase
community
cohesion and
reduce social
exclusion to
encourage a
sense of
community
and welfare

T9
Option
1
T9
Option
2
T10
T10
Option
1
T10
Option
2
T1

T1
Option
1
T2

T3

T4

Temporal
Scale
Nature of
Impact

Geographical
Extent

Commentary and Recommendations

Although construction work is short-term and temporary, it can affect heritage assets
via direct physical disturbance and noise for example.
S,M,LT,I,R,L

OPDC and
surrounding
area

Options that place strict controls have better chance of preserving the historic
environment and heritage assets.

The option would not have any significant effects for the objective.

0
0

The policy would not have any significant effects for the objective.
The option would not have any significant effects for the objective.

The option would not have any significant effects for the objective.

S,MT,D,R,H

S,MT,D,R,H

S,MT,D,R,H

S,MT,D,R,H

S,MT,D,R,H

OPDC and
surrounding
area
OPDC and
surrounding
area
OPDC and
surrounding
area
OPDC and
surrounding
area
OPDC and
surrounding

Measures that encourage safe, accessible transport can help community cohesion.
A recommendation would be to ensure that the needs to vulnerable and wider diversity
groups are factored in to all places as different groups can have different needs
The priority to car travel in this option will create added congestion causing community
severance.
Measures that encourage safe, accessible transport can help community cohesion.
A recommendation would be to ensure that the needs to vulnerable and wider diversity
groups are factored in to all places as different groups can have different needs
Measures that encourage safe, accessible transport can help community cohesion.
A recommendation would be to ensure that the needs to vulnerable and wider diversity
groups are factored in to all places as different groups can have different needs
The policy promotes sustainable transport and hubs like this can benefit communities
by providing a central focus, encouraging sustainable movement.
183

IIA Objective

Page 688

Performance
of Policy

Temporal
Scale
Nature of
Impact

T5

++

S,MT,D,R,H

T6

S,MT,D,R,M

T7
T7
Option
1
T7
Option
2
T8
T8
Option
1
T8
Option
2
T9

0
0

The policy would not have any significant effects for the objective.
The option would not have any significant effects for the objective.

The option would not have any significant effects for the objective.

0
0

The policy would not have any significant effects for the objective.
The option would not have any significant effects for the objective.

The option would not have any significant effects for the objective.

T9
Option
1
T9
Option
2
T10

Large construction projects and new development may help create a greater sense of
place and build the existing community. The Construction Logistics Strategy promises
to minimise disruption to surrounding residents and business should prevent unrest in
the community.
The option would not have any significant effects for the objective.

The option would not have any significant effects for the objective.

S,M,LT,I,R,L

Geographical
Extent

area
OPDC area

OPDC and
surrounding
area

OPDC area

Commentary and Recommendations

Connections to new stations should take priority to capitalise on new transport

services. There is also a need to secure improved bus connections between Old Oak
and Park Royal to ensure that the existing community can take advantage of the
benefits the new interchange at Old Oak Common would bring to the area.
The policy aims to reduce severance and benefit connectivity.

Transport Assessments and Travel Plans will aim to protect the livelihood of the
community through ensuring transport safety, efficiency and mitigating the impact on
the existing network. This should unite the community.
184

IIA Objective

14

Improve safety
and reduce
crime and the
fear of crime

Performance
of Policy

Temporal
Scale
Nature of
Impact

Geographical
Extent

Commentary and Recommendations

T10
Option
1
T10
Option
2
T1

S,M,LT,I,R,M

OPDC area

More scrutiny over development and early pre-application engagement should help
protect the community.

S,M,LT,D,R,H

T1
Option
1
T2

S,M,LT,D,R,H

S,M-T,
D,R,M

T3

S,M-T,
D,R,H

T4

T5

M,LT,D,R,L
S,M-T,
D,R,H

T6
T7
T7
Option
1
T7

0
0
0

There is a range of potential smart rail innovations that could be achieved with
advances in security technology.
The policy seeks to provide clear and legible signage for bus users. Infrastructure
should include bus priority measures such as priority at junctions, bus gates and bus
only links as well as suitably located bus stops, stands and welfare provision for drivers
Improved lighting and high quality shelters should be implemented on all bus services
and at all bus stops.
The policy would not have any significant effects for the objective.
The policy would not have any significant effects for the objective.
The option would not have any significant effects for the objective.

The option would not have any significant effects for the objective.

The option would not have any significant effects for the objective.

OPDC area
and London
wide
OPDC area
and London
wide
OPDC area

Page 689

OPDC and
surrounding
area
London wide
OPDC and
surrounding
area

The policy addresses the importance of safety through the delivery of accessible
transport systems to facilitate the existing community and planned in these areas of
London.
The option to prioritise car travel contradicts safe, accessible transport infrastructure
and may negatively impact on the safety of the community.
The existing pedestrian environment within the development area is poor. There is
limited permeability and a lack of lighting and active frontages, which creates an
unwelcoming streetscape, a perception of poor personal security and a fear of crime,
particularly after dark. However, the policy does aim to make walking routes safer and
more legible for the users to provide clear, comprehensive and consistent wayfinding
information and enable pedestrians to complete more journeys on foot
The policy seeks to promote safety and security measures for cyclists.

185

IIA Objective

Performance
of Policy

Option
2
T8

Page 690
15

Maximise the
health and
wellbeing of
the population,
reduce
inequalities in
health and
promote

T8
Option
1
T8
Option
2
T9
T9
Option
1
T9
Option
2
T10
T10
Option
1
T10
Option
2
T1

Temporal
Scale
Nature of
Impact

Geographical
Extent

Commentary and Recommendations

S,M,LT,D,R

London wide

The policy explains that the volume of freight and servicing movements raises
challenges in terms of maintenance and management of the road network and the
safety and environment for other road users. FORS is an overarching scheme that
encompasses all aspects of safety, fuel efficiency, economical operations and vehicle
emissions.
The option would not have any significant effects for the objective.

The option would not have any significant effects for the objective.

0
0

The policy would not have any significant effects for the objective.
The option would not have any significant effects for the objective.

The option would not have any significant effects for the objective.

0
0

The policy would not have any significant effects for the objective.
The option would not have any significant effects for the objective.

The option would not have any significant effects for the objective.

++

S,M,LT,D,IR,H

OPDC Area
and
nationwide

As explained in the policy The NPPF emphasises the important role that transport
policies have to play in facilitating sustainable development and in contributing to wider
sustainability and health objectives, and notes that the transport system needs to be
balanced in favour of sustainable transport methods that are efficient, safe and
accessible and that have a low impact on the environment.
Encouraging transport improvements that are both sustainable and technologically apt
will deliver enormous quality of life benefits and deliver a step change in the appeal of
walking and cycling as healthy, active travel options. OPDC is striving to become an
186

IIA Objective

Performance
of Policy

Temporal
Scale
Nature of
Impact

Geographical
Extent

healthy living

Commentary and Recommendations

S,M,LT,D,IR,H

OPDC Area
and
nationwide

exemplar NHS Healthy Town and to gain WHO Healthy City status. Provision of
healthy street environments and that encourage walking, cycling and public transport
use must be sought.
This option would support proposals which prioritise cars above more sustainable
modes would increase congestion, noise and emissions and fewer people would make
journeys by foot, bike or public transport impacting on health and well-being.

T2

++

S,M,L
T,D,IR,M

OPDC area
and London
wide

Providing a street network that is safe, attractive and easy to navigate, people will be
encouraged to walk more, which will have social, economic, environmental and health
benefits and support the viability of the development area.

T3

S,M,LT,D,IR,M

OPDC area,
London and
Nationwide

As explained in the policy the expected growth of cycling up to 2026 is estimated to

deliver 250m in economic health benefits annually. Providing a street network that is
safe, attractive and easy to navigate, people will be encouraged to cycle more, which
will have social, economic, environmental and health benefits and support the viability
of the development area.

T4

S,M,LT,D,R,H

T5

S,M,LT,D,R,H

T6

S,M,LT,D,R,M

OPDC area,
London and
Nationwide
OPDC area,
London and
Nationwide
OPDC area

Increased rail use can encourage more walking/cycling and reduce the use of a private
car. This would reduce the levels of carbons emissions and therefore benefit the
objective.
Increased rail use can encourage more walking/cycling and reduce the use of a private
car. This would reduce the levels of carbons emissions and therefore benefit the
objective.
If new streets are well designed with green infrastructure and improved connectivity
they may benefit the objective and help to avoid social exclusion and mental health
issues.

T1
Option
1

Page 691

T7

T7
Option
1
T7

S,M,LT,I,R,M
S,M,LT,I,R,M
S,M,L-

OPDC area
OPDC area

OPDC area

We recommend that new streets should give consideration to connecting more isolated
areas and seek to reduce social exclusion.
Low levels of car parking will be essential to ensure that traffic congestion does not
reach unacceptable levels. This indirectly bring health benefits to the community.
Less stringent car parking standards may encourage private car use therefore
increasing pollution level and potentially harming the health of the local community.
The use of more sustainable transport due to limited car parking would have a positive
187

IIA Objective

Performance
of Policy

Temporal
Scale
Nature of
Impact

Option
2
T8

T,I,R,M

T8
Option
1
T8
Option
2
T9

Page 692

T9
Option
1
T9
Option
2
T10

16

To improve

T10
Option
1
T10
Option
2
T1

Geographical
Extent

Commentary and Recommendations

effect on the health of the local community.

The significant HGV activity in the development area can have negative impacts on the
health and well-being of the community. However, coordination of HGV activity and the
provision of facilities for home deliveries within residential developments may help
maintain the health of the local community.
The option would not have any significant effects for the objective.

The option would not have any significant effects for the objective.

+/-

S,M,LT,I,R,M

OPDC and
surrounding
areas

+/-

S,M,LT,I,R,M

OPDC area

The policy highlights that construction traffic will increase the volume of HGVs and
other construction vehicles on the local and strategic road network. This will need
careful planning, coordination and management to minimise its traffic and
environmental impacts to minimise health risk.

S,M,LT,D,R,M

London wide

S,M,LT,D,R,M

London wide

S,M,LT,I,R,M

OPDC area

The option to programme construction works without any coordination with other
projects would lead to very high volumes of construction vehicles on the road network
which would also have environmental and health disbenefits.
This option would reduce the impacts of construction on the road network due to the
alternative use of rail or water for all freight. The reduced levels of pollution would have
a positive effect on the health of the local residents and the environment.
All development proposals will be assessed for their contribution to traffic generation
and their impact on congestion, particularly on bus routes and on the primary route
network, and against the existing and potential availability of public transport, and its
capacity to meet increased demand. More public transport and sustainable travel
availability should contribute to healthier living.
More control over development proposals against the impact on the transport network
should make it easier to address the health implications for the local community.

S,M,LT,I,R,M

OPDC area

Increased development without sufficient public transport infrastructure could have a

negative effect on the use of sustainable travel and the health of the local community.

S,M,L-T,

OPDC area

The policy benefits connectivity and may help improve access to schools and higher

188

IIA Objective

the education
and skills
levels of all
members of
the population,
particularly
vulnerable
groups

Performance
of Policy

Temporal
Scale
Nature of
Impact

Geographical
Extent

D,R,M

Commentary and Recommendations

education.
We recommend that consideration is given to connecting all residential areas,
especially the most deprived to a range of essential services such as schools.

T1
Option
1
T2

The option would not have any significant effects for the objective.

S,M,L-T,
D,R,M

OPDC area

Page 693

0
0
0

We recommend that consideration is given to connecting all residential areas,

especially the most deprived to a range of essential services such as schools.
The policy benefits walking routes which provide access to schools and higher
education.
We recommend that consideration is given to connecting all residential areas,
especially the most deprived to a range of essential services such as schools.
The policy benefits connectivity through rail use which will help improve access to
schools and higher education.
We recommend that consideration is given to connecting all residential areas,
especially the most deprived to a range of essential services such as schools.
The policy benefits connectivity through bus travel which will help improve access to
schools and higher education.
We recommend that consideration is given to connecting all residential areas,
especially the most deprived to a range of essential services such as schools.
The policy would not have any significant effects for the objective.
The policy would not have any significant effects for the objective.
The option would not have any significant effects for the objective.

The option would not have any significant effects for the objective.

0
0

The policy would not have any significant effects for the objective.
The option would not have any significant effects for the objective.

T3

S,M,L-T,
D,R,M

OPDC area

T4

S,M,L-T,
D,R,M

OPDC area

T5

++

S,M,L-T,
D,R,M

OPDC area

T6
T7
T7
Option
1
T7
Option
2
T8
T8

The policy benefits walking routes which provide access to schools and higher
education.

189

IIA Objective

Performance
of Policy

Option
1
T8
Option
2
T9
T9
Option
1
T9
Option
2
T10

Page 694
17

Maximise the
social and
economic
wellbeing of
the local and
regional
population and
improve
access to
employment
and training

T10
Option
1
T10
Option
2
T1

Temporal
Scale
Nature of
Impact

Geographical
Extent

Commentary and Recommendations

The option would not have any significant effects for the objective.

0
0

The policy would not have any significant effects for the objective.
The option would not have any significant effects for the objective.

The option would not have any significant effects for the objective.

All proposals for new or significantly expanded schools or other education or

institutional uses should be accompanied by a Travel Plan. The Travel Plan could help
improve levels of access to schools from a range of different areas.
The option would not have any significant effects for the objective.

The option would not have any significant effects for the objective.

S,M,LT,D,R,M

OPDC area
and London
wide

S,M,LT,D,R,M

OPDC area
and London
wide

The policy seeks to improve sustainable access as a consequence of the HS2 and
Crossrail projects. Access in this area will be transformed to cater for the additional
homes and jobs.
The option would benefit from the improved access in the area

Redevelopment presents an opportunity to enhance existing and provide new

pedestrian environments across Old Oak and Park Royal. High quality pedestrian
walking routes to Old Oak Common station from all areas will be vital to ensure
residents, employees and business can benefit from this new transport superhub.
The policy will benefit the objective by OPDC working with businesses in Park Royal to
develop training and guidance and improve awareness of the benefits of cycling to
employees to encourage more cycling. In Old Oak, redevelopment provides an
opportunity to push the boundary and provide state of the art cycling infrastructure that

T1
Option
1
T2

S,M,LT,D,R,M

OPDC area
and London
wide

T3

++

S,M,LT,D,R,M

OPDC area

190

IIA Objective

Page 695

Performance
of Policy

Temporal
Scale
Nature of
Impact

Geographical
Extent

T4

++

S,M,LT,D,R,H

OPDC area
and London
wide

T5

S,M,LT,D,R,M

OPDC area
and London
wide

T6

S,M,LT,D,R,M

OPDC area
and London
wide

T7

S,M,LT,D,R,M

OPDC area
and London
wide

+/-

S,M,LT,D,R,M

OPDC area

S,M,LT,D,R,M

OPDC area

T7
Option
1
T7
Option
2
T8
T8
Option
1
T8
Option
2

Commentary and Recommendations

can benefit everyone who lives and works in the area.

The policy explains that the new HS2, Crossrail and Great West Mainline station at Old
Oak Common will be a key driver for regeneration in the area. When built out the core
area at Old Oak will be served by approximately ten different rail services and over 200
trains per hour at peak times. This will benefit the social and economic wellbeing of the
local people and provide sufficient access to key employment and training areas.
The policy states that increased bus services and frequencies would provide improved
connections to homes, office and retail destinations in Old Oak and Park Royal
reducing dependence on the private car. This is of particular relevance for existing
business in Park Royal whereby a high percentage of people live within 5-8km of the
area and therefore making a reliable and frequent bus service a viable option for
travelling to work.
The policy seeks to enhance existing streets and junctions to mitigate the impacts of
development on the surrounding local and strategic road network. A better road
network in the OPDC are would better serve local communities and improve
employment provision.
The policy promotes car free development close to public transport hubs and zero car
parking for non-residential developments in Old Oak. Despite benefitting the
environmental wellbeing of the community this may hinder accessibility to employment
due to dependence on public transport. There is likely to be a strong demand for taxis
and private hire vehicles (PHVs) generated by the HS2/ Crossrail/ National Rail
interchange.
The less stringent car parking standards in this option would place unacceptable
impacts on the surrounding road network which may discourage sustainable travel but
maintain sufficient access to employment.
A car free policy option would also negatively impact businesses that rely on private
vehicles, particularly in Park Royal.

0
0

The policy would not have any significant effects for the objective.
The option would not have any significant effects for the objective.

The option would not have any significant effects for the objective.

191

IIA Objective

Page 696

18

To encourage
inward
investment
alongside
investment
within existing
communities,
to create
sustainable
economic
growth

Performance
of Policy

Temporal
Scale
Nature of
Impact

Geographical
Extent

Commentary and Recommendations

T9

S,M,LT,D,R,M

OPDC area

More construction work would provide an employment source for the local community.

T9
Option
1
T9
Option
2
T10

The option would not have any significant effects for the objective.

The option would not have any significant effects for the objective.

Transport Assessments and Travel Plans will address any access issues to key
services such as employment hubs.
The option would not have any significant effects for the objective.

T10
Option
1
T10
Option
2
T1

S,M,LT,I,R,L

OPDC and
surrounding
area
OPDC area
and London
wide
OPDC and
surrounding
boroughs
OPDC area

S,M,LT,I,R,M

T1
Option
1
T2

++

S,M,LT,D,R,M

++

S,M,LT,D,R,H

T3

++

S,M,LT,D,R,M

OPDC area
and London
wide

T4

++

S,M,L-

OPDC area

This option could lead to access issues, a congested road network and insufficient
public transport infrastructure. This may result in problems accessing employment and
training facilities.
The policy states that, as a consequence of the HS2 and Crossrail projects, there be
greater investment in the area.
This option would benefit the objective with support for proposals which prioritise cars
above more sustainable modes which may benefit some businesses and residents.
Walking as a sustainable form of transport can bring economic benefits. Through an
increase in footfall, the vitality of an area is likely to increase and subsequently bring
benefits to local businesses.
Redevelopment presents an opportunity to enhance the existing pedestrian
environment and deliver a high quality pedestrian environment in Old Oak and Park
Royal. High quality pedestrian walking routes to Old Oak Common station from all
areas will be vital to ensure residents, employees and business can benefit from the
new transport superhub.
Investments in end-of-journey cycle facilities in the form of secure cycle parking,
lockers and showers are also vital across Old Oak and Park Royal. Major employers,
businesses and landowners should invest in this infrastructure, recognising its value
and importance to their businesses, tenants and employees.
The policy explains that the new HS2, Crossrail and Great West Mainline station at Old
192

IIA Objective

Performance
of Policy

Temporal
Scale
Nature of
Impact

Geographical
Extent

Commentary and Recommendations

T,I,R,H

and London
wide

Oak Common will be a key driver for regeneration in the area. This should attract
investment and benefit local businesses to improve the local economy.
The policy promotes sustainable bus travel. Increased bus frequencies, better journey
time reliability, new and improved bus stops and a more efficient service should
encourage inward investment and attract businesses to the area. This will have a
positive effect on the local economy.
The policy states that congestion at key junctions and on links providing access to
strategic routes is a barrier to business growth. However, In Park Royal, the road
network will need to prioritise the movement of freight to facilitate business growth.
This will need to be carefully planned alongside the need to improve bus movements,
pedestrians and cyclists and deliver a healthy street environment.
Sufficient car parking will need to be provided to meet the essential needs of
developments, particularly ensuring that there are suitable places for disabled people,
car clubs and electric cars and facilitating the successful operation of the Park Royal
industrial estate. This approach is justified by the very high level of public transport
accessibility resulting from the planned and proposed investment. The need for access
to a car can be met in part by dedicated car club spaces together with parking for
disabled people.
The option would not have any significant effects for the objective.

S,M,LT,D,R,M

OPDC area
and London
wide

T6

+/-

S,M,LT,D,R,M

OPDC area
and London
wide

T7

++

S,M,LT,D,R,M

OPDC area
and London
wide

S,M,LT,D,R,M

OPDC area

S,M,LT,D,R,M

London wide

S,M,LT,D,R,M

S,M,L-

OPDC and
surrounding
area.
OPDC and

Page 697

T5

T7
Option
1
T7
Option
2
T8
T8
Option
1

T8
Option
2
T9

0
+/-

A car free policy option would also negatively impact businesses that rely on private
vehicles, particularly in Park Royal.
The policy would not have any significant effects for the objective.
This option may have some attraction for businesses. However, if no measures were
put in place to control servicing and deliveries, HGVs and LGVs flow would increase
drastically, exacerbating the congestion issues in the development area, as well as
having noise and environmental impacts, affecting the public realm and using up road
space.
This option explains that banning larger vehicles completely would negatively impact
businesses. This could detract certain types of industries moving into the area.
The nearby delivery of HS2 and Crossrail may encourage other businesses and
193

IIA Objective

Performance
of Policy

Page 698

T9
Option
1
T9
Option
2
T10
T10
Option
1
T10
Option
2

Temporal
Scale
Nature of
Impact

Geographical
Extent

Commentary and Recommendations

T,D,R,M

surrounding
area.

investment to move into the area. For existing businesses the construction disruptions
will be minimised by the Construction Logistics Strategy.
The option would not have any significant effects for the objective.

The option would not have any significant effects for the objective.

0
0

The policy would not have any significant effects for the objective.
The option would not have any significant effects for the objective.

The option would not have any significant effects for the objective.

Table G-10 Chapter 12: Environment and Utilities

x EU1: Strategic Policy: environment and utilities
x EU2: Smart
x EU3: Water
x EU4 Waste management
x EU5: Circular economy and resource efficiency
x EU6: Decentralised Energy
x EU7: Digital communications infrastructure
x EU8: Green infrastructure and biodiversity
x EU9: Extraction of Minerals
x EU10: Air quality
x EU11: Noise
x EU12: Land contamination

194

IIA Objective

To enhance
the built
environment
and
encourage
place-making

Performance
of Policy

Temporal
Scale
Nature of
Impact
S, M and LT, D, R, M

Geographical
Extent

Commentary and Recommendations

OPDC area

The policy seeks to work with developers to promote sustainable development that
utilises high standards of design, innovation, planning etc, this would therefore optimise
opportunities to encourage place making at the start of the planning process. Utilising
high standards of design may also contribute to enhancing local character and
distinctiveness.

OPDC area

Promoting the area as a global leading location for the exploration and implementation
of smart city technology, concepts and systems would benefit this SA Objective as it
actively encourages the use of contemporary technology although the policy does not
explicitly state this would be within the public realm a positive score has been noted.

Page 699

EU1

EU2

Alterna
tive
Policy
Option
1
EU3

EU4

EU4
Option
1

EU5

There is no direct link between the policy and the SA Objective.

EU6

Seeking to support and facilitate the provision of infrastructure to deliver a

decentralised energy network within major new development may affect the character
and quality of the built environment of the OPDC area depending on its visual

S, M and LT, D, R, M

A neutral score has been recorded against the SA Objective as not specifically
supporting inter-operable and open data would not detract nor benefit the SA
Objective.

M and L-T,
I, R, L

OPDC area

M and L-T,
I, R, L

OPDC area

The policy would ensure public areas are accessible in the medium to long term
through managing surface water runoff and implementing flood risk management
solutions. In addition, it would also indirectly contribute to ensuring new buildings are
appropriately designed i.e. through ensuring they do not lead to inappropriate run off or
lead to an unacceptable demand on water resources.
The relocation of waste and recycling sites (depending upon the final design) may lead
to a detrimental effect on landscape character. Due to this uncertainty it is
recommended that the policy is strengthened to include a statement to say that sites
would only be permitted where it can be demonstrated they would not significantly
affect the character of the local area. Although it is noted that plan should be read as a
whole and this is covered elsewhere.
Safeguarding all sites in Old Oak may lead to more waste sites in the area and less
homes, this would therefore go against the principles of place making and why a
negative score has been noted.

195

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

EU6
Option
1
EU7

appearance. Due to this uncertainty it is recommended that the policy is strengthened

to include a statement to say that energy development would only be permitted where
it can be demonstrated it would not significantly affect the character of the local area.
Although it is noted that plan should be read as a whole and this is covered elsewhere.
Although the alternative policy option would bring about more uncertainty as it would
apply to all new development rather than just major development.

Page 700

S, M and LT, D, R, M

OPDC area

++

S, M and LT, D, R, M

OPDC area

EU8
Option
1
EU9

S, M and LT, D, R, M

OPDC area

S, M and LT, D, R, M

OPDC area

EU10

Seeking to integrate technology and seeking to accommodate future technologies

would benefit this SA Objective as it actively encourages the use of contemporary
technology (part of the sub-objectives) although the policy does not explicitly state
this would be within the public realm a positive score has been noted.
A neutral score has been recorded against the SA Objective as not specifically seeking
to integrate contemporary technology and accommodate future technologies to
address challenges and create opportunities.
Ensuring all new development seeks to protect, enhance, and helps create a network
of multi-functional green and water spaces connected by street greening would lead to
a positive effect on the SA Objective as it would directly enhance the built environment
and encourage place making. For this reason a major positive score has been
recorded.
The alternative policy option would lead to a minor positive effect as deleting the policy
reference to all development, so that the policy requirements apply to major
development only would not be as positive.
The policys commitment to ensuring the design of oil / gas development is sensitive to
the character of the urban landscape and to features of national, London, and local
importance would benefit this SA Objective.
There is no direct link between the policy and the SA Objective.

EU10
Option
1
EU11

There is no direct link between the alternative policy and the SA Objective.

EU7
Option
1
EU8

S, M and LT, I, R, L

OPDC area

Guarding against inappropriate increases in noise levels from major development

would indirectly contribute to the creation of safe and welcoming spaces.

196

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

To optimise
the efficient
use of land
through
increased
development
densities and
building
heights, where
appropriate

Page 701

EU12

There is no direct link between the policy and the SA Objective.

EU1

There is no clear link between the policy and the SA Objective.

EU2

There is no direct link between the policy and the SA Objective.

EU2
Option
1
EU3

There is no direct link between the alternative policy option and the SA Objective.

There is no direct link between the policy and the SA Objective.

EU4

There is no direct link between the policy and the SA Objective.

EU4
Option
1
EU5

There is no direct link between the alternative policy option and the SA Objective.

There is no direct link between the policy and the SA Objective.

EU6

There is no direct link between the policy and the SA Objective.

Alterna
tive
Policy
Option
1
EU7

There is no direct link between the alternative policy option and the SA Objective.

There is no direct link between the policy and the SA Objective.

EU7
Option
1
EU8

There is no direct link between the alternative policy option and the SA Objective.

There is no direct link between the policy and the SA Objective.

197

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

Page 702

Maximise the
reuse of
previously
developed
land and
existing
buildings,
including the
remediation of
contaminated
land

EU8
Option
1
EU9

There is no direct link between the alternative policy option and the SA Objective.

There is no clear link between the policy and the SA Objective.

EU10

There is no clear link between the policy and the SA Objective.

EU10
Option
1
EU11

There is no clear link between the alternative policy option and the SA Objective.

There is no direct link between the policy and the SA Objective.

EU12

There is no direct link between the policy and the SA Objective.

EU1

The policy states that OPDC supports proposals that maximise their contribution to

a healthy and safe environment for people and for nature.

EU2

There is no direct link between the policy and the SA Objective.

EU2
Option
1
EU3

There is no direct link between the alternative policy option and the SA Objective.

There is no direct link between the policy and the SA Objective.

EU4

S, M and LT, D, R, M

OPDC area
and wider
area

EU4
Option
1

S, M and LT, D, R, M

OPDC area
and wider
area

The policy seeks to safeguard waste and recycling sites within the OPDC area which
would maintain current accessibility to waste facilities at those identified sites. The
policy also states that OPDC will work with other waste operators to relocate some
sites to suitable areas. This could be strengthened to state that it would be ensured
sites would be relocated to sites that are highly accessible by a variety of transport
modes.
The alternative policy option would result in a change to criterion b). The change
provides for safeguarding all sites in Old Oak rather than just one site. Therefore as
above this would maintain current accessibility to waste facilities as per the preferred
policy. The remainder of the policy and scores recorded would remain as per the
198

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

Page 703

EU5

EU6

preferred option.
The policy would result in ensuring new development provides adequate provision for
convenient domestic and commercial waste storage this would therefore contribute to
increasing accessibility to household and commercial waste management facilities.
There is no direct link between the policy and the SA Objective.

EU6
Option
1
EU7

There is no direct link between the alternative policy option and the SA Objective.

There is no direct r link between the policy and the SA Objective.

EU7
Option
1
EU8

There is no direct r link between the alternative policy option and the SA Objective.

There is no direct link between the policy and the SA Objective.

EU8
Option
1
EU9

There is no direct link between the alternative policy option and the SA Objective.

There is no direct link between the policy and the SA Objective.

EU10

There is no direct link between the policy and the SA Objective.

EU10
Option
1
EU11

There is no clear link between the alternative policy option and the SA Objective.

There is no direct link between the policy and the SA Objective.

S, M and LT, D, R, M

OPDC area
and wider
area

199

IIA Objective

Page 704

Minimise the
need to travel,
improve
accessibility
for all users by
public and
non-motorised
transportation
methods and
mitigate
impacts on the
transport
network

Performance
of Policy

Temporal
Scale
Nature of
Impact
L-T, D, R,
M

Geographical
Extent

Commentary and Recommendations

OPDC area

The policy ensures that development would not be permitted until effective measures
are taken to manage the risk of contaminated land through treating, containing or
controlling. This would therefore fulfil this SA Objective as it would contribute to a
scheme of land remediation and improve soil quality over the long term.

EU12

++

EU1

EU2

EU2
Option
1
EU3

EU4

EU4
Option
1
EU5

EU6

The policy seeks to investigate the movement of waste through by sustainable means
of transport, including by rail and by the Grand Union Canal which may mitigate
impacts on the transport network. It also seeks to design out waste from construction
which may also mitigate impacts on the transport network.
There is no direct link between the policy and the SA Objective.

EU6
Option
1

There is no direct link between the alternative policy option and the SA Objective.

M and L-T,
D, R, L

OPDC area

The policy seeks to ensure that new developments minimise carbon dioxide emissions.
However there is no specific reference to how this would be achieved. This could be
defined in supporting evidence.
Although not explicitly mentioned in the policy the implementation of smart city
technology may benefit this SA Objective as it could encourage sustainable transport
modes.
There is no clear link between the alternative policy option and the SA Objective.

M and L-T,
D, R, L

OPDC area

The policy would maintain accessibility within the OPDC area in the medium to long
term through managing surface water runoff and implementing flood risk management
solutions.
Although a neutral score has been recorded, it is recommended that the relocation of
any waste operators are directed to areas that are readily accessible via a number of
modes of transport.
There is no direct link between the alternative policy and the SA Objective i.e.
safeguarding all sites in Old Oak would not affect the SA Objective.

S, M and LT, D, R, L

OPDC area

200

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

OPDC area

The policy may over the medium to long term contribute to encouraging video
conferencing and home working in addition to home shopping therefore reduce the
need to travel.

Nature of
Impact
EU7

EU7
Option
1
EU8

M and L-T,
D, R, L

Benefits recorded above would not be realised under the alternative option.

Page 705

S, M and LT, I/D, R, L

OPDC area

EU8
Option
1

S, M and LT, I/D, R, L

OPDC area

EU9

EU10

S, M and LT, D, R, M

OPDC area

EU10
Option
1
EU11

S, M and LT, D, R, M

OPDC area

The policy seeks to ensure that all development proposals protect, enhance, and
create a network of multi-functional green and water spaces connected by street
greening. It is considered that this may contribute to the SA Objective through
increasing the connection of the public realm and internal routes to neighbouring areas
alongside local and strategic cycle and walking networks.
Removing the requirement within the policy to require that only major new
development proposals protect, enhance, and create a network of multi-functional
green and water spaces connected by street greening rather than requiring all new
development would water down the positive score recorded for the preferred option.
The policy ensures that any proposals for development associated with the exploration,
appraisal and operation of unconventional oil and gas resources would be acceptable
in terms of site access, traffic generation and the routing of heavy vehicles along with
the effects on public rights of way, open spaces or outdoor recreation. Effects have
been recorded as neutral as the policy would ensure the continuation of the existing
baseline.
Ensuring air quality assessments are undertaken for all major development within the
OPDC area would ensure that the impact of construction traffic (mitigating the impact
of construction traffic is listed as a sub-objective) is minimised as the assessment
would also outline mitigation measures to reduce any identified impacts. For this
reasons a positive score has been recorded over the short to long term.
The alternative policy option would perform is a similar way to the preferred option as it
would only involve the removal major development so that all development would
require an air quality assessment.
There is no direct link between the policy and the SA Objective.

EU12

There is no direct link between the policy and the SA Objective.

201

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
5

Page 706

Improve
access to well
designed,
well-located,
market,
affordable and
inclusive
housing of a
range of types
and tenures,
to meet
identified local
needs

EU1

There is no direct link between the policy and the SA Objective.

EU2

There is no direct link between the policy and the SA Objective.

EU2
Option
1
EU3

There is no direct link between the alternative policy option and the SA Objective.

EU4

The policy would indirectly contribute to ensuring new homes are appropriately
designed and located through ensuring they do not lead to inappropriate run off, flood
risk or unacceptable water demand.
There is no direct link between the policy and the SA Objective.

EU4
Option
1
EU5

There is no direct link between the alternative policy option and the SA Objective.

There is no direct link between the policy and the SA Objective.

EU6

There is no direct link between the policy and the SA Objective.

EU6
Option
1
EU7

There is no direct link between the alternative policy option and the SA Objective.

There is no direct link between the policy and the SA Objective.

EU7
Option
1
EU8

There is no direct link between the alternative policy option and the SA Objective.

There is no direct link between the policy and the SA Objective.

EU8
Option
1

There is no direct link between the alternative policy option and the SA Objective.

S, M and LT, I, R, M

OPDC area

202

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

Page 707

Improve
climate
change
adaptation and
mitigation,
including
minimising the
risk of flooding
and
addressing the
heat island
effect

EU9

There is no direct link between the policy and the SA Objective.

EU10

There is no direct link between the policy and the SA Objective.

EU10
Option
1
EU11

There is no direct link between the alternative policy option and the SA Objective.

There is no direct link between the policy and the SA Objective.

EU12

There is no direct link between the policy and the SA Objective.

EU1

++

S, M and LT, D, R, M

Old Oak and

Park Royal

The policy commits to promoting Old Oak and Park Royal as a best practice
demonstrators for environmental sustainability. OPDC aim to achieve this through the
identification and definition of environmental sustainability targets and indicators for the
area. The policy seeks to increase the areas resilience to the effects of a changing
climate, and seeks to minimise carbon dioxide emissions. Draft targets are provided, of
which one states Use SuDs to achieve run-off rate equivalent to a greenfield site. This
holistic and evolving approach will support the delivery of the Objective.

EU2

M and L-T,
D, R, L

OPDC area

Although not explicitly mentioned in the policy the implementation of smart city
technology may benefit this SA Objective as it could encourage innovative climate
change adaptation and mitigation measures.

EU2
Option
1

EU3

++

EU4

There is no clear link between the alternative policy option and the SA Objective.

S, M and LT, D, R, M

OPDC area
and wider
area

The policy positively fulfils the SA Objective through promoting the use of sustainable
drainage techniques within new development along with implementing flood risk
management solutions identified in the relevant boroughs Surface Water Management
Plans.
There is no direct link between the policy and the SA Objective.

203

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

EU4
Option
1
EU5

There is no direct link between the alternative policy option and the SA Objective.

++

S, M and LT, D, R, M

OPDC area
and wider
area

The policy seeks to promote a circular economy which will ultimately help to mitigate
climate change.

EU6

++

S, M and LT, D, R, M

OPDC area
and wider
area

The policy is principally focused on ensuring new major development is able to

accommodate energy demand through a decentralised energy network which will help
to mitigate climate change and provide a resilient energy supply.

Page 708

EU6
Option
1
EU7

The alternative policy option would perform as per the preferred option. However, the
recommendation would not just apply to energy development associated with major
new development, it would apply to all development.
There is no clear link between the policy and the SA Objective.

EU7
Option
1
EU8

There is no clear link between the alternative policy option and the SA Objective.

++

S, M and LT, D, R, M

OPDC area
and wider
area

The policy will play a leading role to ensure development helps to mitigate and address
climate change by delivering a multifunctional network of green infrastructure.

EU8
Option
1

S, M and LT, D, R, M

OPDC area
and wider
area

This option would limit the delivery of green infrastructure to major development
thereby having less of a positive impact on the objective.

EU9

S, M and LT, D, R, M

OPDC area

EU10

The policy seeks to ensure that applications for the exploration, appraisal and
operation of unconventional oil and gas resources will be permitted subject to series of
criteria to manage a range of impacts. Therefore a positive score has been recorded
against this SA Objective.
There is no clear link between the policy and the SA Objective.

EU10
Option

There is no clear link between the alternative policy option and the SA Objective.
204

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

Page 709

To minimise
contributions
to climate
change
through
greater energy
efficiency,
generation
and storage;
and to reduce
reliance on
natural
resources
including fossil
fuels for
transport,
heating and
energy

1
EU11

There is no clear link between the policy and the SA Objective.

EU12

There is no clear link between the policy and the SA Objective.

EU1

S, M and LT, D, R, M

Old Oak and

Park Royal

EU2

M and L-T,
D, R, L

OPDC area

EU2
Option
1
EU3

There is no direct link between the alternative policy option and the SA Objective.

There is no direct link between the policy and the SA Objective.

EU4

There is no direct link between the policy and the SA Objective.

EU4
Option
1
EU5

There is no direct link between the alternative policy option and the SA Objective.

S, M and LT, D, R, M

OPDC area

EU6

++

M and L-T,
D, R, M

OPDC area

The policy commits to promoting Old Oak and Park Royal as a best practice
demonstrators for environmental sustainability. OPDC aim to achieve this through the
identification and definition of environmental sustainability targets and indicators for the
area. Draft targets are provided, of which one states Generate 25% of Londons
energy locally. This would therefore contribute to encouraging development within the
area to be to be more self-sufficient in terms of energy generation and is why a positive
score has been noted.
Although not explicitly mentioned in the policy the implementation of smart city
technology may benefit this SA Objective as it could encourage innovative energy
generation, distribution and storage.

The policy seeks to reduce waste generated by new development through using waste
as a resource e.g. through maximising the use of secondary materials and the
opportunities for reuse or recycling of materials remaining from construction and
investigating the potential for on-site energy recovery from waste. This would benefit
the SA Objective as it would contribute to minimising the resource requirements and
outputs for new development.
The policy supports and seeks to facilitate the provision of infrastructure to deliver a
decentralised energy network as part of new major development. This would positively
benefit the SA Objective as would encourage new major development to be more self205

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

Page 710
8

To minimise
production of
waste across
all sectors in
the plan area,
maximise
efficiencies for

EU6
Option
1
EU7

++

sufficient over the medium to long term.

The alternative policy option would perform as per the preferred option. However, the
recommendation would not just apply to energy development associated with major
new development, it would apply to all development.
There is no direct link between the policy and the SA Objective.

EU7
Option
1
EU8

There is no direct link between the alternative policy option and the SA Objective.

There is no direct link between the policy and the SA Objective.

EU8
Option
1
EU9

There is no direct link between the alternative policy option and the SA Objective.

EU10

The policys commitment to ensuring the design of oil / gas development controls and
mitigations greenhouse gas emissions and dust during construction and operation
would benefit this SA Objective.
There is no direct link between the policy and the SA Objective.

EU10
Option
1
EU11

There is no direct link between the alternative policy option and the SA Objective.

There is no direct link between the policy and the SA Objective.

EU12

There is no direct link between the policy and the SA Objective.

EU1

++

M and L-T,
D, R, M

S, M and LT, D, R, M

M and L-T,
D, R, M

OPDC area

OPDC area

OPDC area
and wider
area

The policy commits to promoting Old Oak and Park Royal as a best practice
demonstrators for environmental sustainability. OPDC aim to achieve this through the
identification and definition of environmental sustainability targets and indicators for the
area. Draft targets are provided, of which the draft waste targets include: Working
towards zero biodegradable / recyclable waste to landfill by 2026 and 90% re-cycling /
re-purposing of construction materials. This would therefore contribute to increasing
the amount of recycled materials for the construction of buildings and addressing the
displacement of waste. For these reasons a major positive score has been recorded.
206

IIA Objective

transporting
waste and
increasing
rates of reuse, recycling
and recovery
rates as well
as composting
of all green
waste

Performance
of Policy

Temporal
Scale
Nature of
Impact
M and L-T,
D, R, L

Geographical
Extent

Commentary and Recommendations

OPDC area

Page 711

EU2

EU2
Option
1
EU3

Although not explicitly mentioned in the policy the implementation of smart city
technology may benefit this SA Objective as it could encourage innovative waste
collection.
There is no direct link between the alternative policy option and the SA Objective.

There is no direct link between the policy and the SA Objective.

EU4

EU4
Option
1
EU5

S, M and LT, D, R, M

OPDC area
and wider
area

The policy seeks to safeguard waste and recycling sites within the OPDC area which
would maintain current accessibility to waste facilities at those identified sites. The
policy also states that OPDC will work with other waste operators to relocate some
sites to suitable areas. This could be strengthened to state that it would be ensured
sites would be relocated to sites that are highly accessible by a variety of transport
modes.
There is no clear link between the alternative policy and the SA Objective i.e.
safeguarding all sites in Old Oak would not affect the SA Objective.

S, M and LT, D, R, M

OPDC area

EU6

The policy seeks to reduce waste and use it as a resource particularly on building sites.
It also commits to investigating the potential for the movement of waste and recyclable
materials during construction by sustainable means of transport, including by rail, and
by the Grand Union Canal. All of which would promote the circular economy for the
production of waste, increase the use of recycled materials in construction and
maximises the use of innovative waste collection. As the policy largely fulfils their SA
Objective and its sub-objective a major positive score has been recorded.
There is no direct link between the policy and the SA Objective.

EU6
Option
1
EU7

There is no direct link between the alternative policy option and the SA Objective.

There is no direct link between the policy and the SA Objective.

EU7
Option
1

There is no direct link between the policy and the SA Objective.

++

207

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

Page 712
9

Improve the
quality of the
water
environment

EU8

There is no direct link between the policy and the SA Objective.

EU8
Option
1
EU9

There is no direct link between the alternative policy option and the SA Objective.

EU10

The policy stipulates that applications for the exploration, appraisal and operation of
unconventional oil and gas resources will be permitted where they demonstrate the
efficient use of resources such as construction materials. This would therefore
contribute albeit slightly to supporting the SA Objective.
There is no direct link between the policy and the SA Objective.

EU10
Option
1
EU11

There is no direct link between the alternative policy option and the SA Objective.

There is no direct link between the policy and the SA Objective.

EU12

S, M and LT, D, R, M

OPDC area

The policy seeks to remediate contaminated land. This would therefore partially fulfil
the SA Objective through contributing to the sustainable management of contaminated
soils.

EU1

++

S, M and LT, D, R, M

OPDC area

The policy commits to promoting Old Oak and Park Royal as a best practice
demonstrators for environmental sustainability. OPDC aim to achieve this through the
identification and definition of environmental sustainability targets and indicators for the
area. Draft targets are provided and water related targets include minimising use of
mains water and water efficiency of 105 lphpd to match higher requirements of
Building Regulations. This would therefore promote improved efficiency in the use of
water domestically and commercially.

EU2

M and L-T,
D, R, L

OPDC area

Although not explicitly mentioned in the policy the implementation of smart city
technology may benefit this SA Objective as it could encourage innovative
mechanisms to manage and monitor water quality.

M and L-T,
D, R, M

OPDC area

208

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
EU2
Option
1
EU3

There is no direct link between the alternative policy option and the SA Objective.

Page 713

EU4

The policy seeks to ensure new development proposals promote integrated water
management, through addressing surface and waste-water disposal capacity issues,
sustainably managing water supply and minimising water consumption. All of which
promotes efficiency in the use of water. In addition the policy also seeks to ensure new
development protects and improve the water environment of the Grand Union Canal
and other watercourses. This would contribute to the protection of local water courses.
There is no direct link between the policy and the SA Objective.

EU4
Option
1
EU5

There is no direct link between the alternative policy option and the SA Objective.

There is no direct link between the policy and the SA Objective.

EU6

EU6
Option
1
EU7

Seeking to support and facilitate the provision of infrastructure to deliver a

decentralised energy network within major new development may pose a risk to the
water environment through contaminated run-off.
As above. Although the alternative policy option would bring about more uncertainty as
it would apply to all new development rather than just major development.

There is no direct link between the policy and the SA Objective.

EU7
Option
1
EU8

There is no direct link between the alternative policy option and the SA Objective.

EU8
Option
1

++

S, M and LT, D, R, M

OPDC area

S, M and LT, D, R, M

OPDC area

S, M and LT, D, R, M

OPDC area

The policy seeks to maximise opportunities to protect and / or enhance biodiversity in

the Grand Union Canal and protect, enhance, and creates a network of multi-functional
water spaces. This would therefore help to meet the SA sub-objectives, more
specifically to promote the quality of local watercourses.
The alternative policy option would perform in a similar way to the preferred option,
albeit to a lesser extent as the policy would apply to major development only and not
all development.
209

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

Page 714
10

Create and
enhance
biodiversity
and the
diversity of
habitats
across the
area and its
surroundings

EU9

EU10

The policy seeks to ensure that oil and gas development incorporates the efficient use
of resources such as water which could lead to some benefits against this objective.
However, the policy does not specifically state that oil and gas development should
seek to ensure the quality of the water environment is protected. This will be covered
by other Local Plan and London Plan policies. The policy also states that a careful
balance should be struck between any potential impact on the environment on our
communities and businesses. This should restrict the potential for negative effects.
There is no clear link between the policy and the SA Objective.

EU10
Option
1
EU11

There is no direct link between the alternative policy option and the SA Objective.

There is no clear link between the policy and the SA Objective.

EU12

S, M and LT, D, R, M

OPDC area

The policy seeks to ensure that the remediation of contaminated land for new
development does not lead to the contamination of any watercourse, water body or
aquifer. As the policy directly seeks to prevent the risk posed to the water environment
from the run-off of contaminants a positive score has been recorded.

EU1

S, M and LT, D, R, M

OPDC area

EU2

M and L-T,
D, R, L

OPDC area

The policy commits to promoting Old Oak and Park Royal as a best practice
demonstrators for environmental sustainability. OPDC aim to achieve this through the
identification and definition of environmental sustainability targets and indicators for the
area. Draft targets are provided and those relevant include no net loss of biodiversity
and increase tree cover by at least 10%. This would therefore contribute to conserving
biodiversity. The policy also commits to promoting ecological enhancement. To
improve the sustainability performance of the policy it is recommended that the draft
target seeking to ensure there is no net loss of biodiversity is amended in line with the
NPPF to state new development should achieve net gains for nature.
Although not explicitly mentioned in the policy the implementation of smart city
technology may benefit this SA Objective as it could encourage innovative
mechanisms to manage and monitor biodiversity.

EU2
Option

There is no direct link between the alternative policy option and the SA Objective.
210

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

OPDC area

The policy seeks to ensure development proposals within Park Royal and Old Oak
include measures to protect and improve the ecological value of the Grand Union
Canal and other watercourses. This may contribute to improving the existing poor
biological quality Grand Union Canal and conserving overall biodiversity across the
plan area.
The relocation of waste and recycling sites (depending upon the location) may lead to
a detrimental effect on biodiversity.
There is no direct link between the alternative policy and the SA Objective i.e.
safeguarding all sites in Old Oak would not affect the SA Objective.

Nature of
Impact

Page 715

1
EU3

EU4

EU4
Option
1
EU5

There is no direct link between the policy and the SA Objective.

EU6

EU6
Option
1
EU7

Seeking to support and facilitate the provision of infrastructure to deliver a

decentralised energy network within major new development may lead to a loss in
biodiversity resources.
As above. Although the alternative policy option would bring about more uncertainty as
it would apply to all new development rather than just major development.

There is no clear link between the policy and the SA Objective.

EU7
Option
1
EU8

There is no clear link between the alternative policy option and the SA Objective.

EU8
Option
1
EU9

S, M and LT, D, R, M

++

S, M and LT, D, R, M

OPDC area

S, M and LT, D, R, M

OPDC area

A major positive score has been recorded against the SA Objective as the policy seeks
to ensure all new development conserves / enhances existing biodiversity, increases
connectivity of habitats through the provision of green infrastructure and protecting
designated sites.
The alternative policy option would perform in a similar way to the preferred option,
albeit to a lesser extent as the policy would apply to major development only and not
all development.
Effects are recorded as uncertain as extraction of minerals could adversely affect
biodiversity. It is therefore recommended that an additional criterion is added to the
policy to ensure that any applications for the exploration, appraisal and operation of
211

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

Page 716

11

To minimise
air, noise and
light pollution,
particularly for
vulnerable
groups

EU10

unconventional oil and gas resources safeguard existing biodiversity across the plan
area.
There is no clear link between the policy and the SA Objective.

EU10
Option
1
EU11

There is no clear link between the alternative policy option and the SA Objective.

There is no direct link between the policy and the SA Objective.

EU12

S, M and LT, D, R, L

OPDC area

Seeking to remediate contaminated land within the OPDC area and guarding against
the risk of contaminated run off to watercourses would benefit the SA Objective and
may increase biodiversity resources on brownfield sites. However, this would be
dependent upon the final development on the site. A low certainty has therefore been
recorded.

EU1

S, M and LT, D, R, M

OPDC area

EU2

M and L-T,
D, R, L

OPDC area

The policy commits to promoting Old Oak and Park Royal as a best practice
demonstrators for environmental sustainability. OPDC aim to achieve this through the
identification and definition of environmental sustainability targets and indicators for the
area. Draft targets are provided, those relevant include the best air quality of any major
world city by 2020 and guidelines produced under the auspices of the World Health
Organisation. This would therefore contribute to minimising air and noise pollution for
communities and is why a positive score has been noted.
Although not explicitly mentioned in the policy the implementation of smart city
technology may benefit this SA Objective as it could encourage innovative
mechanisms to manage and monitor air, noise and light pollution.

EU2
Option
1
EU3

There is no clear link between the alternative policy option and the SA Objective.

There is no direct link between the policy and the SA Objective.

EU4

M and L-T,
D, R, L

OPDC area

The relocation of waste and recycling sites (depending upon the location) may
negatively impact on sensitive uses including existing and future homes and building
occupants.
212

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

Page 717

EU4
Option
1
EU5

There is no clear link between the alternative policy and the SA Objective i.e.
safeguarding all sites in Old Oak would not affect the SA Objective.

M and L-T,
I, R, L

OPDC area

EU6

M and L-T,
D, R, L

OPDC area

EU6
Option
1

As above. Although the alternative policy option would bring about more uncertainty as
it would apply to all new development rather than just major development.

EU7

There is no direct link between the policy and the SA Objective.

EU7
Option
1
EU8

There is no direct link between the policy and the SA Objective.

S, M and LT, D, R, M

OPDC area

EU8
Option
1
EU9

S, M and LT, D, R, M

OPDC area

EU10

L-T, D, R,
M

OPDC area

The policy commits to designing out waste from construction sites and maximising
waste generated for re use in construction over the medium to long term this may
lead to a reduction in required traffic movements which in turn may contribute to
minimising air pollution.
The policy commits to supporting the provision of a decentralised energy network
within major new development. With this there is the potential for noise, light and air
pollution to be generated during the construction and operational phases.

The policy seeks to protect, enhance, and create a network of multi-functional green
and water spaces connected by street greening which will help to mitigate against air
and noise pollution.
There is no direct link between the alternative policy option and the SA Objective.

The policy seeks to ensure that any applications for the exploration, appraisal and
operation of unconventional oil and gas protects nearby residents and businesses from
the effects of the operations including effects from dust. This would therefore benefit
the SA Objective.
The policy states that that OPDC will seek to improve air quality and minimise air
pollution impacts on health the natural and built environment and on amenity. It also
outlines that they require new major development to be accompanied by an air quality
assessment. This would ensure that new major development provides adequate
mitigation measures to reduce any predicted adverse effects. This may over the long
213

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

12

Page 718

To conserve
and enhance
the historic
environment,
heritage
assets and
their settings

EU10
Option
1
EU11

L-T, D, R,
M

OPDC area

S, M and LT, D, R, M

OPDC area

EU12

EU1

S, M and LT, D, R, M

OPDC area

EU2

M and L-T,
D, R, L

OPDC area

EU2
Option
1
EU3

M and L-T,
I, R, M

OPDC area

EU4

EU4
Option
1
EU5

term contribute to the removal of the designated AQMA within the area. For the
reasons outline above effects are recorded as positive.
The alternative policy option would perform better against the SA Objective than the
preferred option as it would require all developments to require assessment for their
impacts on air quality rather than just major development.
The principle focus of the policy is to ensure that new development does not lead to
unacceptable increases in noise. The policy aims to achieve this through requiring new
development applications to be accompanied by a noise assessment. Therefore effects
have been recoded as positive.
There is no clear link between the policy and the SA Objective.
The policy seeks to work with developers to promote sustainable development that
utilises high standards of design, innovation, planning etc., this would therefore
optimise opportunities to ensure the setting of heritage assets are protected at the start
of the planning process. Utilising high standards of design may also contribute to
enhancing local views and landscapes.
Although not explicitly mentioned in the policy the implementation of smart city
technology may benefit this SA Objective as it could encourage innovative
mechanisms to conserve and enhance the historic environment.
A neutral score has been recorded against the SA Objective as not specifically
supporting inter-operable and open data would not detract nor benefit the SA
Objective.
The policy would ensure surface water runoff is managed and flood risk management
solutions are implemented as part of new development. This would protect heritage
assets over the medium to long term from flood damage.
The relocation of waste and recycling sites (depending upon the final design) may lead
to a detrimental effect on the setting of heritage assets and potential unknown
archaeological remains.
There is no clear link between the alternative policy and the SA Objective i.e.
safeguarding all sites in Old Oak would not affect the SA Objective.
There is no direct link between the policy and the SA Objective.

214

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
EU6

EU6
Option
1
EU7

There is no clear link between the policy and the SA Objective.

EU7
Option
1
EU8

There is no clear link between the alternative policy option and the SA Objective.

Seeking to support and facilitate the provision of infrastructure to deliver a

decentralised energy network within major new development may affect the setting of
historic assets within the OPDC area depending on its visual appearance.
As above. Although the alternative policy option would bring about more uncertainty as
it would apply to all new development rather than just major development.

S, M and LT, D, R, M

OPDC area

EU8
Option
1
EU9

S, M and LT, D, R, M

OPDC area

S, M and LT, D, R, M

OPDC area

EU10

Ensuring all new development seeks to protect, enhance, and helps create a network
of multi-functional green and water spaces connected by street greening would lead to
a positive effect on the SA Objective as it would contribute to promoting the historical
interpretation of heritage assets, including the canal through the use of multifunctional
green infrastructure. In addition, green infrastructure would also contribute to
enhancing local views and landscapes. For this reason a major positive score has
been recorded.
The alternative policy option would lead to a minor positive effect as deleting the policy
reference to all development, so that the policy requirements apply to major
development only would not be as positive.
The policys commitment to ensuring the design of oil / gas development is sensitive to
the character of the urban landscape and to features of national, London, and local
importance would only benefit this SA Objective. However, this could be strengthened
to state urban landscapes, heritage assets and features of .
There is no direct link between the policy and the SA Objective.

EU10
Option
1
EU11

There is no direct link between the alternative policy and the SA Objective.

There is no direct link between the policy and the SA Objective.

EU12

There is no direct link between the policy and the SA Objective.

Page 719

++

215

IIA Objective

13

Increase
community
cohesion and
reduce social
exclusion to
encourage a
sense of
community
and welfare

Performance
of Policy

Temporal
Scale
Nature of
Impact
S, M and LT, D, R, M

Geographical
Extent

Commentary and Recommendations

OPDC area

The policy seeks to work with developers to promote sustainable development that
utilises high standards of design, innovation, planning etc., this would therefore
optimise opportunities to incorporate green infrastructure and the provision of open
space / play spaces at the start of the planning process.

Page 720

EU1

EU2

There is no direct link between the policy and the SA Objective.

EU2
Option
1
EU3

There is no direct link between the policy and the SA Objective.

EU4

The policy would maintain accessibility within the OPDC area in the medium to long
term through managing surface water runoff and implementing flood risk management
solutions.
There is no clear link between the policy and the SA Objective.

EU4
Option
1
EU5

There is no clear link between the policy and the SA Objective.

There is no direct link between the policy and the SA Objective.

EU6

There is no direct link between the policy and the SA Objective.

EU6
Option
1
EU7

There is no direct link between the alternative policy option and the SA Objective.

EU7
Option
1

EU8

M and L-T,
D, R, L

OPDC area

L-T, D, R, L

OPDC area

S, M and LT, D, R, M

OPDC area

Seeking to integrate technology and seeking to accommodate future technologies

would benefit this SA Objective as may help to reduce social exclusion over the long
term.
A neutral score has been recorded against the SA Objective as not specifically seeking
to integrate contemporary technology and accommodate future technologies to
address challenges and create opportunities would significantly affect the SA
Objective.
Ensuring all new development seeks to protect, enhance, and helps create a network
of multi-functional green and water spaces connected by street greening would lead to
216

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

Page 721
14

Improve safety
and reduce
crime and the
fear of crime

EU8
Option
1
EU9

S, M and LT, D, R, M

OPDC area

S, M and LT, D, R, M

OPDC area

EU10

a positive effect on the SA Objective as it would directly increase connectivity and may
help to create social linkages wit surrounding communities. It also seeks to ensure that
development helps to balance the built and natural environment through a strategic
and co-ordinated approach. For these reasons effects have been recorded as
beneficial.
The alternative policy option would lead to a lesser positive effect as deleting the
reference to all development, so that the policy requirements apply to major
development only would not be as positive.
The policy seeks to ensure that any applications for the exploration, appraisal and
operation of unconventional oil and gas protects nearby residents from the effects of
the operations. It also goes further to say that applications will be assessed against the
effects on public rights of way, open spaces and outdoor recreation. As this would help
to maintain access to walking routes and recreation effects have been assessed as
positive against the SA Objective.
There is no direct link between the policy and the SA Objective.

EU10
Option
1
EU11

There is no direct link between the alternative policy and the SA Objective.

EU12

Guarding against inappropriate increases in noise levels from major development

would indirectly contribute to maintaining / or potentially improving the quality of the
public realm, recreation and play spaces which would benefit the SA Objective.
There is no direct link between the policy and the SA Objective.

EU1

There is no direct link between the policy and the SA Objective.

EU2

EU2
Option
1
EU3

There is no direct link between the alternative policy and the SA Objective.

There is no direct link between the policy and the SA Objective.

S, M and LT, I, R, L

M and L-T,
D, R, L

OPDC area

OPDC area

Although not explicitly mentioned in the policy the implementation of smart city
technology may benefit this SA Objective as it could encourage innovative
mechanisms to help improve safety.

217

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

Page 722

EU4

There is no direct link between the policy and the SA Objective.

EU4
Option
1
EU5

There is no direct link between the alternative policy and the SA Objective.

There is no direct link between the policy and the SA Objective.

EU6

There is no direct link between the policy and the SA Objective.

EU6
Option
1
EU7

There is no direct link between the alternative policy and the SA Objective.

There is no direct link between the policy and the SA Objective.

EU7
Option
1
EU8

There is no direct link between the alternative policy and the SA Objective.

There is no direct link between the policy and the SA Objective.

EU8
Option
1
EU9

Deleting the reference to all development, so that the policy requirements apply to
major development only would result in similar uncertainties.

There is no clear link between the policy and the SA Objective.

EU10

There is no clear link between the policy and the SA Objective.

EU10
Option
1
EU11

There is no clear link between the alternative policy and the SA Objective.

There is no clear link between the policy and the SA Objective.

EU12

There is no clear link between the policy and the SA Objective.

218

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

The policy seeks to promote healthy communities through a set of draft sustainability
targets set by OPDC for new development to meet. Targets include; reducing carbon
emissions; achieving the best air quality of any major world city by 2020; meeting noise
guidelines produced under the auspices of the World Health Organisation; and
providing urban greening.
Although not explicitly mentioned in the policy the implementation of smart city
technology may benefit this SA Objective as it could encourage innovative
mechanisms to support health and wellbeing.

Nature of
Impact
15

Maximise the
health and
wellbeing of
the population,
reduce
inequalities in
health and
promote
healthy living

Page 723

EU1

++

S, M and LT, D, R, M

OPDC area

EU2

M and L-T,
D, R, L

OPDC area

EU2
Option
1
EU3

There is no clear link between the alternative policy option and the SA Objective.

There is no clear link between the policy and the SA Objective.

EU4

There is no clear link between the policy and the SA Objective.

EU4
Option
1
EU5

There is no clear link between the alternative policy option and the SA Objective.

There is no clear link between the policy and the SA Objective.

EU6

There is no clear link between the policy and the SA Objective.

EU6
Option
1
EU7

There is no clear link between the alternative policy option and the SA Objective.

There is no clear link between the policy and the SA Objective.

EU7
Option
1
EU8

There is no clear link between the alternative policy option and the SA Objective.

S, M and LT, D, R, L

OPDC area

Ensuring all new development seeks to protect, enhance, and helps create a network
of multi-functional green and water spaces connected by street greening may lead to a
positive effect on the SA Objective as may increase accessibility to social infrastructure
and encourage more active lifestyles. For these reasons effects have been recorded as
219

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

Page 724
16

To improve
the education
and skills
levels of all
members of
the population,
particularly
vulnerable
groups

EU8
Option
1
EU9

EU10

positive.
The alternative policy option would lead to a lesser positive effect as deleting the
reference to all development, so that the policy applies to major development only
would not be as positive.
There is no clear link between the policy and the SA Objective.

S, M and LT, D, R, M

OPDC area

M and L-T,
D, R, M

OPDC area

EU10
Option
1
EU11

M and L-T,
D, R, M

OPDC area

S, M and LT, D, R, M

OPDC area

EU12

M and L-T,
D, R, H

OPDC area

EU1

EU2

M and L-T,
D, R, L

OPDC area

EU2
Option
1
EU3

There is no clear link between the alternative policy and the SA Objective.

There is no clear link between the policy and the SA Objective.

EU4

There is no clear link between the policy and the SA Objective.

EU4
Option

There is no clear link between the alternative policy and the SA Objective.

The policy states that OPDC will seek to improve air quality and minimise air pollution
impacts on health through requiring new major development proposals to meet a set
criteria. For this reason effects have been recorded as positive.
The alternative policy option would perform better against the SA Objective than the
preferred option as it would require all developments to require assessment for their
impacts on air quality rather than just major development.
The principle focus of the policy is to ensure that new development does not lead to
unacceptable increases in noise. The policy aims to achieve this through requiring new
development applications to be accompanied by a noise assessment, which would
include mitigation measures that would guard against any effects on health and quality
of life. Therefore effects have been recoded as positive.
The policy requires developers to complete the implementation of agreed measures to
assess and abate any risks to human health for this reason effects have been
assessed as positive
There is no clear link between the policy and the SA Objective.
Although not explicitly mentioned in the policy the implementation of smart city
technology may benefit this SA Objective as it could encourage innovative
mechanisms to help provide access to education and skills training.

220

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact

Page 725
17

Maximise the
social and
economic

1
EU5

There is no clear link between the policy and the SA Objective.

EU6

There is no clear link between the policy and the SA Objective.

EU6
Option
1
EU7

There is no clear link between the alternative policy and the SA Objective.

There is no clear link between the policy and the SA Objective.

EU7
Option
1
EU8

There is no clear link between the alternative policy and the SA Objective.

There is no clear link between the policy and the SA Objective.

EU8
Option
1
EU9

There is no clear link between the alternative policy and the SA Objective.

There is no clear link between the policy and the SA Objective.

EU10

There is no clear link between the policy and the SA Objective.

EU10
Option
1
EU11

There is no clear link between the alternative policy and the SA Objective.

There is no clear link between the policy and the SA Objective.

EU12

There is no clear link between the policy and the SA Objective.

EU1

++

S, M and LT, D, R, M

OPDC area

The policy seeks to promote healthy communities through a set of draft sustainability
targets set by OPDC for new development to meet. Targets include; meeting noise
guidelines produced under the auspices of the World Health Organisation; and
providing urban greening these would all contribute to improving wellbeing of the
221

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
wellbeing of
the local and
regional
population and
improve
access to
employment
and training

OPDC area

local population.
Although not explicitly mentioned in the policy the implementation of smart city
technology may benefit this SA Objective as it could encourage innovative
mechanisms to help support the social and economic wellbeing of local people.

Page 726

EU2

EU2
Option
1
EU3

There is no clear link between the alternative policy and the SA Objective.

There is no clear link between the policy and the SA Objective.

EU4

There is no clear link between the policy and the SA Objective.

EU4
Option
1
EU5

There is no clear link between the alternative policy and the SA Objective.

There is no clear link between the policy and the SA Objective.

EU6

There is no clear link between the policy and the SA Objective.

EU6
Option
1
EU7

There is no clear link between the alternative policy and the SA Objective.

There is no clear link between the policy and the SA Objective.

EU7
Option
1
EU8

There is no clear link between the alternative policy and the SA Objective.

EU8
Option
1

M and L-T,
D, R, L

S, M and LT, D, R, L

OPDC area

S, M and L-

OPDC area

Ensuring all new development seeks to protect, enhance, and helps create a network
of multi-functional green and water spaces connected by street greening may lead to a
positive effect on the SA Objective as may increase accessibility to employment and
training and improve wellbeing. For these reasons effects have been recorded as
positive.
The alternative policy option would lead to a lesser positive effect as deleting the
reference to all development, so that the policy applies to major development only
would not be as positive.
222

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
T, D, R, M

Page 727

18

To encourage
inward
investment
alongside
investment
within existing
communities,
to create
sustainable
economic
growth

EU9

There is no clear link between the policy and the SA Objective.

EU10

There is no clear link between the policy and the SA Objective.

EU10
Option
1
EU11

There is no clear link between the alternative policy and the SA Objective.

EU12

The principle focus of the policy is to ensure that new development does not lead to
unacceptable increases in noise. The policy aims to achieve this through requiring new
development applications to be accompanied by a noise assessment, which would
include mitigation measures that would guard against any adverse on wellbeing.
Therefore effects have been recoded as positive.
There is no clear link between the policy and the SA Objective.

EU1

There is no clear link between the policy and the SA Objective.

EU2

EU2
Option
1
EU3

The policy may encourage inward investment through its aspiration to become a global
leading location for the exploration, exploitation and implementation of smart city
technology, approaches and systems. For this reason effects have been recorded as
positive.
There is no clear link between the alternative policy and the SA Objective.

There is no clear link between the policy and the SA Objective.

EU4

There is no clear link between the policy and the SA Objective.

EU4
Option
1

There is no clear link between the alternative policy and the SA Objective.

S, M and LT, D, R, M

M and L-T,
D, R, M

OPDC area

OPDC area

223

IIA Objective

Performance
of Policy

Temporal
Scale

Geographical
Extent

Commentary and Recommendations

Nature of
Impact
EU5

There is no clear link between the policy and the SA Objective.

EU6

There is no clear link between the policy and the SA Objective.

EU6
Option
1
EU7

There is no clear link between the alternative policy and the SA Objective.

Page 728

EU7
Option
1
EU8

The policy seeks to deliver exemplar digital communication infrastructure. This may
encourage inward investment through ensuring workspaces meet the needs of new
and emerging businesses and increasing infrastructure capacity including broadband
connections.
A neutral score has been recorded against the SA Objective as not specifically seeking
to integrate contemporary technology and accommodate future technologies to
address challenges and create opportunities.
There is no clear link between the policy and the SA Objective.

EU8
Option
1
EU9

There is no clear link between the alternative policy and the SA Objective.

There is no clear link between the policy and the SA Objective.

EU10

There is no clear link between the policy and the SA Objective.

EU10
Option
1
EU11

There is no clear link between the alternative policy and the SA Objective.

There is no clear link between the policy and the SA Objective.

EU12

There is no clear link between the policy and the SA Objective.

M and L-T,
D, R, M

OPDC area

224

Arcadis Consulting (UK) Limited

Arcadis Cymru House
St Mellons Business Park Fortran Road
Cardiff
CF3 0EY
United Kingdom
T: +44 (0)29 2079 9275

arcadis.com

Page 729

This page is intentionally left blank

Page 730

$SSHQGL[&

OPDC LOCAL PLAN

SUPPORTING
STUDIES
SUMMARY

DECEMBER 2015

Page 731

CONTENTS
Role of this document
1. Air Quality Study
2. Character Areas Study
3. Construction and Logistics Strategy
4. Cultural Principles
5. Decentralised Energy Strategy
6. Decontamination Strategy
7. Development Capacity Study
8. Development Infrastructure Funding Study (DIFS)
9. Green Infrastructure and Open Space Strategy
10. Gypsy and Traveller Accommodation Needs Assessment
11. Industrial Land Review
12. Integrated Impact Assessment (including Habitats Regulations Screening
Assessment)
13. Integrated Water Management Strategy
14. North Acton Station Feasibility Study
15. Old Oak Outline Historic Area Assessment
16. Old Oak Strategic Transport Study
17. Park Royal Transport Strategy
18. Public Realm and Walking/Cycling Strategy
19. Retail and Leisure Needs Study
20. Smart Strategy Interim Report
21. Strategic Housing Market Assessment (SHMA)
22. Waste Strategy

Page 732

ROLE OF THIS DOCUMENT

This document sets out a summary of each of the supporting studies that have been
developed or are currently in development to inform the OPDC Local Plan. These
studies are being developed by the OPDC and by appointed consultants.
It has been developed to help assist in understanding the roles and key
recommendations for each of the studies, the following information is provided:

Document Title
Lead Author
Purpose of the Study
Stage of production
Key outputs
Key recommendations
Links to other studies
Next steps

It is important that this document is read as a high level summary. For detailed
information on each supported study please refer directly to the relevant document.
As part of this public consultation, comments are welcomed on all these draft
supporting studies. Following consultation, these studies will be finalised and will be
used to inform the second stage of consultation on the Local Plan.
It is worth noting that after the first stage of consultation, additional pieces of work
may be identified and these new studies will be prepared as part of finalising the
Local Plan.

Page 733

Document Title
Lead Author
Purpose of the Study

Stage of production
Key outputs

Key
recommendations

Relations to other
studies

Next steps

Document Title
Lead Author

Air Quality Study

AMEC Foster Wheeler
Review of the existing and anticipated air quality issues
across the construction and build-out phases of
development. This will set out recommendations for
mitigation and measures to ensure the highest possible air
quality for future residents and workers.
Draft completed to inform Regulation 18 version of the
Local Plan
Review of relevant international, national, regional and
local policy context and legislation.
Air quality mapping and identification any air quality
hotspots within the OPDC area and its surrounds
Identification of policy implications from inside or outside
the opportunity areas
Advice on measures and policies to be included within
OPDCs Local Plan and Construction and Logistics
Strategy to mitigate threats to air quality and to improve
upon baseline figures.
Advice on the need for OPDC to declare a separate
management area for air quality given the existing
boroughs AQMA designations, and provide advice on
the appropriate process for designation.
Facilitate a network of new roads and streets with
priority given to pedestrians, cyclists and buses;
Work with Bluepoint London (BPL) on the local
component of the Source London network of electric
vehicle charging points, particularly around transport
interchanges;
Applying a speed limit of 20mph in residential roads and
high streets;
Encouraging green space and infrastructure to help
reduce pollutant concentrations and deliver public
spaces that encourage walking and cycling;
Where possible, not locating residential units on the
ground floor near to the A4000; and
Consider a location for a Freight Consolidation centre.
Interfaces with the Park Royal Transport Strategy, the Old
Oak Transport Study, Public Realm, Walking and Cycling
Strategy, Green Infrastructure Strategy, Smart Strategy
Interim Report, the Decentralised Energy Strategy and
forthcoming utilities work.
The Strategy is in draft and is available for comment.
Necessary revisions will be made following public
consultation before the document is finalised to sit
alongside the Regulation 19 consultation on the Local Plan.
Character Areas Note
OPDC

Page 734

Purpose of the Study

Stage of production
Key outputs

Key
recommendations
Relations to other
studies
Next steps

Document Title
Lead Author
Purpose of the Study

Stage of production
Key outputs

Key
recommendations
Relations to other
studies
Next steps

Document Title
Lead Author
Purpose of the Study

Stage of production
Key outputs

Will set out suggested character areas and descriptions of

the existing character areas within and around Old Oak and
Park Royal.
Draft to be completed to inform Regulation 19 version of the
Local Plan
Suggested boundaries of places and character areas
within and around Old Oak and Park Royal to inform
place-based guidance
Identification of positive elements of character
Identify and provide guidance for places within the Local
Plan.
Interfaces with Park Royal Transport Strategy, the Old Oak
Transport Study, Public Realm, Walking and Cycling
Strategy, Green Infrastructure Strategy
The document will be used to inform the Regulation 19
consultation on the Local Plan.
Construction and Logistics Strategy
Transport for London
Provides the overarching construction transport
requirements for Old Oak and Park Royal with specific
suggestions to improve efficiencies.
Draft to be completed to inform Regulation 19 version of the
Local Plan
Identification of interventions required to mitigate the
construction impact indicated by the model; including
Consolidation Centres, Lorry Holding Areas, Routing and
scheduling changes.
Recommendations are currently in development and will
inform the next version of the Local Plan.
Interfaces with the Old Oak Strategic Transport Study, the
Park Royal Transport Strategy and the A40 Study
The document will be used to inform the Regulation 19
consultation on the Local Plan. OPDC will consider the
recommendations and will work with TfL, developers, HS2
and Crossrail to implement the interventions identified.
Cultural Principles
Greater London Authority
To identify how the OPDC area can contribute to Londons
cultural offer and position as the worlds biggest tourist
destination and to become a pro-cultural local planning
authority.
Draft completed to inform Regulation 18 version of the
Local Plan
Suggested policies for inclusion in OPDCs Local Plan
that will support culture.
Recommendations for how OPDC should intertwine
culture into its strategies for Old Oak.

Page 735

Key
recommendations

Relations to other
studies

Next steps

Document Title
Lead Author
Purpose of the Study

Stage of production
Key outputs

Ensure the Local Plan highlights the importance of

culture to the area.
Ensure that character, heritage and culture sit at the
heart of placemaking
Develop a Cultural Strategy to further consider
opportunities for culture in the OPDC area
Ensure that consultation is meaningful, that it reaches
as many people and communities as possible, and that
it includes young people and families.
Encourage anchor tenants and cultural institutions to
locate in the area, and explore options for attracting and
retaining creative businesses and affordable workspace
Outputs cross-relate to the Retail and Leisure Needs Study,
Character Areas note, Old Oak Outline Historic Area
Assessment and OPDCs future Sports and Leisure Study,
being produced by OPDCs Strategy and Programmes
directorate.
The Strategy is in draft and is available for comment and
will be used to inform OPDCs future Cultural strategy and
Sports and Leisure Study. Necessary revisions will be
made following public consultation before the document is
finalised to sit alongside the Regulation 19 consultation on
the Local Plan.

Old Oak Decentralised Energy Strategy

Greater London Authority
Review of the potential for a decentralised energy network
to supply the Old Oak with competitive low to zero carbon
heat.
Draft completed to inform Regulation 18 version of the
Local Plan
A review to determine the potential for a heat network to
supply the Old Oak Common Opportunity Area with
competitive low to zero carbon heat. Draft
recommendations include:
There is potential for a Decentralised Energy (DE) heat
network to supply low or zero carbon.
The DE system could be delivered in phases which
early indicators show could be based on: Phases 1 and
2 between 2016 2025, and Phases 3 and 4 combined
from 2025 2050. However, more work is needed to
develop a comprehensive Utilities and Energy Strategy.
The proposed initial energy production plant would
comprise of three energy centre buildings. The energy
centres could be consolidated into a single energy
centre by 2031 provided the heat network is
dimensioned for this duty.
The overall network length would be approximately
8.2km.

Page 736

High-level CAPEX for plant and distribution pipework to

serve the phases has been estimated at 32.5m.
Produce an Energy Masterplan once the development
quantum is better defined. The EMP should consider
energy centre locations and options in more detail which
may lead to changes in the proposed energy
requirements and network.
Co-ordinate infrastructure operators
Co-ordinate the production of the energy masterplan
with other utility planners and interested parties
including transport, water, gas, electricity and land
developers.
Consider alternative energy sources / technologies
Assess opportunities for the use of other energy sources
including energy from waste, heat pumps, and
secondary heat sources etc.
Consider connecting to nearby DH networks
Opportunities to connect to the nearby decentralised
energy developments proposed at White City and
Wembley to be considered.
Outputs to inform forthcoming Utilities and Infrastructure
Strategy.
Outputs to inform and be informed by Green Infrastructure
and Open Space Strategy, Public Realm Strategy,
Integrated water Management Strategy, and Smart
Strategy.
The Strategy is in draft and is available for comment.
Necessary revisions will be made following public
consultation before the document is finalised to sit
alongside the Regulation 19 consultation on the Local Plan.

Key
recommendations

Relations to other
studies

Next steps

Document Title
Lead Author
Purpose of the Study
Stage of production
Key outputs
Key
recommendations

Decontamination Strategy
OPDC & Environment Agency
Defines the approach to, and guidance for developers on,
dealing with land contamination and remediation.
Draft completed to inform Regulation 18 version of the
Local Plan
The document guides the approach OPDC has taken for
the Local Plan decontamination policy.
Ensure remediation strategies are established for all
contaminated brownfield sites that come forward for
redevelopment within OPDC
Ensure the risk based approaches to contaminated land
management are followed for redevelopment of
potentially contaminated land in Old Oak and Park
Royal.
Support for sustainable remediation options and
promote the use of the CL:AIRE Definition of Waste:
Development Industry Code of Practice (DoWCoP).

Page 737

Relations to other
studies
Next steps

Document Title
Lead Author
Purpose of the Study

Stage of production
Key outputs

Key
recommendations

Relations to other
studies

Next steps

Document Title
Lead Author

OPDC will also explore with waste planners and industry

how DoWCoP could be used to establish soil treatment
centres to serve brownfield sites within Old Oak , Park
Royal and neighbouring development and Opportunity
Areas.
OPDC will review the opportunities for establishing an
overarching strategic Global Remediation Strategy,
depending upon the outcome of discussions with
government on land ownership.
There is an interface with OPDCs Waste Strategy.
The Strategy is in draft and is available for comment.
Necessary revisions will be made following public
consultation before the document is finalised to sit
alongside the Regulation 19 consultation on the Local Plan.
Development Capacity Study
OPDC
Sets out envisaged development capacity and indicative
phasing for housing and commercial uses. Provides
information to inform responses to the Call for Sites
Consultation running alongside the Local Plan Regulation
18 Consultation.
Draft completed to inform Regulation 18 version of the
Local Plan
Inform the locations for housing and commercial uses.
Identification of residential density ranges.
Identification of constraints and solutions for each
development parcel.
Provision of indicative development phasing.
Development densities should be optimised at and
around stations.
Highest densities should be provided at and around Old
Oak Common Station.
Development densities should respond to sensitive
locations within and around the OPDC area.
Interfaces with Park Royal Transport Strategy, the Old Oak
Transport Study, Public Realm, Walking and Cycling
Strategy, Green Infrastructure Strategy, Retail & Leisure
Needs Study, Industrial Land Review, Integrated Water
Management Strategy and Old Oak Outline Historic Area
Assessment.
The Strategy is in draft and is available for comment.
Necessary revisions will be made following public
consultation before the document is finalised to sit
alongside the Regulation 19 consultation on the Local Plan.
Development Infrastructure Funding Study (DIFS)
Peter Brett Associates and Jones Lang LaSalle

Page 738

Purpose of the Study

Stage of production
Key outputs

Key
recommendations

Relations to other
studies

Next steps

Document Title
Lead Author
Purpose of the Study

Stage of production
Key outputs

To identify:
- the infrastructure requirements of growth at Old Oak;
- when the demands for infrastructure arise;
- how much those infrastructure requirements cost;
and
- how those infrastructure requirements might be paid
for.
Completed to inform Regulation 18 version of the Local
Plan
Current indicative assumptions above land values,
abnormal costs including decontamination and sales
values;
Assumptions around potential phasing and release of
development sites
Necessary transport, social, economic, environmental,
utility and physical infrastructure to support the needs of
development
Indications of the current day costs of this infrastructure
Potential mechanisms for the funding of the
infrastructure
An indicative cashflow diagram showing potential
funding gaps and opportunities to finance this.
There is a need for over 1.5billion infrastructure to
support development in Old Oak
CIL and S106 can go some way towards funding this,
but other means of funding this infrastructure will need
to be investigated
There are significant cashflow issues and the phasing of
the infrastructure may need to be reconsidered.
The DIFS work has been used as the basis for phasing
assumptions in OPDCs Development Capacity Study
(DCS). The DIFS work is Old Oak focussed and should be
read alongside new studies with a greater focus on Park
Royal such as the Park Royal Transport Study and the
Public Realm, Walking and Cycling Strategy.
The DIFS has now been finalised and its outputs are being
used to inform OPDCs work on its Community
Infrastructure Levy (CIL) and Section 106 SPD.
Green Infrastructure and Open Space Strategy
OPDC
Reviews existing Green Infrastructure (GI) assets, future GI
requirements, and identifies opportunities for improving
function, connectivity and integration with other
infrastructure.
To be developed to inform the Regulation 19 version of the
Local Plan.
Review of existing GI/open space assets

Page 739

Identification of need arising from development

Identification of potential enhancements to existing
assets
Identification of new open spaces and public realm to
contribute to the GI network
Identification of how buildings can contribute to the GI
network
No recommendations have been provided to date.

Key
recommendations
Relations to other
studies

Next steps

Document Title
Lead Author
Purpose of the Study
Stage of production
Key outputs

Interfaces with Park Royal Transport Strategy, the Old Oak

Transport Study, Public Realm, Walking and Cycling
Strategy, Integrated Water Management Strategy,
Decentralised Energy Strategy, Air Quality Strategy and
Smart Strategy interim report.
The document will be used to inform the Regulation 19
consultation on the Local Plan.
Gypsy and Travellers Accommodation Needs
Assessment (GTANA)
Opinion Research Services
Identifies the specific housing needs of the Gypsy and
Travellers community.
To be developed to inform the Regulation 19 version of the
Local Plan.
Gypsy and Travellers Accommodation Needs Assessment
Report setting out:
fair and effective strategies to meet the need through
identified land for sites.
existing sites capacity and if necessary to provide
evidence of the need to increase the number of traveller
sites.
approach to working with neighbouring authorities in the
housing market area.
No recommendations have been provided to date.

Key
recommendations
Relations to other
studies
Next steps

Document Title
Lead Author
Purpose of the Study
Stage of production
Key outputs

There is an interface with the Strategic Housing Market

Assessment.
The document will be used to inform the Regulation 19
consultation on the Local Plan.
Industrial Land Review
OPDC, Peter Brett Associates, Jones Lang LaSalle
Assesses the current and future supply and demand for
industrial land within Old Oak and Park Royal.
Draft completed to inform Regulation 18 version of the
Local Plan
Site analysis of over 300 employment sites
Quantitative supply and demand of industrial land

Page 740

Key
recommendations

Relations to other
studies

Next steps

Document Title
Lead Author
Purpose of the Study

Market profile and demand for industrial growth sectors

Options for intensifying use of industrial land
Policy recommendations
Protect
Protect industrial uses in Park Royal SIL
Reduce non-conforming uses in Park Royal SIL
Return Park Royal HS2 construction sites to SIL
Development adjacent to Park Royal SIL
Intensify
Efficient use of industrial land
Reduce road congestion
Intensification pilot projects
Expand
Adjust Park Royal SIL boundary
Light industrial floor space in Old Oak
Manage industrial floorspace within the region
Industrial space design and planning guidance
Support
Business relocation
Low carbon transition
Local procurement
Business listing and online forum
Interfaces with Park Royal Transport Strategy, Public
Realm, Walking and Cycling Strategy, Retail & Leisure
Needs Study and other OPDC strategies in development
including the Socio-Economic Regeneration Strategy.
The Review is in draft and is available for comment.
Necessary revisions will be made following public
consultation before the document is finalised to sit
alongside the Regulation 19 consultation on the Local Plan.
Integrated Impact Assessment (including Habitats
Regulation Assessment Screening)
Arcadis (incorporating Hyder Consulting)
Integrates the following impact assessments of the Local
Plan to meet European and national requirements and best
practise approaches :
Sustainability Appraisal and Strategic Environmental
Assessment;
Health Impact Assessment;
Equalities Impact Assessment; and
Habitats Regulations Assessment
Draft completed to assess Regulation 18 version of the
Local Plan following Scoping Report Consultation.
Sustainability Appraisal and Strategic Environmental
Assessment: Process for assessing the social,
economic, and environmental impacts of the Local Plan

Stage of production
Key outputs

Page 741

Key
recommendations

Relations to other
studies
Next steps

Document Title
Lead Author
Purpose of the Study

Stage of production
Key outputs

and aims to ensure that sustainable development is at

the heart of the plan-making process.
Health Impact Assessment: high-level assessment of
the possible health impacts of the Local Plan.
Equalities Impact Assessment: high-level assessment of
the possible equalities impacts of the Local Plan.
Habitats Regulations Assessment: A HRA screening
exercise will be undertaken to determine if the Local
Plan would generate an adverse impact upon the
integrity of a Natura 2000 site (for the OPDC area, these
are Richmond Park and Wimbledon Common).
Ensure the contents of the draft Local Plan consider,
support and enhance:
o the component environmental, social and
economic elements of sustainability
o equality for all
o physical, mental and emotional health and well
being
Ensure the contents of the draft Local Plan are screened
for any impact on Natura 2000 sites.
Interfaces with all other evidence base studies through their
input into the draft Local Plan.
The Assessment is in draft and is available for comment.
Necessary revisions will be made following public
consultation before the document is finalised to sit
alongside the Regulation 19 consultation on the Local Plan.
Integrated Water Management Strategy
AECOM Global
Review of water infrastructure requirements for water
demand, drainage, and flood risk (including OPDCs
Strategic Flood Risk Assessment). Provides options and
costs for integrated water management.
Draft completed to inform Regulation 18 version of the
Local Plan
A strategic assessment of current major redevelopment
proposals in the Counters Creek catchment highlighting
key opportunities and constraints.
A strategic level flood risk assessment of the OPDC
area.
Assessment of baseline water demands, sewage
production and rainfall runoff for the development using
the OAPF information. Estimates for water demand and
sewage and rainfall runoff production for a range of
scenarios.
Review of the capacity and performance of the existing
infrastructure. Information on infrastructure capacity and
performance highlighting when and where incapacity will
lead to failures in levels of service.

Page 742

Assessment of individual building and communal scale

opportunities to sustainably manage potable water,
sewage, drainage and flood risk needs of the OPDC
area using an integrated approach. Assessment
includes the options and options appraisal process; and
the preferred strategy.
An assessment of the smart technology opportunities
to enable scalable, robust and long-term sustainable
water management.
Report detailing costs, implementation mechanisms and
timings for the preferred strategy and how the costs
could be proportionally shared by the developers.
For water management, a range of options are identified
at both strategic and site level for managing surface and
storm water run-off, and for disposing of waste water.
These include the need for a centralised sustainable
drainage system, in addition to site specific measures.
For potable water, recommendations include the need
for rainwater harvesting and greywater re-use to achieve
as close as possible to neutrality in water use.
Outputs to inform Utilities and Infrastructure Strategy
Outputs to inform and be informed by Green Infrastructure
and Open Space Strategy, Public Realm Strategy, and Old
Oak Decentralised Energy Strategy.
The Strategy is in draft and is available for comment.
Necessary revisions will be made following public
consultation before the document is finalised to sit
alongside the Regulation 19 consultation on the Local Plan.
The document will inform the OPDC Infrastructure and
Utilities Strategy in 2016 in regard to options for delivering
water infrastructure sustainably, cost-effectively and in an
integrated way with other infrastructure across the area.

Key
recommendations

Relations to other
studies

Next steps

Document Title
Lead Author
Purpose of the Study

Stage of production
Key outputs

Key
recommendations

North Acton Station Feasibility Study

Transport for London
This study investigates the options for enhancing the
capacity and accessibility of North Acton station and the
options for improving the permeability of the site.
In draft
A phased delivery plan which includes making the
station DDA compliant, increasing the capacity of the
station and providing a connection to the station from
the north.
North Acton station is expected to be subject to
significant additional demand due to the large scale
development that will surround the station.
The existing station is already straining under current
demand. As such reconfiguration to provide both
additional capacity and step free access is key.

Page 743

Improving accessibility from the north is fundamental as

development comes forward.
Interfaces with the Old Oak Strategic Transport Study and
the Park Royal Transport Strategy
Further development of the proposal to feasibility design
stage which will include additional structural considerations
and refinement of the costs and phasing.

Relations to other
studies
Next steps

Document Title
Lead Author
Purpose of the Study
Stage of production
Key outputs

Key
recommendations
Relations to other
studies
Next steps

Document Title
Lead Author
Purpose of the Study

Stage of production
Key outputs

Key
recommendations

Old Oak Outline Historic Area Assessment &

addendum
Historic England
Inform the development of planning policy for Old Oak and
the designation of local heritage assets.
Completed
Summary of historical development
Identification of designated and undesignated potential
heritage assets
Identification of designated assets whose settings may
be affected by development within Old Oak.
Suggested heritage assets to be locally designated
including the Cumberland Park Factory conservation
area.
Interfaces with Green Infrastructure and Open Space
Strategy, Character Area Note, Development Capacity
Study.
The Assessment will inform the development of a Park
Royal focussed heritage assessment.
Old Oak Strategic Transport Study
Transport for London
Provides a strategic assessment of the existing transport
provision in Old Oak, the impact of the planned future
growth on the transport provision and identification of the
transport interventions required to mitigate those impacts.
Completed.
A review of the existing performance of transport modes
in Old Oak
Analysis of future demand and its impact on the
transport modes
Identification of interventions required to improve
existing performance and to mitigate the impact of future
demand on transport modes.
New London Overground Stations at Hythe Road and
Old Oak Common Lane
Willesden Junction station improvements and bridge
over WCML
Potential Crossrail 1 to WCML link
Improved frequencies on London Overground
Increased bus frequencies and new routes

Page 744

New highway connections

A package of highway quick wins
A package of measures to improve conditions for
walking and cycling
A package of demand management measures to ensure
a reduced car mode share
Interfaces with the Park Royal Transport Strategy, the
Public Realm, Walking and Cycling Strategy and the Smart
Strategy Interim Report.
Some of the interventions in the study are being developed
in more detail, including investigating funding mechanisms.

Relations to other
studies
Next steps

Document Title
Lead Author
Purpose of the Study

Stage of production
Key outputs

Key
recommendations

Relations to other
studies
Next steps

Document Title
Lead Author

Park Royal Transport Strategy

SDG
Strategic assessment of the existing transport provision in
Park Royal, the impact of the planned future growth on the
transport provision and identification of the transport
interventions required to mitigate those impacts.
Draft completed to inform Regulation 18 version of the
Local Plan
A review of the existing performance of transport modes
in Park Royal
Analysis of future demand in Park Royal and its impact
on the transport modes
Identification of six packages of interventions required to
improve existing performance and to mitigate the impact
of future demand on transport modes.
Emerging recommendations include:
providing transport networks that enhance the
communities they serve and help local business to
operate and grow, both now and in the future.
interventions for a variety of Planning, Demand
Management, Highway Interventions and Public
Transport Improvements.
Interfaces with the Old Oak Strategic Transport study,
Public Realm, Walking and Cycling Strategy, North Acton
study and the Smart Strategy Interim Report.
The Strategy is in draft and is available for comment.
Necessary revisions will be made following public
consultation before the document is finalised to sit
alongside the Regulation 19 consultation on the Local Plan.
A preferred package of interventions will be defined and
developed in more detail including work with stakeholders
develop and prioritise a shortlist of interventions. This will
include detailed costings of each intervention and how they
can be funded.
Public Realm, walking and cycling Strategy
Consultant to be appointed

Page 745

Purpose of the Study

Stage of production
Key outputs

Key
recommendations
Relations to other
studies

Next steps

Document Title
Lead Author
Purpose of the Study

Stage of production
Key outputs

Key
recommendations

Provides a framework for delivering an exemplar

sustainable, accessible urban environment for Old Oak and
Park Royal with high quality public realm and where walking
and cycling are comfortable, convenient, safe and efficient
choices for people to move around the local area.
To be developed to inform the Regulation 19 version of the
Local Plan.
Walking & Cycling Assessment
Public Amenity Space Assessment
Public Realm Assessment
Public Realm Strategy
Infrastructure Delivery Plan
No recommendations have been provided to date.
Interfaces with Park Royal Transport Strategy, the Old Oak
Transport Study, Integrated Water Management Strategy,
Decentralised Energy Strategy, Character Area Note,
Green Infrastructure and Open Space Strategy, Air Quality
Strategy and Smart Strategy interim report.
Development of Strategy to inform Regulation 19 version of
the Local Plan
Retail and Leisure Needs Study (RLNS)
Peter Brett Associates
To identify the quantitative need for retail and leisure uses
in the OPDC area and make recommendations for
qualitative measures
Draft completed to inform Regulation 18 version of the
Local Plan
Identifies quantitative retail and leisure need and its
likely impacts on the surrounding retail hierarchy
Identifies the required town centre hierarchy to deliver
this retail and leisure need
Identifies case studies showing best practice retail
developments and particularly affordable retail and
meanwhile retail
Identifies qualitative measures for inclusion in the Local
Plan
There is a quantitative need for approximately
65,000sqm of A-class uses in the OPDC area in the
Local Plan period (the next 20 years).
A new town centre hierarchy is established, with a
potential major town centre along and around Old Oak
High Street, a neighbourhood centre in North Acton and
a Neighbourhood Centre in Park Royal
Within the plan period, 52,500sqm of A-class uses
should be provided in the new Old Oak High Street
Major Centre, with 5,000 each in the North Acton and

Page 746

Relations to other
studies

Next steps

Document Title
Lead Author
Purpose of the Study

Stage of production

Key outputs

Outputs cross-relate to the Cultural Principles,

Development Capacity Study, Public Realm, Walking and
Cycling Strategy and OPDCs future Sports and Leisure
Study, being produced by OPDCs Strategy and
Programmes directorate.
The study is in draft and is available for comment.
Necessary revisions will be made following public
consultation before the document is finalised to sit
alongside the Regulation 19 consultation on the Local Plan.
Smart Strategy Interim Report
#HyperCatCity
Review of how contemporary and emerging technologies
can shape the Local Plan and the development of Old Oak
and Park Royal in relation to transport, public realm, utilities
and climate change mitigation/adaptation.
Draft completed to inform Regulation 18 version of the
Local Plan. Final Smart Strategy will be developed for the
Regulation 19 Version of the Local Plan.
Identification of:

Key
recommendations

Park Royal neighbourhood centres

A series of policies should be put in place to ensure a
high quality of retail that supports placemaking,
including the delivery of affordable retail space, support
for other town centres and flexibility in unit uses and
sizes.

Key opportunities
Key challenges
Use classes

Provision of initial recommendations to inform Local Plan

development
Deliver a secure and open, interoperable digital
environment.
Utilise technology and digital systems to:
o assist in the planning, delivery and management
of development
o create opportunities and address challenges
o enhance quality of life for residents, employees
and visitors
Incentivise the growth of emerging smart city economic
sectors.
Embed flexibility and agility in the built and natural
environment alongside infrastructure to accommodate

Page 747

Relations to other
studies

Next steps

Document Title
Lead Author
Purpose of the Study
Stage of production
Key outputs

change.
Explore and support the use of emerging transport
modes to enable understanding of the impacts on the
built environment and address challenges specific to:
o Addressing congestion
o Enabling mobility for all
o Supporting efficient freight movement
o Managing waste
Establish and manage an urban digital platform.
Require the use and delivery of the most recent Building
Information Modelling data for development and
infrastructure proposals.
Deliver integrated utilities infrastructure that is planned
and managed through sensors to increase efficiencies
and minimise disruptions to the public realm.
Consider using appropriate technology to improve and
support the safety of people and the wider built
environment.
Make use of emerging construction techniques to
support the delivery of resilient low-carbon and energy
efficient buildings and spaces that help to actively
address pollution.
Interfaces with Park Royal Transport Strategy, the Old Oak
Transport Study, Public Real, Walking and Cycling
Strategy, Green Infrastructure Strategy, Waste Strategy,
Integrated Water Management Strategy, Decentralised
Energy Strategy, Air Quality Strategy.
The Report is in draft and is available for comment.
Necessary revisions will be made following public
consultation before the document is finalised to sit
alongside the Regulation 19 consultation on the Local Plan.
Strategic Housing Market Assessment (SHMA)
Opinion Research Services
Identifies the objective housing need and the required
supply to meet this need.
Draft completed to inform Regulation 18 version of the
Local Plan
Estimates of:
Range of current dwellings
Analysis of housing market trends, including balance
between supply and demand
Total future number of households
Current number of households in housing needs
Future households requiring affordable housing or
market housing
Sizes of affordable housing required
Household groups who have particular housing
requirements

Page 748

Key
recommendations

Relations to other
studies
Next steps

Document Title
Lead Author
Purpose of the Study

Stage of production
Key outputs

Key
recommendations

Relations to other
studies
Next steps

The emerging SHMA has identified a substantial need

for affordable housing in the OPDC authorities (LB
Brent; LB Ealing; LB H&F)
The full objectively assessed need for affordable
housing is 45,500 housing in OPDC authorities.
It will be important to maximise the amount of affordable
housing that can be delivered through market housing
led development.
Economic viability will determine the amount of
affordable housing that individual schemes are able to
provide.
There is an interface with the GTANA and Development
Capacity Study.
The Strategy is in draft and is available for comment.
Necessary revisions will be made following public
consultation before the document is finalised to sit
alongside the Regulation 19 consultation on the Local Plan.

Waste Strategy
OPDC
To demonstrate how OPDC can help the three host local
authorities meet their waste apportionment targets, in
accordance with paragraph 5.80 of the Mayors London
Plan
Draft completed to inform Regulation 18 version of the
Local Plan
Identifies existing waste sites in the OPDC area.
Identifies OPDCs adoption of the West London Waste
Plan, which deals with apportionment targets for the
London Boroughs of Brent and Ealing.
Identifies ability of sites in the Old Oak to meet the
London Borough of Hammersmith and Fulhams
apportionment
The Powerday waste site should be safeguarded to
meet the London borough of Hammersmith and
Fulhams waste apportionment.
The Local Plan should promote energy from waste to
ensure that waste treated in the OPDC area is recycled
within the area
OPDC should support the relocation of waste operators
on sites not being safeguarded.
Outputs cross-relate to the Decentralised energy strategy
and will inform OPDCs Utilities and Infrastructure Strategy
The Strategy is in draft and is available for comment.
Necessary revisions will be made following public
consultation before the document is finalised to sit
alongside the Regulation 19 consultation on the Local Plan.

Page 749

This page is intentionally left blank

Page 750

Agenda Item 6

Subject:

Scheme
of
Planning
Delegations

Meeting
date:

6
January
2016

Report
to:

Planning
Committee

Report
of:

Director
of
Planning



For
note
and
recommendation

________________________________________________________________________



This
report
will
be
considered
in
public

________________________________________________________________________



1
1.1

Summary

This
report
outlines
the
rationale
for
amending
the
OPDCs
Scheme
of
Planning

Delegations;
seeks
changes
to
the
structure
of
the
Scheme
for
the
reasons
set
out
in

section
4;
and
seeks
two
minor
changes
to
the
existing
delegation
arrangements
for
the

reasons
set
out
in
section
5.


Recommendations

The
Planning
Committee
is
asked
to:

2.1

Note
the
amended
version
of
the
Scheme
of
Planning
Delegations;
and

2.2

Recommend
that
the
Board
approves
the
amended
Scheme
of
Planning

Delegations.

Background

3.1

On
1
April
2015
the
OPDC
came
into
existence
and
the
Board
approved
a
Scheme
of

Planning
Delegations.
The
document
set
out
the
scope
of
decision
taking
by
the
Board,

the
Planning
Committee
and
planning
officers.

3.2

Under
the
current
arrangements
the
Board
takes
all
decisions
relating
to
planning
policy

and
the
Community
Infrastructure
Levy.
The
Planning
Committee
and
planning
officers

both
have
delegated
authority
to
determine
planning
applications,
to
enable
decisions

to
be
taken
at
either
level
as
appropriate.
Agreeing
which
decisions
need
to
be
taken
by

the
Planning
Committee
requires
some
exercise
of
judgement
by
the
Chair
of
the

Committee
and
the
Director
of
Planning
within
the
framework
set
out
by
the
scheme,

though
the
Scheme
also
sets
out
those
cases
where
a
decision
must
be
referred
to
the

Committee.





Page 751

Proposed
changes
to
the
structure
of
the
current
Scheme

4.1

The
structure
of
the
current
Scheme
(attached
at
Appendix
A)
is
set
out
in
such
a
way

that
all
of
the
planning
functions
delegated
to
the
Planning
Committee
and
planning

officers
by
the
Board
are
specifically
listed
with
reference
to
the
legislation
to
which

they
relate.
Whilst
this
approach
provides
clarity
and
certainty,
an
unintended
effect
is

that
the
Planning
Committee
and
officers
would
not
have
delegated
authority
over
any

functions
created
or
amended
by
new
or
replacement
legislation.
The
Scheme
would

therefore
need
to
be
referred
back
to
the
Board
to
be
updated
every
time
such
a

change
occurred.
There
are
also
a
number
of
planning
functions,
such
as
conservation

area
management
plans,
which
are
not
specifically
identified
in
the
current
Scheme
of

Planning
Delegations
and
under
the
present
arrangements
need
to
be
reported
to
the

Board
by
default.

4.2

A
simpler
and
more
resilient
approach
would
be
to
specify
those
matters
to
be
reserved

to
the
Board
and
Planning
Committee
for
decision.
This
would
mean
that
all
of
the

other
functions
not
specified
would
automatically
be
delegated
to
planning
officers.

The
amended
Scheme
(attached
at
Appendix
B)
is
therefore
set
up
on
the
basis
of
this

structure,
with
the
specific
planning
powers
proposed
to
be
reserved
by
the
Board
set

out
in
column
1
of
Table
A
and
those
proposed
to
be
reserved
by
the
Planning

Committee
set
out
in
column
2.

Proposed
changes
to
existing
delegation
arrangements

5.1

In
addition
to
the
revised
approach
to
the
Scheme
of
Planning
Delegations,
there
are

also
two
specific
changes
proposed
to
the
delegation
of
decision
making
powers.

5.2

The
first
change
is
in
response
to
the
approved
structure
of
the
OPDC
planning
team.

The
existing
Scheme
refers
to
a
Head
of
Planning
role,
which
no
longer
exists.
The

revised
Scheme
will
allow
the
Director
of
Planning,
any
officer(s)
directly
reporting
to

that
post
or
any
other
officer
nominated
by
the
Director
of
Planning,
to
take
delegated

decisions
in
accordance
with
the
Scheme.

5.3

The
second
change
relates
to
consultations
on
supplementary
planning
documents

(SPDs).
Presently,
each
step
of
the
process
in
consulting
upon
and
adopting
an
SPD

must
be
approved
by
the
Board.
SPDs
do
not
form
part
of
the
development
plan
and

can
be
produced
more
quickly
than
the
Local
Plan.

It
is
proposed
that
decisions
to

consult
on
draft
SPDs
are
delegated
by
the
Board
to
Planning
Committee.
The
power
to

adopt
SPDs
would
be
reserved
by
the
Board.

5.4

There
are
no
changes
proposed
to
the
existing
arrangements
that
govern
whether

planning
decisions
are
made
by
planning
officers
under
delegated
authority
or
referred

to
Planning
Committee
for
decision.

6
6.1

Next
Steps


The
revised
Scheme
of
Planning
Delegations
to
be
adopted
by
the
Board.

Page 752

Financial
Implications

7.1

There
are
no
direct
financial
implications
for
the
OPDC
arising
from
this
report.

Legal
implications

8.1

No
legal
implications
arise
from
the
report
and
it
is
consistent
with
the
Corporations

legal
framework.

Appendices

Appendix
A

Existing
scheme
of
planning
delegations


Appendix
B

Proposed
scheme
of
planning
delegations



List
of
Background
Papers:

None



Report
originator:

Michael
Drake,
Senior
Planner,
OPDC


Telephone:


020
7983
5783


Email:



michael.drake@opdc.london.gov.uk

Page 753

This page is intentionally left blank

Page 754

Appendix A

SCHEMEOFPLANNINGDELEGATIONS


The
Board
of
the
Old
Oak
and
Park
Royal
Development
Corporation
(the
"Corporation")
will

discharge
some
of
its
town
and
country
planning
functions
and
responsibilities
through
delegation

to
the
Planning
Committee
and
Planning
Officers
as
follows:




A.
Delegations
to
the
Planning
Committee

relating
to
town
and
country
planning
development

management
as
set
out
under
heading
"A"
below;




B.
Delegations
to
Planning
Officers

relating
to
town
and
country
planning
development

management
as
set
out
under
heading
"B"
below;
and




C.
Delegations
to
Planning
Officers

relating
to
town
and
country
planning
policy
and
the

Community
Infrastructure
Levy
as
set
out
under
heading
"C"
below.




For
the
avoidance
of
doubt,
the
Board
has
not
delegated
its
functions
in
relation
to
agreeing
local

planning
policy,
including
community
infrastructure
levy
charging
schedules,
to
the
Planning

Committee,
though
the
Committee
will
advise
the
Board
on
these
matters.




A-DelegationstothePlanningCommittee-relatingtotownandcountryplanning
developmentmanagementdecisions


1.
The
Board
of
the
Old
Oak
and
Park
Royal
Development
Corporation
delegates
the
following
town

and
country
planning
development
management
functions
and
responsibilities
to
the
Planning

Committee
of
the
Corporation:




1.1
all
functions
and
responsibilities
of
the
Corporation
relating
to
town
and
country
planning

development
management
decisions
on
any
town
and
country
planning
matter
within
the
powers
of

the
Corporation
as
local
planning
authority
that
fall
within
the
Town
and
Country
Planning
Act
1990

(as
amended),
the
Planning
(Listed
Buildings
and
Conservation
Areas)
Act
1990
(as
amended)

(other
than
powers
relating
to
the
declaration
of
conservation
areas),
the
Electricity
Act
1989,
the

Planning
and
Compulsory
Purchase
Act
2004
and
all
secondary
legislation
pursuant
to
the
same

including,
in
relation
to
such
planning
applications,
the
power
on
behalf
of
the
Corporation
as
local

planning
authority
to
negotiate,
complete,
discharge
and
vary
any
agreement
under
sections
106

and
106A
of
the
Town
and
Country
Planning
Act
1990
and/or
other
appropriate
powers
(including

under
relevant
highways
legislation)
and
the
power
to
impose
conditions
to
any
planning
permission

granted
pursuant
to
such
planning
applications;




1.2
all
functions
and
responsibilities
of
the
Corporation
relating
to
town
and
country
planning

enforcement
action,
including
the
overseeing
and
monitoring
of
town
and
country
planning

enforcement
action
taken
by
the
Corporation
through
the
provision
of
regular
reports
by
planning

officers;
and




1.3
giving
responses
concerning
or
of
interest
to
the
Corporation
as
local
planning
authority
(as

statutory
or
other
consultee
or
otherwise)
to
any
other
authority
or
person
on
applications,

notifications
and
certificates
outside
of
the
development
area
as
defined
in
The
Old
Oak
and
Park

Royal
Development
Corporation
(Establishment)
Order
2015
(and
any
legislation
amending
or

replacing
the
same).








Page 755

B-DelegationstoPlanningOfficersrelatingtotownandcountryplanningdevelopment
managementdecisions

1.
Except
in
relation
to
the
functions
and
responsibilities
specified
in
paragraph
2
(Exceptions)
of

this
Section
B
below,
the
Board
of
the
Corporation
delegates
the
following
town
and
country

planning
development
management
functions
and
responsibilities
of
the
Corporation
to
the
Director

of
Planning
or
in
his/her
absence
the
Head
of
Planning.




1.1
town
and
country
planning
development
management
decisions
on
any
town
and
country

planning
matter
within
the
powers
of
the
Corporation
as
local
planning
authority
that
fall
within
the

Town
and
Country
Planning
Act
1990
(as
amended),
the
Planning
(Listed
Buildings
and

Conservation
Areas)
Act
1990
(as
amended)
(other
than
powers
relation
to
the
declaration
of

conservation
areas),
the
Electricity
Act
1989),
the
Planning
and
Compulsory
Purchase
Act
2004
and

all
secondary
legislation
pursuant
to
the
same,
including
the
power
on
behalf
of
the
Corporation
as

local
planning
authority
to
negotiate,
complete,
discharge
and
vary
any
agreement
under
sections

106
and
106A
of
the
Town
and
Country
Planning
Act
1990
and/or
other
appropriate
powers

(including
under
relevant
highways
legislation)
and
the
power
on
behalf
of
the
Corporation
as
local

planning
authority
to
impose
(as
far
as
lawfully
possible)
conditions
to
any
planning
permission

granted
pursuant
to
such
planning
applications;
and




1.2
town
and
country
planning
enforcement
action;
and




1.3
the
making
or
modifying
of
TPOs;
and




1.4
the
addition
or
removal
of
individual
buildings
or
structures
to/from
the
local
list
of
heritage

assets;
and




1.5
giving
responses
concerning
or
of
interest
to
the
Corporation
as
local
planning
authority
(as

statutory
or
other
consultee
or
otherwise)
to
any
other
authority
or
person
on
applications,

notifications
and
certificates
outside
of
the
development
area
as
defined
in
The
Old
Oak
and
Park

Royal
Development
Corporation
(Establishment)
Order
2015
(and
any
legislation
amending
or

replacing
the
same);
and




1.6
making
exceptions
to
the
agreed
Schemes
of
Delegation
of
Planning
Functions
with
the
London

Boroughs
of
Brent
and
Ealing.




2.
ExceptionstoPlanningOfficers'delegations



The
following
matters
shall
be
excepted
from
the
delegation
of
functions
and
responsibilities
to

Planning
Officers
set
out
in
paragraph
1
of
this
Section
B
above:




2.1
Planning
applications
made
by
Corporation
members
or
planning
officers
as
applicant
or
agent;




2.2
Planning
applications
which
a
Corporation
Planning
Committee
Member
or
a
Corporation
Board

Member
has
requested
in
writing
to
the
Director
of
Planning
within
21
days
of
the
registering
of

receipt
of
the
application
by
the
Corporation
as
local
planning
authority
should
be
determined
by

the
Corporation's
Planning
Committee;
and




2.3
Planning
applications
which
in
the
opinion
of
the
Director
of
Planning
or
in
his/her
absence
the

Head
of
Planning
which:




2.3.1
are
of
a
significant
or
potentially
contentious
nature;
or




2.3.2
have
received
significant
objections;
or

Page 756

2.3.3
may
prevent
the
Corporation
from
fulfilling
its
functions
or
responsibilities;
or




2.3.4
propose
development
which
involves
a
significant
departure
from
planning
policy
or

other
planning
guidelines
or
a
departure
from
Development
Plan
policy
(which
would
be

required
to
be
subject
to
notification
to
the
Secretary
of
State),
but
where
it
is
proposed
to

approve
the
application;
or




2.3.5
are
proposals
which
should
be
considered
by
the
Planning
Committee
or
the
Board;
or




2.3.6
any
matter,
which,
in
the
opinion
of
the
Director
of
Planning
or
in
his/her
absence
the

Head
of
Planning,
is
of
such
a
significant
nature
in
terms
of
its
impact
on
the
purposes,

functions
or
responsibilities
of
the
Corporation
that
the
matter
should
be
referred
to
the

Corporation's
Planning
Committee
or
the
Board
for
consideration;



C-DelegationstoPlanningOfficersrelatingtotownandcountryplanningpolicyand
CommunityInfrastructureLevychargingschedulepreparation



1.
Subject
to
the
financial
delegations,
the
Board
agrees
to
delegate
the
functions
specified
below

to
the
Director
of
Planning
or
in
his
/
her
absence
the
Head
of
Planning.




1.1
the
power
to
take
preparatory
steps
(but
not
decisions)
in
relation
to
the
town
and
country

planning
functions
of
the
Corporation
under
the
Planning
and
Compulsory
Purchase
Act
2004

which
relate
to
preparing
Local
Plan
documents,
related
guidance
(including
supplementary

planning
documents)
and
other
plan-making
functions,
or
functions
relating
to
the
community

infrastructure
levy,
including
preparatory
steps
in
relation
to
the
charging
schedule
preparation;
and




1.2
subject
to
the
exceptions
set
out
in
paragraph
2
below,
the
power
to
give
responses
concerning

or
of
interest
to
the
Corporation
as
local
planning
authority
(as
statutory
or
other
consultee
or

otherwise)
to
any
other
authority
or
person
on:




1.2.1
new
or
amended
town
and
country
planning
legislation,
policies,
guidance,
plans,

frameworks
or
strategies,
and
consultations
or
proposals
in
respect
of
the
same;




1.2.2
local
development
framework
and
supplementary
planning
document
consultations

for
each
of
the
London
Boroughs
of
Brent,
Ealing
and
Hammersmith
&
Fulham;
and




1.2.3
current
and
emerging
strategic
planning
guidance
for
London.




2.
The
delegation
in
paragraphs
1.1
and
1.2
above
of
this
Section
C
above
shall
not
apply
in
relation

to:




2.1
responses
to
consultations
which
a
Corporation
Board
Member
has
requested
in
writing
to
the

Director
of
Planning
within
21
days
of
the
commencement
of
consultation
should
be
agreed
by
the

Corporation's
Board;
and




2.2
consultations
on
matters
which
in
the
opinion
of
the
Director
of
or
in
his/her
absence
the
Head

of
Planning
which:




2.2.1
are
of
a
significant
or
potentially
contentious
nature;
or




2.2.2
have
received
significant
objection;
or




2.2.3
may
prevent
the
Corporation
from
fulfilling
its
functions
or
responsibilities;
or

Page 757

2.2.4
should
be
considered
by
the
Board;
or




2.2.5
are
of
such
a
significant
nature
in
terms
of
their
impact
on
the
purposes,
functions
or

responsibilities
of
the
Corporation
that
they
should
be
referred
to
the
Corporation's
Board

for
consideration.

Page 758

Appendix B

OLD OAK AND PARK ROYAL DEVELOPMENT CORPORATION

SCHEME OF PLANNING DELEGATIONS
The General Planning Delegation
1. The Board delegates the discharge and exercise of the Corporations Relevant Planning
Functions (called the the General Planning Delegation in this Scheme) concurrently to (1) the Planning Committee, except for the matters reserved to a decision of the Board that are
listed in Column 1 of Table A (which may only be exercised by the Board); and
(2) the Director of Planning, any officer(s) directly reporting to that post and any officer
of the Corporation appointed by the Director, except for the matters respectively
reserved to the Board or to the Planning Committee listed in Columns 1 and 2 of that Table
(which may only be exercised by them).
2. Nothing in this Scheme shall prevent the Board or (except in relation to matters listed in Column 1
of Table A) the Planning Committee from discharging or exercising a Relevant Planning Function
or from the Chief Executive Officer or Director of Planning referring a matter to either body as
she/ he considers appropriate.
3. This Scheme is without prejudice to and shall not restrict the discharge of any Relevant Planning
Function by the London boroughs of Brent, Ealing, Hammersmith and Fulham under any
agreements entered into from time to time under section 203 of the Localism Act 2011.
Scope of General Planning Delegation
4. Relevant Planning Function includes any statutory and other function capable of being
exercised by the Corporation from time to time under any of the following1 (1) the Old Oak and Park Royal Development Corporation (Planning Functions) Order 2015 2
(the OPDC Planning Functions Order);
(2) any compulsory purchase or related legislation generally, including compensation and the
acquisition of land by agreement;
(3) any legislation concerning the Community Infrastructure Levy generally;
(4) any other town and country planning legislation generally; and
(5) includes (without limitation) the power to:
1
2

This includes under any statutory amendment re-enactment or replacement of legislation.

Statutory Instrument 2015/ 442

Page 759

determine any application for planning permission or for other consent, including the refusal
of planning permission and to determine reasons for refusal, or to grant planning permission,
including to grant permission subject to any conditions, informatives or notes considered
appropriate, to determine their content and reasons for imposing them;

set any fee or charge levied by the Corporation in respect of its planning functions3;

take enforcement action or other legal proceedings of whatever nature in connection with or
related to any Relevant Planning Function;

respond to consultations of whatever nature (whether statutory or not) including in relation to

new or amended town and country planning legislation, policies, guidance, plans, frameworks
or strategies, the local development framework and supplementary planning documents for
each of the London boroughs of Brent, Ealing and Hammersmith & Fulham, other local
planning authorities with a Duty to Cooperate, and current and emerging strategic planning
guidance for London;

otherwise, to take any action or do any other thing (including any preparatory or preliminary
act) that is considered appropriate, necessary, expedient, facilitative, conducive or incidental in
connection with or related to the exercise of any of the above.

5. A summary of the Corporations functions under the OPDC Planning Functions Order is set out in
Appendix 1.
6. For the avoidance of doubt the Corporations functions under any of the following are (without
limitation) considered Relevant Planning Functions within the General Planning Delegation:(1) Town and Country Planning (General Permitted Development) (England) Order 2015;
(2) Town and Country Planning (Development Management Procedure) Order 2015;
(3) Community Infrastructure Levy Regulations 2010 (SI 2010/ 948) (as amended).
Referral of certain applications and consultations to Board or Planning Committee
7. The General Planning Delegation under paragraph 1 above shall be discharged and exercised in
accordance with the following provisions.
8. The Director of Planning (or in his/ her absence the Head of Development Management or Head
of Planning Policy) shall refer (a) an application for planning permission or for other consent or (b)

This is reserved to the Planning Committee in Table A

Page 760

the approval of a response to a consultation to the Planning Committee or (in exceptional

circumstances) to the Board (as the Director considers appropriate) where (1) In the Directors opinion the application or consultation subject matter falls within any of the
following categories:

It is of a significant or a potentially contentious nature; or

It has received significant objections; or

It may prevent the Corporation from fulfilling its functions and responsibilities; or

It involves a significant departure from development plan policy (which would be required
to be notified to the Secretary of State), but where it is proposed to approve the
application; or

It is of such a significant nature in terms of impact on the Corporations purposes,

functions or responsibilities that it should be referred to the Planning Committee or Board.

(2) A member of the Board or of the Planning Committee has requested that the application or
consultation response be decided by the Board or Planning Committee, rather than under
delegated powers, and the request has been made in writing to the Director within 21 days of
the registration of the application or start of the statutory consultation.
(3) An application for planning permission or other consent (only) is made (either as applicant or
agent) by a member of the Board, a member of the Planning Committee or any other
Committee of the Corporation or by any officer of the Corporation.

Page 761

Table A: matters reserved to the Board and Planning Committee

1

Matters reserved to a

Matters reserved to a

decision of the Board

decision of the Planning

3
Notes

Committee
A. Local Plan and other

1.

planning policies

Decision to approve the

Decision to consult on

Any report concerning the

text of the proposed local

draft supplementary

matters listed in Column 1

plan and any alterations

planning documents.

should normally be

Decision to consult on the

considered by the Planning

statutory consultation.

designation of a

Committee first unless time

Decision to approve and

Conservation Area.

does not allow it to be

to it for the purposes of

2.

adopt the local plan and

3.

4.

1.

2.

Decision to publish and

considered before the next

any alterations to it.

3.

consult on any proposed

scheduled Board meeting.

Decision to adopt

neighbourhood area

supplementary planning

application and / or

documents.

neighbourhood forum

Decision to designate a

application.

Conservation Area.
5.

Decision to approve and

adopt any other
significant local planning
policies including for
consultation (statutory or
otherwise).

6.

Decision to designate any

neighbourhood area and /
or neighbourhood forum.

7.

Decision to send any

neighbourhood plan or
Order to referendum.

8.

Decision to make any

neighbourhood plan or
Order.

B. Community

1.

Infrastructure Levy

2.

The decision to approve

Any report concerning the

the proposed text of the

matters listed in Column 1

CIL charging schedule

should normally be

and any alterations to it

considered by the Planning

for the purposes of

Committee first unless time

statutory consultation.

does not allow it to be

The decision to approve

considered before the next

Page 762

and adopt the CIL

scheduled Board meeting.

charging schedule and

any alterations to it.
C. Compulsory

The decision in principle to

Any report concerning the

purchase and related

make a compulsory purchase

matters listed in Column 1

matters including

order (but not the actual

should normally be

compensation and

making, withdrawing or

considered by the Planning

acquisition by

amending of any specific

Committee first unless time

agreement

order, and any connect matter

does not allow it to be

such as compensation, which

considered before the next

are delegated to officers

scheduled Board meeting.

under the General Planning

Delegation).
D. Other matters

The setting of any fees or

charges in respect of the
Corporations planning
functions.

Page 763

APPENDIX 1

Corporations functions under the Old Oak and Park Royal Development
Corporation (Planning Functions) Order 2015

1. Planning permissions: local planning authority for the purposes of Part 3 of the
Town and Country Planning Act 1990 (see article 3).
2. Local plans: local planning authority for the purposes of Parts 2 and 3 of the
Planning and Compulsory Purchase Act 2004 (see article 3).
3. Additional planning functions:
(1) The functions conferred by Schedule 8 to the Electricity Act 1989 so far as
applying to applications for consent for overhead lines under section 37 of that
Act (see article 5).
(2) The following provisions, which are specified in Part I of Schedule 29 to the
Local Government Planning and Land Act 1980, where references to an urban
development corporation are deemed to include a Mayoral development
corporation (see article 4):

Sections 171C, 172, 173, 173A , 178, 183, 184, 187A, 187B, 188, 196A
to 196C, 197, 198, 199, 201, 206, 207, 209, 211, 213 to 215, 219, 220,
224 and 324(1)(b) and (c) and (7) of the Town and Country Planning Act
1990.

Sections 3, 4, 8, 10, 11, 13 to 16, 20, 23 to 25, 38, 42, 44A, 47, 48, 50,
53, 54, 60, 69 to 72, 74, 75,82, 88 and 88A of the Planning (Listed
Buildings and Conservation Areas) Act 1990.

4. Other urban development corporation powers: the powers of an urban

development corporation under any statutory instrument (whenever passed or
made) including under regulation 9AA of the Town and Country Planning General
Regulations 1992 (see article 6).

5. Listed buildings: The following provisions which are specified in Part 2 of

Schedule 29 to the Local Government Planning and Land Act 1980 (where
Page 764

references to an urban development corporation is deemed to include a Mayoral

development corporation; see article 7):

Sections 139, 140(2)(d), 141(4), s 143(1)(b), 249, 251, 258, 330 of the Town and
Country planning Act 1990;

Sections 33, 34(2)(d) 35(6), 36(4) and 91(4) of the Planning (Listed Buildings
and Conservation Areas) Act 1990.

Page 765

This page is intentionally left blank

Page 766

Agenda Item 7

Subject:

Statement
of
Community
Involvement

Meeting
date:

6
January
2016

Report
to:

Planning
Committee

Report
of:

Director
of
Planning



For
Decision

________________________________________________________________________



This
report
will
be
considered
in
public

________________________________________________________________________



1
1.1

1.2

Summary

The
involvement
of
local
people
and
businesses
in
all
aspects
of
planning
at
Old
Oak

and
Park
Royal
is
central
to
the
success
of
the
OPDC.
In
July
2015,
the
OPDC,
as
the

Local
Planning
Authority,
drafted
a
Statement
of
Community
Involvement
(SCI)
to
set

out
how
local
and
statutory
consultees
will
be
involved
in
the
planning
process,
using

principles
in
the
Community
Charter.
The
OPDC
consulted
on
the
documents
from
27

August
to
14
October
2015.




As
part
of
the
public
consultation,
the
OPDC
received
22
individual
responses
which
are

detailed
in
the
attached
OPDCs
SCI
Consultation
Response
Report.
Building
upon
the

Community
Charter
principles
and
suggested
ground
rules,
the
proposed
final
SCI
is
a

clear
and
concise
document
which
will
guide
community
involvement
conducted
by

developers
and
OPDC.
The
final
SCI,
subject
to
comments
from
the
Planning
Committee

and
Board,
will
be
proposed
for
adoption
in
January
2016
by
the
Board.

Recommendations

The
Planning
Committee
is
asked
to:

2.1

Note
the
final
Statement
of
Community
Involvement
(SCI)
and
recommend

that
the
Board
agree
and
publish
the
final
SCI.

OPDCs
Statement
of
Community
Involvement

3.1

The
proposed
final
Statement
of
Community
Involvement
is
attached
at
Appendix
A
and

is
restructured
into
the
following
sections:

3.2

Introduction

outlines
the
OPDCs
approach
to
community
involvement
and
includes
a

set
of
ground
rules
that
will
act
as
guidance
for
all
those
undertaking
or
participating
in

community
involvement
activities.
The
inclusion
of
ground
rules
represents
the
main

change
to
the
SCI
and
this
will
reflects
the
comments
received
during
consultation.

Page 767

3.3

Involvement
in
planning
policy

clearly
sets
out
who
will
be
involved,
how
they
will
be

involved
as
well
as
specific
guidance
for
involvement
in
Local
Plan,
Supplementary

Planning
Documents,
Neighbourhood
Planning
and
Community
Infrastructure
Levy.

3.4

Involvement
in
planning
applications

clearly
sets
out
how
the
community
is
involved

at
each
stage
of
the
application
process,
building
upon
the
ground
rules
as
outlined
in

the
introduction,
and
how
the
OPDC
will
encourage
applicants
to
be
involved.

3.5

Assessment
and
monitoring

there
is
a
commitment
to
regularly
monitoring
the
SCI
and

updating
when
and
where
needed.

3.6

Glossary

although
the
document
limits
the
use
of
acronyms
or
technical
definitions,
a

glossary
is
included
for
information
purposes.

SCI
Consultation
Response
Report

4.1

A
summary
of
the
consultation
responses
is
included
at
Appendix
B.
The
OPDC
has

included
the
majority
of
suggested
changes,
most
notably
the
SCI
is
re-structured
and

re-formatted
to
avoid
the
use
of
lengthy
tables
so
that
information
is
presented
in
a

clear
and
concise
manner.
The
inclusion
of
ground
rules
will
help
guide
all
those

undertaking
community
involvement
activities.
Also,
it
should
be
noted
that
the

approach
to
engagement
at
a
corporation-wide
level,
will
be
developed
through
the

Communications
and
Engagement
strategy.

Financial
Implications

5.1

There
are
no
direct
financial
implications
for
the
OPDC
arising
from
this
report.
All
costs

relating
to
activities
arising
from
implementing
the
SCI
are
within
OPDCs
allocated

budget
for
engagement.

Legal
implications

6.1

No
legal
implications
arise
from
the
report
and
it
is
consistent
with
the
Corporations

legal
framework.

Appendices

Appendix
A

OPDCs
Statement
of
Community
Involvement
(SCI)

Appendix
B
-
OPDCs
SCI
Consultation
Response
Report



List
of
Background
Papers:

None




Report
originator:

Alex
Snelling-Day,
Senior
Community
Engagement
Officer,
OPDC

Telephone:


020
7983
4909


Email:



alexandra.day@opdc.london.gov.uk

Page 768

Appendix A


OldOakandParkRoyalDevelopmentCorporation


StatementofCommunityInvolvement



Contents

1. Introduction
- Old
Oak
and
Park
Royal

- Old
Oak
and
Park
Royal
Development
Corporation
(OPDC)

- What
is
the
Statement
of
Community
Involvement?

- OPDCs
Duty
to
Co-operate

- OPDCs
approach
to
delivering
effective
involvement
using
ground
rules



2. Involvementinplanningpolicy
- Introduction

- Who
will
be
involved?

- How
will
they
be
involved?

- Involvement
in
preparing
the
Local
Plan

- Involvement
in
preparing
Supplementary
Planning
Documents


- Involvement
in
Community
Infrastructure
Levy

- Involvement
in
Neighbourhood
Planning



3. Involvementinplanningapplications
- Introduction

- Importance
of
pre-application
community
involvement

- Types
of
development
proposal
and
recommended
pre-application
involvement

- Encouraging
effective
pre-application
involvement

- Involvement
when
an
application
is
submitted

- Making
a
decision
on
the
application

- Appeals



4. Assessmentandmonitoring


5. Glossary















Page 769

1. Introduction

OldOakandParkRoyal


The
OPDC
area
covers
the
Old
Oak
Common
and
Park
Royal
Opportunity
Areas
in
the
Mayors

London
Plan
(2015),
which
together
are
identified
as
having
the
capacity
to
deliver
a
minimum

additional
25,500
homes
and
indicative
65,000
jobs.
The
London
Plan
identifies
Old
Oak
alone

as
having
the
capacity
to
deliver
a
minimum
24,000
homes
and
55,000
jobs
representing

London
and
the
UKs
largest
regeneration
project.
This
scale
of
development
has
far
reaching

benefits
at
a
national,
regional,
West
London
and
local
scale.
Park
Royal
is
Europes
largest

industrial
estate
and
accommodates
over
2,000
businesses
employing
over
30,000
people.
The

Mayors
London
Plan
(2015)
identifies
that
through
redevelopment
and
intensification,
it
has

the
potential
to
deliver
an
additional
10,000
jobs
and
minimum
additional
1,500
homes.



The
spatial
vision
is
to
create
a
thriving
part
of
London
connected
to
the
rest
of
the
UK
and

internationally.
Old
Oak
and
Park
Royal
will
be
a
centre
for
innovation
and
growth
that
will

shape
west
London
and
strengthen
Londons
role
as
a
global
city.
A
new
commercial
hub
with

cultural
uses,
alongside
a
diverse
network
of
vibrant
neighbourhoods,
will
help
create
a
London

destination
recognised
as
an
exemplar
in
large-scale
housing
and
employment
led
regeneration.



The
objectives
for
the
area
are:



Consolidating


1.

Optimise
a
once
in
a
life-time
opportunity
created
by
High
Speed
2
and
Crossrail
to

secure
investment
that
will:



a.

deliver
a
thriving
new
centre
at
Old
Oak
that
delivers
much
needed
homes,
a
mix
of

employment
space
and
associated
social
and
physical
infrastructure;

b.

protect
and
regenerate
the
Park
Royal
industrial
area
as
a
cornerstone
of
the
London

economy.



Connecting


2.

Accessible
and
high
quality
national,
regional
and
local
transport
connections,
focused

around
a
new
world
class
station
at
Old
Oak
Common
will
catalyse
comprehensive
regeneration

with
well-designed
streets
connecting
surrounding
areas.



Creating


3.

Deliver
a
varied
mix
of
uses
and
culture
that
supports
the
growth
of
a
vibrant
London

destination.




4.

Celebrate
existing
features
of
the
Grand
Union
Canal,
Wormwood
Scrubs,
Park
Royal,

Heritage
assets,
and
local
communities
to
help
create
a
unique
sense
of
place.



5.

Utilise
the
scale
of
opportunity
to
embed
and
showcase
exemplar
design,
smart

environmental,
social
and
economic
standards
during
planning,
construction
and
operation.



6.

Flexible
and
adaptable,
both
to
the
effects
of
a
changing
climate,
and
future
changes
in

practices,
including
the
circular
economy,
that
delivers
an
open
and
secure
digital
place.

Page 770





Communities


7.

Create
a
series
of
connected
and
inclusive
lifetime
neighbourhoods,
designed
to

improve
the
quality
of
life,
enhance
health
and
well-being
and
deliver
social
and
economic

benefits
for
local
communities.
Integrated
with
their
surroundings,
new
development
will
foster

a
sense
of
community
and
diversity.









OPDC
wants
people
to
be
at
the
heart
of
the
proposals
through
open
dialogue,
developing

effective
community
involvement,
engagement
and
regeneration
programmes,
and
business

strategies
for
Old
Oak
and
Park
Royal,
to
ensure
that
local
communities
and
businesses
can

reap
the
benefits
of
the
new
infrastructure
and
investment.




OldOakandParkRoyalDevelopmentCorporation(OPDC)


New
communities
require
years
to
grow
and
evolve,
and
planning
is
part
of
this
process.
The

Mayor
of
London
established
OPDC
on
1st
April
2015
under
powers
provided
by
the
2011

Localism
Act,
to
ensure
that
the
huge
potential
of
the
area
is
fulfilled.



OPDCs
mission
is
to:

Pro-actively
lead
the
comprehensive
and
best
practice
planning
of
Old
Oak
and
Park

Royal
that
complements
the
wider
area.


Drive
forward
the
delivery
of
a
liveable
new
place
for
a
mix
of
residents,
employees
and

visitors,
ensuring
new
development
achieves
the
highest
standards
of
design.



Work
positively
with
stakeholders
to
unlock
and
coordinate
the
areas
regeneration

potential.


Engage
with,
and
support
the
participation
of,
local
communities
during
the
plan

making
and
development
management
processes.


Run
a
responsive,
customer
focused
planning
service.




OPDC
as
the
local
planning
authority
for
a
defined
area
of
approximately
650
hectares
in
west

London
which
includes
parts
of
the
London
Boroughs
of
Brent,
Ealing,
and
Hammersmith
and

Fulham.
OPDC
is
responsible
for
preparing
and
maintaining
the
areas
Local
Plan.
The
policies

in
the
Local
Plan
are
used
to
make
decisions
on
planning
applications
in
the
area,
alongside
the

National
Planing
Policy
Framework
(NPPF),
the
London
Plan
and
other
Development
Policy

Documents.
Other
documents
and
plans
such
as
Supplementary
Planning
Documents
are
also

important
documents
which
can
be
relevant
in
decision
making.
We
are
also
responsible
for

giving
guidance
to
developers,
setting
the
Community
Infrastructure
Levy,

designating

proposals
for
Neighbourhood
Planning
Areas
and
Forums,
and
supporting
the
development
of

Neighbourhood
Plans.



OPDC
will
be
developing
a
Communications
and
Engagement
Strategy
which
will
set
the

approach
for
all
engagement
on
planning
and
non-planning
matters.
The
drafted
Community

Charter
will
be
reviewed
during
this
process
to
ensure
there
is
a
clear
and
robust
framework
for

engagement.



WhatistheStatementofCommunityInvolvement?

Page 771



The
Statement
of
Community
Involvement
(SCI)
explains
how
OPDC
involves
the
community
in

deciding
planning
applications
and
preparing
planning
policy,
and
sets
out
how
it
will

effectively
utilise
the
rich
wealth
of
knowledge
that
the
existing
communities
have,
in
and

around
the
OPDC
area.




Community
refers
to
residents,
businesses,
community
and
interest
groups,
neighbourhood

planning
forums,
landowners,
developers,
London
Boroughs
within
and
neighbouring
the
OPDC

area,
government
agencies
and
any
other
individuals,
groups
and
organisations
interested
in,

and
affected
by,
the
development
and
use
of
land
at
Old
Oak
and
Park
Royal.


OPDCsDutytoCo-operate


OPDC
is
under
a
duty
to
co-operate
with
other
authorities
and
agencies
when
it
reviews
its

planning
policies.
These
authorities
and
agencies
include
boroughs
within
the
OPDC
area

(London
Borough
of
Ealing,
London
Borough
of
Hammersmith
&
Fulham,
and
London
Borough

of
Brent),
neighbouring
boroughs
(including
royal
Borough
of
Kensington
and
Chealsea),
the

Mayor
of
London
and
GLA
associated
bodies
(such
as
Transport
for
London),
as
well
as
bodies

such
as
the
Environment
Agency,
Network
Rail,
Historic
England,
Natural
England,
the
Civil

Aviation
Authority,
the
Clinical
Commissioning
Groups,
the
Homes
and
Communities
Agency,

the
Office
of
Rail
Regulation
and
Highways
England
(see
Town
and
Country
Planning
(Local

Planning)
(England)
Regulations
2012
for
the
full
list
of
specific
and
general
consultation

bodies).





OPDCsapproachtodeliveringeffectiveinvolvement(groundrules)

OPDC
is
committed
to
achieving
a
high
level
of
community
involvement.
As
a
result,
it
has

incorporated
10
ground
rules
which
are
intended
to
ensure
a
consistent
and
minimum
standard

for
community
involvement.
These
have
been
developed
from
suggestions
from
community

groups,
received
during
the
SCI
consultation
in
September
and
October
2015.
The
ground
rules

are
based
on
those
included
in
Bristol
City
Councils
SCI,
adopted
in
November
2015.






OPDC
expects
organisers
and
participants
of
community
involvement
activities
to
make

reasonable
endeavours
to
follow
the
ground
rules.
The
ground
rules
are
for:

- Prospective
planning
applicants
carrying
out
pre-application
community

involvement
on
development
proposals
that
will
be
determined
by
OPDC

- Individuals(s),
community
group(s),
and/or
organisation(s)
having
an
interest
in

the
planning
application
or
policy

- OPDC
in
preparing
planning
policy




Ground
Rules



1. Inclusive
invitation



a)

Reasonable
attempts
should
be
made
by
prospective
planning
applicants
and
/
or
OPDC

to
ensure
that
a
representative
cross-section
of
the
community
is
invited
to
the
same

community
involvement
event(s)
to
ensure
that
all
participants
are
aware
of
each
others
views.

Where
community
groups
or
individuals
are
unable
to
attend
events
but
nevertheless
wish
to

participate,
engagement
by
written
dialogue
should
be
pursued.

Page 772



b)

Invitations
should
go
to
existing
community
groups
in
and
around
the
OPDC
area
(e.g.

local
residents
associations,
neighbourhood
planning
forums,
amenity
societies)
where
they

exist
or
are
formed
as
a
result
of
the
proposal.




c)

It
may
be
necessary
to
hold
additional
events
for
those
groups
not
traditionally
involved

in
the
planning
process,
liaising
with
trusted
organisations
to
devise
activities
which
cater
for

hard-to-reach
groups.



d)

Events
should
be
held
in
accessible
locations
and
inclusive
premises.
Accessible

locations
will
enable
the
highest
possible
attendance
by
people
affected
by
the
proposal
or

plan;
for
example,
in
the
area
where
a
development
scheme
is
being
proposed.
Inclusive

premises
are
those
able
to
be
adequately
accessed
by
all
sections
of
the
community.



e)

All
participants
in
the
involvement
process
should
be
provided
with
a
rationale
for
the

developmet
proposals
and
a
plan
for
how
comments
will
be
considered
and
a
response
given.

Participants

should
also
be
asked
to
provide
their
contact
details
to
ensure
they
receive

feedback
on
the
results
of
involvement.



f)

To
ensure
all
sections
of
the
community
are
able
to
effectively
engage
in
the

involvement
process,
the
use
of
accessible
and
diverse
range
of
communication
formats
and

methods
should
be
considered,
where
appropriate



2. Authorisation




a)

Those
representing
community
groups,
the
prospective
planning
applicant
and
OPDC
at

community
involvement
events
should
be
able
to
show
that
they
are
authorised
to
speak
for

their
organisations.



b)

The
scale
and
remit
of
those
organisations
should
also
be
made
clear.


3. Continuity


a)

Involvement
should
be
a
continuous
process
with
the
timetable
for
the
period
of

preparing
the
plan
or
making
the
planning
application
made
clear.
It
is
desirable
that
the

timetable
should
allow
adequate
time
for
participants
to
effectively
engage
in
the
involvement

process.
This
includes
providing
participants
with
reasonable
notice
of
events
and
an
adequate

time
period
in
which
to
consider
and
respond
to
the
development
proposal
or
plan.



b)

Where
involvement
is
intended
to
include
a
series
of
meetings
or
events
then,
as
far
as

possible,
the
same
individuals
that
represent
the
community,
the
prospective
planning
applicant

and
OPDC
should
continue
to
be
involved
throughout
the
process
to
ensure
continuity
of

views.
Nevertheless,
it
may
be
appropriate
for
other
participants
or
advisers
to
be
involved

intermittently.



4. Independent
advice



a)
Where
technical
or
professional
advisers
or
private
consultants
are
employed
as

independent
facilitators
to
manage
the
involvement
process,
they
should
have
a

client
duty
of
care
to
all
parties
equally
and
should
be
instructed
to
follow
these

ground
rules,
irrespective
of
the
party
employing
them.
Where
facilitators
or
advisers

are
not
independent,
this
should
be
declared.

Page 773



5. Early
involvement


a)

Arrangements
should
be
made
for
the
community
involvement
process
to
begin
at
the

early
stages
of
a
plan
or
development
proposals
process.
This
should
occur
when
significant

options
are
still
open
and
while
there
is
still
the
potential
to
make
a
difference
to
the
final

plans.
Where
community
groups
or
individuals
are
unable
to
attend
the
initial
meeting
but

nevertheless
wish
to
participate,
engagement
by
written
dialogue
should
be
pursued


6. Presenting
options


a)

The
aim
should
be
to
set
out
reasonable
options
or
choices
and
to
have
input
from
local

communities
on
how
plans
and
proposals
could
be
taken
forward
including
those
suggested
by

the
community
that
are
reasonable,
reflect
the
communitys
needs,
ambitions
and
experience.



b)

For
development
proposals,
presentation
materials
will
be
accessible
and
clear
to
allow

all
the
opportunity
to
understand
the
proposals.
This
is
likely
to
include
oral,
written
and
visual

presentational
material.
This
could
also
include
the
use
of
three
dimensional
models
and

drawings,
videos
and
aerial
photographs
as
well
as
other
smart
and
innovative
technology.


7. Choosing
between
options

a)

The
planning
criteria
for
choosing
between
options
should
be
made
clear
and

transparent.


8. Consensus

a)

Best
efforts
should
be
made
to
reach
consensus,
making
it
clear
how
far
the

involvement
has
resulted
in
agreement
to
adopt
or
to
alter
proposals.
Where
agreement
has
not

been
possible,
a
clear
and
reasoned
response
should
be
provided


9. Transparent
records

a)

For
major
planning
applications,
a
Community
Involvement
Statement
should
be

submitted
by
the
planning
applicant
to
OPDC
as
a
supporting
document
to
their
planning

application.
The
statement
will
summarise:

the
community
involvement
undertaken;
the
main
issues
raised
by
the
community;

how
the
proposal
has
been
revised,
if
necessary,
to
take
account
of
the
issues
raised

and,
where
the
proposal
has
not
been
revised,
the
reasons
why
not



b)

For
Local
Plan
documents,
a
consultation
statement
will
be
made
available
alongside

the
Local
Plan
published
for
representations.
This
will
set
out:

who
was
consulted
when
preparing
the
Local
Plan

a
summary
of
the
main
issues
raised
by
those
persons

how
those
issues
have
been
addressed
in
the
Local
Plan



c)

For
Supplementary
Planning
Documents,
a
consultation
statement
will
be
published

alongside
the
final
document.
This
will
set
out:

-who
was
consulted
when
preparing
the
draft
document;

-a
summary
of
the
main
issues
raised
by
those
persons;
and
how
those
issues
have
been

addressed
in
the
draft
document.



d)
Participants
may
provide
a
written
statement
of
omissions
and
corrections
which
will
be

reported
and
considered
by
OPDC
along
with
the
Community
Involvement
Statement

and
/
or
consultation
statement.



Page 774



10. Feedback
on
the
outcome
of
community
involvement



a)

b)


c)


d)

For
major
planning
applications,
the
report
summarises
the
pre-
and
post-application

submission,
community
involvement
undertaken
by
the
applicant
and
how
it
has

influenced
the
application.
For
applications
below
the
major
threshold,
the
officers

report
summarises
the
responses
received
to
consultation
on
the
planning
application.

For
applications
being
considered
by
Planning
Committee,
OPDC
will
notify
those

people
who
commented
on
the
application
as
to
when
the
Planning
Committee
meeting

will
be
held
and
when
the
report
will
be
available
online.


For
Local
Plan
documents,
feedback
is
provided
in
the
consultation
statement
referred

to
under
9b.
For
Supplementary
Planning
Documents
this
will
be
the
consultation

statement
referred
to
under
9c.

In
making
decisions
on
planning
applications
and
planning
policy
documents,
OPDC
will

carefully
consider
comments
made
during
involvement
and
consultation
on
the

application
or
plan.

Page 775

2.Involvementinplanningpolicy

Introduction


This
section
sets
out
how
OPDC
involves
the
community
in
preparing
planning
policy

documents,
based
on
the
ground
rules
as
guiding
principles
and
follows
the
statutory

requirements
for
consultation.
A
list
of
all
planning
policy
is

available
in
OPDCs
Local

Development
Scheme
(LDS)which
is
available
online
or
can
be
requested
by
contacting
OPDC.


As
a
public
authority
OPDC
must
comply
with
the
Public
Sector
Equality
Duty
under
Section

149
of
the
Equality
Act
2010.
Under
the
Equality
Act
2010,
those
with
protected
characteristics

can
expect
OPDC
to
take
their
needs
into
account.
The
protected
characteristics
are:
age,

disability,
gender
reassignment,
pregnancy
and
maternity,
race,
religion
or
belief,
sex
(gender)

and
sexual
orientation.




Whowillbeinvolved?

Consultationdatabase

OPDC
will
develop
and
maintain
a
database
of
individuals,
groups,
and
organisations
that
have

an
interest
in
opportunities
to
get
involved.
It
includes
those
who
Government
regulations

require
OPDC
to
consult
or
who
have
expressed
an
interest
in
being
informed
about
the
Local

Plan.
It
includes
residents,
businesses,
neighbourhood
planning
forums,
community
groups,

voluntary
organisations,
interest
groups,
landowners,
developers,
businesses,
London
Boroughs

within
and
neighbouring
the
OPDC
area
and
government
agencies.
Requested
to
be
added
to

this
database
can
be
made
by
contacting
OPDC
by
email,
telephone
or
in
writing,



Existinglocalmeetingsandinitiatives

OPDC
has
set
up
regular
local
meetings
and
will
attend
existing
community
meetings,
where

possible,
to
raise
awareness
about
the
Local
Plan
and
seek
involvement.
OPDC
will
look
for

local
opportunity
to
raise
awareness
about
planning
policy
and
applications
to
encourage

involvement.


NeighbouringBoroughinvolvement

For
planning
policy
documents
likely
to
have
impacts
on
adjoining
local
authority
areas,
OPDC

will
engage
with
relevant
London
Boroughs
at
the
earliest
possible
stage
in
preparing
the

document.
This
helps
ensure
communities
in
the
neighbouring
areas
are
notified
and
have

opportunities
in
preparing
the
document.













Page 776



Howwilltheybeinvolved?

Involvementmethod
Consultation
documents

paper
copies

OPDC
Website

Discussion
events,
e.g.
workshops

Drop-in
events
/
exhibitions

Emails
and
letters

Meetings

Press
releases

Questionnaires

Social
media

Explanation
Planning
policy
documents
will
be
available
to

view
at
City
Hall,
local
libraries
and
other

community
locations.

OPDCs
planning
webpages
will
include

information,
and
when
appropriate,
a
dedicated

micro-site
for
community
engagement
and

consultation
will
be
used.
We
will
encourage

other
organisations
to
also
include
links
to
key

information
on
their
webpages.

These
events
are
facilitated
round-table

discussions
about
emerging
planning
policy

These
include
staffed
drop-in
events
/

exhibitions.
They
provide
opportunities
for

people
to
gain
information,
ask
OPDC
officers

questions
and
provide
feedback.
Exhibitions

can
also
be
non-staffed.
They
are
held
at

accessible
locations
and
at
times
aimed
at

encouraging
maximum
attendance.


Emails
and,
when
appropriate,
letters
are
sent

to
the
Consultation
Database.

OPDC
will
have
regular
email
newsletters
which

will
notify
subscribers
about
opportunities
for

involvement

These
are
used
to
discuss
and
gain
feedback
on

emerging
planning
policies.
They
include

OPDCs
organised
regular
local
meetings
as
well

as
other
meetings
with
interest
groups
and

particular
audiences.

Produced
to
raise
awareness
of
opportunities
to

engage,
however
dependent
on
press

publishing
releases.

These
are
a
means
for
gathering
feedback
at

drop-in
events
or
exhibitions
to
gathering

feedback
on
emerging
policies

OPDC
will
use
platforms
such
as
Twitter
or

Facebook
which
can
help
to
raise
awareness

and
encourage
feedback















Page 777



InvolvementinpreparingtheLocalPlan

The
most
recent
Regulations
that
came
into
force
in
April
2012
(as
amended)
set
out
the

statutory
requirements
for
the
production
of
Local
Plans
and
SPDs.
These
requirements
include

criteria
for
the
preparation
and
publication
of
a
draft
Local
Plan,
receiving
representations,

consideration
of
representations,
examination,
publication
of
recommendations
and
adoption.

Throughout
these
stages
of
policy
production,
OPDC
will
seek
to
ensure
that
issues
are

considered
and
that
policies
are
drafted
that
take
full
account
of
equality
and
sustainability

considerations.
As
part
of
this
process
there
will
be
appropriate
community
involvement
as
set

out
in
this
document
to
ensure
that
all
groups
have
the
opportunity
to
engage
in
the
planning

process.



Planning
law
requires
that
decision
on
planning
applications
should
be
made
in
accordance
with

the
development
plan,
which
includes
the
Local
Plan,
unless
other
relevant
planning
matters

indicate
otherwise.
The
development
plan
is
therefore
the
starting
point
for
when
OPDC
makes

decisions
on
planning
applications.




Information
about
the
Local
Plan
documents
to
be
produced
is
provide
in
the
Local

Development
Scheme
which
is
available
on
OPDCs
website
or
paper
copies
can
be
requested

by
contacting
OPDC.





Diagram:MainstagesofLocalPlandevelopment


Stage1PreparationofLocalPlan

Identify
and
consult
on
main
issues
that
the
Local
Plan
needs
to
address
and


consider
alternative
policy
options.


options.


Stage2PublicationofproposedLocalPlan

Local
Plan
policy
options
published
for
a
last
stage
of
consultation.


Local
Plan
and
public
responses
submitted
to
Secretary
of
State,
who
appoints
a


Planning
Inspector






Stage3Examination

The
Local
Plan,
public
responses
and
written
statements
examined
by
the
planning


inspector
at
public
examination.
There
may
be
further
modifications
published
for


consultation,
after
which
a
report
on
the
soundness
of
the
Local
Plan
is
issued
by


the
Inspector.






Stage4Adoption

The
recommendations
of
the
Inspectors
report
are
considered
and
OPDC
adopts


the
Local
Plan.










Page 778



CommunityinvolvementinproducingtheLocalPlan

Stage1PreparationoftheLocalPlan

The
main
plan-making
activities
undertaken
by
OPDC
during
the
preparation
stage
are
evidence

gathering,
identifying
issues
and
options,
and
selecting
preferred
options.



To
ensure
the
community
is
effectively
involved
in
these
activities,
OPDC
will
carry
out
a
range

of
community
involvement
methods:

1)

As
required
by
Government
regulations
OPDC:

a)

Invites
statutory
and
general
consultees1,
residents
and
businesses
in
the
OPDC
area
to

comment
on
what
the
Local
Plan
should
contain
during
a
public
consultation
for
a
minimum
of

6
weeks;

b)

Consults
bodies
listed
in
the
relevant
regulations2
on
the
scope
of
the
information
and

level
of
detail
that
should
be
included
in
the
environmental
report
which
accompanies
the
draft

Local
Plan.
The
environmental
report
addresses
the
requirements
of
the
European
Union

Directive
2001/42/EC
on
the
assessment
of
the
effects
of
certain
plans
and
programmes
on
the

environment.




In
addition,
OPDC:

2)

Emails
and
writes
to
members
of
the
consultation
database
throughout
the
Local
Plans

preparation;

3)

Makes
consultation
documents
and
questionnaires
available
on
its
website,
at
City
Hall

and
public
libraries;

4)

Holds
meetings,
discussion
events
and
drop-in
events
/
exhibitions;

5)


Issues
a
statutory
press
notice,
advertises
in
local
press,
uses
the
OPDC
email

newsletter
and
its
social
media
sites
to
raise
awareness.


Stage2PublicationoftheproposedLocalPlan

Taking
into
account
feedback
from
community
involvement
activities
during
the
preparation

stage,
OPDC
finalises
and
publishes
the
proposed
Local
Plan.



At
this
stage
OPDC
carries
out
the
following
participation
required
by
Government
regulations:

1)

Makes
the
Local
Plan
and
supporting
documents
specified
in
the
regulations
available

on
the
OPDCs
website
and
at
City
Hall
for
representations
to
be
made
for
a
minimum
period
of

six
weeks.

2)

Sends
notification
to
all
those
bodies
invited
to
make
comments
at
Stage
1
that
the

Local
Plan
and
supporting
documents
are
available
for
inspection
and
provide
details
about

how
to
make
representations.




Feedback
on
community
involvement



Alongside
the
Local
Plan,
a
consultation
statement
is
published
setting
out:
who
was
consulted

in
preparing
the
Local
Plan;
a
summary
of
the
main
issues
raised
by
those
persons;
and
how

those
issues
have
been
addressed
in
the
Local
Plan






















































1
2

As
defined
in
the
Town
and
Country
Planning
(Local
Planning)
(England)
Regulations
2012


Environmental
Assessment
of
Plans
and
Programmes
Regulations
2004

Page 779



Stage3Examination


The
Local
Plan,
along
with
supporting
documents
and
the
representations
received,
is
then

submitted
to
the
Secretary
of
State
for
independent
examination
by
a
Planning
Inspector.



At
this
stage
OPDC
carries
out
the
following
actions
required
by
Government
regulations:

1)

Makes
the
Local
Plan
and
supporting
documents
specified
in
the
regulations
available

on
OPDCs
website
and
at
City
Hall.

2)

Sends
notification
to
all
those
consultation
bodies
invited
to
make
representations

under
Regulation
18(1)
of
the
Town
and
Country
Planning
(Local
Development)
Regulations

2012
that
the
Local
Plan
and
supporting
documents
are
available
for
inspection.

3)

Notifies
those
who
requested
notification
that
the
Local
Plan
has
been
submitted
to
the

Secretary
of
State.



Stage5Adoption


Provided
the
Inspector
considers
the
Local
Plan
meets
Government
and
Mayoral
policy
and

legal
requirements,
approval
will
be
sought
from
OPDC
Boardto
adopt
the
Local
Plan
as
part
of

OPDCs
development
plan.



3.17
Following
adoption
OPDC
carries
out
the
following
actions
required
by
Government

regulations:

1)

Makes
the
adopted
Local
Plan,
the
adoption
statement
and
other
supporting

documents
specified
in
the
regulations
available
on
OPDCs
website
and
at
City
Hall.

2)

Sends
the
adoption
statement
to
those
who
asked
to
be
notified
of
the
adoption
of
the

Local
Plan.




InvolvementinpreparingSupplementaryPlanningDocuments

Supplementary
Planning
Documents
(SPDs)
add
detail
to
the
policies
in
the
Local
Plan.
They

are
only
produced
when
OPDC
considers
them
necessary
to
provide
additional
guidance
for

new
developments
at
specific
locations
or
on
particular
topics.




Diagram:MainstagesofproducingSupplementaryPlanningDocuments






Stage1:PreparationofthedraftSPD

OPDC
officer
compile
documents
and
supporting
evidence.
There
is
an
optional


preliminary
consultation.








Stage2:ConsultationondraftSPD

OPDC
published
the
draft
SPD
for
public
comments
for
a
minimum
of
6
weeks





Stage3:Adoption

OPDC
considers
comments
made
and
makes
any
necessary
changes.



OPDC
adopts
SPD
as
a
Local
Development
Document
and
prepares
adoption

statement.





Page 780




CommunityinvolvementinproducingSupplementaryPlanningDocuments

Stage1Preparation


OPDC
carries
out
a
range
of
involvement
methods
during
this
stage
to
ensure
effective

community
engagement
in
preparing
the
document:



1) As
required
by
Government
regulations,
OPDC
consults
bodies
listed
in
the
relevant

regulations3

as
to
whether
the
Supplementary
Planning
Document
are
likely
to
have

significant
environmental
effects.
This
will
assist
in
determining
whether
an

environmental
report
should
be
produced
to
accompany
the
draft
Supplementary

Planning
Document.
The
environmental
report
addresses
the
requirements
of
the

European
Union
Directive
2001/42/EC
on
the
assessment
of
the
effects
of
certain

plans
and
programmes
on
the
environment.



In
addition,
OPDC:



2)
Emails
and
writes
to
members
of
the
Local
Plan
Consultation
Database
about

opportunities
to
be
involved
in
preparing
the
Supplementary
Planning
Document;

3)
Where
appropriate,
holds
meetings,
discussion
events
or
drop-in
events
/
exhibitions;

4)
Advertises
in
local
press,
uses
the
OPDC
email
newsletter
and
its
social
media
sites
to

raise
awareness.





Stage2ConsultationondraftSupplementaryPlanningDocument


3.30

Taking
into
account
the
results
from
the
community
involvement
activities

during
the
preparation
stage,
OPDC
finalises
and
publishes
the
draft
Supplementary

Planning
Document.
At
this
stage,
as
required
by
Government
regulations
the
OPDC:

1)
Makes
the
draft
Supplementary
Planning
Document
available
on
OPDCs
website
and
at

City
Hall
for
representations
to
be
made
for
a
minimum
period
of
six
weeks.



In
addition,
OPDC:



2)
Emails
and
writes
to
members
of
the
Local
Plan
Consultation
Database
seeking

comments
on
the
draft
document;

3)
Advertises
in
local
press,
uses
the
OPDC
email
newsletter
and
its
social
media
sites

to
raise
awareness;

4)
Considers
holding
meetings,
discussion
events
and
drop-in
events
/
exhibitions
to

discuss
the
draft
and
seek
feedback.



Feedbackoncommunityinvolvement


A
consultation
statement
is
published
setting
out:

who
was
consulted
when
preparing
the
Supplementary
Planning
Document


a
summary
of
the
main
issues
raised
by
those
persons

how
those
issues
have
been
address
in
the
draft
document






















































3

Environmental
Assessment
of
Plans
and
Programmes
Regulations
2004

Page 781



Stage3Adoption


Having
regard
to
the
comments
received
on
the
draft,
the
final
document
will
be
prepared.

It
will
then
be
presented
for
adoption
at
OPDC
Board
meeting.
Following
adoption
OPDC

carries
out
the
following
actions
required
by
Government
regulations:

1)
Makes
the
adopted
Supplementary
Planning
Document
and
the
adoption
statement

available
on
OPDCs
website
and
at
City
Hall.

2)
Sends
the
adoption
statement
to
those
who
asked
to
be
notified
of
the
adoption
of
the

Supplementary
Planning
Document


InvolvementinCommunityInfrastructureLevy(CIL)

4.9 The
Community
Infrastructure
Levy
(CIL)
is
a
statutory,
non-negotiable
charge
on
new

development.
The
levy
will
be
used
to
help
deliver
a
wide
range
of
infrastructure

needed
to
support
the
development
of
the
area.




Diagram:MainstagesofdevelopingachargingscheduleforCommunityInfrastructureLevy




Stage1:Preliminarychargingschedule(PDCS)


PDCS
published
with
a
minimum
6
week
period
of
consultation







Stage2:ConsultationonDraftchargingschedule(DCS)

Draft
Charging
Schedule
published
with
a
minimum
6
week
period
of
consultation







Stage3:Examination

OPDC
considers
comments
made
on
the
draft
Charging
Schedule
and
makes
any


necessary
changes.
OPDC
submits
to
the
Secretary
of
State.
A
Planning
Inspector


is
appointed.
The
Charging
Schedule
is
examined
by
the
planning
inspector
at


public

examination.








Stage4:Adoption


OPDC
adopts
the
Charging
Schuedle
and
prepares
adoption
statement.







Stage1Preparationofapreliminarydraftchargingschedule


OPDC
carries
out
a
range
of
involvement
methods
during
this
stage
to
ensure
effective

community
engagement
in
preparing
the
document:



1)
As
required
by
Government
regulations
OPDC
consults
bodies
listed
in
the
relevant

regulations
to
invite
them
to
make
representations
on
the
PDCS.





In
addition,
OPDC



2)
Emails
and
writes
to
members
of
the
consultation
database
about
consultation
on
the

preliminary
draft
charging
schedule;

Page 782



3)
Where
appropriate,
holds
meetings,
discussion
events
or
drop-in
events
/
exhibitions;

4)
Advertises
in
local
press,
uses
the
OPDC
email
newsletter
and
its
social
media
sites
to

raise
awareness




Stage2-ConsultationondraftChargingSchedule


Taking
into
account
the
results
from
of
the
preliminary
draft
charging
schedule

consultation,
OPDC
finalises
and
publishes
the
draft
Charging
Schedule.
At
this
stage,
as

required
by
Government
regulations
the
OPDC:

1)
makes
the
draft
Charging
Schedule
available
on
OPDCs
website
and
at
City
Hall
for

representations
to
be
made
for
a
minimum
period
of
six
weeks.



In
addition,
OPDC:



2)
Emails
and
writes
to
members
of
the
Local
Plan
Consultation
Database
seeking

comments
on
the
draft
document;

3)
Advertises
in
local
press,
uses
the
OPDC
email
newsletter
and
its
social
media
sites

to
raise
awareness;

4)
Considers
holding
meetings,
discussion
events
and
drop-in
events
/
exhibitions
to

discuss
the
draft
and
seek
feedback.




Feedback
on
community
involvement



Alongside
the
draft
charging
schedule,
a
consultation
statement
is
published
setting
out:

who
was
consulted
when
preparing
the
Charging
Schedule;
a
summary
of
the
main
issues

raised
by
those
persons;
and
how
those
issues
have
been
address
in
the
draft
document.



Stage3-Examination


The
draft
Charging
Schedule
is
then
submitted
to
an
independent
examiner.



At
this
stage
OPDC
carries
out
the
following
actions
required
by
Government
regulations:

1)

Makes
the
draft
Charging
Schedule
available
on
OPDCs
website
and
at
City
Hall.

2)

Sends
notification
to
all
those
bodies
invited
to
make
comments
at
Stage
1
and
Stage
2

that
the
draft
Charging
Schedule
is
available
for
inspection.

3)

Notifies
those
who
requested
notification
that
the
draft
Charging
Schedule
has
been

submitted
to
the
Secretary
of
State.

4)


Publishes
a
consultation
statement
setting
out
who
was
consulted
when
preparing
the

Charging
Schedule;
a
summary
of
the
main
issues
raises
by
those
persons;
and
how
those
issues

have
been
addressed
in
the
draft
document.





Stage4-Adoption


Provided
the
Examiner
considers
the
draft
Charging
Schedule
to
have
met
Government
policy

and
legal
requirements,
approval
will
be
sought
from
OPDC
Board
to
adopt
the
Charging

Schedule.



3.17
Following
adoption
OPDC
carries
out
the
following
actions
required
by
Government

regulations:

1)

Makes
the
Charging
Schedule
and
the
adoption
statement
available
on
OPDCs
website.

Page 783



2)

Sends
the
adoption
statement
to
those
who
asked
to
be
notified
of
the
adoption
of
the

Charging
Schedule.
InvolvementinNeighbourhoodPlanning

Neighbourhood
development
plans
are
prepared
by
designated
neighbourhood
planning

forums.
Preparation
includes
consultation
on
a
draft
plan.
Following
a
successful
independent

examination
and
local
referendum,
neighbourhood
development
plans
are
brought
into
legal

force
and
are
made
part
of
the
development
plan.
Their
policies
are
then
considered
alongside

Local
Plan,
and
other
planning
policies
when
OPDC
makes
decisions
on
planning
applications.



Community
involvement
in
the
preparation
of
neighbourhood
development
plans
is
the

responsibility
of
the
neighbourhood
planning
forums
producing
the
plan.



The
Governments
National
Planning
Practice
Guidance
expects
forums
to
ensure
the
wider

community
is
kept
fully
informed
of
what
is
being
proposed
and
has
opportunities
to
be

involved
in
shaping
the
emerging
plan.
OPDC
will
continue
to
offer
advice

to
forums
on
how

effective
involvement
can
take
place
and,
where
resources
allow,
provide
assistance
in
carrying

out
the
involvement.



Whilst
most
community
engagement
in
the
preparation
of
neighbourhood
development
plans

will
be
led
by
the
neighbourhood
planning
forum,
there
are
certain
stages
where
OPDC
carries

out
formal
consultation:



1. Applicationtodesignateaneighbourhoodplanningarea


OPDC
publishes
on
its
website
the
name
and
map
of
the
proposed
neighbourhood
planning

area,
the
name
of
the
relevant
body
who
applied
for
the
designation
and
details
about
how
to

comment.
It
also
notifies
and
seeks
comment
from
members
of
the
Consultation
Database.

Following
this
consultation
OPDC
publishes
on
its
website
the
decision
to
either
designate,
alter

the
area
or
refuse
the
application
(with
reasons,
if
refusing).



2. Applicationtodesignateaneighbourhoodplanningforum


OPDC
publishes
on
its
website
a
copy
of
the
application
made
by
the
prospective
forum
and

details
about
how
to
comment.
It
also
notifies
and
seeks
comment
from
members
of
the

Consultation
Database.
If
OPDC
approves
the
proposed
area
and
forumit
will
publish
on
its

website
the
forums
name,
its
constitution
and


contact
details.
If
OPDC
decides
to
refuse
the

designation
then
it
will
publish
reasons
for
the
refusal
on
its
website.



3. Submissionofaneighbourhooddevelopmentplan


Once
the
neighbourhood
planning
forum
has
submitted
their
finalised
neighbourhood

development
plan
following
consultation
on
a
draft,
OPDC
publishes
on
its
website
the
draft

plan
and
supporting
documents,
including
details
on
how
to
make
comments.
It
also
notifies

and
seeks
comment
from
members
of
the
Consultation
Database.
Copies
of
these
documents

are
also
made
available
at
designated
locations
within
the
neighbourhood
planning
area.



4. Decisiononaneighbourhooddevelopmentplan


OPDC
sends
a
copy
of
the
submitted
draft
neighbourhood
development
plan,
the
supporting

documents
and
comments
received
at
the
submission
stage
to
an
appointed
Examiner
for

Page 784



independent
examination.
Hearing
sessions
may
or
may
not
be
required
at
the
discretion
of
the

Examiner.



OPDC
then
publishes
the
Examiners
report
and
decision
statement
on
its
website
and
makes
it

available
to
view
at
the
designated
locations
within
the
neighbourhood
planning
area.
Subject

to
the
Examiners
recommendation,
OPDC
then
proceeds
to
arrange
a
referendum
within
the

neighbourhood
planning
area
on
the
plan.




3. Involvementinplanningapplications


Introduction


In
line
with
national
guidance,
OPDC
will
strongly
encourage
applicants
to
involve
local

communities
in
the
pre-application
stages
and
once
the
application
has
been
submitted.
The

diagram
below
outlines
OPDCs
recommendations.
However,
it
is
recognised
that
preapplication
consultation
and
engagement
is
not
a
statutory
requirement.


Main
stages
in
the
planning
application
process



[Make
the
below
text
into
a
flow
diagram]



Beforeanapplicationissubmitted
- Community
involvement
carried
out
by
perspective
planning
applicant
(the

developer)



1. Decide
appropriate
involvement

Developer
considers
approach
to
pre-application

involvement.
This
should
reflect
the
SCI

2. Involvement

developer
carries
out
community
involvement

3. OPDC
may
consider
it
necessary
to
arrange
a
planning
forum
for
significant

development
proposals
at
the
pre-application
stage.

A
planning
forum
enables
local

resident
groups
and
others
to
discuss
proposals
directly
with
the
applicant
and
to

make
suggestions
about
how
schemes
could
be
improved.

4. Report
on
result
of
involvement

for
major
planning
application,
developer
submits

a
Community
Involvement
Statement
which
reports
on
the
involvement
undertaken

and
how
it
has
influenced
the
proposed
scheme.
For
applications
below
major

threshold,
developers
are
strongly
encouraged
to
submit
a
Community
involvement

Statement



Planningapplicationsubmitted
-OPDC
published
and
seek
comment
on
the
application



5. Publicity
and
consultation

OPDC
publishes
planning
application
(e.g.
website,
site

notice,
letter
to
neighbours
and
statutory
consultees,
press
advert)
and
seeks

comments
for
a
statutory
period
of
21
days.


6. Officer
assessment

a
planning

officer
will
assess
the
application
against

development
plan
policies
and
all
other
relevant
planning
considerations
including

comments
made



Decisiononwhethertograntplanningpermission

Page 785



7. Decision
Development
Management
officer
makes
decision
on
whether
to
grant

planning
permission
using
authority
delegated
by
OPDC
Planning
Committee.

Larger
scale
and
/
or
particularly
sensitive
or
controversial
applications
will
be

decided
by
OPDC
Planning
Committee.
For
these
applications
the
officers
report

will
recommend
a
decision
to
the
Planning
Committee.
Officers
report
and
OPDC

Planning
Committee
decision
placed
will
be
placed
on
OPDCs
website



[Separate
box
in
flow
chart]



Appeals
-
A
developer
may
appeal
to
the
Planning
Inspectorate
against
a
refusal
of

planning
permission.
A
Planning
Inspector
will
decide
whether
to
allow
or
dismiss
the

appeal.
All
comments
made
on
the
application
are
sent
to
the
Planning
Inspectorate.
OPDC
also

notifies
those
parties
consulted
on
the
planning
application
about
the
appeal
and
of
the

opportunity
to
submit
further
comments
to
the
Planning
Inspectorate.
The
exception
is
appeals

for
householder
and
minor
commercial
development;
for
these
the
Planning
Inspectorate
will

only
consider
comments
made
on
the
application

Involvement
before
an
application
is
submitted



Importanceandbenefitsofpre-applicationcommunityinvolvement


The
Governments
National
Planning
Policy
Framework
emphasises
the
importance
of
planning

applicants
carrying
out
involvement
on
their
emerging
proposals.
Paragraph

66
states:



Applicants
will
be
expected
to
work
closely
with
those
directly
affected
by
their
proposals
to

evolve
designs
that
take
account
of
the
views
of
the
community.

Proposals
that
can
demonstrate
this
in
developing
the
design
of
the
new
development
should

be
looked
on
more
favourably.



The
benefits
of
involvement
are
also
made
clear
in
the
Governments
National
Planning
Practice

Guidance.
It
sets
out
how
pre-application
engagement
improves
the
quality
and
likelihood
of

success
of
planning
applications
by:

working
with
interested
parties
at
an
early
stage
to
identify,
understand
and
seek

to
resolve
issues
associated
with
a
proposed
development

discussing
the
possible
mitigation
of
the
impact
of
a
proposed
development

including
any
planning
obligations
and
conditions

identifying
the
information
required
to
accompany
an
application,
thus
reducing
the

likelihood
of
delays
in
registering
the
submitted
application

Page 786



The
recommended
suggestions
for
effective
and
proportionate
pre-application
community

involvement
are
set
out
in
the
following
table.






Typeofproposal
Recommendedpre-application
involvement
Householderdevelopment
Discuss
proposal
with
neighbours
and
other

nearby
occupiers
/
owners
of
properties
/
land

This
is
development
within
the

curtilage
of
a
house
(or
a
single
flat)
requiring
at
earliest
possible
stage
in
developing
the

planning
permission.
For
example,
extensions,
proposal.

Consider
using
OPDCs
pre-application
advice

conservatories,
loft
conversions,
dormer

service,
particularly
for
proposals
within

windows,
outbuildings
and
fences.

Conservation
Areas
or
affecting
Listed

Buildings.

Minordevelopment
Discuss
proposal
with
neighbours
and
other

nearby
occupiers
/
owners
of
properties
/
land

This
is
defined
as:

at
earliest
possible
stage
in
developing
the

Less
than
10
homes,
including
the

proposal.

change
of
use
to
flats;

Where
the
proposal
is
likely
to
have
significant

Less
than
1000
m
of

impact
due
to
the
type
and
nature
of
the

non-residential
floorspace.

proposal
and
/
or
the
sensitivity
of
the
site
or

its
surroundings,
implement:

the
guidance
for
pre-application
community

involvement
and
ground
rules
within
this
SCI.

Use
OPDCs
pre-application
advice
service.

Majordevelopment
Discuss
proposal
with
neighbours
and
other

nearby

This
is
defined
as:

occupiers
/
owners
of
properties
/
land
at

10
or
more
homes,
or
on
a
site
of
at

earliest
possible
stage
in
developing
the

least
0.5
hectares;

proposal.

1,000
m
or
more
of
non-residential


Implement:
the
guidance
for
pre-application

floorspace
or
on
a

community
involvement
and
the
ground
rules.

site
of
at
least
1
hectare;

Use
OPDCs
pre-application
advice
service.

Waste
development.

Otherdevelopment
Discuss
proposal
with
neighbours
and
other

nearby
occupiers
/
owners
of
properties
/
land

Examples
include
advertisements
and

at
earliest
possible
stage
in
developing
the

telecommunications
masts.

proposal.
Where
the
proposal
is
likely
to
have



significant
impact
due
to
the
type
and
nature

of
the
proposal
and
/
or
the
sensitivity
of
the

site
or
its
surroundings,
implement:
the

guidelines
for
pre-application
community

involvement;
and
the
ground
rules.

Consider
using
OPDCs
pre-application
advice

service,
particularly
for
proposals
within

Conservation
Areas
or
affecting
Listed

Buildings

Page 787



Encouragingeffectivepre-applicationinvolvement


OPDC
will
strongly
encourage
applicants
to
take
a
positive
and
pro-active
approach
to

engaging
the
community
and
applicants
in
the
planning
process.
This
should
include

engagement
with
established
community
network
organisations,
such
as
but
not
limited
to
local

residents
associations,
the
Grand
Union
Alliance
and
Park
Royal
Business
Group,
and
when

appropriate
will
take
place
before
an
application
has
been
submitted,
as
well
as
during
the

formal
application
process.



Developers
for
all
major
schemes
will
be
encouraged
to
engage
fully
with
OPDC,
residents
and

businesses
to
discuss
proposals
at
an
early
stage
before
the
submission
of
any
planning

applications.
Early
discussions
with
all
sections
of
the
community
can
help
avoid
problem
areas

and
improve
the
quality
and
acceptability
of
a
planning
application.



OPDC
will
offer
a
confidential
pre-application
advice
service.
However
any
advice
given
is

without
prejudice
to
future
decisions
of
OPDC.
When
necessary,
internal
and
external

consultees
may
be
asked
for
their
comments
on
proposals.



Applicants
for
all
major
schemes
will
be
encouragedto
engage
with
the
community
before

submitting
a
planning
application.
There
are
a
number
of
ways
in
which
OPDC
will
encourage

applicants
to
engage
fully
with
local
residents:



Publicexhibitions


These
are
run
by
the
applicant
and
typically
give
residents
the
opportunity
to
see
and
comment

on
emerging
proposals.
OPDC
can
provide
advice
to
applicants
regarding
the
extent
of

consultation
but
it
is
the
responsibility
of
applicants
to
plan
and
deliver
public
exhibitions
and

consultations.
It
is
the
responsibility
of
the
applicant
to
ensure
that
venues,
times
of
day,
as

well
as
publicity
material,
are
accessible
and
inclusive
to
all.



Planningforum

OPDC
may
consider
it
necessary
to
arrange
a
planning
forum
for
significant
development

proposals
at
the
pre-application
stage.
These
could
include
representatives
from
local
resident

and
amenity
groups,
and
community
network
organisations,
and
ward
councillors
who
are

invited
to
participate
in
a
round
table
discussion
with
the
applicants,
facilitated
by
a
chair

person
who
acts
impartially.

A
planning
forum
enables
local
resident
groups
and
others
to

discuss
proposals
directly
with
the
applicant
and
to
make
suggestions
about
how
schemes
could

be
improved.





Involvementwhenanapplicationissubmitted

PublicityandconsultationbyOPDC

OPDC
wants
to
involve
the
community
in
decision
making
and
will
consult
the
community
on

every
planning
application
with
the
method
of
consultation
depending
on
the
type
and
location

of
the
application.
Each
application
has
an
initial
statutory
consultation
period
of
21
days.
The

methods
of
consultation
include:

Page 788

NeighbourNotifications-
notifications
of
planning
applications
will
be
sent
to
properties

that
are
immediately
adjacent
to
an
application
site
and
directly
affected
by
an
application

and/or
SiteNotices-
where
required,
a
site
notice
will
be
put
up
near
the
site


PressNotices-where
required
a
public
notice
will
be
placed
in
the
local
press

In
some
cases,
the
consultation
period
may
be
extended
or
new
periods
granted
at
the

discretion
of
OPDCs
case
officer.



OPDC
is
exploring
whether
interested
parties
can
sign
up
for
e-alerts
for
planning
applications,

as
well
as
searching
for
planning
applications
by
reference
number,
address,
postcode
or
on
a

map.
Planning
applications
will
also
be
available
to
view.



For
some
large
schemes,
OPDC
may
also
produce
a
specific
webpage
with
information,
and

updates,
as
well
as
a
link
to
the
consultation
page.


Makingadecisionontheapplication


Following
the
end
of
the
consultation
period,
OPDC
considers
the
comments
received
and

makes
a
decision
on
the
planning
application
having
regard
to
development
plan
policies
and
all

other
relevant
planning
considerations.
Some
applications
are
decided
by
planning
officers

using
authority
delegated
by
OPDC
Planning
Committee.
Larger
scale
and
/
or
particularly

sensitive
or
controversial
development
proposals
will
be
decided
by
OPDC
Planning
Committee.

This
is
a
public
meeting
with
the
opportunity
for
members
of
the
public
to
speak
by
prior

arrangement.




Officers
reports
setting
out
delegated
decisions
or
recommendations
to
OPDC
Planning

Committee
summarise
the
comments
received
from
consultation
on
the
planning
application.

For
major
applications,
officers
reports
also
summarise
the
involvement
undertaken
by
the

applicant
and
how
it
has
influenced
the
proposed
development.



Officers
reports
and
decision
notices
on
whether
to
grant
planning
permission
are
placed
on

the
OPDC
website.



Appeals

When
OPDC
has
been
notified
of
an
appeal
by
the
Planning
Inspectorate,
it
will
notify
all

interested
parties
of
the
appeal
and
provide
a
copy
of
all
comments
made
on
an
application
to

the
Inspectorate.
Interested
parties
are
advised
of
how
they
can
be
involved
in
the
appeal

process.



If
an
appeal
is
to
be
considered
at
an
informal
hearing
or
public
inquiry,
OPDC
will
also
notify
all

interested
parties
of
the
venue
and
time
of
the
hearing
in
line
with
the
Planning
Inspectorates

requirements.
The
venue
will
be
accessible
and
inclusive.



The
exact
consultation
methods
appropriate
to
specific
planning
applications
will
depend
on

the
complexity
of
the
proposals.







Page 789





4. Assessmentandmonitoring

The
purpose
of
this
document
is
to
ensure
that
the
most
effective
techniques
are
being
used
to

deliver
the
optimum
levels
of
community
involvement
and
that
all
groups
in
the
community

have
the
opportunity
to
get
involved
in
planning
policy
and
planning
decisions.




As
such,
it
will
be
important
for
OPDC
to
assess
the
effectiveness
of
the
SCI
periodically
and

monitor
the
success
rates
of
the
various
methods
being
used.
This
will
be
carried
out
through

the
analysis
of
feedback
to
consultation
on
policy
and
applications
requested
via
feedback

forms
or
other
methods
which
make
it
easy
and
quick
for
participants
to
give
feedback



The
SCI
will
be
reviewed
and
regularly
updated
to
reflect
any
changes
required
as
identified

through
this
monitoring
as
well
as
through
any
changes
to
national
legislation.
The
first
review

date
is
proposed
to
be
following
the
adoption
of
the
Old
Oak
and
Park
Royal
Local
Plan.
Where

material
changes
are
made,
the
SCI
will
be
re-consulted.



OPDC
will
undertake
this
task
to
maintain
its
goal
of
actively
involving
as
much
of
the

community
as
it
can
reach
in
the
development
of
policy
and
in
the
assessment
of
planning

applications
as
well
as
increasing
the
quality
of
engagement
through
monitoring
and
surveying

of
individuals/groups
involved.






Page 790

5. Glossary

CIL:The
Community
Infrastructure
Levy
(CIL)
is
a
new
power
which
enables
a
charge
to
be

levied
on
the
net
increase
in
gross
internal
area
floorspace
arising
from
development
in
order
to

fund
infrastructure
that
is
needed
to
support
development
in
the
area.
CoreStrategy:sets
out
the
long-term
spatial
vision
for
the
local
planning
authority
area,
the

spatial
objectives
and
strategic
policies
to
deliver
that
vision.
The
Core
Strategy
is
a

Development
Plan
Document.
Developmentplan:as
set
out
in
Section
38(6)
of
the
Act,
a
London
local
authoritys

development
plan
consists
of
the
London
Plan
and
the
Development
Plan
Documents

contained
within
its
Local
Plan
and
neighbourhood
plans.


Developmentplandocuments:spatial
planning
documents
that
are
subject
to
independent

examination,
and
together
with
the
London
Plan,
will
form
the
development
plan
for
the

borough
for
the
purposes
of
the
Act.
They
can
include
a
Core
Strategy,
Site
Specific
Allocations

of
land,and
Area
Action
Plans(where
needed).
Other
Development
Plan
Documents,
including

Development
Management
Policies,
can
be
produced.
Individual
Development
Plan
Documents

or
parts
of
a
document
can
be
reviewed
independently
from
other
Development
Plan

Documents.
Each
authority
must
set
out
the
programme
for
preparing
its
Development
Plan

Documents
in
the
Local
Development
Scheme.

Developmentmanagementpolicies:these
will
be
a
suite
of
criteria-based
policies
which
are

required
to
ensure
that
all
development
within
the
areas
meets
the
spatial
vision
and
spatial

objectives
set
out
in
the
Local
Plan.
They
may
be
included
in
any
Development
Plan
Document

or
may
form
a
standalone
document.

IssuesandOptions:produced
during
the
initial
stage
of
the
preparation
of
Development
Plan

Documents.

Localdevelopmentdocument:
the
collective
term
for
Development
Plan
Documents
and

Supplementary
Planning.

Localdevelopmentframework:the
name
previously
used
for
the
portfolio
of
Local

Development
Documents.
It
consisted
of
Development
Plan
Documents,
Supplementary

Planning
Documents,
a
Statement
of
Community
Involvement,
the
Local
Development
Scheme

and
Annual
Monitoring
Reports.

Localdevelopmentscheme:sets
out
the
programme
for
preparing
Local
Development

Documents.

Localstrategicpartnership:partnerships
of
stakeholders
who
develop
ways
of
involving
local

people
in
shaping
the
future
of
their
neighbourhood
in
how
services
are
provided.
They
are

often
single
non-statutory,
multi-agency
bodies
which
aim
to
bring
together
locally
the
public,

private,
community
and
voluntary
sectors.

LocalPlan:The
Local
Plan
consists
of
Development
Plan
Documents
drawn
up
by
the
Local

Planning
Authority
to
guide
the
future
development
of
the
local
area.
It
also
consists
of

Neighbourhood
Plans
for
Neighbourhood
Areas,
where
these
have
been
examined
and

approved
at
referendum.

Page 791




LondonPlan:the
Spatial
Development
Strategy
for
London.
The
Plan
came
into
effect
in

February
2004
and
set
out
an
integrated
social,
economic
and
environmental
framework
for
the

development
of
London
for
15-20
years.
The
most
recent
iteration
was
adopted
in
July
2011,

which
provides
the
London
wide
context
within
which
individual
boroughs
set
their
local

planning
policies
as
part
of
their
Development
Plan.

NeighbourhoodPlan:A
Neighbourhood
Plan
is
prepared
by
a
designated
Neighbourhood

Forum
(or
parish
or
town
council)
for
their
Neighbourhood
Area.
It
sets
out
the
policies
for

development
and
use
of
land
for
all
or
part
of
the
neighbourhood
area.
Neighbourhood
plans

are
subject
to
examination
and
referendum,
after
which
they
are
adopted
as
part
of
the

Development
Plan
for
the
local
area.
As
such,
they
much
be
in
conformity
with
OPDCs
Local

Plan.


PlanningInspectorate:
is
a
government
body
whose
main
work
involves
processing
planning

and
enforcement
appeals
and
holding
inquiries
into
local
development
frameworks.

OPDC:
The
Old
Oak
and
Park
Royal
Development
Corporation.
This
is
a
Mayoral
Development

corporation
and
therefore
directly
accountable
to
Londoners
through
an
independent
Board.

OPDC
is
a
functional
body
of
the
Greater
London
Authority.
Launched
on
1
April
2015,
OPDCs

purpose
is
to
secure
the
maximum
benefits
for
London
and
Londoners
from
the
transport

investment
planned
for
the
Old
Oak
and
Park
Royal
area.


PlanningPortal:A
national
website
that
offers
a
wide
range
of
services
and
guidance
on
the

planning
system
advising
on
planning
permission,
online
planning
applications,
planning

appeals
and
how
the
planning
system
works
(see
http://www.planningportal.gov.uk/).

PlanningObligations:Legal
agreements
between
a
planning
authority
and
a
developer,
or

undertakings
offered
unilaterally
by
a
developer,
that
ensure
that
certain
extra
works
related
to

a
development
are
undertaken.
For
example,
the
provision
of
highways.
Sometimes
called

"Section
106"
agreements
or
Planning
Agreements.

Proposalsmap:the
adopted
proposals
map
illustrates
on
a
base
map
all
the
policies
contained

in
Development
Plan
Documents.
It
must
be
revised
as
each
new
Development
Plan
Document

is
adopted,
and
it
should
always
reflect
the
up-to-date
planning
strategy
for
the
area.

TheRegulations:Town
and
Country
Planning
(Local
Planning)
(England)
Regulations
2012.

Supplementaryplanningdocuments:provide
supplementary
information
in
respect
of
the

policies
in
Development
Plan
Documents
and
may
take
the
form
of
design
guides,
development

briefs,
master
plans
or
issue
based
documents
that
supplement
the
policies
in
a
DPD.
They
do

not
form
part
of
the
Development
Plan
and
are
not
subject
to
independent
examination.

Sustainabilityappraisal:tool
for
appraising
policies
to
ensure
they
reflect
sustainable

development
objectives
(i.e.
social,
environmental
and
economic
factors)
and
required
in
the

Act
to
be
undertaken
for
all
Local
Plan
documents.

Page 792

Appendix B

Page 793

OPDCsStatementofCommunityInvolvement(SCI)ConsultationResponseReport

Overview

The
draft
SCI
was
based
on
the
principles
of
OPDCs

Community
Charter
and
explains
how
and
when
the

22 Responses Received:
community
can
be
involved
in
the
preparation
of
planning

policy
documents
and
in
the
consideration
of
planning

applications,
including
pre-application
proposals
and
appeals.

Every
local
planning
authority
must
prepare
an
SCI,
which
is
a

Individuals (11)
means
of
improving
the
quality
of
the
planning
process

through
greater
involvement
of
the
whole
community.
The

Businesses (2)
draft
SCI
aimed
to
ensure
that
the
appropriate
type
and
scale

of
engagement
is
undertaken
for
both
planning
policy

documents
and
specific
development
proposals
at
preGroups - community and
application,
application
and
appeal
stages.
OPDC
will
assess

interest (5)
and
regularly
review
our
approach
to
community
involvement

in
planning.
An
SCI
is
no
longer
considered
a
development

Faith
plan
document
and
therefore
not
subject
to
examination.


groups/organisations (3)


OPDC
developed
a
draft
SCI
and
received
approval
to
go
out

Local Authority (1)
to
consultation
from
OPDC
Board
in
July
2015.The

consultation
was
carried
out
from
27August
to
14th
October

2015



Approximately
350
consultees
were
contacted
directly
via
email
to
inform
them
of
the
consultation
and
invite
representations.
An
information

session
was
held
on
12th
October
2015
regarding
how
to
get
involved
in
the
planning
process
and
the
elements
of
the
draft
SCI
to
invite

representations.
The
draft
SCI
and
an
explanation
of
the
consultation
were
published
on
the
London.Gov
website
within
the
OPDC
webpages.


Representations
were
received
from
individuals,
businesses
and
other
groups/organisations,
The
groups
or
organisations
that
responded
are:


Diocese
of
London

Harlesden
Town
Team

Parish
of
All
Souls
Harlesden



Pentecostal
City
Mission
Church

Royal
Borough
of
Kensington
and
Chelsea

St
Quintin
and
Woodland
Neighbourhood
Forum

The
Hammersmith
Society

Westcott
Park
Residents
Network

Page 794

The
document
provides
a
summary
of
the
main
comments
from
the
representations
received.
Where
comments
have
been
made
the
document
also

provides
OPDCs
response
and
an
indication
as
to
where
it
has
led
to
changes
in
the
revised
document.
This
report
follows
a
format
of
you

said,
we
will
in
order

to
explain
what
points
were
made,
what
changes
requested
and
how
OPDC
have
responded
to
that
comment
or

request
in
order
to
show
how
the
SCI
has
developed
as
a
result
on
the
representations
received.



























Page 795

Yousaid,wewill

What
Yousaid
Document
format,

The
OPDC
should
ensure
that
all
its
documents
are
set
out
in
an

legibility
and

accessible
fashion

easy
to
understand
and
communicate
and
using
easy

accessibility

to
read,
plain
English.

Suggested
changes:










a
larger
type
size
would
be
more
accessible;










ensure
that
background
colours
dont
make
the
text
more
difficult

to
read
-
especially
for
older
people
and
those
with
sight
problems:










use
simple
diagrams
relating
to
the
processes
of
consultation
that

the
OPDC
is
statutorily
required
to
engage
in,
as
tables
used
in
the
draft

are
over
complex,
badly
laid
out
and
are
difficult
to
read.

The
SCI
also
refers
to
appendices
which
were
not
included.

Inclusion
of
Ground
An
extensive
set
of
Ground
Rules
was
submitted
by
several
respondents

Rules

based
upon
the
ground
rules
included
in
Bristol
City
Councils
SCI.

Planning

Applications

The
organisation
of
Planning
fora
is
positive.
However,
more
information

on
how
these
would
function
would
be
appreciated.

Community

engagement

OPDC
wishes
to
become
an
exemplar
in
the
delivery
of
its
consultations,

this
can
be
achieved
if
at
the
outset
if
community
partners
are
given

certain
assurances
that
help
them
to
participate
on
terms
that
they
can

manage.

Wewill
OPDC
has
developed
its
own
guidance
to
ensure

consistency
and
accessibility
in
formatting
for

documentation
and
will
incorporate
the
issues

raised
regarding
font
size
and
colour
palette
in

design.



The
diagrams
in
the
final
SCI
has
been
simplied

and
reconfigured
to
make
them
legible
and

clearer.



.
OPDC
has
reviewed
the
suggested
ground
rules

and
incorporated
all
ground
rules.
Some

amendments
to
clarify
and
consolidate
the

description
as
well
as
reflect
that
the
ground

rules
are
guidance.

OPDC
has
included
suggested

engagement/consultation
channel
in
the
final

SCI.

The
final
SCI
will
set
out
the
expectations
for

planning
process
and
expectations
on
all

community
engagement
will
be
outlined
in
the

Communications
and
Engagement
Strategy.





What

Yousaid

Database

Request
by
respondent
for
confirmation
that
they
are
on
our
stakeholder

database
and
are
formally
invited
to
participate
in
all
future
OPDC

consultations.

Wewill

Page 796

The
details
of
those
who
responded
to
this

consultation
have
been
added
to
our
database

and
will
receive
information
about
this
and

future
consultations
and
OPDc
information.

Community
Charter
OPDCs
Community
Charter
was
consulted
on
in
February
2015
and
none
All
responses
related
to
the
Community
Charter

and
SCI

of
the
previous
responses
appear
to
have
been
incorporated.

in
this
consultation
and
the
previous

consultation
will
be
assessed
and
where

appropriate
being
incorporated
into
the

Community
Charter
and,
development
of
the

Communications
and
Engagement
Strategy.



Community

Request
that
the
Grand
Union
Alliance
should
constitute
the
Community
OPDC
has
the
responsibility
to
plan
and
organise

Working/Champions
Champions/Working
Group,
however
further
resource
would
be
required.
on-going
engagement
channels,
OPDC
will
work

Group

Also,
conflicting
comments
that
a
Working
Group
needs
to
be
wider
than
with
the
co-ordinators
of
local
networks,

the
current
Grand
Union
Alliance
members.

including
the
Grand
Union
Alliance,
to
ensure

the
OPDC-led
engagement
responds
to
needs
of

local
people
and
businesses
within
local

networks
and
beyond.

Community
Charter
Suggestion
that
if
the
community
charter
is
to
be
used
outside
the


OPDC
will
explore
the
role
of
the
Community

and
SCI

OPDCs
planning
remit,
it
needs
to
be
stronger.

Charter
and
direction
will
be
taken
by
the

corporate
Communications
and
Engagement

Strategy
on
it's
role.

Policy
/
planThe
community
should
be
effectively
involved
in
the
formative
stages
of
OPDC
includes
a
commitment
to
involve
the

making

planmaking.
OPDC
must
set
out
how
it
will
incorporate
the
views
of
the
community
in
the
formative
stages
of
plancommunity
having
consulted
with
them.

making
and
the
SCI
sets
out
the
various
stages



at
which
consultation
will
take
place.
In
respect



of
the
Local
Plan,
information
about
how
the



community
will
be
involved
in
the
formative



stages
will
be
shared
in
January
2016
ahead
of



the
first
Local
Plan
consultation.





What

Yousaid

OPDC
and
Borough

responsibilities

Clearly
set
out
OPDCs
duties
and
responsibilities
/
obligations
around

community
involvement
as
distinct
to
those
of
the
local
authorities;

explaining
the
remit
of
OPDC
as
a
planning
authority
and
wider
remit
in

context
with
the
Borough
responsibilities
including
service
delivery.
This

could
be
included
in
a
separate
accessible
and
published
document.

Set
out
precisely
how
it
will
involve
communities
in
developing
planning

policy
-
particularly
hard-to-reach
groups
or
people
who
do
not
usually

engage
in
consultations
in
order
to
conform
with
the
National
Planning

Policy
Framework

Communicating

engagement
plans

Communicating

engagement
plans

Page 797
Policy
/
planmaking

Community
Charter

and
SCI

Wewill

The
SCI
is
specific
to
OPDC
and
what
our

requirements
are
for
community
involvement.
In

the
SCI
introduction,
we
will
explain
the
role
of

OPDC
in
context
to
that
of
the
London

Boroughs.


We
will
provide
more
detail
about
how
OPDC
will

work
with
trusted
organisations
to
develop

engagement
programmes
and
ensure

communication
is
tailored
for
different

audiences.


Use
words
such
as
collaboration,
co-creation
and
pro-active
involvement
OPDC's
SCI
clearly
sets
out
the
process
for
this

to
conform
with
the
NPPF;
the
supporting
text
(paragraph
7.6)
of
the

engagement.
Also,
in
the
corporation's

London
Plan
policy
7d
Lifetime
Neighbourhoods
is
clear
that
boroughs

Communication
and
Engagement
Strategy
there

and
presumably
all
planning
authorities
should
be
clear
about
the

is
a
recognition
of
the
benefits
of
collaboration

expectations
for
their
communities
and
neighbourhoods.
Authorities

and
co-creation
in
order
to
produce
projects
that

should
not
just
work
with
neighbouring
authorities,
relevant
infrastructure
have
local
support
and
benefit.


service
providers,
but
also
with
local
communities
to
ensure
that
all

sections
of
the
community,
including
local
businesses,
are
engaged
and

therefore
encouraging
a
sense
of
belonging
to
their
neighbourhood.

Neighbourhood
Plans
are
one
mechanism
for
both
Boroughs
and

OPDC's
SCI
includes
details
on
Neighbourhood

community-led
groups
to
agree
on
local
priorities,
resident
and

Planning
and
also
sets
out
how
individuals,

community
groups
might
also
be
involved
in
coproduct
ion
or
co
groups
and
businesses
can
get
involved
in

creation
of
the
authoritys
planning
policy.

shaping
planning
policy.


The
Community
Charter
should
inform
and
be
incorporated
into
the
SCI.

OPDC
will
explore
the
role
of
the
Community

The
charter
is
a
much
weaker
document
if
it
is
separated
from
the
SCI.

Charter
and
direction
will
be
taken
by
the



corporate
Communications
and
Engagement



Strategy
on
it's
role.





What

Yousaid

Planning

Applications

OPDC
will
provide
support
and
guidance
to
the
community
to
assist
them
Neighbours
that
are
located
in
close
proximity
to

in
responding
to
planning
applications

development
proposals
will
be
notified
in
writing

when
a
valid
planning
application
is
received.

The
letter
will
explain
how
representations
can

be
submitted
and
contain
advice
on
the
range
of

planning
issues
that
can
be
considered
by
the

Development
Corporation.
Telephone
and
email

contact
details
will
be
provided
for
anyone
who

requires
further
information
or
assistance
with

submitting
a
representation.

The
community
will
be
protected
from
poor
consultation
by
developers

OPDC
will
provide
advice
to
developers
on

particularly
prior
to
the
OPDC
Local
Plan
being
adopted

consultation
processes
at
the
pre-application



stage
and
will
encourage
developers
to



undertake
meaningful
consultation
with
the



community.

However,
this
is
not
a
pre-requisite



to
submission
of
a
planning
application
and



OPDC
will
undertake
its
own
consultation
on



submission
of
a
planning
application.

Planning

Applications

Wewill

Page 798



Page 799

What

Yousaid

Wewill

Planning

Applications

Clear
information
should
he
provided
to
which
authority
(OPDC
or

Boroughs)
community
members
should
submit
their
objections
to

planning
applications.

Assessments
and

Monitoring

It
is
essential
that
the
SCI
set
outs
how
it
will
measure
and
monitor
the

effectiveness
of
its
strategies
around
community
involvement,
including

monitoring
of
level
involvement
in:



co-production
of
planning
policy;


levels
of
submissions
to
consultations;


what
changes
have
been
made
as
a
result
of
community
involvement.

Notifications
about
planning
applications
will
be

made
by
the
relevant
authority
who
is

processing
and
determining
the
application.

Therefore
residents
will
always
know
where
to

send
their
representations.

OPDC
will
include
more
detail
regarding

measurement
and
monitoring
of
the

effectiveness
of
community
engagement
within

the
SCI,
where
engagement
relates
to
planning,

and
within
the
communications
and
Engagement

Strategy,
where
it
relates
to
wider
policy
and

project
engagement.

Assessment
and

Monitoring

The
OPDC
should
carry
out
annual
tracking
of
the
views
and
experiences
OPDC
will
investigate
options
for
annual

of
a
representative
survey
group
of
resident
and
community
organisations
tracking
of
views
and
experiences
to
inform

and
small
businesses
from
within
and
surrounding
the
OPDC
area
over
the
corporate-wide
monitoring.

next
1015
years.

Community
Charter

Agreement
with
the
proposed
consultation
meetings
and
membership
of
a

Working/Champions
Group
and
an
offer
of
venues
for
those
meetings.

Concern
that
limited
engagement
on
development
proposals
by

developers;
request
that
meaningful
steps
are
taken
towards
preconsultation
process
as
well
as
ensuring
events
for
Old
Oak
businesses

not
just
Park
Royal
businesses.

Business

engagement

Community
Charter

Diocese
of
Londons
response
to
the
first
OPDC
Community
Charter
has

not
been
included
the
list
noted
in
the
draft
SCI
Appendix.

OPDC
has
started
a
series
of
monthly
local

meetings
and
is
grateful
for
the
offer
of
venues.


The
SCI
sets
out
the
requirements
that

developers
need
to
follow
with
regard
to

community
engagement,
and
we
will
include

specific
reference
to
existing
businesses
in
the

Old
Oak
area
as
well
as
Park
Royal
businesses.



OPDC
will
explore
the
role
of
the
Community

Charter
and
direction
will
be
taken
by
the

corporate
Communications
and
Engagement

Strategy
on
it's
role.
OPDC
will
revisit
all

comments
received
on
the
Community
Charter.





What

Yousaid

Wewill

Community

engagement
plans

The
community
faces
considerable
disruption
with
the
advance
of

planned
construction.

The
construction
works
will
deliver
great
benefits

in
the
long
term
however
at
this
stage,
relationships
need
to
be
cultivated

to
help
allay
concerns,
reliable
information
produced
that
will
keep
the

community
up
to
date
with
the
developments
and
engaged
in
what
will

be
happening
around
them.
The
OPDC
can
choose
at
this
stage
to
work

differently,
put
its
commitment
at
the
heart
of
their
SCI
and
pledge

essential
resources
for
use
within
the
community
to
deliver
those

community
engagement
principles
that
genuinely
influence
plans
at
Old

Oak
and
Park
Royal.

In
the
draft
SCI
the
intention
is
to
conduct
appropriate
community

involvement

request
to
go
beyond
satisfying
statutory
requirements.

OPDC
is
developing
a
Communications
and

Engagement
Strategy
which
will
set
out
the

ways
in
which
we
can
ensure
communities
have

timely
and
accurate
information
about
planned

construction.

Community

engagement
plans

Page 800

Community

engagement
plans

Community

engagement
plans

OPDC's
starting
point
will
be
to
deliver
high

quality
and
effective
community
involvement

and
this
is
likely
to
go
beyond
the
statutory

requirements.

We
recommend
an
approach
that
also
allows
for
sufficient
time
and

OPDC
will
ensure
that
consultations
are

access
to
expertise
to
help
local
people
within
their
groups
or
as

organised
in
order
to
enable
people
to
input;

individuals
consider
what
is
proposed,
consult
within
their
constituencies
this
means
information
will
be
clear
and

and
then
submit
responses
on
fundamental
changes
in
the
area.
This

explained.
OPDC
will
use
workshops
to
create
an

adequacy
of
resource
is
not
yet
in
place
and
effectively
compounds
the

environment
where
the
community
can
come

disadvantage
often
felt
by
the
community
when
consulted.



together
and
discuss
topics
and
provide

comments,
ideas
and
co-design
approaches.

OPDC
will
investigate
independent
support
for

groups,
from
agencies
such
as
Planning
Aid.


Recent
experience
includes
OPDC
consultations
that
have
commenced

OPDC
will
ensure
that
community

with
little
notice,
and
deadlines
that
place
pressure
on
those
consulted,

representatives
are
given
as
much
notice
as

making
it
sometimes
impossible
for
volunteers
and
others
to
respond

possible
before
all
engagement
activity.
A

easily
or
in
detail
having
not
had
resources
to
obtain
the
right
advice.

programme
of
monthly
local
meetings
has
been

established
which
means
advance
notice
can
be

given.
Also,
improved
use
of
notifcation
via

email
will
be
used.





What

Yousaid

Community

engagement
plans

Aim
to
reach
beyond
vocal
representative
to
check
views
are

representative
of
the
whole
community.
Explore
the
use
of
social
media,

such
as
Facebook,
to
reach
local
people.

Community

engagement
plans

Geographical
scope

Wewill

Page 801

OPDC
agrees
that
the
way
in
which
community

involvement
is
carried
way
must
strive
to
find

representative
views
from
the
whole
community.

OPDC's
Communications
and
Engagement

Strategy
will
set
out
how
social
media
can

support
that
aim.

Suggested
change
to
include
engaging
with
communities
in
the
three

OPDC's
SCI
states
that
neighbouring

stated
boroughs
as
well
as

the
neighbouring
Royal
Borough
of

communities
must
be
included
in
engagement

Kensington
and
Chelsea
as
appropriate

and
consultation
activities,
this
will
be

ammended
to
specify
those
in
the
Royal

Borough
of
Kensington
and
Chelsea.


Paragraph
3.2
should
be
amended
to
say
They
will
be
coordinated
with

OPDC
has
updated
the
SCI
to
reflect
wider

the
strategies
of
the
London
Boroughs
of
Brent,
Ealing
and
Hammersmith
partners
and
neighbouring
communities.
OPDC

and
Fulham,
and
those
of
wider
partners,
such
as
the
GLA
and
TfL.

will
explore
ways
in
which
measures
for
cross

Regard
will
also
be
had
to
the
strategies
of
the
Royal
Borough
of

boundary
consultation
can
be
carried
out

Kensington
and
Chelsea,
which
lies
directly
to
the
east
of
the
OPDC

boundary,
where
appropriate.



With
regards
to
the
other
specific
provisions
as
set
out
in
the
Draft
SCI
we

would
further
welcome
mention
of
RBKC
and
the
local
populations
in
the

areas
neighbouring
the
OPDC
area.
Measures
for
cross
boundary

consultation
where
appropriate
should
be
set
out,
when
consulting
with

RBKC
and
affected
residents
and
local
amenity
groups.





Yousaid

Wewill

Support
for
the
transparency
ground
rule,
as
developed
by
Bristol
City

Council.
Suggested
wording
for
inclusion
in
the
OPDC
SCI
regarding

availability
of
Financial
Viability
Assessment
information
submitted
as
part

of
the
planning
process.

Financial
viability
information
provided
by

developers
is
normally
deemed
to
be

commercially
sensitive
and
exempt
from
release

into
the
public
domain.
However
OPDC
will
seek

further
legal
advice
on
the
matter
as

appropriate.

SCI
adoption

Defer
the
adoption
of
the
SCI
to
allow
time
for
collaborative
process

involving
the
community
in
developing
the
SCI.

OPDC
regards
it
as
imperative
that
the
SCI
is
in

place
as
soon
as
possible
to
provide
clear

expectations
on
all
consultation
activities

relating
to
planning
matters.
The
broader

Communications
and
Engagement
Strategy
will

involve
stakeholders
in
shaping
activities.
The

SCI
will
be
reviewed
periodically
to
reflect
new

ways
to
consult
which
are
appropriate
for
the

Old
Oak
and
Park
Royal
area.

Page 802

What








Page 803

Summary

OPDC
has
taken
on
board
the
comments
received
and
adapted
the
layout,
and
formatting
of
the
document
and
the
content,
to
clarify
the

expectations
and
requirements
for
community
involvement
in
planning
process
within
Old
Oak
and
Park
Royal.
The
suggested
ground
rules
have

been
adapted
and
included
within
the
final
SCI.




It
should
also
be
noted
that
OPDC
will
be
developing
a
corporate
strategy
for
Communications
and
Engagement,
and
Socio-Economic
Regeneration

which
will
incorporate
some
of
the
broader
points
made
regarding
community
involvement
ground
rules,
community
development
and
monitoring
of

impacts
on
local
people
and
businesses
during
construction.




OPDC
thanks
all
those
who
submitted
detailed
and
thoughtful
responses
to
the
SCI
consultation
and
hopes
that
the
table
above
provides
full

responses
to
all
points
made
by
respondents.
A
track-changed
SCI
will
be
presented
to
the
Planning
Committee,
for
comment,
and
Board
for

approval
with
a
view
to
adoption
of
the
SCI
in
January
2015.






















This page is intentionally left blank

Page 804

Agenda Item 8

Subject:

Planning
applications
received
since
27
October
2015

Meeting
date:

6
January
2016

Report
to:

Planning
Committee

Report
of:

Director
of
Planning



For
Noting

________________________________________________________________________



This
report
will
be
considered
in
public

________________________________________________________________________



1

Summary

1.1

This
report
appends
a
list
of
all
planning
applications
received
by
the
OPDC
from








27
October
2015
to
14
December
2015.

Recommendations

The
Planning
Committee
is
asked
to:

2.1

Note
the
list
of
planning
applications
received
since
27
October
2015,

appended
to
this
report.

Appendices

Appendix
A

List
of
planning
applications
received
since
27
October
2015







Report
originator:

Claire
OBrien,
Head
of
Development
Management,
OPDC


Telephone:


020
7983
5705


Email:



claire.obrien@opdc.london.gov.uk

Page 805

This page is intentionally left blank

Page 806

Appendix
A




List
of
Planning
Applications
received
since
27
October
2015

Page 807

Date
received by
OPDC

Applicant name

Site address

Postcode

Description of development

Status

28/10/2015

Mr Oleg Zinko

The Courtyard, Park Royal Road

W3 6XA

Construction of additional floor for office (Class B1a) use

Delegated - Ealing

28/10/2015

Insite Poster
Properties

622 Western Avenue

W3 0TF

Replacement of 1no 48-sheet backlit hoarding and 1no

Mega 6 backlit hoarding with 1no 48-sheet LED display
hoarding and 1no Mega 6 LED display hoarding

02/11/2015

Sandflames Ltd

Sandflames resraurant, Victoria

Road

W3 6UN

04/11/2015

Guinness Ltd and

London and
Regional Properties

Land at Lakeside Drive, Park

Royal

NW10

Retention of single storey front, rear and side extensions in

connection with the continued use of the premises as a
restaurant and sheesha lounge.
Discharge of condition 22 (energy centre) of planning
permission 10/3221

For
recommendation
by Ealing and
decision by OPDC
Delegated - Ealing

05/11/2015

J C Decaux

Rail Embankment, Western

Avenue, Acton

W3 0NJ

Upgrade of existing single-sided advertisement display

technology to a digital screen and automatic change of
adverts

06/11/2015

Brixton Properties
Ltd

Telford Way, Acton

W3 7XS

Discharge of condition 14 (iv) (land contamination) of

planning permission PP/2014/2942

13/11/2015

JP Boden & Co

Boden House, 114 Victoria Road

NW10 6NY

Variation of condition 2 of planning permission

PP/2014/2361 for alterations to south elevation

Delegated - Ealing

13/11/15

Genesis Housing
Association

Land to the north east of Old Oak

Common Lane and south of the
Grand Union Canal

NW10

For determination
by OPDC

16/11/2015

Mr Damian Teevan

6 Standard Road, Park Royal

NW10 6EU

16/11/2015

Mr Charlie Bighams

2 McNicol Drive

NW10
7AW

Request for an Environmental Impact Assessment Scoping

Opinion in accordance with Regulation 13 of the Town and
Country Planning (Environmental Impact Assessment)
(England) Regulations 2015 (as amended)
Change of use from B8 warehouse to B1c bakery with
ancillary caf
Construction of two storey entrance tower and first floor
level walkway

17/11/2015

All Bees Ltd

3 Bashley Road, Park Royal

NW10 6TE

Discharge of condition 7 (construction management

statement) of planning permission PP/2015/0960

Delegated - Ealing

Delegated - Brent

For
recommendation
by Ealing and
decision by OPDC
Delegated - Ealing

Delegated - Ealing
Delegated Brent



Page 808

25/11/2015

Mr M Amin

6B and 8B Wesley Avenue, Park

Royal

NW10 7BN

Erection of a hip to gable and rear dormer extensions and

insertion of roof lights to first floor flats 6B and 8B

Delegated - Ealing

30/11/2015

HSS

Unit B, Rear of Builder's Depot,

27 Abbey Road

NW10 7SJ

Construction of new vehicular access

Delegated - Brent

03/12/2015

H R Owen PLC

Unit 12, Premier Park Road

NW10 7NZ

Installation of 4no. Illuminated fascia signs

Delegated - Brent

04/12/2015

Horsley Estates Ltd

13 Waxlow Road

NW10 7NU

Delegated - Brent

04/12/2015

Mariusz Wasel

10 St Leonard's Road

NW10 6SY

Change of use from a coach depot (sui generis) to B1c, B2 or

B8
Change of roof and new windows in front elevaton

05/12/2015

JP Boden & Co

Boden House, 114 Victoria Road

NW10 6NY

Delegated - Ealing

08/12/2015

Aberdeen Asset
Management

Units 3, 4 & 5 Nucleus Industrial

Estate, Central Way

NW10 7FY

900 sqm of additional B1a floorspace, a new glazed link, two

additional smoke vents and revised parking arrangement
5 no. fascia signs to warehouse units

14/12/2015

Mr Sam Reynolds

13 Stephenson Street

NW10 6TX

Loft conversion with dormer window, rear extension and

boundary wall

Delegated Ealing

For
recommendation
by Ealing and
decision by OPDC
Delegated - Ealing