AGENDA

Meeting:

Board of the Old Oak and Park Royal Development

Corporation

Date:

Tuesday 28 July 2015

Time:

2.00 pm

Place:

Committee Room 4, City Hall, The Queen's Walk,

London, SE1 2AA

Members of the Board of the Old Oak and Park Royal Development Corporation are hereby
notified and requested to attend the meeting of the Board at 2.00 pm on Tuesday 28 July
2015 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
www.london.gov.uk/sites/default/files/openness-in-meetings.pdf

Members of the Board:

Sir Edward Lister (Chairman)
Cllr. Julian Bell
David Biggs
Cllr. Muhammed Butt
Cllr. Stephen Cowan
Rahul Gokhale
Debra Humphris
Observers:
Richard de Cani
Andrew Donald
Fiona Fletcher-Smith
Pat Hayes
Juliemma McLoughlin

Simon Kirby
William McKee CBE
Matthew Pencharz
David Prout
Eric Sorensen
Amanda Souter

Welcome and Chairman's Opening Remarks

Apologies for Absence

Declarations of Interest

Minutes of the Meeting Held on 25 June 2015 (Pages 1 - 6)

Matters Arising and Actions List (Pages 7 - 10)

Chief Executive Officer's Report (Pages 11 - 18)

Report of the Meeting of the Planning Committee held on 15 July 2015 (Pages
19 - 20)

Old Oak and Park Royal Development Corporation - Proposed Adoption of

the West London Waste Plan (Pages 21 - 142)

Draft Statement of Community Involvement (Pages 143 - 194)

10

Greater London Authority Old Oak and Park Royal Opportunity Area Planning
Framework Consultation Responses (Pages 195 - 352)

11

Old Oak and Park Royal Development Corporation Local Development

Scheme (Pages 353 - 364)

12

Crossrail Old Oak Common Depot (Pages 365 - 366)

13

OPDC Growth Strategy Submission (Pages 367 - 370)

14

Exclusion of the Press and Public

15

Crossrail Old Oak Common Depot (Pages 371 - 382)

16

OPDC Growth Strategy Submission Update (Pages 383 - 386)

17

Date of Next Meeting

Tuesday 15 September 2015 at 3.00pm, City Hall, The Queens Walk, London, SE1
2AA

18

Close of Meeting

2

Agenda Item 4

MINUTES

Meeting:

BoardoftheOldOakandParkRoyalDevelopment
Corporation

Date:

Thursday25June2015

Time:

3.00pm

Place:

CommitteeRoom2,CityHall,TheQueen'sWalk,London,
SE12AA

Present:

Sir
Edward
Lister
(Chairman)

Cllr.
Julian
Bell

David
Biggs

Cllr.
Stephen
Cowan

Rahul
Gokhale

Debra
Humphris

William
McKee
CBE

Matthew
Pencharz

David
Prout

Eric
Sorensen

Amanda
Souter



InAttendance:
Victoria
Hills,
Chief
Executive
Officer

Doug
Wilson,
Chief
Finance
Officer

Richard
de
Cani



Andrew
Donald

Fiona
Fletcher-Smith

Pat
Hayes

Juliemma
McLoughlin

James
Varley,
Secretariat







WelcomeandChairman'sOpeningRemarks

1


1.1
The
Chairman
welcomed
Members
to
the
third
meeting
of
the
Board
of
the
Old
Oak
and
Park

Royal
Development
Corporation
(OPDC).




1.2
The
Chairman
informed
Members
that
Sir
Peter
Hendy
CBE
had
been
appointed
to
the

position
of
Chairman
of
Network
Rail
and,
as
a
consequence,
he
would
now
cease
to
attend

subsequent
OPDC
Board
Meetings
in
any
capacity.




1.3
Work
on
the
Growth
Strategy
was
progressing
and
positive
discussions
had
taken
place
with

Government.

Meetings
had
also
taken
place
with
the
three
Boroughs
in
the
area.
The
Leader

of
Hammersmith
and
Fulham
Council
explained
that
the
council
had
its
own
workstream
and

would
welcome
the
opportunity
to
feed
its
work
into
that
of
the
OPDC.






Page 1





2
2.1





3
3.1





4
4.1





5
5.1



5.2





6
6.1



6.2



6.3



6.4



6.5



6.6

ApologiesforAbsence



Apologies
for
absence
had
been
received
from
Cllr.
Muhammed
Butt,
Sir
Peter
Hendy
CBE

and
Simon
Kirby.

DeclarationsofInterest



There
were
no
interests
to
be
declared
that
were
relevant
to
items
on
the
agenda.


MinutesoftheMeetingHeldon18May2015



The
minutes
of
the
Board
meeting
held
on
18
May
2015
were
approved
as
a
correct
record

and
the
Chairman
was
authorised
to
sign
them.


MattersArisingandActionsList



The
Chief
Executive
Officer
introduced
the
item.


DECISIONS:
TheActionsListbenoted.
ChiefExecutiveOfficer'sReport



The
Chief
Executive
Officer
introduced
the
report
which
updated
the
Board
on
the
activities

of
the
Corporation
since
the
last
meeting.




Following
a
meeting
of
the
London
Assemblys
Confirmation
Hearings
Committee
on
20
May

2015,
the
Mayor
had
confirmed
the
appointment
of
Sir
Edward
Lister
as
Chairman
of
the

Corporation.



In
response
to
a
request
from
the
Board,
future
reports
would
include
additional
information

on
studies
taking
place
in
the
area.


Advisers
had
been
appointed
to
provide
intelligence
on
land
ownership
and
retail
intelligence

in
the
development
area.

Two
outline
European
Regional
Development
Fund
bids
had
been
prepared.

The
Corporation

would
receive
a
response
on
the
first
stage
of
the
bids
in
July
2015
and
the
status
of
the
bids

would
be
reported
to
the
next
meeting
of
the
Board.


The
Planning
Framework
would
be
considered
at
the
next
meeting
of
the
OPDC
Planning

Committee
on
15
July
2015
prior
to
submission
to
the
Board
for
endorsement
on
28
July

2015.

2


Page 2

6.7



6.8



6.9

The
OPDC
Utilities
Panel
would
be
meeting
on
9
July.
The
purpose
of
the
meeting
was
to

secure
support
from
the
utilities
providers
for
a
smart
strategy
for
the
Corporation
area.

The

desire
was
for
the
OPDC
to
become
an
exemplar
for
development
areas
in
London.




Dialogue
had
taken
place
with
planners
from
Shanghai
who
were
interested
in
the
work
being

done
around
the
clean
tech
cluster
and
the
Climate-
KIC
initiative
which
would
help
inform

their
work
on
development
of
part
of
the
city.


The
Leader
of
the
London
Borough
of
Hammersmith
and
Fulham
commented
that
it
was

encouraging
to
see
the
level
of
engagement
taking
place
with
NHS
England.

The
west

London
Boroughs
were
also
engaged
in
their
own
work
in
this
area
and
requested
input
into

the
work
of
the
Corporation.

6.10 DECISIONS:

a)
That the appointment of Sir Edward Lister as Chairman of the Old Oak and Park
RoyalDevelopmentCorporationbenoted;and

b)
Thatthereportbenoted.






ReportoftheMeetingofthePlanningCommitteeheldon21May2015

7


7.1
The
Chairman
of
the
Planning
Committee
introduced
the
report
which
summarised
the

meeting
of
the
Planning
Committee
held
on
21
May
2015.




7.2 DECISION:


Thatthereportbenoted.




OPDCStaffEstablishmentandRemuneration

8


8.1
The
Chief
Executive
Officer
introduced
the
paper
which
set
out
proposals
for
the
staffing

structure
of
the
Corporation.




8.2
The
Board
congratulated
Victoria
Hills
on
her
appointment
as
Chief
Executive
Officer.



8.3
A
key
part
of
the
staffing
strategy
was
for
the
OPDC
to
become
an
exemplar
organisation
for

encouraging
talent
into
the
regeneration
sector.

The
Corporation
would
utilise
the

experience
of
the
GLA
in
recruiting
the
best
people.







8.4
Consideration
would
be
given
to
the
terminology
used
for
departments
to
best
describe
their

functions.




8.5
Board
Members
who
wished
to
participate
in
the
interview
process
for
permanent
senior

positions
would
be
invited
to
sit
on
the
relevant
Interview
Panels.

















[Action:
Chief

Executive
Officer]



8.6 DECSIONS:



3


Page 3




Itwasagreedthat:
a)

theappointmentofVictoriaHillsasChiefExecutiveOfficeroftheOldOakand
ParkRoyalDevelopmentCorporationbenotedandtheBoardSecretarybe
authorisedtorevisetheStandingOrdersandtheSchemeofDelegationto
reflecttheappointmentasappropriate;

b)

theproposedindicativestaffingestablishmentforOPDCduring2015/16and
2016/17benoted;



c)

anAppointmentsandRemunerationCommitteeoftheBoardbeestablished;


d)


e)

f)

g)

h)




9
9.1



9.2

9.3



9.4




futuredecisionsonstaffstructure,appointmentsandremunerationbe
delegatedtotheAppointmentsandRemunerationCommittee,subjectto
Mayoralconsentswhererequired,andtheBoardSecretarybeauthorisedto
amendtheSchemeofDelegationtoreflectthisdelegation;
theTermsofReferenceoftheAppointmentsandRemunerationCommitteebe
agreed;
EricSorensen(asChairman)togetherwithDebraHumphrisandCouncillor
MuhammedButtbeappointedasthemembersoftheAppointmentsand
RemunerationCommittee;
thattheChiefExecutiveOfficerbeauthorisedproceedwithurgentinterimand
permanentappointments;and
theGLAsTermsandConditionsofEmploymentandtheGLAPayscalesfor
OPDCstaffbeadopted,subjecttoMayoralconsent.

NHSHealthyTownsAnnouncement



The
Chief
Executive
Officer
introduced
the
paper
which
provided
an
overview
of
the
initiative

being
developed
by
NHS
England
(NHSE).


The
School
of
Public
Health
at
Imperial
College
was
involved
in
work
on
healthy
aging
in
its

Lifelong
Health
Project
and
expressed
in
interest
in
getting
involved
in
the
programme

alongside
the
Corporation.

Hammersmith
and
Fulham
Council
was
also
interested
in
further

involvement.



It
was
acknowledged
that
the
use
of
term
New
Town,
used
by
NHS
England,
had
both

implications
legally
and
in
terms
of
peoples
perception
and
this
was
not
appropriate
to

describe
the
development
area.



DECSIONS:
Itwasagreedthat:
a)

the work being developed with NHS England around the Healthy Towns
Initiativebenoted;


4

Page 4


b)

c)

theopportunityforOldOaktobeanexemplarHealthyNewTownwithNHSE
wouldbeexplored;and
updatesonNHSEnglandHealthyNewTownsProgrammewillbebroughtto
theBoardatsuitableopportunities

10

OPDCBudgetUpdate



10.1
The
Chief
Finance
Officer
introduced
the
paper
which
set
out
the
change
to
the
OPDC

budget
which
now
included
330,000
carried
forward
to
2015-16.




10.2 DECSION:


ThattheOPDCnewbudgetpositionthatincludesthecarryforwardofOPDC
budgetfrom2014-15to2015-16benoted.




Dateofnextmeeting
11



ThenextmeetingoftheBoardoftheCorporationwasduetobeheldonTuesday


28July2015at2.00pm

CloseofMeeting
12




12.1
The
meeting
ended
at
3.35pm.













Chairman




Date



ContactOfficer:
James
Varley

5


Page 5

This page is intentionally left blank

Page 6

Agenda Item 5

Subject:

Actions
List

Meeting
date:

28
July
2015

Report
to:

Board

Report
of:

Board
Secretary



For
noting


________________________________________________________________________



This
report
will
be
considered
in
public

________________________________________________________________________



1

Summary

1.1 This
paper
informs
the
Board
of
the
progress
against
actions
agreed
at
previous

meetings.



2

Recommendations

The
Board
is
invited
to:

2.1 Note
the
actions
list
attached
as
Appendix
A.

3

Appendices

Appendix
A

Actions
List.

Background
Papers


Minutes
of
the
previous
meetings
of
the
Board






Report
originator:

James
Varley,
Board
Secretary

Telephone:


0207
983
4613

Email:



jamesvarley@opdc.london.gov.uk

Page 7

This page is intentionally left blank

Page 8

Appendix
A

Board
Actions
List
(reported
to
the
meeting
on
28
July
2015)



Outstanding
Actions
from
the
last
meeting

Page 9

Minute
No.
Item/Description

Action
By

Target
Date

Status/note

8.5

Chief
Executive
Officer

Members
will
be

invited
to

participate
in

Interview
Panels.

OPDC
Staff
Establishment
and
Appointments



Board
Members
who
wished
to
participate
in
the
interview
process
for
senior

positions
would
be
invited
to
sit
on
the
relevant
Interview
Panels.

This page is intentionally left blank

Page 10

Agenda Item 6

Subject:

Chief
Executive
Officers
report
to
the
OPDC
Board

Meeting
date:

28
July
2015

Report
to:

Board

Report
of:

Chief
Executive
Officer



For
noting

________________________________________________________________________



This
report
will
be
considered
in
public

________________________________________________________________________



1
1.1
2

Summary

This
report
provides
progress
updates
on
the
activities
of
the
Old
Oak
and
Park
Royal

Development
Corporation
(OPDC)
since
the
last
Board
meeting.


Recommendations

The
Board
is
invited
to:

2.1
3

Note
this
report.

Chief
Executives
Overview

3.1

It
has
been
a
busy
few
weeks
since
the
last
Board
meeting,
with
negotiations
on
HS2

Bill
petitioning
and
the
Old
Oak
and
Park
Royal
Growth
Strategy
continuing,

recruitment
of
interim
posts
well
underway
and
key
evidence
studies
for
the
Local
Plan

being
commissioned.

This
report
sets
out
highlights
of
key
areas
of
work
and
priorities

for
the
coming
month.

3.2

As
requested
at
the
last
Board
meeting,
attached
at
Appendix
A
is
a
current
list
of

studies,
activities
and
projects
currently
being
commissioned
or
undertaken
by
officers

at
the
OPDC,
or
to
which
our
officers
are
contributing
in
collaboration
with
our

partners.
Where
consultants
have
been
appointed,
the
Corporation
has
followed
the

procurement
process
set
out
in
the
OPDC
Contracts
and
Funding
Code
as
agreed
by

the
Board
at
the
meeting
of
1
April,
making
use
of
the
GLA
procurement
framework
as

administered
by
TfL
under
our
shared
service
agreement
with
TfL
for
procurement

services.


Operations

3.3

Following
the
agreement
by
the
Board
that
the
Chief
Executive
Officer
proceed
with

urgent
appointments,
interim
appointments
are
progressing
and
recruitment
of
the

Director
of
Planning,
and
Heads
of
Planning
Policy
and
Development
Management
has

commenced
with
posts
advertised

on
the
GLA,
OPDC,
planningjobs
and
Guardian

Page 11

recruitment
websites.

Interviews
for
the
Director
of
Planning
will
take
place
on
31

July,
with
interviews
for
the
other
roles
to
follow
in
mid
to
late
August.



3.4

The
OPDC
team
has
moved
into
office
space
leased
by
the
GLA
at
Union
Street,

London
Bridge,
within
the
London
Fire
Brigades
headquarters
to
accommodate
the

growing
team.
The
OPDC
will
be
joined
by
the
GLAs
regeneration
team,
and
will

benefit
from
increased
access
to
meeting
rooms
as
well
as
desk
space.


Planning

3.5

The
OPDC
Planning
Committee
met
on
15
July.

The
Chairman
of
the
Planning

Committees
report
on
that
meeting
is
on
the
agenda
for
this
Board
meeting.


Smart
Utilities
Panel

3.6

As
noted
previously
the
OPDC
has
prioritised
early
engagement
with
utility
companies,

contractors
and
their
suppliers
to
discuss
a
smart
utilities
strategy
for
Old
Oak
that
will

seek
to
create
a
new
level
of
best
practice
in
delivering
utility
infrastructure
in
London.


The
inaugural
meeting
of
the
OPDC
Utilities
Panel
was
held
on
9
July
and
was
chaired

by
Matthew
Pencharz,
OPDC
Board
Member
and
Deputy
Mayor
for
Environment.

Growth
Strategy

3.7

Further
to
the
update
provided
at
the
last
Board
meeting,
OPDC
officers
have

continued
to
work
closely
with
DCLG
and
DfT,
to
provide
clarification
and
detail
on
the

proposed
Growth
Strategy
for
Old
Oak.
DCLG
are
now
leading
on
the
discussions
with

OPDC,
and
the
proposals
will
be
considered
as
part
of
the
Comprehensive
Spending

Review
Process.


HS2
Bill
Petition
items

3.8

GLA,
TfL
and
OPDC
officers
have
been
working
closely
and
in
collaboration
with
the

London
Boroughs
of
Ealing
and
Hammersmith
and
Fulham
to
progress
discussions
with

HS2
on
their
shared
petition
items.
Discussions
have
been
ongoing
over
the
last
12

months.

3.9

Richard
de
Cani,
Managing
Director
Planning
at
Transport
for
London
and
Observer
to

the
OPDC
Board
was
scheduled
to
appear
at
Select
Committee
on
1
July
to
discuss
the

petition
items
raised
by
the
GLA
to
the
HS2
Bill
relating
to
Old
Oak
Common.


However,
through
collaborative
working,
officers
were
able
to
agree
a
set
of
assurances

with
HS2
to
address
Old
Oak-related
petition
items.

Having
reached
agreement
on

those
items,
there
was
no
requirement
for
GLA
or
TfL
to
appear
at
Select
Committee
as

no
outstanding
HS2
petition
items
remained
in
relation
to
Old
Oak.

3.10

It
should
be
noted
that
future/additional
provisions
to
the
HS2
bill,
which
were

published
on
13
July,
will
require
scrutiny
and
may
require
future
petitions
from
OPDC,

GLA
and
TfL.



Engagement
and
events

3.11

The
OPDC
was
represented
at
the
following
events
since
the
last
meeting
of
the
Board:

1
July

ULI
event
on
health

1
/
2
July
-
HS2
Select
Committee


6
July
-
RTPI
Awards
for
Planning
Excellence:
The
Park
Royal
Atlas
was
a
finalist

for
the
Excellence
in
Planning
to
Create
Economically
Successful
Places
Award


Page 12

7
July
-
London
Infrastructure
Delivery
Board:
CEO
update
presentation

8
July
-
UK
Rail
Station
Regeneration
and
Development
conference:
CEO

presentation

9
July
-
Old
Oak
and
Park
Royal
smart
utilities
panel
meeting
(OPDC
hosted)

3.12

3.13

The
OPDC
will
be
represented
at
the
following
events
in
advance
of
the
15
September

Board
meeting:

29
July

SMART
Old
Oak
and
Park
Royal
Event
(hosting)

12
August

DfT
Officials
site
visit
to
Old
Oak
and
Park
Royal
(OPDC
hosting)



The
OPDC
will
continue
to
make
the
most
of
appropriate
engagement
opportunities
to

highlight
the
work
programme
and
opportunities
that
lay
ahead
for
Old
Oak
and
Park

Royal.


Priorities
for
the
coming
months

4.1

Over
the
next
few
months
the
OPDC
will
focus
on
recruitment
and
organisational

development
to
build
a
strong
team
to
deliver
on
the
objectives
set
out
in
the
Business

Plan.

Key
activities
for
the
organisation
will
include
the
progression
of
discussions
with

Government
departments
on
the
Growth
Strategy
and
HS2,
supporting
the
GLA
and

TfL
on
publication
of
the
OAPF
for
Old
Oak
and
Park
Royal,
and
development
of
the

draft
Local
Plan
in
preparation
for
early
rounds
of
public
consultation.

4.2

OPDC
officers
will
continue
to
hold
pre-application
discussions
with
interested

landowners
and
developers
as
requested,
and
will
facilitate
where
possible
discussion

amongst
Public
Sector
Landowners,
other
public
and
private
stakeholders
in
a
variety

of
fora.

Strategies
will
be
developed
on
socio-economic
regeneration,
land
and

communications
amongst
other
areas
over
the
months
ahead.

5
5.1
6
6.1
7

Financial
Implications

There
are
no
financial
implications
arising
from
this
report.


Legal
Implications

There
are
no
legal
implications
arising
from
this
report.

Appendices

Appendix
A

Schedule
of
Studies
and
Projects
undertaken
by
OPDC

Background
Papers

None





Report
originator:

Alexandra
Reitman,
Programme
Manager,
OPDC

Telephone:


0207
983
4804


Email:



alexandra.reitman@opdc.london.gov.uk

Page 13

This page is intentionally left blank

Page 14

OPDC-ListofStudiesandCommissionedWork
July2015



Activity
title

1

2

Page 15

3

4

5
6

7

Description/purpose

Areviewofdemandandsupply
EmploymentLand
ofemploymentlandwithin
Review
OPDCarea
Assessmentoftrendsacross
Londonsemploymentsectors
FutureEmployment
andrecommendationsofwhich
GrowthSectorsStudy
sectorsmaywishtomoveto
OPDCarea
SubmissiontoDCLG/DfTto
HS2/OPDCGrowth
seekGovernmentsupportof
Strategy
regenerationatOldOak
Areviewofexistingwater
capacityandrecommendations
IntegratedWater
forhowtoincreasecapacity
anddesignthisareatomake
ManagementStudy
mostefficientuseofwater
resources
Fulfilsthestatutoryobligation
LocalPlanSustainability
toundertakeaSustainability
Appraisal
AppraisalfortheLocalPlan
Developastrategytoprovide
OldOakEnergyStrategy energyrequirementsina
sustainablemanner
Astrategytointegratethe
SMARTcitiesconceptacrossall
OPDCSMARTstrategy
planning,designanddelivery
work

Workstream

Consultant

Status

LocalPlan
evidencebase

PeterBrettAssociates

LocalPlan
evidencebase

Tenderhasnotstartedbut
consultantteamwillbe
Scoping
required

Reportbeingfinalised

Target

Completion

date

Q215/16

Q415/16

Funding&
Financing

Deloitte

Firststagereport
issued;discussionson
detailongoing

LocalPlan
evidencebase

AECOM

Consultantteam
Q315/16
appointedinJuly2015

Local
Development
Scheme

HyderConsulting

Consultantteam
appointinJune2015

OAPFsupporting
work

OPDC/GLAofficer-led,
withsupportfromARUP

Reportbeingfinalised. Q215/16

LocalPlan
Evidencebase

OPDC/GLAofficer-led,
withsupportfrom
HypercatCity

Scoping

ongoing

Q116/17

Q315/16

Page 16

AppointmentofaPLACEreview
paneltoassessemerging
PlaceReviewPanel-
planninganddesignproposals
8
administration
withinOPDCareatoensure
proposalsachievethehighest
standards
Astudytoassessthecurrent
transportnetworkinParkRoyal.
Toidentifyinterventionsto
ParkRoyalTransport
addresscurrenttransportissues
9
Study
andproposeinterventions
(physicalandpolicy)tomitigate
futurechallenges

Aretailandleisureimpact
RetailandLeisureneeds assessmenttoassessthelevel
10
ofretailandleisurefloorspace
study
thatwouldbeappropriate
ToensureLocalPlan
appropriatelyconsidersLBHFs
wasteapportionmenttarget,
(BrentandEalings
11 WasteStudy
apportionmentrequirementsare
dealtwiththroughtheWest
LondonWastePlan,asadopted
byOPDC}.
Toassesscurrentairquality
standardsandtopropose
12 AirQualityStudy
interventions(physicaland
policy)toaddresscurrentissues
andmitigatefuturechallenges

HousingMarket
Assessmentofhousingneed
13 Assessment
basedonevidencepanLondon,

Development
Management

Tenderprocessis
On-going
underwaywithconsultants
Tenderbidssubmitted PLACE
duetobeappointedin
reviewpanel
August2015

LocalPlan
Evidencebase

Tenderprocessis
underwaywithconsultants Tenderbidssubmitted.
Q415/16

duetobeappointedin
August2015

LocalPlan
evidencebase

PeterBrettAssociates

Draftingworkis
underway

Q315/16

LocalPlan
evidencebase

OPDC/GLAofficer-led

Draftingworkis
underway

Q116/17

LocalPlan
evidencebase

Tenderprocessis
underwaywithconsultants
Scoping
duetobeappointedin
October2015

Q415/16

LocalPlan
evidencebase

OPDCofficerled,with
supportfromaconsultant

Q415/16


Scoping

Page 17

westLondonandacrossthe
team,stillbeappointed
localboroughs
Assessmentofexistingand
OPDCofficerled,with
GypsyandTraveller
LocalPlan
14
futureGypsyandTraveller
supportfromaconsultant
Assessment
evidencebase
needswithinOPDCarea
team,stillbeappointed
Aviabilityassessmentofthe
proposedlocalplanpoliciesto
Tenderhasnotstartedbut

LocalPlanviability
ensuretheproposedpolicies
LocalPlan
consultantteamwillbe
15 assessment(wholeplan) (includingaffordablehousing
evidencebase
required
policies)andmasterplanworkis
viableanddeliverable
Development
Identificationandcostingof
CILandLocalPlan PeterBrettAssociatesand
16 InfrastructureFunding
futureinfrastructure
evidencebase
JonesLangLeSalle
Study
requirements
Reviewofexistingutility
Tenderhasnotstartedbut
provision.Identificationof
CILandLocalPlan
17 Utilitiesstrategy
consultantteamwillbe
targets.Earlydesignand
evidencebase
required.
costingofutilityprovision.
Section106
GuidanceonhowOPDCwill
Tenderhasnotstartedbut
CILandLocalPlan
18 SupplementaryPlanning implementitsuseofsection
consultantteamwillbe
evidencebase
Document
106agreementsalongsideCIL
required.

OPDCisalsocontributingtothefollowingstudies,whicharebeingledbyotherorganisations:



Scoping

Q415/16

Scoping

Q415/16

Complete

Complete

Autilitypanelhas
beensetup

Q116/17

Scoping

Q116/17


Activity
title
1

HS2OverStation
Development(OSD)

Description/purpose

WorkingwithHS2toassessthe
potentialtodeliver
developmentabovethe
proposedHighSpeed2

Workstream

Planning

Lead
agency

HS2

Status

Scoping

Target

Completion

date

Q315/16

Afeasibilitystudytoidentify
optionsfortherenovation
and/orrebuildofNorthActon
station

Planning

TfL

Consultantteam
appointedinJuly
2015

Q415/16

3

HS2improvedeastern
andwesternlinks

WorkingwithHS2todesign
improvedeastandwestroutes
intotheproposedHS2station

Planning

HS2

Scoping

Q415/16

4

WillesdenJunction
stationimprovement
feasibilitystudy

Planning

TfL

Scoping

Q116/17

5

Publicrealmand
amenityspace
strategy/SPD

Planning

TfL/OPDC

Scoping

Q116/17

6

Constructionand
LogisticsStrategy

Planning

TfL/OPDC

Scoping

Q116/17

7

WormwoodScrubs
Strategy

Planning

OPDC

Notstarted

Notstarted

Page 18

2

NorthActonstation
improvementfeasibility
study

Afeasibilitystudytoidentify
optionsfortherenovation
and/orrebuildofWillesden
Junctionstation
Areviewoftheproposed
movementnetworkanddetailed
proposalsforthefunction,
design,layoutofnewstreets
andspacesacrosstheOPDC
area
Aplanforhowbesttomanage
thecomprehensiveconstruction
programmefortheareaand
howtomitigateadverseimpacts
onsurroundingareas
Developabaseline
understandingofwormwood
scrubsandidentifypotential
newaccesslocationfromOld
OakintotheScrubs.Consider
opportunitiesforsensitive
enhancements.

Agenda Item 7

Report
of
the
Meeting
of
the
Planning
Committee
held
on
15
July
2015

Subject:

Meeting
date:

28
July
2015

Report
to:

Board

Report
of:

William
McKee,
Chair
of
the
Planning
Committee




For
noting


________________________________________________________________________



This
report
will
be
considered
in
public

________________________________________________________________________



1
1.1
2

Summary

This
report
provides
a
summary
of
the
meeting
of
the
Old
Oak
and
Park
Royal

Development
Corporation
(OPDC)
Planning
Committee
held
on
15
July
2015.


Recommendation

The
Board
is
invited
to

2.1
3

Note
this
summary
of
the
meeting
of
the
OPDC
Planning
Committee
held
on
15
July

2015.

Meeting
of
the
Planning
Committee
on
18
July
2015

3.1

The
OPDC
Planning
Committee
met
at
6pm
on
18
July
2015,
in
Committee
Room
5
at

City
Hall,
The
Queens
Walk,
London
SE1
2AA.

3.2

The
Planning
Committee
meeting
agenda
and
papers
were
issued
to
Committee

members
and
made
available
on
the
GLA/OPDC
website
five
clear
working
days
in

advance
of
the
meeting.
The
meeting
was
open
to
and
attended
by
members
of
the

public.
Minutes
of
the
Planning
Committee
meeting
will
be
made
publicly
available.

3.3

All
Planning
Committee
members
attended
the
Planning
Committee,
there
were
no

apologies.
The
meeting
was
chaired
by
the
Board-appointed
Chair
of
the
Planning

Committee.

3.4

The
items
on
the
Planning
Committee
meeting
agenda
were
as
follows:

3.4.1

Minutes
of
previous
meeting
(for
approval).
The
minutes
from
the
Planning

Committee
meeting
will
be
taken
to
the
next
board
meeting
for
noting.

3.4.2

Draft
Statement
of
Community
Involvement
(for
recommendation
to
the

Board).
This
report
and
comments
from
the
Planning
Committee
will
be

considered
in
more
detail
under
item
8
on
the
Board
agenda.

Page 19

4
4.1
5
5.1
6

3.4.3

Greater
London
Authority
Old
Oak
&
Park
Royal
Opportunity
Area
Planning

Framework
consultation
responses
(for
comment
and
recommendation
to
the

Board).
This
report
and
comments
from
the
Planning
Committee
will
be

considered
in
more
detail
under
item
9
on
the
Board
agenda.

3.4.4

OPDC
Local
Development
Scheme
(for
recommendation
to
the
Board).
This

report
and
comments
from
the
Planning
Committee
will
be
considered
in
more

detail
under
item
10
on
the
Board
agenda.

3.4.5

Proposed
adoption
by
the
OPDC
of
the
West
London
Waste
Plan
(for

recommendation
to
the
Board).
This
report
and
comments
from
the
Planning

Committee
will
be
considered
in
more
detail
under
item
7
on
the
Board
agenda.

3.4.6

OPDC
Response
to
the
Royal
Borough
of
Kensington
and
Chelseas
Local
Flood

Risk
Management
Strategy
Consultation
(for
noting).

3.4.7

The
full
list
of
22
planning
applications
received
by
OPDC
between
5
May
and

29
June
2015
(for
noting).

Financial
Implications

There
are
no
financial
implications
arising
from
this
report.


Legal
Implications

There
are
no
legal
implications
arising
from
this
report
and
it
is
consistent
with
the

Corporations
legal
framework.


Appendices


None

Background
Papers

OPDC
Planning
Committee
papers
from
15
July
2015

Report
originator:

Michael
Mulhern,
Head
of
Planning

Telephone:


020
7983
6535


Email:



Michael.mulhern@opdc.london.gov.uk

Page 20

Agenda Item 8

Subject:

Old
Oak
and
Park
Royal
Development
Corporation

Proposed

Adoption
of
the
West
London
Waste
Plan


Meeting
date:

28
July
2015

Report
to:

Board

Report
of:

Chief
Executive
Officer



For
decision


________________________________________________________________________



This
report
will
be
considered
in
public

________________________________________________________________________



1

Summary

1.1

The
West
London
Waste
Plan
(WLWP)
has
been
prepared
by
six
London
Boroughs

(Brent,
Ealing,
Harrow,
Hillingdon,
Hounslow
and
Richmond
upon
Thames)
to
address

how
those
Authorities
can
sustainably
manage
their
waste
in
the
period
up
to
2031.
It

is
now
in
the
process
of
being
adopted
by
the
Boroughs
as
a
Development
Plan

Document
following
an
Examination
in
Public.

1.2

This
report
provides
the
background
to
the
WLWP
and
an
explanation
of
its
relevance

to
the
Old
Oak
and
Park
Royal
Development
Corporation
(OPDC)
which
is
now
the

Planning
Authority
for
part
of
the
plan
area.
It
also
sets
out
the
reasons
why
OPDC

Board
is
recommended
to
adopt
the
WLWP
as
a
Development
Plan
Document.

Recommendations

The
Board
is
invited
to:

2.1

Note
the
recommendation
from
OPDC
Planning
Committee
on
the
15
July
2015

regarding
the
proposed
adoption
of
the
WLWP;
and

2.2

Adopt
the
WLWP
as
a
Development
Plan
Document.

3
3.1

Background

The
WLWP
sets
out
the
planning
strategy
to
2031
for
the
sustainable
waste

management
of
six
west
London
Boroughs.
It
contributes
to
the
delivery
of
national

and
regional
targets
for
waste
recycling,
composting
and
recovery
including
the
waste

apportionment
targets
that
are
set
for
each
London
Borough
in
the
Further
Alterations

to
the
London
Plan
2015
(London
Plan
FALP).
The
WLWP
identifies
and
safeguards

appropriate
waste
management
sites
and
demonstrates
that
there
is
sufficient
capacity

to
manage
the
waste
generated
across
the
six
Boroughs
for
the
plan
period.

Page 21

3.2

The
Plan
forms
part
of
the
group
of
Local
Plan
documents
that
Planning
Authorities

must
prepare.
Following
adoption,
the
determination
of
planning
applications
relating

to
waste
processing
facilities
in
the
Old
Oak
and
Park
Royal
Opportunity
Areas
will
be

considered
in
the
light
of
the
WLWP
in
addition
to
the
relevant
Boroughs
Local
Plan,

the
Draft
OAPF
and
any
other
material
considerations.

Relevance
to
OPDC

Following
the
establishment
of
the
OPDC
on
1st
April
2015,
Ealing
and
Brent
are
no

longer
the
local
planning
authority
for
part
of
the
waste
plan
area
addressed
by
the

WLWP.
As
a
joint
Development
Plan
Document
the
plan
is
only
formally
adopted
when

all
seven
authorities
(including
OPDC)
have
formalised
the
adoption
of
this
plan

through
their
respective
decision
making
body.
It
has
therefore
recommended
that

OPDC
should
adopt
the
document
once
the
six
original
boroughs
have
each
resolved

to
adopt.

3.3

Preparation
of
the
West
London
Waste
Plan

3.4

The
drafting
process
has
taken
into
account
relevant
planning
legislation,
national

planning
policy,
regional
policy
including
the
London
Plan
(FALP),
on-going
advice

from
the
Greater
London
Authority
(GLA)
and
the
Planning
Inspectorate,
and
also

lessons
learnt
from
professional
planning
bodies
and
agencies.

3.5

A
number
of
public
consultation
exercises
have
been
undertaken
by
the
Boroughs
at

various
stages
of
the
Plans
production
comprising:

Issues
and
Options
(February
2009)


Proposed
Sites
and
Policies
(February
2011)


Draft
Pre-Submission
Version
of
the
WLWP
(February
2014)

Proposed
Main
Modifications
(November
2014)

The
draft
pre-submission
version
was
submitted
with
details
of
the
representations
received

during
the
consultation
process
to
the
Secretary
of
State
for
Communities
and
Local

Government
who
appointed
an
Inspector
to
examine
the
plan
for
its
soundness
and

legality.

The
proposed
main
modifications
resulted
from
the
subsequent
Examination

in
Public
which
included
public
hearing
sessions
during
which
respondents
to
the

public
consultation
process
were
invited
to
speak.
This
process
also
enabled
the
Plan
to

be
considered
against
the
National
Policy
for
Waste
that
was
published
by

Government
on
the
16th
October
2014.
A
six
week
consultation
on
the
proposed
main

modifications
also
provided
an
opportunity
for
the
Boroughs
to
makes
a
joint

submission
to
the
Inspector
to
ensure
that
the
WLWP
was
in
general
conformity
with

the
Further
Alterations
to
the
London
Plan
which
was
published
on
10th
March
2015.

3.6

Subject
to
the
main
modifications
being
made
(the
majority
of
which
were
discussed

during
the
Examination
in
Public),
the
Inspector
concluded
in
his
final
report
of
March

2015
that
the
Plan
was
legally
compliant
and
sound.

3.7

The
Boroughs
have
all
published
the
Inspectors
Report
in
accordance
with
Regulation

25
of
the
Town
and
Country
Planning
(Local
Planning)
(England)
Regulations
2012.

This
means
that
the
Report
is
available
to
view
via
the
dedicated
West
London
Waste

Plan
website
and
in
hard
copy
at
the
Boroughs
offices.

Page 22

3.8

The
Boroughs
are
in
the
process
of
recommending
the
adoption
of
the
WLWP
at
their

respective
Full
Council
meetings
which
will
take
place
between
May
and
July
2015.
It
is

expected
that
all
six
Boroughs
will
be
in
a
position
to
formally
adopt
the
WLWP
by
the

time
that
a
paper
is
presented
to
the
OPDC
Board.

3.9

Amendments
have
been
made
to
the
WLWP
which
reference
that
the
WLWP
is
a
joint

waste
plan
for
the
6
local
authorities
and
OPDC.
Other
amendments
have
been
made

to
the
WLWP
to
make
reference
to
OPDC,
where
relevant.

3.10

It
should
be
noted
there
will
be
a
six-week
period
following
adoption
by
the
six

Boroughs
and
the
OPDC
during
which
any
final
objection
on
legal
grounds
can
be

made
to
the
High
Court
(as
required
by
section
113
of
the
Planning
&
Compulsory

Purchase
Act,
2004).


Sustainability
Appraisal
and
Habitats
Assessment

3.11

Section
19
of
the
Planning
and
Compulsory
Purchase
Act
(2004)
and
the

Environmental
Assessment
of
Plans
and
Programmes
Regulations
(2004)
require
local

planning
authorities
to
carry
out
a
sustainability
appraisal
of
Local
Plan
documents
and

to
prepare
a
report
of
the
findings
of
the
appraisal.
The
Regulations
prescribe
the

requirements
for
Environmental
Assessment
pursuant
to
relevant
European
Union

directives.
However
as
a
matter
of
national
policy,
the
UK
Government
requires
a

sustainability
appraisal
to
also
assess
economic
and
social
effects,
as
well
as
those
in

relation
to
the
environment.

3.12

At
all
stages
of
preparation
of
the
WLWP
the
partner
boroughs
have
undertaken
a

sustainability
appraisal
of
the
document,
in
accordance
with
requirements
and

proportionate
to
the
level
of
detail
contained
within
the
documents
at
the
stage

reached.
This
includes
the
public
consultations
on
modifications
made
throughout
the

Public
Examination
process,
as
described
above.
The
Sustainability
Appraisal
Report

has
been
made
available
alongside
the
WLWP
at
each
stage
of
public
consultation

including
on
the
Main
Modifications.
The
final
Sustainability
Appraisal
Report
will
be

permanently
available
for
inspection
alongside
the
WLWP.

3.13

The
Conservation
of
Habitats
and
Species
Regulations
2010
(the
Habitats
Regulations)

requires
local
planning
authorities
to
make
an
appropriate
assessment
of
the

implications
for
designated
European
sites
of
a
plan
that
they
intend
to
bring
into

effect.
The
Habitats
Regulations
prescribe
the
requirements
for
Habitats
Assessment

pursuant
to
relevant
European
Union
directives.

3.14

The
partner
boroughs
undertook
an
assessment
in
accordance
with
the
Habitats

Regulations,
and
in
consultation
with
Natural
England,
of
the
impact
of
the
WLWP
on

all
European
sites
within
10
kilometres
of
the
Plan
area.
The
assessment
was
first

carried
out
in
December
2010
and
an
update
was
completed
in
2014.
As
with
the

Sustainability
Appraisal,
the
Habitats
Assessment
has
also
been
made
available

alongside
the
WLWP
for
public
consultation.

Page 23

Implications
of
the
WLWP
for
OPDC

4.1

The
WLWP
designates
two
sites
within
the
OPDC
boundary
that
must
be
safeguarded

as
waste
processing
sites.
These
are
the
Twyford
Waste
Transfer
Station
and
Quattro,

Victoria
Road.
A
location
map
is
attached
in
Appendix
A.

4.2

The
Twyford
Waste
Transfer
Station
is
located
in
Park
Royal
where
the
OAPF
supports

the
retention
of
employment
generating
uses
in
accordance
with
a
Strategic
Industrial

Location
designation
under
policy
2.17
of
the
London
Plan
FALP.
The
retention
of

this
site
as
a
waste
processing
facility
therefore
accords
with
the
aims
and
objectives
of

the
OAPF
which
also
states
that:
The
Mayor
will
support
the
local
authorities
in

protecting
and
safeguarding
waste
sites
that
are
identified
in
the
WLWP
(paragraph

9.5).

4.3

Although
development
proposals
for
the
Shield
site
will
need
to
be
carefully
considered

to
accommodate
the
Quattro
designation,
officers
do
not
consider
that
its
presence

will
undermine
growth
objectives
for
the
area.
This
is
because
the
site
is
safeguarded
in

association
with
HS2
for
the
period
2017-2026
so
will
not
come
forward
for
waste

management
purposes
until
at
least
2026.

Furthermore,
the
WLWP
makes
clear
that

the
apportionment
targets
can
be
met
without
the
Quattro
site
coming
forward.
The

designation
of
this
site
in
the
WLWP
provides
contingency
capacity
for
the
latter
part

of
the
plan
period
should
it
be
required.

4.4

There
a
number
of
large
waste
processing
facilities
in
the
Old
Oak
Common

Opportunity
Area
that
are
not
included
within
the
WLWP,
most
notably
European

Metal
Recycling,
Powerday,
Capital
Waste
Ltd,
UK
Tyre
Exporters
and
ODonovans

Waste
Disposal
Ltd.
These
sites
fall
within
the
London
borough
of
Hammersmith
and

Fulham
and
so
do
not
form
part
of
the
West
London
Waste
Planning
Authority
area.

Waste
planning
for
these
sites
will
need
to
be
addressed
through
a
future
OPDC
Local

Plan
for
the
area.

4.5

It
should
be
noted
that
the
London
Borough
of
Hammersmith
&
Fulham
are
producing

a
separate
waste
management
plan
in
conjunction
with
other
neighbouring
Boroughs

which
will
impact
on
the
remaining
area
within
the
OPDC
boundary
that
is
not
covered

by
the
WLWP.
There
a
number
of
large
waste
processing
facilities
in
the
Old
Oak

Common
Opportunity
Area
that
are
not
within
the
WLWP,
most
notably
European

Metal
Recycling,
Powerday,
Capital
Waste
Ltd,
UK
Tyre
Exporters
and
ODonovans

Waste
Disposal
Ltd.
The
OAPF
encourages
consideration
of
how:
existing
waste
sites

can
be
incorporated
into
solutions
for
the
treatment
and
transfer
of
waste
in
the
area.

Notwithstanding
this,
the
document
also
notes
that
one
or
more
waste
sites
will
need

to
be
relocated
to
accommodate
new
development
in
the
Old
Oak
area.
Any
proposals

for
the
relocation
of
these
sites
will
need
to
be
in
compliance
with
the
London
Plan

FALP
and
the
separate
waste
management
plan.
OPDC
Board
will
be
advised
of
the

progress
of
the
plan
and
the
implications
for
OPDC
when
further
information
is

available.

5
5.1

Comments
from
the
OPDC
Planning
Committee

The
OPDC
Planning
Committee
considered
the
WLWP
and
the
implications
for
the

OPDC
and
recommended
that
the
OPDC
Board
adopt
the
WLWP
as
a
Development

Plan
Document.

Page 24

Financial
implications

6.1

There
are
no
direct
financial
implications
for
the
OPDC
arising
from
this
report.

Legal
implications

7.1

8

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

legal
framework.

Appendices

Appendix
A

Location
map
showing
designated
sites
in
the
WLWP
(Twyford
Waste

Transfer
Station
and
Quattro,
Victoria
Road)



Appendix
B

The
West
London
Waste
Plan

Background
Papers

None





Report
originator:

Michael
Drake,
Senior
Planner,
OPDC

Telephone:


020
7983
5783

michael.drake@opdc.london.gov.uk


Email:



























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Appendix A

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Appendix B

Version for Adoption

March 2015

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West London Waste Plan

A Joint Waste Plan for the London Boroughs of Brent,
Ealing, Harrow, Hillingdon, Hounslow, Richmond upon
Thames and Old Oak and Park Royal Development
Corporation

Version for Adoption

March 2015
This is a version of the Plan to be considered for adoption.

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West London Waste Plan

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Executive Summary
1.

For some time, both the European and UK Governments have been concerned
that we are sending too much of our waste for disposal not enough is being
recycled and re-used.

2.

Consequently, every local authority must produce a plan detailing how it will deal
with waste generated in its area over the next 15 years. These plans make up a
part of the authoritys Local Plan and show which factors they will take into
account when deciding on whether to grant planning permissions for new waste
management facilities or extensions and substantive changes to existing ones.

3.

In West London, six London Boroughs agreed to co-operate to produce a single

waste plan for their combined area. When adopted, this plan will form part of
each of their respective Local Plans. It will also form part of the development
plan for the Old Oak and Park Royal Development Corporation (OPDC).

4.

Preparation of the West London Waste Plan involved a number of stages and
these have included evidence gathering, technical assessment and public
consultation. This version of the Plan includes modifications made to the
Proposed Submission Plan that underwent independent examination between
July 2014 and March 2015 and was found sound by an independent planning
Inspector in March 2015.

5.

In London, the Mayor set out in the London Plan (adopted in 2011) projections of
how much municipal waste and commercial and industrial waste is likely to be
generated in the capital over the next 20 years. Each borough was allocated an
amount of Londons waste that it is required to positively plan for and manage.
This includes ensuring that sufficient capacity is identified to meet the
apportioned targets in the London Plan (2011). By each borough meeting its
apportionment, London will dramatically reduce its reliance on landfill and move
towards being net self-sufficient1 overall.
P

6.

The West London Waste Plan:

details the estimated amounts for the different types of waste that will be
produced in West London up to 2031;

identifies and protects the current sites to help deal with that waste;

Net self- sufficient means that the equivalent of 100 per cent of Londons waste will be managed within London.

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West London Waste Plan

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identifies the shortfall of capacity needed over the life of the Plan (to
2031); and

proposes a set of sites to meet the shortfall which are preferred for waste
related development.

7.

This Plan has been prepared with the objective of ensuring consistency with
national Government policy and general conformity with the London Plan (2011).

8.

All policies of this Plan will be taken into account when decisions are made on
planning applications for waste development along with any relevant policies in the
development plan.

9.

The Plan comprises seven sections, covering:

10.

i.

An introduction to the West London Waste Plan;

ii.

The Vision and Objectives of the Plan;

iii.

How waste is managed at present;

iv.

An explanation of what will be needed in the future to manage waste;

v.

Details of the sites identified for future waste facilities;

vi.

Policies to guide the determination of planning applications for new waste

facilities; and

vii.

An explanation of how the Plan will be monitored in future.

The existing sites and additional sites proposed for inclusion in the Plan are set out
in the tables below:
Table i: Existing waste sites proposed for allocation
Site
Number

Name

Site Area (ha)

Borough

Brent
352

Twyford Waste Transfer Station

1.24
(OPDC)**

1261

Veolia Transfer Station, Marsh Road

309*

Greenford Reuse & Recycling Site

310*

Greenford Depot, Greenford Road

328#

Quattro, Victoria Road, Park Royal

Page 32

2.71

Brent

1.78

Ealing

0.7

Ealing

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West London Waste Plan

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Site
Number

Name

Site Area (ha)

Borough

(OPDC)**
222

Council Depot, Forward Drive

2.31

Harrow

331

Rigby Lane Waste Transfer Station

0.91

Hillingdon

342

Twickenham Depot

2.67

Richmond

Total

12.32

*These two sites are contiguous and part of a larger site: for the purposes of the Plan, they are
considered as a single, consolidated site
**Falls within the Old Oak and Park Royal Development Corporation area
# This site is subject to a High Speed 2 (HS2) Safeguarding Direction and will not be available
from 2017 until 2024

Table ii: Additional sites allocated in the Plan for waste management uses
S

Site
Number

Name

Site Area
(ha)

Borough

2861

Western International Market

3.20

Hounslow

Total

3.20

Combined Total Area = 15.52 hectares

Page 33

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Contents
Executive Summary ...................................................................................................... i
Contents ...................................................................................................................... iv
Figures & Tables ......................................................................................................... vi
Maps of Allocated Sites............................................................................................. vii
1
The West London Waste Plan ............................................................................ 1
1.1 Preparation of the Plan ......................................................................................... 1
1.2 Why Is The West London Waste Plan Needed?.................................................... 2
1.3 Relationship with Other Planning Strategies and the Plans Status ....................... 3
1.4 Sustainability Appraisal and Other Assessments .................................................. 8
1.5 Community and Stakeholder Consultation ............................................................ 8
1.6 Proposed Submission WLWP ............................................................................... 9
1.7 Planning applications for waste management facilities ........................................ 10
1.8 West London Waste Authority ............................................................................. 11
2
Vision and Objectives of the Plan .................................................................... 12
2.1 Vision
12
2.2 Strategic Objectives ............................................................................................ 12
3
Existing Waste Management ............................................................................ 13
3.1 Existing Waste Management............................................................................... 13
3.2 Municipal Solid Waste ......................................................................................... 13
3.3 Commercial and Industrial Waste ....................................................................... 16
3.4 Construction, Demolition and Excavation Waste ................................................. 16
3.5 Hazardous Wastes.............................................................................................. 17
3.6 Wastewater and Sewage sludge ......................................................................... 18
3.7 Agricultural Waste ............................................................................................... 19
3.8 Radioactive Waste .............................................................................................. 19
3.9 Cross boundary Movement of Waste .................................................................. 19
3.10 Role of Landfill in the Management of Residual Waste ....................................... 21
4
Future Waste Management ............................................................................... 23
4.1 How much waste will need to be managed in West London? .............................. 23
4.2 How much capacity is needed?........................................................................... 25
4.3 What kind of facilities will be needed? ................................................................. 29
4.4 Construction, Demolition and Excavation Wastes ............................................... 30
4.5 Hazardous Wastes.............................................................................................. 30
5
The Sites ............................................................................................................ 31
6
West London Waste Plan Policies ................................................................... 39
6.1 Policy WLWP 1 - Provisions of New Waste Management CapcacityKKKKKK40
6.2 Policy WLWP 2 Safeguarding and Protection of Existing and Allocated Waste
Sites ....................................................................................... 41
6.3 Policy WLWP 3 Location of Waste Development ............................................. 42
6.4 Policy WLWP 4 Ensuring High Quality Development ....................................... 43
6.5 Policy WLWP 5 Decentralised Energy ............................................................. 47

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West London Waste Plan

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6.6
6.7

Policy WLWP 6 Sustainable Site Waste Management ..................................... 48

Policy WLWP 7 National Planning Policy Framework: Presumption in Favour
of Sustainable Development ................................................... 49
7
Monitoring of the West London Waste Plan.................................................... 50
8
Glossary ............................................................................................................ 56
9
Appendices........................................................................................................ 65
Appendix 1: Sustainability Objectives ..................................................................... 66
Appendix 2: Existing Waste Sites in West London ................................................. 68
Appendix 3: Supporting Assessments .................................................................... 72
Appendix 4: General Waste Treatment Facility descriptions ................................. 74
Appendix 5: Borough waste arisings and apportionments .................................... 75
Appendix 6: Descriptions of Allocated Sites6666666666666666...76
Appendix 7: Relationship between WLWP Plan policies and previously adopted
policies in Boroughs' DPDs .............................................................. 103

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Figures & Tables

48T

48T

Figure 1-1: The West London Waste Plan Area ............................................................ 1

48T

Figure 1-2: The West London Waste Plan Area context ............................................... 2
48T

Figure 1-3: The Waste HierarchyKKKKKKKKKKKKKKKKKKKKKKKK5

48T

Figure 3-1: West London Waste Authority MSW management route (2008
2012) ......15
48T

Figure 3-2: Destination of hazardous waste arisings from West London (2012)KK.....18
Figure 3-3: Exports of waste out of West London by management typeKKKK..K.K21
Figure 3-4: Where West London sent waste in 2012 by fate & WPAKKKKK.K.......22
Figure 4-1: Forecast Arisings and Capacity Apportionment for West London
Boroughs from the London Plan (2011)KKKKKKKKKK.KKKK....25
Figure 4-2: Projected Capacity Gap between London Plan (2011) Apportionment
and Existing CapacityKKKKKKKKKKKKKKKKKKKKKKK26
Figure 4-3: Interim Capacity Gap between Existing Capacity and Arisings as
forecast by the London Plan (2011)KKKKKKKKKKKKKKKK... 29
Figure 5-1: Location Plan showing all proposed sites (Policies Map)KK.KK............ 32

Table 1-1: Recycling/composting/reuse targets set in the London Plan (2011) ............... 2
Table 1-2: Timetable for the development of the West London Waste Plan .................... 3
Table 3-1: West London Waste Authority management of MSW (2011-2012)KKKK.15
Table 3-2: Management of CD&E waste in West LondonKKKKKKKKKKKKK17
Table 3-3: Principal Flows of Waste out of West London 2012KKKKKKKKK..K20
Table 3-4: Waste sent to Landfill from West London in 2012, by receiving site typeK..23
Table 4-1: Quantity of MSW and C&I waste forecast to be produced in West London
& the apportionment figures from the London Plan (2011) for target years ... 23
Table 4-2: West London Capacity Requirements for Target Years based on the
London Plan (2011) ..................................................................................... 27
Table 4-3 Contribution of allocated sites to meet the London Plan apportionmentKK..28
Table 5-1: Existing waste sites considered to have potential for redevelopment ........... 31
Table 5-2: Additional sites with opportunity for developing waste facilitiesKKKKK...39
Table 7-1: Monitoring programme for the West London Waste Plan ............................. 53

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Maps of Allocated Sites

Site 352 Twyford Waste Transfer Station, Abbey Road, BrentKKKKKKKK...K.35
Site 1261 Veolia Transfer Station, Marsh Road, Alperton, BrentKKKKKKKKK...35
Site 309 Greenford Reuse and Recycling Site & Site 310 Greenford Depot,
Greenford Road, Greenford, EalingKKKKKKKKKKKKKKKK..K.36
Site 328 Quattro, Victoria Road, Park Royal, EalingKKKKKKKK..KKKKK....36
Site 222 Council Depot, Forward Drive, HarrowKKKKKKKKKKKKKKK.....37
Site 331 Rigby Lane Waste Transfer Station, Hayes, HillingdonKKKKKKKK.... 37
Site 342 Twickenham Depot, Langhorn Drive, Twickenham, RichmondKKKKK....38
Site 2861 Western International Market, Hayes Road, Southall, HounslowKKK...K.39

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West London Waste Plan

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The West London Waste Plan

1.1
1.1.1

Preparation of the Plan

The West London Waste Plan has been prepared jointly by the six West London
Boroughs of Brent, Ealing, Harrow, Hillingdon, Hounslow and Richmond upon
Thames. The area covered by the plan, and how it is split into its constituent boroughs
is shown in Figure 1-1. This also shows the area covered by the Old Oak and Park
Royal Development Corporation (OPDC). How the West London Waste Plan area sits
within its wider regional context is illustrated at Figure 1-2.

Figure 1-1: The West London Waste Plan Area

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Figure 1-2: The West London Waste Plan Area context

1.2
1.2.1

Why Is The West London Waste Plan Needed?

The West London Waste Plan (the Plan) provides a planning framework for the
management of all waste produced in the six Boroughs over the period to 2031. The
Boroughs and OPDC are required by Government to prepare local planning policy for
waste management which needs to be in general conformity with the Mayors London
Plan. The London Plan is the Mayor of Londons planning strategy for the capital that
sets out targets for recycling and composting for waste from households, businesses
and industry (See Table 1-1 below). At the time of preparation of this Plan the London
Plan (2011) 2 was in force. The London Plan has been updated by the Further
Alterations to the London Plan (FALP) which were adopted by the Mayor in March
2015. This Plan reflects the targets and waste apportionments specified in the 2011
version. The Boroughs and OPDC have committed to reviewing this Plan in light of
FALP adoption.
P

See http://www.london.gov.uk/priorities/planning/london-plan

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West London Waste Plan

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Table 1-1: Recycling /composting/reuse targets set in the London Plan (2011)

Waste stream

2015

2020

2031

Municipal Solid Waste

45%

50%

60%

Commercial & Industrial Waste

>70%

Construction, Demolition & Excavation

>95%

Diversion of biodegradable/recyclable
wastes from landfill

100%

Source: London Plan (2011)

1.2.2

A significant amount of waste is transferred outside of London for treatment or disposal.

The London Plan (2011) aims to ensure that as much of Londons waste is managed
within London as practicable working towards managing the equivalent of 100% of
Londons waste within London by 2031.

1.2.3

The West London Waste Plan will form part of the Development Plan for each of the
Boroughs and the Old Oak and Park Royal Development Corporation (which covers part
of Brent and Ealing). This Plan supersedes certain policies in other Borough
Development Plan Documents as set out in Appendix 7. The Development Plan
comprises a number of development planning documents containing both specific
policies for waste and sites identified for waste management. These planning
documents must be in general conformity with the London Plan and pay regard to
national policies and advice. Before the Plan can be adopted the independent Inspector
has to find that it has been prepared in accordance with the Duty to Co-operate; that it
satisfies legal and procedural requirements; and that it is sound.

1.2.4

This Plan identifies the sites proposed for waste management development in the plan
area and provides policies with which planning applications for waste developments
must conform. This Plan reflects the London Plan (2011) apportionment targets
providing management of waste from households, business and industry in the Plan
area up to 2031. The timetable for the production of the Plan and for its final adoption is
shown in Table 1-2.
Table 1-2: Timetable for the development of the West London Waste Plan

Period

Stage of development

January - March 2009

Issues and Options Consultation

February - March 2011

Proposed Sites and Policies Consultation

March - April 2014

Proposed Submission Consultation

July 2014

Submission to the Secretary of State c/o Planning

Inspectorate

Autumn 2014

Public Examination

Summer 2015

Adoption by the West London Boroughs and OPDC

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1.3
1.3.1

1.3.2

Relationship with Other Planning Strategies and the Plans Status

The Plan is influenced by, and has to give consideration to, relevant European,
national, regional and local policy in relation to waste development (both adopted and
emerging). The Plan supports the implementation of the Boroughs Sustainable
Community Strategies in several ways which follow the three pillars of sustainable
development, which underpin the Sustainable Community Strategies, as follows:

Social: The Plan ensures that waste is managed in a way that protects
communities and their health;

Environmental: The Plan ensures that waste will be managed in a manner that
does not harm the environment

Economic: The Plan seeks to provide sufficient opportunities for the

management of waste that is an essential part of a high performing economy.

Once this Plan is adopted by each of the constituent boroughs and OPDC, it will take on
the status of a statutory Local Development Document, and form part of the
Development Plan. Determination of planning applications shall be made in
accordance with the Development Plan unless material considerations indicate
otherwise.
European Legislation




The revised Waste Framework Directive [2008/98/EC] 3 , which has been implemented
P

by the Waste (England and Wales) (Amended) Regulations 2012 4 , is the over-arching
European Union (EU) legislation for waste. The directive requires Member States to
take appropriate measures to encourage firstly, the prevention or reduction of waste
and its harmfulness and secondly, the recovery of value from waste by means of
recycling, re-use or reclamation or any other process with a view to extracting
secondary raw materials, or the use of waste as a source of energy. This management
scheme is called the waste hierarchy (see Figure 1-3), and the objective is to manage
waste as near to the top of the hierarchy as possible with safe disposal of waste as a
last resort. Article 28 of the Directive also requires Member States to prepare one or
more waste management plans that cover its entire geographical area. Insofar as
waste local plans are concerned, the key provisions relate to the waste hierarchy;
protection of human health and the environment; the principles of proximity and selfsufficiency; the establishment of waste management plans; and periodic inspections.
P

Waste Framework Directive (Directive 2008/98/EC): http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2008:312:0003:0030:en:PDF

See: http://www.legislation.gov.uk/uksi/2012/1889/made

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1.3.4

The West London Waste Plan provides for the management of waste according to the
waste hierarchy (Figure 1-3 below).

Figure 1-3: The Waste Hierarchy

National Policy
1.3.5

The planning system, as well as the waste management industry has undergone
significant changes over the past few years. The National Planning Policy Framework
(March 2012) sets out the national policy approach to ensuring sustainable
development but does not include policy concerned specifically with the management
of waste.
National Planning Policy for Waste

1.3.6

National Planning Policy for Waste 5 sets out national objectives and guidance to be
considered when producing planning policies for waste development and
consideration of applications for waste development and for development that have
waste management implications.
P

Waste Management Plan for England

1.3.7

To meet the requirement of the Waste Framework Directive for a national waste plan,
in December 2013, the Government published an updated waste strategy for England

National Planning Policy for Waste, October 2014 https://www.gov.uk/government/publications/nationalplanning-policy-for-waste

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in the form of a National Waste Management Plan (known as the Waste Management
Plan for England December 2013) along with a separate National Waste Prevention
Plan. Production of local waste plans is also intended to contribute towards meeting
this requirement.
1.3.8

Publication of the Waste Management Plan for England followed The Government
Review of Waste Management Policy in England 2011 6 which was published following
a comprehensive review of The Waste Strategy for England 2007. The Waste
Management Plan for England provides an overview of waste management in England
and fulfils Article 28 of the Waste Framework Directive mandatory requirements, and
other required content as set out in Schedule 1 to the Waste (England and Wales)
Regulations 2011.
P

Localism Act 2011 and the Duty to Co-operate

1.3.9

The Localism Act 2011 provides for the abolition of all Regional Spatial Strategies
(RSSs), except the London Plan (2011) which is retained in the capital. The RSSs
apportioned quantities of waste to be managed in each sub-regional area which
generally corresponded to a Waste Planning Authority (WPA) area. WPAs outside
London are no longer required to be in conformity with the now abolished RSSs or
meet waste management apportionments for London. In the South East and East of
England, this included provision for landfill of some residual waste from London.
This means that some counties that previously considered West Londons residual
waste management needs when planning landfill capacity may no longer be doing so.
Clearly this has a significant implication for the management of waste from London
boroughs where waste is exported to be managed outside the London area. The
London Plan (2011) expects London boroughs to plan for 100% net self-sufficiency in
waste management by 2031, whilst recognising that there is likely to be ongoing
management of waste arising in London outside of the capital, albeit in decreasing
amounts.

1.3.10

The Localism Act 2011 introduced the Duty to Co-operate requiring local planning
authorities (and other public bodies) to co-operate in relation to the planning of
sustainable development. All public bodies have a duty to co-operate on planning for
strategic matters that have cross administrative boundary impacts. The NPPF notes
the need for co-operation on strategic priorities 7 such as the provision of infrastructure
for waste management and wastewater. In carrying out their duty, the Act expects
bodies to engage constructively, actively and on an ongoing basis. In the case of
West London the particular cross boundary movements of waste considered are as
P

6 Government Review

of Waste Management for England 2011 -http://www.defra.gov.uk/publications/files/pb13540-waste-

policy-review110614.pdf
7

National Planning Policy Framework 2012, paragraph 156

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follows:

Management of residual waste

Management of hazardous waste

1.3.11

The extent of these movements is detailed in Section 3. In considering this, the West
London boroughs have engaged formally with the Environment Agency as well as
relevant WPAs. Contact was made with all WPAs currently accepting waste from the
Plan area. Emails, meetings and telephone conversations were used to exchange
and confirm information on waste flows between areas and to agree significant cross
boundary issues regarding the waste flows, future requirements and other, related
matters. Attendance at meetings of regional groupings of Waste Planning Authorities
such as the London Regional Technical Advisory Board (RTAB) and the South East
Waste Planning Advisory Group (SEWPAG) provided further opportunities to discuss
cross boundary issues.

1.3.12

Published and emerging waste planning documents of the counties concerned were
also consulted to assess current and projected capacities and policies regarding
accepting waste from West London in the future.

1.3.13

Throughout the Plan process there has been ongoing engagement with other WPAs.

1.3.14

Details of how the West London Boroughs engaged with bodies to meet the Duty to
Co-operate requirements are contained in a separate Duty to Co-operate Schedule.
S

Regional Policy
1.3.15

The London Plan provides the regional planning framework for the six West London
Boroughs and OPDC and outlines the principal guidelines for waste development. The
Government has agreed that, although Regional Spatial Strategies (RSS) for other
parts of England have been revoked, the London Plan will continue to provide strategic
guidance for the capital, as part of the Development Plan.

1.3.16

This Plan is in general conformity with the policies in the London Plan and in particular
those regarding waste management. As mentioned above, this includes an
apportionment of the tonnages of municipal and commercial and industrial waste to be
managed by each London borough; revised targets for recycling of municipal waste;
and new targets for recycling of commercial and industrial waste and recycling or
reuse of construction and demolition waste and diversion of waste from landfill (see
Table 1-1).

1.3.17

Implementation of the policies in this Plan will ensure that the Boroughs contribute
towards the London Plan aim of net self-sufficiency by 2031.

1.3.18

In March 2015 the Mayor adopted Further Alterations to the London Plan (FALP).
These include amendments to the forecast quantities of commercial and industrial
waste arising within London, based on baseline data adjusted down to reflect the
findings of the national C&I waste survey of 2010. As a consequence the revised

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projected overall capacity shortfall identified has fallen and hence the revised Borough
apportionment targets have reduced. The need for changes to this Plan in light of the
FALP will be considered in due course.
Local Policy
1.3.19

Each borough must produce a Local Plan which replaces what was previously called
the Local Development Framework or Unitary Development Plan. The Local Plan
includes policies, strategies and plans, such as this Plan, and may comprise more
than a single document.

1.3.20

This Plan has been prepared jointly by the six West London Boroughs, and is aligned
with their individual Local Plans and helps deliver their Sustainable Community
Strategy.

1.4
1.4.1

Sustainability Appraisal and Other Assessments

The Plan has been subjected to a Sustainability Appraisal (SA) during the course of its
development. An SA appraises whether planning documents accord with the
principles outlined in the Governments UK Sustainable Development agenda 8 and
implements the EU Strategic Environmental Assessment Directive. The SA aims to
ensure that sustainability considerations are taken into account early in the process of
policy development.
P

1.4.2

A Habitats Regulations Assessment (HRA); an Equalities Impact Assessment (EqIA)

and a Strategic Flood Risk Assessment (SFRA) have also been undertaken as part of
the development of this Plan. Appendix 2 provides details on the processes followed
for each of these assessments.

1.5
1.5.1

Community and Stakeholder Consultation

The West London Waste Plan has been informed by consultation with statutory
bodies, local organisations, key stakeholders and the wider community throughout its
preparation. This has been carried out in accordance with each boroughs Statement
of Community Involvement. Initial consultation took place in January and February
2009 on the key issues which the West London Waste Plan needs to address, as set
out in the West London Waste Plan Issues and Options report 9 . A wide range of
responses was received at various public workshops and meetings held across the six
Boroughs, and by written representations.
P

1.5.2

The Boroughs preferred approach to deal with the issues raised, as well as a list of
the proposed sites, was published for comment in February 2011 in the Proposed

See DEFRA: http://sd.defra.gov.uk/what/

West London Waste Plan Issues and Options Report (February 2009) available to download from
http://www.wlwp.net/documents.html

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Sites and Policies report 10 . Staffed drop-in sessions in each of the six Boroughs were
attended by over 120 people, with 64 people attending further meetings. In addition to
responses received at these events, 248 questionnaires were completed, and a further
133 additional written and email submissions were made. Two petitions containing
2,399 signatures were also submitted. A summary report on this consultation is
available on the West London Waste Plan website (www.wlwp.net).
P

1.6
1.6.1

Proposed Submission WLWP

Representations were received on the Proposed Submission draft of the West London
Waste Plan, including the Sustainability Appraisal and Equalities Impact Assessment
during a six week period between 28 February and 11 April 2014.

1.6.2

All representations (which were not withdrawn) were submitted for consideration by a
Planning Inspector at a formal examination. The purpose of the examination was to
consider whether the Waste Plan complies with the legal and procedural requirements
and is sound.

1.6.3

Since the Planning Inspectors purpose is to answer these questions, the

representations relate to legal compliance and soundness, as set out in the National
Planning Policy Framework, 2012 (NPPF). This includes being prepared in
accordance with the Duty to Co-operate.

1.6.4

In summary, for this Plan to have been found 'sound' it passed the following tests:

10

Positively prepared the plan should was prepared based on a strategy which
seeks to meet objectively assessed development and infrastructure
requirements, including unmet requirements from neighbouring authorities
where it is reasonable to do so and consistent with achieving sustainable
development;

Justified the plan is the most appropriate strategy, when considered against
the reasonable alternatives, based on proportionate evidence;

Effective the plan is deliverable over its period and based on effective joint
working on cross-boundary strategic priorities; and

Consistent with national policy the plan enables the delivery of sustainable
development in accordance with the policies in the National Planning Policy
Framework.

Proposed Sites and Polices Report (February 2011) available to download from

http://www.wlwp.net/documents.html

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1.6.5

More guidance on the meaning of these terms is available from the Planning
Inspectorate 11 and in the National Planning Policy Framework, 2012 12 which outlines
the requirements for Local Plans and the National Planning Policy for Waste which
provides specific guidance for planning for sustainable waste management.
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Public Examination
1.6.6

Following submission, the Secretary of State appointed a Planning Inspector to hold

an independent examination of the Plan. This examination included public hearings
which took place between 7 and 10 October 2014.

1.6.7

Further information can be obtained via the website:

www.wlwp.net

1.6.8

The West London Waste Plan document and an accompanying, Sustainability

Appraisal and Equalities Impact Assessment are available for download via the West
London Waste Plan website at: www.wlwp.net . Hard copies are also available to
view at:
48T

48T

1. All Libraries across the six Boroughs; and

2. Local Council Offices across the six Boroughs.
1.6.9

All other submission documents, including the evidence base, are available for
download. The West London Boroughs will seek to ensure that all reports are
accessible to everyone and will offer assistance to those who are blind or partially
sighted or do not speak English fluently.

1.7
1.7.1

Planning applications for waste management facilities

Once adopted, the West London Waste Plan will be the primary policy framework
against which planning applications for waste management facilities in the West
London Boroughs and OPDC area will be assessed. In the first instance developers
should use the plan to guide them in identifying suitable sites to accommodate new
waste management facilities. These site allocations are also supplemented by
development management policies which provide a framework to assess the
acceptability of individual proposals. Developers should also consider requirements
and policies within the following documents before submitting a planning application
for a waste management facility in West London:

National policy and guidance, including that relating to waste management;

11

See: http://www.planningportal.gov.uk/uploads/pins/dpd_brief_guide_examining.pdf

12

See: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf

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Borough and OPDC Local Development Documents;

London Plan;

1.7.2

0T

Mayor of London Order (2008); and

Supplementary Planning Guidance from the Mayor or relevant Supplementary

Planning Documents from the Boroughs.

Certain types of waste development need to be referred to the Mayor. Under the
Mayor of London Order (2008) the Mayor has powers to take a decision on the
following types of waste development applications as follows:

Waste development to provide an installation with capacity for a throughput of

more than 5,000 tonnes per annum of hazardous waste, 50,000 tonnes per
annum of waste or occupying more than one hectare.

Waste development that does not accord with one or more provisions of the
Local Plan (including this Plan once adopted) and either occupies more than
0.5 hectares or has capacity for more than 20,000 tonnes per annum of waste
or 2,000 tonnes per annum of hazardous waste.

1.8
1.8.1

West London Waste Authority

The West London Waste Authority (WLWA) is the statutory Waste Disposal Authority
for the six West London Boroughs and as such is solely responsible for the transport,
treatment and disposal of municipal solid waste (MSW) collected by the Boroughs.
The WLWA is not responsible for Commercial and Industrial Waste (C & I),
Construction, Demolition and Excavation Waste (CD & E) or forms of non-municipal
hazardous waste.

1.8.2

The WLWA and its constituent Boroughs consulted on and subsequently adopted a
Joint Municipal Waste Management Strategy 13 in 2005. The strategy sets out the
future waste and recycling plans and targets for the Authority and each of the six
Boroughs to 2020. This was updated in 2009.
P

13

See: WLWA Draft Joint Municipal Waste Management Strategy, September 2005 -

http://westlondonwaste.gov.uk/about-us/waste-strategy/

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Vision and Objectives of the Plan

2.1
2.1.1

Vision
The unique characteristics of West London, as well as the key challenges and
opportunities that have been identified in developing the Plan, have fed into the vision
of the Plan, which is supported by its aims and objectives.

2.1.2

The vision of the Plan sets out how the Boroughs wish to see waste managed in West
London by 2031. Its formulation has been informed by national, regional and local
guidance along with the views of key stakeholders and the evidence base that
underlies the Plan.
West London Waste Plan Vision
Over the period to 2031, the West London Waste Plan area will have made provision
for enough waste management facilities of the right type and in the right locations to
provide for the sustainable management of waste guided by the waste hierarchy to
achieve net self-sufficiency and meet the needs of local communities. It will seek to
do so, in a progressive manner, whilst protecting the environment, stimulating the
economy and balancing the needs of West Londons communities.

2.2
2.2.1

Strategic Objectives
The West London Waste Plan strategic objectives underpin the achievement of the
vision and were developed in response to the key issues for West London and
responses received through community consultation.
West London Waste Plan Strategic Objectives
1. To identify sufficient land for the management of the six Boroughs pooled
waste apportionment as set out in the London Plan (2011), including
safeguarding existing waste sites and maximising their use as waste
management sites and to provide for the sustainable management of an
amount of waste equivalent to the amount arising within the Plan Area.
2. To ensure that waste is managed as far up the waste hierarchy as possible, by
encouraging the minimisation of waste and the use of waste as a resource.
3. To reduce the impact of waste management on climate change by encouraging
the use of sustainable transport and new, clean technologies, whilst seeking to
locate waste management facilities as close to waste sources as practicable.
4. To ensure that, through appropriate policies, waste facilities meet the highest
standards possible of design, construction and operation to minimise adverse
effects on local communities and the environment.
5. To support the key aims and objectives of Brent, Ealing, Harrow, Hillingdon,
Hounslow and Richmonds Sustainable Community Strategies.

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Existing Waste Management

3.1
3.1.1

Existing Waste Management

West London produces, and is expected to continue to produce, a significant quantity
of waste. This section looks at the different types of waste being generated in West
London and how it is currently being managed, along with future trends which allowed
the West London Boroughs and OPDC to determine the polices and sites needed to
facilitate the development of the sustainable infrastructure required to meet the
London Plan (2011) waste apportionment figures (Table 4-2) and net self sufficiency.
The main types of waste produced include:

Municipal Solid Waste

Commercial and Industrial Waste

Construction, Demolition & Excavation Waste

Hazardous Waste

Wastewater and Sewage Sludge

It should be noted that the London Plan (2011) apportionment targets are for municipal
and commercial & industrial wastes, including the hazardous element of both, only.
3.2
3.2.1

Municipal Solid Waste

Municipal Solid Waste (MSW) in the West London Boroughs is managed by the
WLWA and includes household waste, kerbside collected recyclables, green waste
and waste and recyclables collected at household waste recycling centres.

3.2.2

As the statutory body responsible for managing MSW generated in the West London
Boroughs, the WLWA has in place long term contracts for the management of this
waste. The main objective of the contracts is to end the landfilling of residual
municipal waste. The contracts involve the management of up to 390,000 tonnes of
MSW per year. 14
P

3.2.3

Since 2008 there has been a steady decline in MSW sent to landfill from the Plan
area, both in terms of the total tonnage sent and the percentage this represents of the
area's total waste stream. Figure 3-1 below uses financial year data since 2008 and
shows the different waste management routes used for the MSW stream. Note that the
material initially sent to Materials Recovery Facilities (MRFs) is then sent on for
management via other waste management routes.
Figure 3 1 West London Waste Authority MSW management (2009 2012) Financial years

14

See WLWA website for further detail http://westlondonwaste.gov.uk/about-us/where-your-waste-goes/

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100.00%

Recycling &
Reuse

90.00%
80.00%

Energy
Recovery

70.00%
60.00%
50.00%

Composting

40.00%

Landfill

30.00%
20.00%
10.00%

2009/10

0.00%
2011/2012

2010/2011

Source: WLWA

3.2.4

In 2012 the WLWA and its constituent Boroughs dealt with around 657,000 tonnes of
MSW, excluding abandoned vehicles. Of this total some 154, 000 tonnes was
recycled, 90,000 tonnes was composted, and 93,000 tonnes was sent to MRFs from
which waste went on to other routes. Ultimately, 413,000 tonnes was sent either to
Energy from Waste (EfW) or to landfill sites in Oxfordshire and Buckinghamshire (just
over 80% by rail from the WLWAs transfer stations in Brentford and South Ruislip).
See Table 3-1 below.
Table 3-1: WLWA management of Municipal Solid Waste 2012
Calendar year (tonnes rounded to nearest 000 and percentages rounded)
S

Municipal Solid Waste management

Tonnes

Percentage

Recycling

154,000

23

Composting

90,000

14

Energy from Waste

117,000

18

Landfill

296,000

45

TOTAL

657,000

100

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3.2.5

From 2009/10 increasing quantities of waste, not recycled or composted, have been
diverted from landfill by sending it to EfW. The WLWA has a contract to send residual
waste to the Lakeside Energy from Waste plant near Slough, until 2034/35. This
contract has an annual tonnage of 25,000 tonnes until 2014/15 when for one year the
tonnage increases to 45,000 tonnes. The following year (2015/16) the tonnage
increases to 90,000 tonnes and remains at that level until the final year of the contract.
In addition materials sent to certain MRFs in the Plan area are then sent to recycling,
EfW and landfill respectively. The tonnages of these outputs are included in Table 3-1
and Figure 3-1 above (by financial year). This illustrates how the dominance of landfill
has been broken by use of other management routes so that less than 50% of waste
managed by the WLWA was actually landfilled in 2012 (calendar year).

3.3
3.3.1

Commercial and Industrial Waste

The most recent and comprehensive national Survey of C&I waste arisings 15 took
place in 2009. This survey estimated that West London produced 845,000 tonnes of
C&I waste during that year, which is a reduction of 621,000 tonnes (42%) on the
previous C&I Survey conducted in 2002/03 (this estimated that 1,466,000 tonnes of
C&I waste was produced). Work carried out to underpin the London Plan (2011)'s
apportionment targets has estimated that West London produced 1,299,000 tonnes of
C&I waste in 2009 and for the purposes of consistency, this estimate has been used in
the Plan. However the proposed Further Alterations to the London Plan (FALP)
propose aligning the C&I waste baseline and forecasts with the national survey results.
If the FALP is adopted as proposed, this would mean a significant fall in projected
arising of this waste stream.

3.4
3.4.1

Construction, Demolition and Excavation Waste

A detailed study of arisings 16 has been undertaken which estimated that just over 3
million tonnes of Construction, Demolition and Excavation waste (CD&E) waste is
produced in West London each year. This is managed at sites within and beyond West
London. This estimate is based on consideration of previous national surveys and
analysis of data within the most recent Environment Agency Waste Data Interrogator
(EA WDI).

3.4.2

According to the EA WDI 2012, around 776,000 tonnes of CD&E was imported for
management at facilities within West London in 2012. This estimate is based on an
analysis of waste managed at sites permitted for the management of waste by the
Environment Agency, and does not account for aggregate production nor uses of
CD&E in development (e.g. as an engineering material) which are exempt from the

15

DEFRA: Commercial and Industrial Waste Survey 2009 Final Report (May 2011) http://archive.defra.gov.uk/evidence/statistics/environment/waste/documents/commercial-industrialwaste101216.pdf

16

CDEW Baseline, Forecast & Target Setting Paper Final Issue v1.0 27.02.14, BPP Consulting

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need for a permit. Table 3-2 below shows the management of CD&E waste in West
London based on 2012 data from the EA Waste Data Interrogator.
Table 3-2 Management of CD&E waste in West London 2012
CD&E Arising in
West London

CD&E Imported
into West London

Total

Managed at permitted sites

within West London

>331,000

776,000

1.107million

Managed at permitted sites

beyond West London

411,000

N/A

N/A

Total

742,000

N/A

N/A

Source: EA Waste Data Interrogator 2012

3.5
3.5.1

Hazardous Wastes
Hazardous wastes are categorised as those that are harmful to human health, or the
environment, either immediately or over an extended period of time. They range from
asbestos, chemicals, and oil through to electrical goods and certain types of
healthcare waste. A detailed study of arisings 17 has been undertaken which found the
following:
P

In 2012, West London produced just over 88,000 tonnes of which

approximately 85% was exported for management.

At the same time 20,000 tonnes was imported from outside the Plan area.

Overall the Plan Area achieved 40% net self sufficiency in 2012.

Hazardous waste requires a range of specialist facilities for treatment and

disposal, but it is not anticipated that substantial additional need for new
capacity locally will arise and so land allocations specifically for the
development of additional hazardous waste management capacity have not
been identified in this Plan.

Figure 3-2 - Destination of hazardous waste arisings from West London (2012)

Increasing intensity of colour corresponds to increasing tonnage sent.

17

Estimate of Baseline, Forecast, Management & Flows for Hazardous Waste Arising in west London Final issue
v1.0 27.02.14, BPP Consulting

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Source: EA Hazardous Waste Interrogator (HWI) 2012 & EA Waste Data Interrogator 2012

3.5.2

In 2012, West London Boroughs exported hazardous waste to 38 different destinations

across England, with the main ones being Northamptonshire, Hertfordshire, Surrey
and Kent. The primary destinations of hazardous waste exported out of London
generated in West London are shown in Figure 3-2 above.

3.6
3.6.1

Wastewater and Sewage sludge

Thames Water Limited is responsible for wastewater and sewage sludge treatment in
London and, as part of this responsibility, it manages key pieces of sewerage
infrastructure, including a number of sewage treatment works (STW). The majority of
wastewater in West London is either treated at Mogden STW in Isleworth, Beckton
STW in East London. During 2010, these facilities generated over 100,000 tonnes of
sewage sludge (dry solids) with all of this sludge being recovered in some way either
through incineration with energy recovery, recycled to agricultural land or used for land
restoration.

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3.7
3.7.1

Agricultural Waste
The Environment Agency Waste Data Interrogator (WDI) indicates that in 2012, a total
of 7, 236 tonnes of waste from agricultural sources (EWC18 chapter 02 01) in West
London was managed at waste management sites with Environmental Permits
reporting through the WDI 99% of this was managed through treatment. However this
figure doesn't include waste types which are known to be produced on farms recorded
in the WDI under other waste codes. The main types of this type of waste include:
P

Agricultural packaging such as plastic film;

End of Life vehicles such as tractors;

Tyres; and

Asbestos construction waste.

Nor does it include waste managed through routes other than permitted sites.
However, in light of the predominantly urban character of the Plan area there are
limited opportunities for the production of this waste stream and so its management is
not considered to be an issue needing specific consideration in this Plan.
3.8
3.8.1

Radioactive Waste
Limited information is available regarding the generation of radioactive waste in West
London, with no arisings records held by either the Environment Agency or the
Department of Energy and Climate Change. A detailed study of arisings 19 has been
undertaken which found the only identified sources that may generate small amounts
of low level radioactive waste (LLW) and very low level radioactive Waste (VLLW) are
at 21 locations across the Boroughs including hospitals, universities, research facilities
and a few commercial operations.
P

3.8.2

Most radioactive waste produced by minor waste producers is not reported in the UK
Inventory as it is either low volumes of LLW that can be disposed of by controlled
burial at landfill sites under special licence, or low volume VLLW that is disposed
within the MSW and C&I waste streams. As separate recording of VLLW production
or management is not required it is not possible to quantify how much is managed
from the Plan area. It is possible that some VLLW is managed at the Hillingdon clinical
waste incinerator along with other wastes. The nearest available landfill accepting
LLW is a nationally strategic site in Northamptonshire. In addition a High Temperature
Incinerator in Fawley, near Southampton has some capability to deal with these types
of waste. These facilities are preferred for use than sending it to the national LLW
disposal facility near Drigg, Cumbria.

18

EWC = European Waste Classification

19

Review of Radioactive Waste Arising in west London Final Issue, BPP Consulting

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3.8.3

There is no apparent market appetite or demand for a LLW management facility to be

developed in the Plan area and so the practice of exporting those quantities that may
be produced for management elsewhere is likely to continue. In light of this, the Plan
does not include specific policies to cover such development.

3.9
3.9.1

Cross boundary Movement of Waste

Whilst around 1 million tonnes of West London's own waste is managed within West
London Boroughs, waste also moves into and out of the Plan area for management. It
is important to assess the level of this cross boundary movement of waste and to
identify potential implications for the West London Waste Plan during the Plan period,
particularly to meet the Duty to Co-operate.
Table 3-3: Exports of waste out of West London by management type, 2012

Municipal Solid Waste

(from WDF)

Commercial and Industrial

Waste (from WDI +)

Construction, Demolition and

Excavation Waste (from
WDI)

TOTAL

Principal Management
Route

Tonnes

Principal Destination

415,000

Bucks (35%)
Oxon (33%)
Slough (24%)

537,000

Bucks (33%)
M Keynes (32%)
Slough (15%)
LB Southwark (6%)
LB Bexley (5%)
Herts (4%)
NLWP (3%)
Surrey (1%)

Landfill
Landfill
Co-Incineration
Treatment
Treatment
Landfill
Treatment
Landfill

412,000

Bucks (26%)
M Keynes (24%)
Slough (19%)
Herts (11%)
LB Greenwich (7%)
NLWP (5%)
Surrey (5%)
Oxon (4%)

Landfill
Landfill
Landfill
Landfill
Treatment
Treatment
Landfill
Landfill

Landfill
Landfill
EfW

1.36 million

NB: CD&E value excludes substantial quantities managed through activity that do not require permits

3.9.2

Around 1.3 million tonnes of West London's waste were exported out of London in
2012. This comprises Municipal Solid Waste (MSW), Commercial and Industrial

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Waste (C & I), Construction, Demolition and Excavation Waste (C, D & E) and certain
types of hazardous waste. A proportion of this waste is handled by the WLWA. Table
3-3 above shows the level of exports or flows out of the West London area.
3.9.3

Landfill accounted for less than three quarters of the movements of all waste out of the
Plan area in 2012 as shown in Figure 3-3 below which while varying from year to year
is following a reducing trend.
Figure 3-3: Exports of waste out of West London by management type, 2012

1%
8%

5% 2% 1%

0
Landfill
Treatment

11%

Transfer
72%

Co-Incin
EfW
On/In Land
MRS
Use of Waste

Source: WDI 2012

3.9.4

Figure 3-4 illustrates that the majority of waste exported in 2012 was sent to
Buckinghamshire (31%), Milton Keynes (20%), Slough (19%) followed by Oxfordshire
(11%) with the bulk of the remaining 19% divided between 6 other authorities. This
has changed significantly from previous years when Bedfordshire received substantial
quantities of waste for landfilling (just under 200,000 tonnes in 2011).

3.9.5

A high level totalling exercise of WDI 2012 data alone indicates that of the 2.37 million
tonnes of waste received by permitted sites in West London from within the capital, up
to 1.3 million tonnes comes from outside West London. This compares with 132,000
tonnes of waste from West London managed within the rest of London, which is only
10% of quantity of waste imported from London into West London. This demonstrates
the significant contribution facilities within West London already make to the
management of London's waste and overall target of achieving net self sufficiency by
2031.

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Figure 3-4: Waste sent for management to any type of facility beyond the Plan area

450,000
Haz

tpa

400,000

Post Treatment Residues

350,000

Active

300,000

CDEW/Inert

250,000
200,000
150,000
100,000
50,000
0

Receiving WPA

NB: All active i.e. biodegradable waste sent to landfill must be pre-treated in compliance with
the Landfill Directive
Source: WDI 2012 plus EA Pollution Inventory

3.10
3.10.1

Role of Landfill in the Management of Residual Waste

Landfill disposal accounted for approximately 1,143,000 tonnes of waste arising in
West London in 2012, with 90% of that exported to landfill facilities outside of the Plan
area. The remaining 107,400 tonnes was managed at Harmondsworth Landfill located
in southwest Hillingdon.

3.10.2

There are several different types of landfill, all of which play a different role in helping
to manage waste from West London. Generally these are categorised by the types of
waste they can accept for disposal. Table 3-4 below shows the types and amounts of
waste sent to landfill from West London in 2012

3.10.3

Non-hazardous landfill usually receives residual MSW and C&I waste plus inert CD&E
waste that is used for engineering and operational purposes, whereas Inert Landfill
only receives inert waste from the CD&E waste stream. Hazardous waste landfills are
highly specialised and only accept certain hazardous waste, while stable, non-reactive
hazardous waste (SNRHW) (e.g. asbestos) sent to non-hazardous landfill can be

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deposited in an area specifically designed to accept SNRHW isolated from

biodegradable waste.
Table 3-4 Waste sent to landfill from West London in 2012, by receiving site type
Type of waste received by site

Tonnes

Hazardous (SNRHW) via Separate Cell

5,459

Non Hazardous

1,079,915

Inert

57,655

Total

1,143,029

Source: WDI & HWI, 2012

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Future Waste Management

4.1
4.1.1

How much waste will need to be managed in West London?

The London Plan (2011) sets a target for London of becoming net self-sufficient in the
management of waste by 2031. To help achieve this target each borough has been
given a share of Londons total MSW and C&I waste to manage (called the boroughs
apportionment figure) for which it must identify sufficient and suitable existing waste
management sites for the development of waste management capacity. The West
London boroughs have pooled their apportionments and will meet the collective
apportionment figures through this Plan.

4.1.2

MSW and C&I waste arisings projections are also included in the London Plan (2011).
These figures were considered the most up-to-date for West London at the time and
were also used by the Mayor to determine the apportionment figures. The waste
arisings and apportionment figures for West London are displayed in Table 4 -1 below.
Figure 4 -1 below shows the forecast arisings plotted against capacity apportionment
targets from 2011 to 2031. It should be noted that CD&E wastes are not included in
the waste projections but hazardous wastes from MSW and C&I sources are. These
wastes are discussed in paragraphs 4.4 and 4.5 below.
Table 4-1: Quantity of MSW and C&I waste forecast to be produced in West London and the
apportionment figures from the London Plan (2011) for target years
2011

2016

2021

2026

2031

798,000

826,000

852,000

879,000

900,000

C&I waste arisings (tonnes

per annum)

1,287,000

1,258,000

1,240,000

1,233,000

1,236,000

Total (MSW and C&I waste)

arisings (tonnes per annum)

2,085,000

2,084,000

2,092,000

2,112,000

2,136,000

1,399,000

1,595,000

1,798,000

2,019,000

2,250,000

MSW arisings (tonnes per

annum)

London Plan (2011)

Apportionment (tonnes per
annum)

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Figure 4-1: Forecast arisings and capacity apportionment for West London Boroughs as set out in the
London Plan (2011)

4.2

How much capacity is needed?

London Plan 2011 apportionment

4.2.1

The West London Waste Plan was prepared in accordance with the waste projections
and apportionment figures contained in the London Plan (2011). The West London
Boroughs are not required to meet the individual MSW and C&I waste apportionment
figures in the London Plan (2011) separately as long as the total combined
apportionment figure is addressed. This will require the delivery of sites and capacity
as set out in the Plan.

4.2.2

Currently, West London has a range of sites where the management of MSW & C&I
waste is taking place. The intention of the Plan is to prioritise the use of the existing
sites in West London, including redevelopment of some waste management sites and
depots, and then adding some new sites for waste management uses, as necessary.

4.2.3

Existing waste management capacity (excluding any landfill) in West London is 1.64
million tonnes per annum including both waste processing sites and the recycling

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undertaken at household waste and recycling centres (see Appendix 2).

Subsequently, additional waste management facilities will need to be developed in
West London during the Plan period up to 2031 to address the gap between the
apportionment target and the waste management capacity that currently exists (see
Figure 4-2 below). Table 4-2 below sets out the existing and projected waste
management capacity in West London and the additional capacity required to address
the apportionment gap for target years.
Figure 4-2 Projected capacity gap (in pink) between London Plan (2011) apportionment and
existing capacity

39T

NB vertical red line indicates point at which apportionment exceeds existing capacity

39T

39T

4.2.4

For the six West London Boroughs to meet the London Plan (2011) apportionment
targets for MSW & C&I waste, additional capacity of 162,000 tonnes by 2021, 383,000
tonnes by 2026 and 614,000 tonnes by 2031 will be needed (see Table 4-2 below).
To determine what area of land will be required to provide this additional capacity, an
average capacity of 65,000 tonnes per annum per hectare was used to calculate the

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amount, 20 based on the range of possible processes and their processing intensity.
39TP

P39T

4.2.5

The London Plan (2011) does not prescribe the specific waste management
technologies, their scale, or the number that will need to be implemented across
London. Accordingly, the West London Waste Plan also does not take a prescriptive
approach to what types of waste management facilities/technologies are required.
This approach allows for innovation in the management of waste to be incorporated
into proposed development in West London.

4.2.6

The land required to meet the apportionment capacity gap is also displayed in Table
4-2 below. This shows that by 2031, West London Boroughs will need to have an
additional 9.4 hectares of land available for waste management.

39T

39T

39T

Table 4-2: West London Capacity Requirements for Target Years based on the London Plan
(2011)
2011

2016

2021

2026

2031

Apportionment (tonnes
per annum)

1,399,000

1,595,000

1,798,000

2,019,000

2,250,000

Total existing waste

management capacity
21
(tonnes per annum)

1,636,000

1,636,000

1,636,000

1,636,000

1,636,000

Additional capacity
required to meet the
apportionment (tonnes per
annum)

162,000

383,000

614,000

Land required to address

the capacity gap
(hectares)

2.5

5.9

9.4

61T

61T

61TP

61T

61T

4.2.7

To meet this land requirement, eight existing waste sites (accounting for 12.32
hectares) have been identified as suitable and available for redevelopment. An
additional 3.20 hectares of land currently not developed for waste management use
has also been identified as suitable and deliverable (see Section 5 for details of the
sites).

4.2.8

Overall, it is thus estimated that within West London there are at least 15.52 hectares
of land suitable and deliverable for development for additional waste related uses. This
exceeds the notional land requirements of the London Plan (2011) apportionment
targets and creates some flexibility in the Plan should some sites not come forward for

20

Calculations based on Table 4A.7 - throughput and land take of different types of facilities from the London Plan
(2008) and further discussions and agreement with the GLA in 2013.

21

This assumes that existing capacity remains constant via the operation of the safeguarding policy

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development during the lifetime of the Plan. Annual monitoring of the Plan will help
assure that provision of capacity remains sufficient for the Plan period. The table
below shows how the contribution of the allocated sites to the capacity required to
meet the London Plan (2011) apportionment has been calculated.
Table 4-3: Contribution of allocated sites to meeting the London Plan Apportionment

Site Name

Included
Area
(ha)

Potential
contribution @
65,000t/he (tpa)

Existing
Contribution
(tpa)

Potential
additional
contribution

Col1

Col2

Col3

Col4

Col1 x 65,000

From WDI

Col2 minus
Col3

Twyford Waste Transfer Station

1.24

80,600

22,714

57,886

Veolia/Brent Transfer Station & Depot

2.71

176,150

82,691

93,459

Greenford Depot (inc HWRC)

1.783

115,895

35,610

80,285

Rigby Lane Waste Transfer Station

0.91

59,150

25,280

33,870

Twickenham Depot

2.67

173,550

173,550

Quattro, Victoria Road, Park Royal

0.7

45,500

45,500

Forward Drive Depot

2.31

150,150

Western International Market

3.2

208,000

208,000

Total

15.523

1,008,995

816,920

25,780

124,370

Providing for the Plan area waste before net self sufficiency is achieved
4.2.9

National Planning Policy for Waste has a stated expectation that development plan
documents should make provision for all waste arising within the Plan area. In this
case the London Plan (2011) apportionment trajectory only aims for self sufficiency at
2029 (Figure 4 -1 above). Before that date a shortfall of capacity between forecast
arisings and existing capacity is indicated if the apportionment targets are met on a
progressive basis as suggested by the London Plan. This is illustrated in Figure 4 - 3
below. The pink section shows the theoretical gap were provision to be solely driven
by the London Plan trajectory. The maximum amount per annum it represents is
around 470,000 tonnes reducing from 2016 when planned provision to meet the
apportionment target would start to kick in.
SS

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Figure 4-3 Interim capacity gap between existing capacity and arisings as forecast by London
Plan (2011)

4.2.10

The following arrangements will operate in the interim. Firstly a long term contract for
MSW has been entered into by the WLWA. This will involve the export of up to
300,000 tonnes per annum to an Energy from Waste facility in South Gloucestershire.
In addition the WLWA has a contract to supply a minimum annual tonnage of 25,000
tonnes to Lakeside EfW plant until 2014/15 when the tonnage increases to 45,000
tonnes. The following year (2015/16) the tonnage increases to 90,000 tonnes and
remains at that level until the final year of the contract in 2034/5. While this export of
material to generate energy is not countable towards the apportionment targets under
the terms of the London Plan (2011) it will account for the bulk of the shortfall. In
addition around 70,000 tonnes of waste (as refuse derived fuel) may be sent to the
Slough Heat & Power facility or exported abroad for energy recovery. So in total
460,000 tonnes per annum are accounted for to address the apparent shortfall. It
should be emphasised that these arrangements reflect actual arrangements put in
place and are not a strategy developed as part of the Plan-making process. However
the fact that such long term arrangements catering for significant quantities of West
London's waste exist, cannot be ignored.

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4.3
4.3.1

What kind of facilities will be needed?

A range of different waste management facilities may be required to provide for
management of waste within West London, including recycling, composting and
energy recovery. Modern waste management facilities utilise clean technologies and
are subject to stringent regulation and monitoring of their operations and impacts.
Innovative design and architecture are important to ensure facilities are acceptable
and sensitive to their settings, although many technologies can be housed in industrial
building similar in appearance to a warehouse. Appendix 4 to this report gives a brief
description of most of the principal waste treatment technologies.

4.3.2

It is important that modern methods of dealing with waste are found which also
produce value added, usable outputs (including fuel, heat and power). Waste
management facilities should be seen positively, as an opportunity rather than a bad
neighbour, as they can be co- located with developments and industry to provide heat,
power and other beneficial products potentially attractive to industrial, commercial and
residential developments.
S

4.3.3

The West London Waste Plan identifies sites for general waste management use and
sets out policies to ensure development is suitable for the site and its surrounding land
uses. The Plan is designed to be flexible to allow for developments and improvements
in waste management technologies and the changing habits of consumers and waste
producers. Any planning application for additional waste management capacity will be
considered against the West London Waste Plan policies, including those of the
London Plan, and other relevant policies and material considerations and be subject to
public consultation.

4.4
4.4.1

Construction, Demolition and Excavation Wastes

Construction, Demolition and Excavation (CD & E) waste is a large waste stream
within London, although it is not included within the London Plan (2011) apportionment
target assigned to boroughs. Work undertaken in support of the Plan has established
that the Plan Area has a substantial quantity of processing capacity for this waste
stream and that the London Plan (2011) city-wide targets of 95% recycling and reuse
by 2020 are close to being met. This is expected to continue into the future and
accordingly no allocations are made in this plan for facilities dealing specifically with
such wastes. However the evidence also indicates that it is not possible for the more
specific target of 80% of that recycling to be met in the form of aggregates by 2020
due to the lack of suitable waste. The preference in West London is to ensure more
on-site recycling and re-use on construction sites together with effective use of existing
waste management sites and the appropriate provision of facilities at mineral
extraction sites to ensure adequate provision of treatment capacity for this waste
stream particular policy encouragement will be given to development of capacity for
the production of material suitable for use as substitutes for virgin materials such as
recycled aggregates.
S

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4.5
4.5.1

Hazardous Wastes
Policy 5.19 of the London Plan (2011) states that the Mayor will prepare a Hazardous
Waste Strategy for London and will work in partnership with the boroughs, the
Environment Agency, industry and neighbouring authorities to identify the capacity gap
for dealing with hazardous waste and to provide and maintain direction on the need for
hazardous waste management capacity. This policy also directs that existing
hazardous waste sites should be safeguarded unless compensatory provision is
made. In January 2014 the Mayor released a report 22 to help inform Londons
hazardous waste management capacity requirements and planning policy for the
next iteration of the London Plan (FALP) adopted in 2015. This study is a nonstatutory document and sets out the Mayor's understanding of Londons hazardous
waste management arrangements.
P

4.5.2

Work undertaken in support of the Plan 23 has established that the Plan area has a
moderate level of capacity for this waste stream with a number of sites managing
hazardous waste within the Plan area. Other flows have been tracked with the general
finding being that waste of this type travels within 1.5 hours of the Plan area for
treatment. The resilience of these flows has been confirmed by contacting the
appropriate receiving authorities. It is not anticipated that a substantial local need for
new capacity will arise and so land allocations specifically for the development of
additional hazardous waste management capacity have not been identified in this
Plan. However Policy WLWP 1 is included to encourage the development of further
capacity where it is identified as being needed in the regional context. Planning
applications for new hazardous waste facilities will be determined in the same way as
applications for all waste management facilities and the capacity of hazardous waste
facilities will be monitored closely to establish whether additional provision is required
at a later date.
P

22

Londons Hazardous Waste A Report For The Mayor Of London, January 2014

23

Estimate of Baseline, Forecast, Management & Flows for Hazardous Waste Arising in west London Final issue
v1.0 27.02.14, BPP Consulting [MM1G]

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The Sites

5.1.1

In accordance with the criteria outlined in National Planning Policy for Waste, the West
London Waste Plan identifies 8 sites which it considers will ensure adequate waste
management provision for the lifetime of the Plan. The sites have been subjected to a
detailed evaluation and assessment which is summarised in an accompanying report
on the site selection process24 . A description of the sites proposed for allocation is
included in Appendix 6.
P

5.1.2

The Plan identifies 15.52 hectares considered to be suitable and available on existing
and new sites for future waste management located as per Figure 5-1 below. Table 51 sets out existing sites capable of redevelopment to expand existing capacity, while
Table 5-2 refers to additional sites that may be developed for waste management
purposes. Maps showing the location of the sites and their boundaries are also
provided.

5.1.3

In order to retain flexibility and avoid stifling innovation, the Plan does not dictate which
type of waste management technology could be developed in which location. Any
proposal for development at any of the allocated sites will be considered against its
consistency with all the polices of this Plan, as well as other policies included in the
wider Development Plan for that area at that time. This means that it is possible that
detailed assessment may reveal that certain proposals may not prove to be acceptable
in certain locations as their predicted impacts on the surroundings cannot be
adequately mitigated, However all the allocated sites have been assessed as broadly
suitable for the development of additional waste management capacity that would
count towards meeting the London Plan apportionment.

24

WLWP Site Selection and Assessment Process Summary Report February 2014 http://www.wlwp.net/documents.html

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Figure 5-1: Location Plan showing all allocated sites (Policies Map)

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25

Table 5-1: Existing waste sites considered to have potential for redevelopment
Site
Number
352

Description

Twyford Waste Transfer Station

Site Type

Site Area
(ha)

Transfer Station

1.24

Borough

Brent
(OPDC)**

1261

Veolia Transfer Station, Marsh Road

Transfer Station

309*

Greenford Reuse & Recycling Site

Transfer Station

310*

Greenford Depot, Greenford Road

Depot Facility

328#

Quattro, Victoria Road, Park Royal

Transfer Station

2.71

Brent

1.78

Ealing

0.7

Ealing
(OPDC)**

222

Council Depot, Forward Drive

331

Rigby Lane Waste Transfer Station

342

Twickenham Depot

Depot Facility

2.31

Harrow

Transfer Station

0.91

Hillingdon

Depot Facility

2.67

Richmond

Total

12.32

*These two sites are contiguous and part of a larger site: for the purposes of the Plan, they are considered
a single consolidated site
** Falls within Old Oak and Park Royal Development Corporation area
# This site is subject to an HS2 Safeguarding Direction and will not be available from 2017 until 2024

High Speed 2 (HS2)

5.1.4

It should be noted that one of the sites proposed for allocation - Quattro at Victoria
Road - has been identified by HS2 Ltd as requiring safeguarding under the HS2
Safeguarding Direction. This means that if HS2 proceeds it will only become available
from 2024 for waste management uses, following its use to host a construction
compound. The site has been included to provide a contingency capacity for the latter
period of the Plan although it is not essential to meeting the apportionment targets of
the London Plan (2011).

25

Redevelopment means changing existing waste management arrangements such that an increase in the sites
recovery capacity is achieved.

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Site 352 Twyford Waste Transfer Station, Abbey Road, Brent

Crown copyright and database rights 2013 Ordnance Survey 100019283

Site 1261 Veolia Transfer Station, Marsh Road, Alperton, Brent

Crown copyright and database rights 2013 Ordnance Survey 100019283

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Site 309 Greenford Reuse & Recycling Site & Site 310 Greenford Depot, Greenford
Road, Greenford, Ealing

Crown copyright and database rights 2013 Ordnance Survey 100019283

Site 328 Quattro, Victoria Road, Park Royal, Ealing

Crown copyright and database rights 2013 Ordnance Survey 100019283

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Site 222 Council Depot, Forward Drive, Harrow

Crown copyright and database rights 2013 Ordnance Survey 100019283

Site 331 Rigby Lane Waste Transfer Station, Hayes, Hillingdon

Crown
Crown copyright and database rights 2013 Ordnance Survey 100019283

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Site 342 Twickenham Depot, Langhorn Drive, Twickenham, Richmond

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Table 5-2: Additional sites with opportunity for developing waste facilities
Site Number

Site Name

Site Area
(ha)

Borough

2861

Western International Market

3.20

Hounslow

Total

3.20

Site 2861 Western International Market, Hayes Road, Southall, Hounslow

@Crown copyright and database rights 2013 Ordnance Survey 100019283

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West London Waste Plan Policies

6.1
Policy WLWP 1 Provision of New Waste Management Capacity
6.1.1 The following policy is aimed at delivering the necessary minimum amount of
additional waste management capacity of the right type and at the right time.
Developments are to accord with all parts of the development plan unless material
considerations indicate otherwise. Particular attention will be given to avoiding
unacceptable harm to the environment and adverse effects on the well-being of
communities.
6.1.2 In respect of Municipal Solid Waste, and Commercial and Industrial Waste, the main
requirement arising out of the London Plan (2011) is to meet the stated apportionment
for the six West London Boroughs combined. This is the principal aim of the policy.
However, the current London Plan (2011) projections indicate that net self-sufficiency
would not be achieved until 2029 for London as a whole. In the interim, there would be
a gap between the quantity of eligible existing capacity within West London (the
apportionment baseline of 1.64 million tpa) and the quantity of MSW and C&I waste
forecast to arise in West London. In these circumstances, the provision of capacity to
manage the requisite London Plan tonnages at a faster rate than indicated will be
encouraged. The expectation is that substantive provision would be made on allocated
sites (Policy WLWP 2) in the first instance. Any such provision should be consistent
with the waste hierarchy.

Policy WLWP 1 - Provision of New Waste Management Capacity

Apportioned Waste MSW & Commercial and Industrial Waste:
Over the period to 2031, there is a need for about 614,000 tonnes of additional
annual capacity to meet the apportionment set in the London Plan (2011). This is to
be delivered on the allocated sites identified in Policy WLWP 2 as follows:

162,000 tonnes in the period up to 2021

A further 221,000 tonnes (total 383,000 tonnes) in the period 2021 to 2026
A further 231,000 tonnes (total 614,000 tonnes) in the period 2026 to 2031

The requirement is for capacity in the re-use, recycling, and other recovery
categories.
Provision over and above the tonnages required to meet the London Plan (2011)
apportionment and of a nature similar to that identified above will be encouraged
where this would contribute towards net self-sufficiency.
Provision should be made in accordance with the waste hierarchy, 27a and this
should be addressed and justified as a pre-requisite of any grant of planning
permission.

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Non apportioned Waste:

Development of management capacity will be supported in principle that
contributes towards net self sufficiency across the Plan Area for:
a. Construction, Demolition and Excavation Waste in accordance with the waste
hierarchy with particular support for the production of material suitable for use as
substitutes for virgin materials such as recycled aggregates; and
b. Hazardous waste treatment capacity that accords with any hazardous waste.

6.2
6.2.1

Policy WLWP 2 Safeguarding and Protection of Existing and Allocated Waste

Sites
A list of all the sites that are in existing waste management use in the West London
Boroughs and OPDC area can be found in Appendix 2. These safeguarded sites form
an essential resource for dealing with all waste streams within the Plan area and
protection of these sites minimises the need for any additional sites and so they are all
safeguarded. This also ensures general conformity with Policy 5.17 G (a) and
paragraph 5.82 of the London Plan (2011). Policy WLWP 3 provides support for
waste development proposals on existing sites.
S

6.2.2

The sites in Table 5.1 are those existing sites that are considered to have particular
potential for redevelopment for future waste capacity expansion, including alternative
forms of waste management that could result in waste moving up the hierarchy. Table
5.2 contains the additional site that is allocated in the Plan for future waste
management facilities. The protection of these sites is required to ensure the West
London Boroughs' pooled apportionment targets are met and thereby demonstrate
general conformity with the requirement of the London Plan (2011).

6.2.3

The policies of this Plan apply to the existing management capacity for hazardous
waste and to proposals for additional such capacity.

Policy WLWP 2 Safeguarding and Protection of Existing and Allocated Waste

Sites
Land accommodating existing waste management uses in West London will be
protected for continued use for waste management 27b .
P

Existing sites which have been allocated as having the potential for capacity
expansion by redevelopment (Table 5-1) and new sites with potential for
development for waste management facilities (Table 5-2) will also be safeguarded.
To ensure no loss in existing capacity, re-development of any existing waste

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management sites must ensure that the quantity of waste to be managed is equal to
or greater than the quantity of waste which the site is currently permitted26 to
manage, or that the management of the waste is being moved up the waste
hierarchy.
P

Development for non-waste uses will only be considered on land in existing 27c waste
management use, or land allocated in Table 5-2 if compensatory and equal provision
of capacity for waste, in scale and quality, is made elsewhere within the West
London Boroughs*.
33TP

P33T

* This includes the Old Oak and Park Royal Development Corporation area within the London Boroughs
of Brent and Ealing

6.3
6.3.1

Policy WLWP 3 Location of Waste Development

To ensure conformity with the London Plan (2011), the Plan identifies 15.52 ha of land
for the development of waste management facilities to meet the pooled apportionment
for the six West London Boroughs up to 2031.

6.3.2

All existing waste management sites in the six Boroughs, allocated existing sites with
potential for redevelopment, and new allocated sites are safeguarded for waste
management uses under this Plan, unless an equal and compensatory suitable,
acceptable and deliverable site can be provided, or there is an appropriate level of
movement up the waste hierarchy.

6.3.3

The Plan identifies the safeguarded existing sites and proposed sites considered
appropriate and suitable for waste management development as set out in Table 5-1
and Table 5.2. Policy WLWP 3 sets out the key criteria against which planning
applications for waste management capacity will be determined.

6.3.4

Policy WLWP 3 also sets out the circumstances under which development proposed
on unallocated or new sites may also come forward.

6.3.5

Assessments of ongoing requirements for capacity to meet the London Plan

27a

Provision would not constrain movement up the waste hierarchy

27b

Existing waste management sites are those sites managing waste which are lawfully permitted to do so as set

out in Appendix 2. The latest list of existing waste management sites will be found in Authority Monitoring Reports.
Safeguarded existing permitted facilities will be shown on the Policies Maps associated within each Boroughs Local
Plan.
26

permitted = granted planning permission

27c

As stated in paragraph 5.14 the Quattro site is subject to HS2 safeguarding direction and therefore may be

expected to be developed as an exception to this policy until 2024

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apportionment will take account of the most recent monitoring of the implementation of
the Plan.
Policy WLWP 3 Location of Waste Development
Waste development proposals on existing waste management sites 28A and the sites
listed in Table 5-2 will generally be supported, provided that the proposals comply
with the Development Plan for the area.
33TP

P33T

Waste development on other sites will be supported in principle if the proposals

comply with the other WLWP policies and the Boroughs and OPDC's adopted
development plans, and:
a. It can be demonstrated that the development cannot be delivered at any
available and suitable existing waste management site within the Borough 27
where the development is proposed and at the sites listed in Tables 5-1 and
5-2; and
SS

b. In the case of facilities proposed for the management of MSW and C&I
waste, identified sites in Tables 5-1 and 5-2 have not come forward and it can
be demonstrated that there will be a shortfall in the waste management
capacity required to meet the Boroughs joint apportionment target as
specified in Policy WLWP 1; and
c. There is no adverse cumulative effect, when taken together with existing
waste management facilities, on the well-being of the local community,
including any significant adverse impacts against the WLWP sustainability
objectives (see Appendix 1); and
d. The proposed site meets the criteria set out in the subsequent WLWP
Policies if applicable.

6.4
6.4.1

Policy WLWP 4 Ensuring High Quality Development

Modern waste management facilities should bring a benefit to the community and
environment. Policy WLWP 4 provides a range of criteria to ensure developers
consider and mitigate the impacts of their development on the environment, the
community and the appearance of the local area. Developments should also comply
with the London Plan, any relevant Borough or OPDC Local Plans, Development

28A

Existing waste management sites are those sites managing waste which are lawfully permitted to do so as set
out in Appendix 2. The latest list of existing waste management sites will be found in Authority Monitoring Reports.

27

Prospective developers are encouraged to contact the local planning authority for pre-application advice on
suitability of existing sites. Suitability may be taken to mean capable of accommodating the type and scale of
activity proposed including consideration of any specific requirements that arise from the Plan policies and
operational needs

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Management Policy documents, Site Allocations and Area Action Plans.

6.4.2

As a general principle, all waste management developments will be expected to

complement the surrounding area and act as a good neighbour to all existing and
proposed uses 28 on neighbouring land and in the vicinity.
P

6.4.3

Noise, litter and all other emissions (including those to air and water) must be
adequately controlled so as not to cause any adverse impact on the surrounding area.
Developers will be expected to submit details of proposed control measures with any
planning application. Where proposals involve operations which could result in fugitive
emissions (e.g. noise, dust, litter etc.) there is an expectation that such operations will
be properly contained and normally this will be achieved by enclosing operations
within a covered building enclosed with vertical sides with defined access and egress
points 29A .
33TP

P33T

6.4.4

Developers will be expected to have actively considered innovative and sustainable

design approaches to ensure that the development is in accordance with best practice
and complements the local area in terms of topography, landscape and setting.
Where necessary a Design and Access statement should be submitted to set out
matters which include how the facility complements the local area and ensure that
there is no significant effect on existing transport facilities, Public Rights of Way, or
public safety.

6.4.5

Where sites include, or are likely to have an impact on the setting of a heritage asset,
including archaeology, it should be demonstrated that the development will conserve
the asset. Where the site has potential to include assets with archaeological
interest, such as if it is in an archaeological area identified in a local plan or may affect
a site recorded on the Greater London Historic Environment Record, an
appropriate desk based assessment and where necessary, a field evaluation, will be
required to accompany the planning application. Where such assessment and
evaluation confirms a significant archaeological interest then appropriate mitigation by
design or investigation will also be required.

6.4.6

The road network within West London is often congested and therefore proposals
must demonstrate active consideration of transport modes other than by road. There
must not be any significant or unacceptable adverse impacts on the local road network
or other road users, in terms of congestion or parking associated with the

28

Proposed uses are those which have been granted planning permission and those allocations set out in adopted
DPDs on neighbouring land and in the vicinity.

29A

Proposed control measures including the possible full enclosure of the waste handling (including processing and
storage) operations where the site is located within an AQMA. The potential for waste handling activities to
adversely affect air quality will depend both on the nature of materials and the processes to which they will be
subjected. The requirement for full enclosure will take into account the likely impact that the waste handling
operations will have on the achievement of the objectives of the relevant AQMA designation. Advice on the
application of this requirement to a specific proposal should be sought from the local planning authority at preapplication stage.

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development. Proposals should demonstrate that adequate parking for all vehicles is
available on site.
6.4.7

If the proposed waste management development is required to have an Environmental

Impact Assessment, then a Health Impact Assessment is also required.

6.4.8

The management of waste in accordance with the waste hierarchy is a key element of
European, national and regional policy. The West London Boroughs and OPDC
support the increased management of wastes as far up the hierarchy as possible and
each of the six Boroughs and OPDC has a commitment to waste minimisation and
recycling/reuse. Waste minimisation is also an important issue to the residents and
community within West London.

6.4.9

The West London Boroughs and OPDC support the use of local, reclaimed,
renewable, recycled and low environmental impact materials in construction and
estate management. Their details should be considered and included within the
sustainable design and construction statement. Materials should be sourced from
within 100km from the site, where available and appropriate.

6.4.10

Development should not exacerbate flood risk and should take place in accordance
with the Environment Agencys policies on the protection of groundwater.

Policy WLWP 4 Ensuring High Quality Development

All waste development proposals will be required to demonstrate, for both the
construction and operational phases of the development, that:
a. Development will be permitted only where it can be shown that unacceptable
impact to local amenity will not arise from the construction and operation of a
facility;
b. Adequate means of controlling noise, vibration, dust, litter, vermin, odours,
air and water-borne contaminants and other emissions are incorporated into
the scheme29
P

c. The development is of a scale, form and character appropriate to its location

and incorporates a high quality of design, to be demonstrated
d. through the submission of a Design and Access statement 30 as appropriate;
P

29

Where necessary, this is to be demonstrated through the submission of noise, air, odour and vibration surveys,
impact assessments and proposed mitigation measures

31A

It should be assumed that waste management proposals will require a Transport Assessment although the need
for one should be confirmed with the Highway Authority at the earliest opportunity.

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e. Active consideration has been given to the transportation of waste by modes

other than road, principally by water and rail and this has been incorporated
into the scheme or proven not to be practicable;
f.

Transport directly and indirectly associated with the development will not
exceed the capacity of the local road network or result in any significant
adverse impact on the amenities of the area. Where necessary, this is to be
demonstrated by a Transport Assessment 31A ;
33TP

P33T

g. An appropriate BREEAM 31 or CEEQUAL 32 rating, as specified in Borough

Development Plans, will be achieved;
P

h. The development has no significant adverse effects on local biodiversity and

it can be demonstrated that there will be no significant adverse impacts or
effects on the integrity of an area designated under the Habitats Directive;
i.

There would not be a significant impact on the quality of surface and

groundwater. The development incorporates the principles of Sustainable
Drainage Systems (SUDS) unless evidence is provided to justify alternative
drainage methods;

j.

There will be no increased flood risk, either to the immediate area or

indirectly elsewhere. Where necessary 33A , this is to be demonstrated by a
Flood Risk Assessment;
33TP

P33T

k. Green Travel Plans have been considered, where appropriate 33B .

33TP

l.

P33T

The site does not contain features, or will not lead to substantial harm to, or
loss of significance of, any heritage assets such as conservation areas,
archaeological sites, listed buildings etc;

m. There is no foreseeable adverse impact on health, and where necessary this

30

Not all developments will need a Design and Access Statement - the need for such a statement is specified in
legislation and reflected in local validation lists.

31

BREEAM: Building Research Establishment Environmental Method an established method of assessing, rating
and certifying the sustainability of buildings. www.breeam.org

32

CEEQUAL: Civil Engineering Environmental Quality Assessment and Award Scheme a UK industry evidence

scheme for assessing environmental and sustainability performance in civil engineering, infrastructure, landscaping
and public realm projects. www.ceequal.comb
33A

As specified by the National Planning Practice Guidance

33B

It should be assumed that waste management proposals will require a Green Travel Plan although the need for
one should be confirmed with the Highway Authority at the earliest opportunity.

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is to be demonstrated by a Health Impact Assessment.

In addition:
n. Adjacent development proposals which would prevent or prejudice the use
of safeguarded sites for waste purposes will be resisted unless suitable
alternative provision is made.
o. Applications shall provide details of the management arrangements for
residues arising from any waste management facility.

6.5
6.5.1

Policy WLWP 5 Decentralised Energy

New waste management and recycling methods can offer more efficient use of
resources than existing waste management methods. Waste management facilities
can also contribute to the provision of decentralised energy by providing heat and
power for use in domestic and industrial processes.

6.5.2

The London Plan and emerging national planning policy guidance encourages
boroughs to take opportunities for the development of combined heat and power
technologies.

Policy WLWP 5 Decentralised Energy

All waste management facilities that are capable of directly producing energy or a
fuel must secure, where reasonably practicable:
The local use of any excess heat in either an existing heat network or through the
creation of a new network;
The use of biogas/syngas in Combined Heat and Power facilities, either directly
through piped supply or indirectly through pressurisation and transport;
The use of any solid recovered fuel in Combined Heat and Power facilities or as a
direct replacement for fossil fuels in London; or
Any other contribution to decentralised energy in London.
Where it is demonstrated that the provision of decentralised energy is not
economically feasible or technically practicable, the development shall not preclude
the future implementation of such systems.
Energy from waste facilities will only be considered where it can be demonstrated
that they qualify as a recovery operation as defined in the Waste Framework

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Directive. Proposals for Energy from Waste should demonstrate that they will not
compromise the management of waste in accordance with the waste hierarchy
requirement of the Waste Framework Directive.

6.6
6.6.1

Policy WLWP 6 Sustainable Site Waste Management

The management of waste in accordance with the waste hierarchy is a key element of
European, national and regional policy. The West London Boroughs and OPDC
support the increased management of wastes as far up the hierarchy as possible and
each of the six Boroughs has a commitment to waste minimisation and
recycling/reuse. Waste minimisation is also an important issue to the residents and
community within West London.

6.6.2

The West London Boroughs and OPDC support the use of local, reclaimed,
renewable, recycled and low environmental impact materials in construction and
estate management. Their details should be considered and included within the
sustainable design and construction statement and the Site Waste Management
Plans. Materials should be sourced from within 100km from the site, where available
and appropriate.

6.6.3

Site Waste Management Plans are intended to do the following:

Describe each type of waste expected to be produced

Estimate the quantity of each type of waste

Identify the waste management action for each type of waste including reusing, recycling, recovery or disposal.

Once the development has commenced the developer should ensure the following
takes place with respect to the plan:

Review and update the plan

Record quantities and types of waste produced

Record the types and quantities of waste that have been:

Reused (on or off site)

Recycled (on or off site)

Sent of other forms of recovery (on or off site)

Sent to landfill

Otherwise disposed of

The Site Waste Management Plan should be updated to reflect the progress of the
project.

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Policy WLWP 6 Sustainable Site Waste Management

To encourage sustainable waste management, waste management developments
will be permitted where it can be demonstrated that:

6.7
6.7.1

a.

At least 10% of the materials or products used in the construction and

operation of the development are re-used or recycled and sourced from
within 100km from the site;

b.

Construction, demolition and excavation wastes are minimised and then

reused or recycled on site, where practicable and environmentally
acceptable; and

c.

Site Waste Management Plans are comprehensive and capable of being

delivered.

d.

Where on-site management of waste is not possible, active consideration

has been given to the transportation of construction, demolition and
excavation wastes away from the site by modes other than road, principally
by water and rail and this has been incorporated into the scheme or proven
not to be practicable.

Policy WLWP 7 National Planning Policy Framework: Presumption in Favour

of Sustainable Development
The National Planning Policy Framework 2012 introduced the presumption in favour of
sustainable development which applies to waste development.

Policy WLWP 7 National Planning Policy Framework: Presumption in Favour

of Sustainable Development
When considering development proposals, boroughs will take a positive approach
that reflects the presumption in favour of sustainable development contained in the
National Planning Policy Framework. They 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.
Planning applications that accord with the policies in this waste plan (and, where
relevant, with policies in neighbourhood plans) will be approved without delay,
unless material considerations indicate otherwise.
Where there are no policies relevant to the application or relevant policies are out of
date at the time of making the decision then the borough or OPDC will grant
permission unless material considerations indicate otherwise taking into account
whether:

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a. 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
b. Specific policies in the NPPF indicate that development should be restricted.

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Monitoring of the West London Waste Plan

7.1
7.1.1

Monitoring Mechanisms and Proposed Indicators

Once the West London Waste Plan is adopted, the implementation and effectiveness
of its policies will be reported each year in each of the Boroughs and OPDC's
Authority Monitoring Reports. Monitoring will involve the collation of data to check
progress against the Plans objectives and implementation of the Plans policies. For
example, this mechanism will enable the West London Boroughs and OPDC to
compare quantities of waste actually produced with those forecast and to monitor
development on the sites identified in the Plan. The Boroughs will then consider
whether the allocation of sites is sufficient and whether the Plan needs reviewing and
updating.

7.1.2

The proposed indicators to be used to report progress for each borough, the OPDC
and the six combined West London Boroughs (including OPDC) comprise:

Quantity of each type of waste produced;

Capacity (maximum permitted throughput in tonnes per annum) of new waste

management facilities given planning permission in the previous year:

separately for MSW, C&I and CD&E

recycling and composting

other recovery

landfill;

Additional waste management capacity (maximum permitted throughput in

tonnes per annum) on:
o

sites allocated within the West London Waste Plan, and

non-allocated sites;

Loss of waste management capacity on:

sites identified as contributing to the London Plan (2011) apportionment

other sites;

The quantity (maximum permitted throughput in tonnes per annum) of

consented capacity that is actually active in any given year - active being
accepting waste;

The quantity (maximum permitted throughput in tonnes per annum) of

consented capacity that is under construction in any given year;

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The quantity of municipal waste (tonnes) managed in the following ways:

o

Re-use;

recycling;

Composting

other recovery;

landfilled (showing whether management took place within or beyond

the Plan area (where known);

Comparison of municipal and commercial & industrial waste that is recovered

compared with the apportionment targets set out in the London Plan (2011).
This should show whether management took place within or beyond the Plan
area (where known);

Tonnage of construction, demolition and excavation waste managed, showing

management method and whether management took place within or beyond
the Plan area (where known);

The quantity of recycled aggregates produced and other waste which could be
used in place of primary materials following processing (in the Plan area);

Tonnage of hazardous waste produced and managed, showing if management

took place within or beyond the Plan Area;

Amount of energy produced and delivered using waste as a fuel source; and

Other indicators that may be decided to measure performance against policies

and/or the Sustainability Indicators set out in the Sustainability Appraisal.

the number of sites consented that offer non-road transport options, the
number of those sites where such options have been implemented and the
total tonnage transported through non-road options where known.

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7.1.3

Where monitoring identifies that there is a major failure to meet the targets for waste
management within the Plan area the six West London Boroughs and OPDC will seek
to identify the reasons why this is occurring and take effective management measures
to rectify any problems that may put delivery of the Plans strategy at risk. The triggers
for such an investigation are included in table 7-1.

7.1.4

Table 7-1 indicates how the policies of the Plan will be monitored.
Table 7-1 Monitoring programme for the West London Waste Plan

WLWP
Policy &
Strategic
Objective

Indicator

Reason

Delivery

Delivery
Agency

Trigger for
review of
Plan/policy

Policy
WLWP 2
&3

Number and capacity

of safeguarded sites
and amount of any
compensatory land
provided

To ensure no loss
of waste capacity in
the West London
area

The planning
process

Local
Authorities

The waste
management
capacity
provided by
existing and
allocated sites
falls to a level
10% below or
rises to a level
10% above
that required
by the London
Plan
apportionment.

Waste
industry
Developers

Objectives
1, 2, 5

Policy
WLWP 4

Objectives
1, 3, 4, 5

Number, type and

capacity of waste
facilities approved and
completed at
safeguarded sites and
new identified sites
Impact of new sites
measured using:
1. Number of sites
failing to comply with
any relevant
environmental permit
2. Number of
enforcement
complaints breaches
of conditions

Compliance with
sequential policy
approach
To ensure
adequate waste
capacity is being
provided
To ensure sites are
not causing harm to
the environment or
communities
including heritage
assets

3. Negative
impact/damage to
heritage asset or
setting

The planning
process and
combined
private and
public initiative
to provide
waste
management
developments

West London
Waste
Authority

Waste
industry

1. 10% of
existing sites
are failing to
comply with
any relevant
environmental
permit.
2.
Substantiated
complaints
regarding
permitted
waste sites
exceed one
per borough in
any six month
period.
3. Breaches of

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WLWP
Policy &
Strategic
Objective

Indicator

Reason

Delivery

Delivery
Agency

Trigger for
review of
Plan/policy
conditions
exceed one
per borough in
any six month
period.
4. One existing
waste site
causes a
negative
impact or
damage to a
heritage asset
or setting
(confirmed by
English
Heritage).

Policy
WLWP 5

Amount of energy
produced and
delivered

Objectives
1, 3, 5

Policy
WLWP 6

Amount of construction
waste sent to landfill

To ensure
compliance with the
aims of the London
Plan (2011) and
prescribed carbon
savings

Through the
planning and
permitting
process.

To monitor
progress towards
Plan strategy of
zero waste to
landfill.

Use of Site
Waste
Management
Plans;
monitoring and
enforcement of
these and
planning
conditions

Developers

To ensure
compliance with the
NPPF

Through the
planning
process

Developers

Objectives
1, 2, 5

Policy
WLWP 7

Objectives
1, 5

The success of the

implementation of
Policy WLWP 7 will be
dependent on the
success of
implementation of all
other policies

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Local
Authorities
Waste
industry
Developers

West London
Boroughs

One existing
permitted
thermal
treatment
facility
operating
without
harnessing
energy
Amount of
construction
waste sent to
landfill (for
nonengineering
purposes)
exceeds
London Plan
landfill
diversion
targets

N/A

West London
Boroughs

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7.2

The Boroughs and OPDC will carry out appropriate inspections of waste facilities when investigating
compliance with planning conditions and possible breaches of planning control.

7.3
7.3.1

Review of the West London Waste Plan

The Plan will be reviewed following adoption of the Further Alterations to the London
Plan (FALP) and any other changes to the policies of the London Plan and at least
every five years. In part this is to ensure that the Plan is still meeting the apportionment
requirements of the London Plan (2011) and to take into account any changes to waste
management capacity and the need for the identified sites.

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Glossary

Term/Acronym

Definition

Anaerobic
Digestion (AD)

A process whereby biodegradable material is broken down in the

absence of air (oxygen). Material is placed into a closed vessel and
in controlled conditions it breaks down into digested material and
biogas.

Apportionment

Please see London Plan (2011) Apportionment.

Area Action Plan

Type of Local Development Document focused on a specific

location or area which guides development and improvements. It
forms one component of a Local Plan.

Autoclave

A method of sterilisation. Waste is loaded into a rotating sealed

cylinder and the biodegradable fraction of this waste is then broken
down by steam treatment into a homogeneous fibre.

Biodegradable

Biodegradable materials are generally organic, such as plant and

animal matter. They can be chemically broken down by naturally
occurring micro-organisms into simpler compounds. Waste which
contains organic material can decompose producing bio-gas
(methane) and other by-products.

Biodegradable
Municipal Waste
(BMW)

Waste from households and similar that is capable of undergoing

natural decomposition such as paper and cardboard, garden and
food waste. Typically BMW makes up around 68% of residual
municipal solid waste (MSW).

Biogas

Biogas is a gaseous fuel, especially methane, produced by the

fermentation of organic matter

Civic Amenity
Site (CAS)

Facilities where members of the public can bring a variety of

household waste for recycling or disposal. Materials accepted
include, for example: paper, plastic, metal, glass and bulky waste
such as tyres, refrigerators, electronic products, waste from DIY
activities and garden waste. These sites are also known as
HWRCs (Household Waste Recycling Centres), or RRCs (Reuse
and Recycling Centres).

Climate Change

Regional or global-scale changes in historical climate patterns

arising from natural and/or man-made causes that produce an
increasing mean global surface temperature.

Clinical Waste

Waste arising from medical, nursing, veterinary, pharmaceutical,

dental or related practices, (where risk of infection may be
present).

Combined Heat
and Power
(CHP)

The use of heat (usually in the form of steam) and power (usually
in the form of electricity). The heat can be used as hot water to
serve a district-heating scheme while power is generally supplied
to the National Grid.

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Term/Acronym

Definition

Commercial and
Industrial Waste
(C&I)

Waste arising from business and industry. Industrial waste is waste

generated by factories and industrial sites. Commercial waste is
waste produced from premises used for the purpose of a trade or
business or for sport, recreation or entertainment and arising from
the activities of traders, catering establishments, shops, offices and
other businesses. Commercial and Industrial waste may, for
example, include food waste, packaging and old computer
equipment.

Composting

A biological process which takes place in the presence of oxygen

(i.e. it is aerobic) in which organic wastes, such as garden and
kitchen waste are converted into a stable granular material. This
material (compost) can be applied to land to improve soil structure
and enrich the nutrient content of the soil.

Construction,
Demolition and
Excavation
Waste (CD&E)

Waste arising from the construction, maintenance, repair and

demolition of roads, buildings and structures. It is mostly composed
of concrete, brick, stone and soil, but can also include metals,
plastics, timber and glass. Generally collected in skips or trucks.

Department for
Communities
and Local
Government
(DCLG)

Government department with overall responsibility for, amongst

other things, the planning system.

Department for
the Environment
Food and Rural
Affairs (DEFRA)

Government department with national responsibility for waste

management policy amongst other things.

Development
Management
Document

A set of criteria-based policies in accordance with the Local Plan,

against which planning applications for the development and use of
land and buildings will be considered. Also known as Site
Development Policies.

Energy from
Waste (EfW)

Energy that is recovered through thermally treating waste. EfW is

also used to describe some thermal waste treatment plants.

Energy
Recovery

The combustion of waste under controlled conditions in which the

heat released is captured to provide hot water and steam (usually)
for electricity generation (see also Recovery). For waste sent to
energy from waste plants to qualify as recovery they should meet
the R1 formula specified in the revised Waste Framework
Directive.

Environment
Agency (EA)

Environmental regulatory authority formed in 1996, that issues and

monitors compliance with environmental permits. Referred to as a
'pollution control authority'

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Term/Acronym

Definition

European Waste
Catalogue
(EWC)

A comprehensive listing of all wastes. Wastes are categorised

using a 6 digit code which identifies the source of the waste. For
example, EWC code 20.01.01 is paper and cardboard, separately
collected from municipal waste, whereas 20.03.01 is mixed
municipal waste. The full catalogue can be downloaded from:
http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=CONSLEG:2000D
0532:20020101:EN:PDF
48T

Environmental
Permit (EP)

A permit issued by the Environment Agency to regulate the

operation of a waste management activity. Formerly known as a
Waste Management Licence or PPC permit.

Examination

Process presided over by an Inspector appointed by the Secretary

of State; this can consist of hearing sessions, or consideration of
written representations to consider whether the policies and
proposals of the local planning authoritys Local Development
Documents are sound. Only persons who have made
representations seeking change to a Local Development
Document at the submission stage are entitled to an oral hearing at
the examination.

Gasification

The thermal breakdown of organic material by heating waste in a

low oxygen atmosphere to produce a gas. This gas may then be
used to produce heat/electricity or as a fuel/feedstock.

Greater London
Authority (GLA)

Strategic citywide government for London. It is made up of a

directly elected Mayor the Mayor of London and a separately
elected Assembly the London Assembly.

Green Belt

A planning designation intended to check the unrestricted sprawl of

large built-up areas; to prevent neighbouring towns from merging
into one another; to assist in safeguarding the countryside from
encroachment; to preserve the setting and special character of
historic towns; and to assist in urban regeneration, by encouraging
the recycling of derelict and other urban land.

Green Waste

Organic waste from households, parks, gardens, wooded and

landscaped areas such as tree prunings, grass clippings, leaves
etc.

Greenhouse
Gas

A gas in the Earths atmosphere that traps heat and can contribute
to global warming. Examples include carbon dioxide and methane.

Ha

Hectare (10,000m of area, which is equivalent to 2.47 acres).

Habitat Directive
Assessment

This is a requirement of the European Habitats Directive. Its

purpose is to assess the predicted impacts of plans and projects on
internationally designated sites and nature conservation sites.

Hazardous
Waste

Waste that has potentially damaging properties which may make it

harmful to human health or the environment. It includes materials
such as asbestos, fluorescent light tubes and lead-acid batteries.
The European Commission has issued a Directive on the
controlled management of hazardous waste; wastes are defined as
hazardous on the basis of a list created under that Directive.

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Term/Acronym

Definition

Heritage Asset

A building, monument, site, place, area or landscape identified as

having a degree of significance meriting consideration in planning
decisions, because of its heritage interest. Heritage asset includes
designated heritage assets and assets identified by the local
planning authority (including local listing).

Household
Waste

Waste from homes or other specified premises, including waste

taken to household waste recycling centres.

Household
Waste Recycling
Centre (HWRC)

Facilities to which the public can bring household waste, such as

bottles, textiles, cans, paper, green waste and bulky household
items/waste for free disposal. Otherwise known as Reuse &
Recycling Centres or Civic Amenity Sites.

Incineration

The burning of waste at high temperatures in the presence of

sufficient air to achieve complete combustion, either to reduce its
volume (in the case of municipal solid waste) or its toxicity (such as
for organic solvents). Municipal solid waste incinerators can
recover power and/or heat. Incinerators are often referred to as
EfW (energy from waste) plants.

Industrial
Business Park
(IBP)

Strategic employment location designed to accommodate general

industrial, light industrial and research and development uses that
require a higher quality environment and less heavy goods access
than a Preferred Industrial Location.

Inert Waste

Waste that does not decompose or otherwise change.

In-vessel
Composting
(IVC)

Process to produce compost from green waste combined with food

waste. It is a controlled process and is capable of treating both
food and green waste by achieving the required composting
temperatures. It is also known as enclosed composting.

Joint Municipal
Waste
Management
Strategy
(JMWMS)

The development of a Municipal Waste Management Strategy is a

dynamic process and results in a clear framework for the
management of municipal waste, and waste from other sectors as
appropriate. It sets out how authorities intend to optimise current
service provision as well as providing a basis for any new systems
or infrastructure that may be needed. The Strategy acts as an up to
date, regularly reviewed, route-map for further investment in
management of MSW generated in the Plan Area.

Kerbside
Collection

Any regular collection of waste/recyclables from premises,

including collections from commercial or industrial premises as well
as from households.

ktpa

Kilo-tonnes per annum (a kilo-tonne is 1,000 tonnes).

Landfill

The disposal of waste onto and into land, in such a way that
pollution or harm to the environment is prevented and, through
restoration, to provide land which may be used for another
purpose.

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Term/Acronym

Definition

Local
Development
Document (LDD)

Local Development Documents are statutory documents prepared

under the Planning and Compulsory Purchase Act 2004, which set
out the spatial planning strategy and policies for an area. They
have the weight of development plan and are subject to community
involvement, public consultation and independent examination.

Local
Development
Framework
(LDF)

LDFs are now referred to as Local Plans. Formerly a portfolio of

local development documents that provides the framework for
delivering the spatial planning strategy and policies for an area.

Local
Development
Scheme (LDS)

A document setting out the local planning authority's intentions for

its Local Development Framework; in particular, the Local
Development Documents it intends to produce and the timetable
for their production and review.

Local Plan

A Local Development Document (formerly known as a Core

Strategy) which provides a written statement of the policies for
delivering the spatial strategy and vision for a borough, supported
by a reasoned justification.

London Plan
(2011)

This is the Spatial Development Strategy for London. This

document was produced by the Mayor of London to provide a
strategic framework for the Boroughs' Local Plans. It was first
published in February 2004 and alterations have since been
published in September 2006, September 2007, February 2008
and July 2011. It has the status of a development plan under the
Planning & Compulsory Purchase Act 2004.

London Plan
(2011)
Apportionment

A given proportion of Londons total MSW and C&I waste

(expressed in tonnes) allocated to each individual borough for
which the borough must identify sufficient sites for managing and
processing waste within their Local Plans.

Materials
Recycling
Facility or
Materials
Recovery
Facility (MRF)

A sorting factory where mixed recyclables are separated into

individual materials prior to despatch to repressors who prepare
the materials for manufacturing into new recycled products or use
as a fuel.

Mechanical
Biological
Treatment
(MBT)

A combination of mechanical separation techniques and biological

treatment either aerobic or anaerobic, or a combination of the
two, which are designed to recover value from and/or treat
fractions of waste to reduce its degradability and amount.

Mechanical Heat
Treatment
(MHT)

A combination of mechanical and heating techniques which are

designed to sterilise, stabilise and treat waste and recover value
from it.

Metropolitan
Open Land

Metropolitan Open Land is afforded the same level of protection as

the Green Belt. Designation is intended to protect areas of
landscape, recreation, nature conservation and scientific interest
within London which are strategically important.

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Term/Acronym

Definition

Municipal Solid
Waste (MSW)

Any waste collected by or on behalf of a local authority. For most

local authorities the vast majority of this waste is from the
households of their residents. Some is from local businesses and
other organisations such as schools and the local authoritys own
waste.

National
Planning Policy
for Waste

Policy document produced by central government relating to

planning for sustainable waste management that sets out a
number of key concepts which should be considered and statutory
requirements of local and regional planning policy documents. First
published in October 2014.

Net selfsufficiency

Situation where there a balance between incoming and outgoing

waste such that the Plan area deals with an equivalent amount of
waste to that produced within its area.

Old Oak and

Park Royal
Development
Corporation
(OPDC)

Tom Cardis or other to fill in definition/explanation

Planning Policy
Statement 10
(PPS10)

Precursor to National Planning Policy for Waste, policy document

produced by central government relating to Planning for
Sustainable Waste Management which sets out a number of key
concepts which should be considered and statutory requirements
of local and regional planning policy documents.

Preferred
Industrial
Location (PIL)

Strategic employment site normally suitable for general industrial,

light industrial and warehousing uses.

Policies Map

Formerly known as the Proposals Map, a map showing the

location of the sites identified in the Plan

Pyrolysis

The heating of waste in a closed environment, in the absence of

oxygen, to produce a fuel and char.

Railhead

This is a terminus of a railway line that interfaces with another

transport mode e.g. road network.

RAMSAR

Sites which are wetlands of international importance designated

under the Ramsar Convention.

Recovery

The process of extracting value from waste materials, including

recycling, composting and energy recovery. For waste sent to
energy from waste plants to qualify as recovery they should meet
the R1 formula specified in the revised Waste Framework
Directive.

Recycling

Recovering re-usable materials from waste for manufacturing into

new products.

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Term/Acronym

Definition

Refuse Derived
Fuel (RDF)

Material produced from waste that has undergone processing that

is suitable for use as a fuel. Processing can include separation of
recyclables and non-combustible materials, shredding, size
reduction, and pelletising. Similar to solid recovered fuel but more
generic.

Residual waste

Residual waste refers to the material that remains that cannot

practicably be recycled, re-used, or composted any further.

Re-use

The re-use of materials in their original form, without any

processing other than cleaning and/or small repairs.

Re-use and
Recycling
Centre (RRC)

Facilities to which the public can bring household waste, such as

bottles, textiles, cans, paper, green waste and bulky household
items/waste for free disposal.

Scoping

The process of deciding the scope and level of detail of the

strategic environmental assessment (SEA) or environmental
impact assessment (EIA) which might be required to support a
planning application.

Section 106
Agreement

A legal agreement between the planning authority (borough) and

the developer, linked to a planning permission, which requires the
developer to carry out works to offset the potential impacts of their
development or to benefit the local community.

Site
Development
Policies

A set of criteria-based policies in accordance with the Local Plan

against which planning applications for the development and use of
land and buildings will be considered. To set out all qualifying site
allocations other than those contained in Area Action Plans.

Site of Special
Scientific
Interest (SSSI)

A statutory designation that gives legal protection to specifically

defined areas which have ecological or geological value.

Site Waste
Management
Plan (SWMP)

A detailed plan setting out how waste will be managed during a

construction project.

Solid Recovered
Fuel (SRF)

These are fuels prepared from non-hazardous waste to be used for

energy recovery that meet a specified quality specification. (May
also be known under more generic name Refuse Derived Fuels or
RDF)

Sound
(Soundness)

According to the NPPF, for a plan to be sound it should be

positive, justified, effective and consistent with national policy.
Justified means that the document must be founded on a robust
and credible evidence base and must be the most appropriate
strategy when considered against the reasonable alternatives.
Effective means that the document must be deliverable, flexible,
and able to be monitored (see para. 1.6.4).

Spatial Planning

Spatial Planning goes beyond traditional land use planning to bring

together and integrate policies for the development and use of land
with other policies and programmes which influence the nature of
places and how they function.

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Term/Acronym

Definition

Special
Protection Areas
(SPA)

An SSSI which is considered to be of international importance

designated under the EC Directive on the Conservation of Wild
Birds.

Statement of
Community
Involvement
(SCI)

A statement of a local authoritys policy for involving the community

in preparing and revising local development documents and for
consulting on planning applications.

Strategic
Employment
Locations
(SELs)

These comprise Preferred Industrial Locations, Industrial Business

Parks and Science Parks and exist to ensure that London provides
sufficient quality sites, in appropriate locations, to meet the needs
of the general business, industrial and warehousing sectors.

Strategic
Environmental
Assessment
(SEA)

A process of incorporating environmental considerations into

policies, plans and programmes. It is sometimes referred to as a
Strategic Environmental Impact Assessment and is a legally
enforced assessment procedure required by European Directive
2001/42/EC.

Sub-Regions

Sub-regions are the primary geographical features for

implementing strategic policy at the sub-regional level.

Sustainable
Waste
Management

Using material resources efficiently to cut down on the amount of

waste we produce and, where waste is generated, dealing with it in
a way that actively contributes to economic, social and
environmental goals of sustainable development.

Sustainability
Appraisal (SA)

A formal process and statutory requirement which analyses and

evaluates the environmental, social and economic impacts of a
plan or programme. May be conducted with SEA.

Sustainability
Appraisal
Commentary

A commentary report that raises sustainability issues relating to the

Issues and Options report.

Syngas

Syngas is short for synthesis gas which is a mixture of carbon

monoxide and hydrogen produced industrially, from the treatment
of waste.

Transport for
London (TfL)

Body responsible for Londons transport system. The primary role

of TfL, which is a functional body of the Greater London Authority,
is to implement the Mayor of Londons Transport Strategy and
manage transport services across London.

Thermal
Treatment

Treatment of waste using heat e.g. incineration, pyrolysis,

gasification, etc.

tpa

Tonnes per annum.

Unitary
Development
Plan (UDP)

A type of development plan introduced in 1986, which was

replaced by Local Development Frameworks, which in turn have
been replaced by Local Plans.

Waste Arisings

The amount of waste generated in a given locality over a given

period of time.

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Term/Acronym

Definition

Waste Collection
Authority (WCA)

Organisation responsible for collection of household wastes e.g.

your local council.

Waste Local
Plan (WLP)

Planning document which provides a basis for the provision of

waste management infrastructure in a sub-region e.g. the West
London Waste Plan (see West London Waste Plan).

Waste Disposal
Authority (WDA)

Organisation responsible for disposing of municipal waste. For

West London this is the West London Waste Authority (WLWA).

Waste Hierarchy

An order of waste management methods, enshrined in European

and UK legislation, based on their predicted sustainability. The
hierarchy is summarised as prevention, preparing for re-use,
recycle/compost, other recovery, dispose.

Waste
Management
Capacity

The amount of waste currently able to be managed (recycled,

composted or recovered) by waste management facilities within a
given area.

Waste
Management
Licence (WML)

Licence required by in most cases where proposes to deposit,

recover or dispose of most waste. These are now known as an
Environmental Permit.

Waste
Minimisation

Reducing the quantity of waste that is produced. This is at the top

of the Waste Hierarchy.

Waste Planning
Authority (WPA)

Local authority responsible for waste planning. In West London

each of the six Boroughs are the Waste Planning Authority for their
respective areas.

Waste Transfer
Station

A facility where waste is delivered for bulking prior to transfer to

another place e.g. landfill. Some sorting may take place there too.

West London
Waste Authority
(WLWA)

West Londons statutory waste disposal authority. The WLWAs

main function is to arrange the disposal of waste collected by its six
constituent Boroughs.

West London
Waste Plan
(WLWP)

The Waste Local Development Document being produced for West

London (see Waste Local Plan).

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Appendices

Appendix 1: Sustainability Objectives

Appendix 2: Existing Waste Sites in West London
Appendix 3: Supporting Assessments
Appendix 4: General Waste Treatment Facility descriptions
Appendix 5: Borough waste arisings and apportionments
Appendix 6: Descriptions of Allocated Sites
Appendix 7: Relationship between WLWP Plan policies and previously adopted
policies in Boroughs' DPDs

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Appendix 1 Sustainability Objectives

No

Objectives
1

To create conditions to improve health and well being of the community

To improve health and safety of workers

To reduce waste related crime

To actively challenge discrimination in a consistent and comprehensive way and

ensure equal access to waste management services

To promote social inclusion and ensure that waste management sites do not have a
disproportionate effect on communities

To protect, manage and, where possible, improve local environmental quality

(noise, air quality, light, vermin etc.)

To ensure active voluntary and community engagement in decision making for

waste planning

To provide opportunities for waste education and awareness raising

To reduce the need to travel and improve choice and use of more sustainable
transport modes

10

To minimise the impacts of waste related transport by promoting sustainable

transport including rail and water freight transport options

11

To protect and, where possible, enhance biodiversity

12

To protect and improve surface and Groundwater quality

13

To reduce the risk and impacts of flooding

14

To use derelict, vacant or previously developed land and buildings

15

To prevent air pollution or limit it to levels that do not damage natural systems
(including human health)

16

To encourage energy efficiency, maximise use of renewable energy sources and

minimise greenhouse gas emissions

17

To mitigate the impacts of climate change

18

To protect maintain and enhance the quality, integrity and distinctiveness of West
London's open space/green infrastructure, landscape and townscape including its
historic environment and cultural assets

19

To minimise the production of waste and increase reuse, recycling, composting and
recovery rates

20

To improve utilisation of waste related resources

21

To minimise the impacts of hazardous waste

22

To actively promote clean technologies, particularly potential growth sectors of the

economy

23

To ensure that West London uses natural resources more efficiently and
sustainably in particular land, mineral aggregates and water

24

To promote sustainable design and construction techniques for both new and
existing waste management facilities

25

To maximise economic opportunities and benefits for development of waste

management facilities

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To ensure that inward investment projects are environmentally, socially and

economically sustainable

27

To maximise opportunities for the local workforce

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Appendix 2 Existing Waste Sites in West

London
Operator Name

Facility Name

Site Activity

Borough

Ace Waste Haulage

Ltd

Neasden Goods Yard

CDE Waste
Processing/ Transfer

Brent

G. Pauncefort

Steele Road, London

CDE Waste
Processing/ Transfer

Brent

X - Bert Haulage
Ltd.

Neasden Goods Yard

CDE Waste
Processing/ Transfer

Brent

X- Bert Haulage Ltd

(Glynn Skips)

Fifth Way, Wembley

CDE Waste
Processing/ Transfer

Brent

Biffa Waste
Services Ltd

Wembley Transfer
Station & Recycling
Facility

MSW&C&I Waste
Processing/ Transfer

Brent

Seneca
Environmental
Solutions Ltd

Hannah Close,
Neasden

MSW&C&I Waste
Processing/ Transfer
plus biomass CHP

Brent

Veolia

Veolia Transfer
Station, Marsh Road

MSW&C&I Waste
Processing/ Transfer

West London
Waste Authority

Twyford Waste
Transfer Station

Metal & Waste

Recycling Ltd

Counted
Against
Apportionment?

Brent

Brent
(within
OPDC
area)

MSW&C&I Waste
Processing/ Transfer

Mitre Works, Neasden

Goods Yard

Metal Recycling &

Vehicle Depollution

Brent

Brent Oil
Contractors Ltd.

Fourth Way Waste

Transfer Facility

Oil Reclamation
Facility

Brent

Wembley Car
Breakers

Edwards Yard Mount

Pleasant

Vehicle Depollution

Brent

Bridgemarts Ltd
(Gowing & Pursey)

100 Twyford Abbey

Road

CDE Waste
Processing

Brent

London Borough Of
Ealing Council

Acton Waste &

Recycling Centre

Civic Amenity Site

Ealing

London Borough of
Ealing

Greenford Reuse &

Recycling Site,

Civic Amenity Site

Ealing

O C S Group U K
Ltd.

Unit 2 & Yard,

Sovereign Park, Park
Royal Site

Clinical Waste
Transfer

Ealing

Yeoman
Aggregates Ltd

Stone Terminal, Acton

CDE Waste
Processing

Ealing

Quattro (UK) Ltd

Victoria Road, Park

Royal

CDE Waste
Processing/ Transfer

Ealing
(within
OPDC
area)

Bridgemart Ltd
(Gowing & Pursey)

Atlas Wharf

CDE Waste
Processing/ Transfer

Ealing

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Counted
Against
Apportionment?

Operator Name

Facility Name

Site Activity

Borough

Bridgemart Ltd
(Gowing & Pursey)

Horn Lane Waste

Transfer Station

CDE Waste
Processing/ Transfer

Ealing

Iver Recycling (U K)
Ltd

British Rail Goods

Yard, Greenford

CDE Processing/
Transfer

Ealing

D B Schencker Rail
(UK) Ltd.

Willesden Freight
Terminal

Waste Transfer

Ealing

Environmental Tyre
Disposals Ltd

Chase Road, Park

Royal

C&I Waste
Processing

Ealing

London Borough Of
Richmond

Greenford Depot,
Greenford Road,

MSW&C&I Waste
Processing/ Transfer

Ealing

London Auto Parts

Ltd

Alperton Lane,
Wembley

Metal Recycling

Ealing

London Borough of
Harrow

Forward Drive C A
Site, Harrow

Civic Amenity Site

Harrow

Metronet Rail B C V
Ltd

Ruislip Underground
Depot

CDE Waste Transfer

Harrow

Paxton Recycling

Barratt Way,
Wealdstone

MSW&C&I Waste
Processing/ Transfer

Harrow

R J Gower & G G
Gower

Roxeth Green Avenue,

South Harrow

Metal Recycling

Harrow

Harrow Breakers

Pinner View, Harrow

Vehicle Depollution

Harrow

Powerday Plc

Yiewsley Rail Sidings,

Temporary H W R C

Civic Amenity Site

Hillingdon

SRCL Ltd

Hillingdon Hospital

Clinical Waste
Incinerator

Hillingdon

Personnel Hygiene
Services Ltd

Pump Lane Ind.

Estate, Hayes

Clinical Waste
Transfer

Hillingdon

Country Compost
Ltd

Crows Nest Farm,

Harefield

Composting

Hillingdon

West London
Composting Ltd

High View Farm,

Harefield

Composting

Hillingdon

West London
Composting Ltd

Pylon Farm, Harefield

Composting

Hillingdon

A & A Recycling Ltd

Wallingford Road,
Uxbridge

CDE Waste
Processing/ Transfer

Hillingdon

Bridgemart Ltd
(Gowing & Pursey)

Civic Way, Waste

Transfer Station

CDE Waste
Processing/ Transfer

Hillingdon

Envirowayste
(London) Ltd

Trout Lane Depot,

West Drayton

CDE Waste
Processing/ Transfer

Hillingdon

Heathrow Airport
Ltd

Cranford Lane T S,
Heathrow

CDE Waste
Processing/ Transfer

Hillingdon

P G Allen

Allens Yard, Hayes

CDE Waste
Processing/ Transfer

Hillingdon

Uxbridge Skip Hire

Ltd

Harvil Road, Harefield

CDE Waste
Processing/ Transfer

Hillingdon

F M Conway Ltd

Bulls Bridge, Yeading

Brook, Hayes

CDE Waste
Treatment Plus gulley

Hillingdon

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Operator Name

Facility Name

Site Activity

Borough

emptying processing

Counted
Against
Apportionment?
counts as MSW)

Iver Recycling (UK)

Ltd.

Holloway Lane
Materials Recycling
Facility

MSW/ C&I Waste

Processing/ Transfer

Hillingdon

L J Grundon &
Sons Ltd

High View Farm,

Harefield

CDE Waste
Processing/ Transfer

Hillingdon

Hep Oils

Waybeards Farm,
Harefield

Oil Reclamation
Facility

Hillingdon

Kershire Ltd

Station Goods Yard,

West Ruislip

MSW&C&I Waste
Processing/ Transfer

Hillingdon

London Borough Of
Hillingdon

New Years Green

Lane Civic Amenity
Site

Civic Amenity Site

Hillingdon

SITA UK Ltd

Victoria Road Waste

Transfer Station, South
Ruislip

MSW&C&I Waste
Transfer

Hillingdon

Balfour Beatty Rail

Projects Ltd.

Ruislip Depot
Hazardous Waste
Containment Bay

Hazardous Waste
Transfer

Hillingdon

Powerbuild Ltd.

Downes Barns Farm

Golf Course, Northolt

Land Recovery

Hillingdon

B F A Recycling Ltd

New Years Green

Lane, Harefield

Metal Recycling

Hillingdon

SITA Wastecare Ltd

Rigby Lane Waste

Transfer Station

Metal Recycling

Hillingdon

Inactive

Johal Mya Waste

Management Ltd.

Wallingford Road
Recycling Facility

MSW&C&I Waste
Processing/ Transfer

Hillingdon

Car Spares of West

Drayton Ltd

Riverside Cottages,
West Drayton

Vehicle Depollution

Hillingdon

London Borough of
Hounslow Council

Space Waye Civic

Amenity Site

Civic Amenity Site

Hounslow

Heathrow Airport
Ltd

Heathrow Airport
Camp 4

Composting

Hounslow

London Borough of
Hounslow Council

Bridge Road Depot,

Pears Road

CDE Waste Transfer

Hounslow

Fowles Crushed
Concrete Ltd

Bedfont Trading
Estate, Feltham

CDE Waste
Treatment

Hounslow

Day Group Ltd

Brentford Aggregate
Materials Recycling
Facility

CDE Waste, MSW &

C&I Processing

Hounslow

Ron Smith
(Recycling) Ltd

St Albans Farm
Recycling Facility,
Feltham

CDE Waste
Processing/ Metal
Recycling

Hounslow

Rentokil Initial
Services Ltd

Brentford Service
Centre, West Cross Ind
Park

Clinical Waste
Transfer

Hounslow

Veolia E S

Bedfont Way, Feltham

General Waste

Hounslow

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(Metal only)

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Operator Name

Facility Name

Site Activity

Cleanaway (UK) Ltd

Borough

Counted
Against
Apportionment?

Transfer
(CA only)

SITA UK Ltd

Transport Avenue
Transfer Station,
Brentford

MSW & C&I Waste

Transfer & Civic
Amenity Site

Hounslow

Hounslow Homes
Ltd

Ashmead Road Depot

Hazardous waste
transfer

Hounslow

Mayer Parry
Recycling Ltd

Transport Avenue,
Brentford

Metal Recycling

Hounslow

Thames Water
Utilities Ltd

Mogden Sewage
Treatment Works,
Isleworth

Sewage Treatment

Hounslow

Goldstar
Commercials

North Feltham Trading

Est., Feltham

Vehicle Depollution

Hounslow

Whitton Salvage

Kneller Road, Whitton

Vehicle Depollution

Hounslow

London Borough Of
Richmond

Townmead Civic
Amenity Site, Kew

Civic Amenity Site

Richmond

The Royal Botanic

Gardens

The Royal Botanic

Gardens, Kew

Composting

Richmond

London Borough Of
Richmond

Twickenham Depot

CDE Waste Transfer

Oakland Golf &

Leisure Ltd.

Richmond Park Golf

Club

Land Recovery

Richmond

Sharpes Recycle
Oil Ltd.

Arlington Oil
Reclamation Facility,
Twickenham

Oil Reclamation
Facility

Richmond

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Appendix 3 - Supporting Assessments

Strategic Flood Risk Assessment
The Strategic Flood Risk Assessment (SFRA) was undertaken to ensure that flood risk
is considered as part of the spatial planning process. As required by the National
Planning Policy Framework, 2012, we have used the findings of the Strategic Flood
Risk Assessment on regional and local flood risk issues in the assessment of sites
suitable for waste management.
Equalities Impact Assessment
The Equalities Impact Assessment (EqIA) was undertaken to ensure that the West
London Waste Plan does not discriminate against specific target groups. The
Equalities Impact Assessment of the Issues and Options identified the options that
may have a negative impact on certain target groups. Since the development of the
Plans policies, a further assessment has been undertaken and suggested mitigation
has been incorporated into the Plan and Sustainability Appraisal Report. We have
taken this into account when developing the Plan to ensure that no target group
experiences a high level negative impact from the West London Waste Plan. The EqIA
was published alongside the draft Proposed Submission Version of the Plan.
Habitats Regulations Assessment
The Habitats Regulations Assessment relates to Natura 2000 sites designated under
the European Habitats and Birds Directive33 .
P

In October 2009 a screening exercise was carried out to determine the need for a
Habitat Directive Assessment of the potential impacts of the West London Waste
Plans Issues and Options upon any European designated site located within 10 km of
the six West London Boroughs. The report concluded that some of the Issues and
Options had the potential to impact the Natura 2000 sites identified, and that an
Appropriate Assessment and ascertainment of the effect on site integrity was required.
A further screening exercise was undertaken to determine whether any of the recently
developed policies are likely to trigger the need for a full Habitats Directive
Assessment of the Plan, in compliance with the EC Habitats Directive.
The Plan policies have now been updated to incorporate the recommendations from
the Habitats Regulations Assessment Screening. The Screening Report therefore
concludes that the Plan is unlikely to have an adverse effect on the qualifying features
of any Natura 2000 sites and therefore no further work is required.
The Strategic Flood Risk Assessment, Equalities Impact Assessment and Habitats
Directive Screening Assessment can be found at http://www.wlwp.net/.
48T

48T

33

European Directive 992/43/EC on the conservation of natural habitats and of wild fauna and flora and European
Directive 79/409/EEC on the conservation of wild birds.

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Appendix 4: General Waste Treatment Facility

Descriptions
Facility type

General Description

General
Appearance

Anaerobic Digestion

Anaerobic Digestion is only suitable for organic

wastes such as food and garden waste. The
waste is enclosed in tanks without oxygen and
digested to produce a biogas which can be used
as a fuel. A sludge is also produced which can be
composted and used on land.

Large industrial
tanks and
warehouse-type
buildings.

Composting

Composting facilities are generally enclosed in

special units to minimise odours. Enclosed
composting units can compost food and garden
waste collected from homes and businesses.

Generally housed
inside warehouse
type buildings.

Gasification/
Pyrolysis/Autoclave

Advanced thermal treatment technologies are

methods of breaking down waste using heat, to
produce heat and power. Gasification uses a little
oxygen to break the waste down whereas
pyrolysis does not use any oxygen. Such
methods give more control over the process and
reduce emissions. Autoclaving involves cooking
the waste with steam to separate materials to
produce recyclables and fuel.

Industrial type
buildings, normally
with a low chimney.

Materials Recovery
Facility (MRF)

A facility that sorts recyclable material collected

from households or businesses into separate
materials. The materials are then sent for
reprocessing into useful materials or products.

Consists of
mechanical sorting
equipment and
conveyor belts.
Normally housed
inside a warehouse
type building.

Mechanical
Biological
Treatment (MBT)

MBT is generally used to treat residual waste

biologically and mechanically. This separates the
materials suitable for recycling from an organic
fraction which may be used as a fuel or can be
composted.

Generally housed
inside warehouse
type buildings.

Recycling and
Reuse Centre
(RRC)

Site for the public to take recyclable and general

waste to. The sites normally consist of skips and
containers for a wide range of different materials,
encouraging recycling.

Open facilities with

accessible waste
containers.

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Appendix 5: Borough Waste Arisings and

Apportionments

Waste arising figures London Plan (2011)

Borough

2011

2016

2021

2026

2031

MSW

C&I

MSW

C&I

MSW

C&I

MSW

C&I

MSW

C&I

Brent

136

202

143

200

149

199

156

196

161

194

Ealing

158

232

164

219

170

211

176

209

181

207

Harrow

120

143

123

139

126

136

129

134

131

133

Hillingdon

152

336

157

335

162

338

167

341

171

348

Hounslow

132

231

136

223

140

215

144

212

147

211

Richmond

100

143

103

142

105

141

107

141

109

143

Totals

798

1,287

826

1,258

852

1240

879

1,233

900

1,236

All figures are in a 1000 tonnes. MSW = Municipal Solid Waste C&I = Commercial and
Industrial Waste

Waste apportionment figures London Plan (2011)

Borough

2011

2016

2021

2026

2031

MSW

C&I

MSW

C&I

MSW

C&I

MSW

C&I

MSW

C&I

Brent

90

160

109

174

130

190

152

207

175

225

Ealing

114

202

138

221

165

241

193

262

221

286

Harrow

57

101

69

110

82

120

96

131

111

143

Hillingdon

96

170

116

186

139

202

162

220

186

240

Hounslow

92

165

112

179

134

195

157

213

180

232

Richmond

56

100

68

109

81

119

95

129

109

141

505

898

612

979

731

1067

855

1162

982

1267

Totals

All figures are in a 1000 tonnes. MSW = Municipal Solid Waste C&I = Commercial and
Industrial Waste

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Appendix 6: Descriptions of Allocated Sites

Descriptions of each site allocated in the WLWP are provided below. The descriptions
bring together information collected as part of the process of selecting these sites as
well as that received during stages of consultation on the Plan.
General Information
Suitable waste management technologies
It is considered that the sites would be likely able to accommodate most non-landfill
waste management technologies. Environment Agency permitting rules do not allow
certain activities to operate within certain distances of a sensitive receptor, which
includes a dwelling or workplace, under a standard permit.
Land Contamination
Each allocated site is located on previously developed land but no investigation has
been carried out to establish whether the ground itself is contaminated 34 .
Redevelopment of the sites might therefore require work to decontaminate the sites.
P

Setting Back from Rivers

Where a site is adjacent to a river the Environment Agency has advised that a setback
of a minimum of 8 metres from the top of the bank be incorporated into any
redevelopment proposals. Setting back development from watercourses and providing
an undeveloped buffer zone free from built structures is important for maintaining
access to the river, to allow the riparian landowner access for routine maintenance
activities and for the Environment Agency to carry out Flood Defence duties. It is also
important that a sufficient wildlife and riverside corridor should be maintained to
minimise the potential adverse impacts to the water quality and riverine habitats. This
will provide opportunities for flood risk management in line with the Environment Agency
Catchment Flood Management Plans. Opportunities for river restoration through the
redevelopment of sites should also be encouraged which will also ensure compliance
with requirements under the Water Framework Directive.
Air Quality Management Areas
All sites are located within Local Authority Air Quality Management Areas.
Waste Input tonnages
The input tonnages provided are taken from records provided by the Environment
Agency Waste Data Interrogator for waste inputs for 2011. This information is only
supplied for sites that hold an environmental permit and received waste during the
course of that year.

34

In all cases, in light of current and previous uses it is possible that the sites might be classified as contaminated
land under the Environment Act 1995.

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Site Name

Twyford Waste Transfer Station

Site Ref. No.

352

Locational Information

Borough

Brent

Site Area
(hectares)

1.24

Northing

83461

(Site falls within

OPDC area)

Easting

TQ 19380

Site Address

Twyford Waste & Recycling Centre, Abbey Road, Brent, NW10 7TJ

Site Location

The site is located in a predominantly industrial area.

Neighbouring Uses
(within 250 metres)

The Paddington Branch of the Grand Union Canal, which is a navigable

waterway, follows the south western boundary of the site divided by a 22
metre wide strip of land owned by the adjacent landowner. There are other
industrial properties at varying distances to the north, east, south and west.
The nearest residential properties are located 150m to the west of the site
boundary beyond the industrial estates.

Planning Status

The site benefits from a Certificate of Lawfulness for use as a waste transfer
station (CLUD 92/1830).

Allocation in Borough
Local Plan

No

Current Use

Waste Transfer Station (for trade waste, processing site for waste wood from
WLWA) and Household Waste Site.

Current Vehicle
Movements

HGVs (including articulated lorries and Rollonoffs) and private vehicles

currently deliver waste to the site. Waste is removed by articulated lorries
and Rollonoffs.

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Current Waste Inputs

Input tonnage counted as 22,714 tpa in existing capacity.

Site once operated as a transfer station with an approximate throughput of
125,000tpa.
Maximum current capacity is estimated to be 85-90,000tpa.

Nominal potential
throughput (tpa) (based
on 65,000 per hectare)

57,886 tpa (after deduction of existing capacity contribution)

Environmental Considerations
Access/Highway

The site has a dedicated 100m access onto Abbey Road near to the junction
of the A406 North Circular Road.
The Grand Union Canal follows the south western boundary of the site
divided from the site by a 22 metre wide strip of land owned by the adjacent
landowner.

Archaeology/Historic
Interest

Site contains no known archaeological sites.

CCHP Potential

The site is adjacent to other industrial areas which may be able to utilise heat
and power generated although no anchor load has been identified.

Ecology/HRA

The site is greater than 1km from any internationally/nationally designated

site.

Flood Risk/Water
Protection

The Grand Union Canal follows the south western boundary of the site.

Green Belt

The site is not in or near Green Belt

Landscape/Visual
Impact

The site is on a number of levels. Existing buildings on the site are no more
than 10 metres high at the lower level. There is a 10m high structure on the
highest part of the site.
Views of the site from the north - across the north circular or Abbey Road are
obscured by the old landfill mound.
Views of the site from the south are obscured by large warehouse buildings
on the adjacent site.
Views of the site from the west are across the Grand Union Canal and from
the residential area would be across an industrial area with chimney stacks.

Public Rights of Way

There are no PRoW crossing or immediately adjacent to the site. The Grand
Union Canal Walk runs along the opposite side of the Grand Union Canal

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with views into the site.

Key Development Criteria

Flood Risk

The site is greater than 1ha and so a flood risk assessment that focuses on
the management of surface water run-off will be required.

Neighbouring Land Uses

Proposals should carefully consider existing and proposed neighbouring land

uses and ensure that any development will not result in any significant
adverse impact on these uses. In particular, such impacts will include those
which might arise from the construction and operation of the site and the
movement of vehicles associated with any proposal.

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Site Name

Veolia/Brent Transfer Station, Marsh Road

Site Ref. No.

1261

Locational Information

Borough

Brent

Site Area
(hectares)

2.71

Easting

TQ 17784

Northing

83085

Site address

Veolia Waste Transfer Station, Marsh Road, Wembley, HA0 1ES

Site Location

This site is located in the Alperton Lane Industrial Estate and borders the River
Brent, a railway line, Alperton Lane, a scrap yard and another waste facility.

Neighbouring Uses
(within 250 metres)

There is housing 170 metres to the north west of the site across Alperton Lane
and 130 metres to the south. There are sports fields on the other side of
Alperton Lane. A railway line runs past the southern corner of the site. The site
is above the River Brent which runs adjacent to the south eastern boundary.
There are industrial areas immediately to the west and east of the site.

Planning Status

94/1413 Erection of single detached building in connection with the use of the
site as a waste transfer station.

Allocation in
Borough Local Plan

Site is a designated site in the 'saved' Brent UDP as a Waste Management

Manufacturing Area.

Current Use

Permitted Waste Transfer Station plus Vehicle Depot for Veolia refuse vehicle
fleet serving Westminster & Camden collection contracts and salt store serving
Westminster, Camden and Brent. There are existing, large waste transfer station
buildings on site, and open hard stand areas for storage and vehicle depot
facilities. Existing building heights are approximately 10-18 metres.

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Current Vehicle
Movements

Waste is delivered to the site in refuse vehicles and removed in articulated

HGVs.

Current Waste Inputs

Input tonnage 82,691 tpa counted in existing capacity.

Nominal potential
throughput (tpa)
(based on 65,000 per
hectare)

93,459 tpa (after deduction of existing capacity contribution)

Environmental Considerations
Access/Highway

The site is close to strategic roads A4005, A40 and A406. The site is currently
accessed from the A4005 from Alperton Lane and then along Marsh Road which
runs through an industrial estate including another waste transfer station. The
site has in the past been accessed directly from Alperton Lane.
The River Brent runs along the southern boundary of the site, being a small
tributary running from Brent Reservoir to the River Thames at Brentford.

Archaeology/Historic
Interest

No internationally or nationally designated site present. There is potential for

palaeo environmental remains alongside the River Brent.

CCHP Potential

The site is adjacent to other industrial areas which may be able to utilise heat
and power generated.

Ecology/HRA

Site is within 250m of a SINC designated in the Ealing Local Plan which is of
Grade 1 Borough Importance. It forms part of the much larger Brent River Park:
Hanger Lane to Greenford Line SINC (site 15/EaBI14A).

Flood Risk/Water
Protection

Southern boundary is adjacent to the River Brent

Green Belt

The site is not in or near Green Belt

Landscape/Visual
Impact

The site is level with the surrounding area. Existing buildings on the site are
between 10 and 18 metres high which is in keeping with heights of buildings on
adjacent land.
Distant views from the north would be across the open Alperton Sports Ground.
Views from the east would be from Marsh Lane and would be obscured by light
industrial units.
Views from the south would be from low and high rise office space with views
from the residential area obscured by the railway embankment.

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Public Rights of Way

The pedestrian pavement of Alperton Lane runs adjacent to the sites northern
boundary.

Key Development Criteria

Archaeology

Proposals should be supported by a desk-based assessment unless agreed with

English Heritage.

Flood Risk/Water
Protection

The site is greater than 1ha and so a flood risk assessment that focuses on the
management of surface water run-off will be required. The Environment Agency
advises a setback of a minimum of 8 metres from the top of the bank of the
River Brent must be incorporated into re-development proposals. The site
boundary is itself over 8 metres from the bank.

Visual amenity

Careful attention would be needed to avoid adverse impact on sensitive

receptors including the sports fields to the north of the site.

Access

Any redevelopment would need to pay particular attention to impacts on Marsh

Lane which can be constricted due to vehicles parking on this highway.

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Site Name

Greenford Reuse & Recycling Site & Greenford Depot, Greenford Road

Site Ref. No.

309 & 310

Locational Information

Borough

Ealing

Site Area (hectares)

1.78

Easting

TQ 14334

Northing

81848

Site Address

Greenford Road Reuse and Recycling Centre & Greenford Depot,

Greenford Road, Middlesex, UB6 9AP

Site Location

The site is adjacent to the Greenford Bus Depot and near to Brent River Park.

Neighbouring Uses
(within 250 metres)

There is a bus depot adjacent to the northern boundary of the site. The River
Brent runs along the south-eastern boundary. Beyond the river is Brent River
Park Metropolitan Open Land (MOL). There are residential properties to the
west (separated from the site by a large bus maintenance garage) and also a
school to the north of site.

Planning Status

Consent granted in 1973 for waste use. More recent consents have however
been granted. These include: P/2000/4510 (completed 2004) - The erection
of building for paper and leather storage and two additional bays for storage
of paper and glass for recycling. P/2005/2560 (completed 2006) - The
installation of a new organic waste recycling facility enclosure.

Site Identified in
Borough Local Plan?

Redevelopment of Greenford Depot is covered by policy 4.3 of Ealing

Development (Core) Strategy.

Current Use

Part of the site is a raised split level household waste recycling centre,
located in the north-eastern corner. The recycling centre includes a threesided covered tipping and bulking area (10 metres high from site level 15
metres from ground level) and the remainder of the site is open. Commercial

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waste may also be tipped at the re-use and recycling centre.

The adjacent depot site incorporates various Ealing Council services
including the Ealing Council highways services, street cleansing, grounds
maintenance and refuse vehicle depot. The majority of the allocated depot
site is used for open storage of refuse vehicles. There are two
waste/recycling bulking areas: a small open one and a larger enclosed area.
Baling of recyclable materials takes place on the depot site. Building heights
range from approx. 3-8 metres.
Current Vehicle
Movements

At peak periods approximately 600 vehicles deliver waste to the re-use and
recycling centre which can cause vehicles to queue back to, and onto, the
main highway. Approximately 30% of the waste deliveries is from commercial
sources including transit vans and small lorries. These movements are
additional to those associated with the depot including the waste use.

Current Waste Inputs

The re-use and recycling and recycling centre handles approximately 15,000
tonnes of waste per annum.
The depot receives source segregated and comingled recyclables from
recycling rounds. In total approximately 30,000 tonnes per annum of food
waste and bulky waste is also brought into the depot.
Combined input tonnage 35,610 tpa is counted in existing capacity.

Nominal potential
throughput (tpa) (based
on 65,000 per hectare)

80,285 tpa (after deduction of existing capacity contribution)

Environmental Considerations
Access/Highway

The nearest strategic road (A40) is over a mile away to the north with access
via Greenford Road (a busy thoroughfare). The Depot and Re-use and
Recycling Centre have separate entrances onto the shared access road
which are adjacent to each other. The access onto the highway is shared with
the bus depot to the north of the site. The entrances are lower than the main
highway.

Archaeology

The site is located within the Brent River Valley Archaeological Interest Area
as defined in Ealing Local Plan with some potential for palaeo- environmental
remains but largely former landfill.

CCHP Potential

There are industrial areas adjacent to the site.

Ecology/HRA

The site is greater than 1km from any internationally/nationally designated

site.

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Flood Risk/Water
Protection

Site within Flood Zone 2

Green Belt

The site is not in or near Green Belt.

Landscape/Visual
Impact

There are sensitive receptors in proximity to the site in the form of residential
areas and the River Brent Park. Current noise impact has been mitigated by
erection of an acoustic barrier along north eastern boundary to the rear of
bays.

Public Rights of Way

A PRoW runs alongside the River Brent on the opposite bank but diverts
away before it passes the main body of the depot.

Key Development Criteria

Archaeology

Proposals should be supported by a desk-based assessment unless agreed

with English Heritage

Flood Risk/ Water

Protection

A setback of a minimum of 8 metres from the top of the bank of the River
Brent must be incorporated into re-development proposals. The site is greater
than 1ha and so a flood risk assessment that focuses on the management of
surface water run-off will be required.

Visual and amenity

impact

Redevelopment of the site would need to consider views of the site from the
River Brent Park in particular. Policy 7D of Ealing Development Management
DPD expects a buffer strip to be provided around existing or proposed open
spaces. The depth of the buffer is to be determined having regard to the
particular circumstances of the site and the open space, but would typically
be in the region of 5-10m (see para. E7.D.5). Policy 2.18 of the same
document is also relevant as regards views to and from open space. In
addition impact on residential uses including noise would need to be
mitigated.

Highways

Any redevelopment should seek to mitigate the current congestion on the

highway which occurs at peak times.

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Site Name

Quattro Park Royal

Site Ref. No.

328

Locational Information

Borough

Ealing

Site Area (hectares)

0.7

Northing

82109

(Site falls within

OPDC area)
Easting

TQ 20931

Site Address

Quattro Ltd, Park Royal, Regency Street (off Victoria Road), Park Royal NW10
6NR

Site Location

The site is situated within the Park Royal Industrial Estate situated just off the
A4000 (Victoria Road) adjacent to Old Oak Common rail sidings.

Neighbouring Uses
(within 250 metres)

The site adjoins a distribution depot to the north (this includes the handling of
foodstuffs), a railway line runs along the eastern and southern boundary on an
embankment and to the west is an office block and distribution warehouse.
The nearest residential properties are approximately 40 metres away at Wells
Road (East) with their gardens as close as 25 metres on the other side of the
railway embankment.

Planning Status

Permanent consent granted in 2001 on appeal for continued use of premises

as waste transfer station (ref P/2000/0570).

Allocation in Borough
Local Plan

No

Current Use

A construction materials distribution, concrete batching and waste bulking

depot for excavation waste from utility works. There are two industrial units on
site and several portacabins.

Current Vehicle

The site is currently accessed by HGVs delivering and removing materials and

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Movements

waste to the site plus employees' private vehicles.

Current Waste Inputs

Input tonnage not counted in existing capacity as this is currently utilised for
CDEW.

Nominal potential
throughput (tpa)
(based on 65,000 per
hectare)

45,500 tpa

Environmental Considerations
Access/Highway

The site is accessed from the A4000 (Victoria Road.) Routing is via Victoria
Road to the A40, a route carrying industrial estate traffic.

Archaeology/Historic
Interest

Acton Wells was a mineral bearing spring discovered in the 17th century but
which ceased to be used from the 18th century. No apparent evidence of the
spring onsite.
The site is less than 500m from local nature reserve Wormwood Scrubs.

CCHP Potential

The site is located in a predominately light industrial area which may offer
opportunities for use of space heating generated at the site. In the event that
redevelopment associated with HS2 goes ahead there may be opportunities to
redevelop adjacent land in a manner that allows for the use of any heat and
power generated at this site.

Ecology/HRA

The site is greater than 1km from any internationally/nationally designated

site.

Flood Risk/Water
Protection

There are no open water bodies in proximity to the site.

Green Belt

The site is not in or near Green Belt.

Landscape/Visual
Impact

Existing buildings on the site are around 6 metres high.

Views of the site from the north would be obscured by the distribution
warehouse.
The site currently has 8-10 metre high boundary structures on the eastern
boundary which combined with the railway embankment would reduce any
potential impacts on the residential properties to the east beyond the railway
line.
Views of the site from the south would be obscured by a railway embankment.
Views of the site from the west would be obscured by the office

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block/warehouse on the adjacent site.

Public Rights of Way

There are no PRoW crossing or adjacent to the site.

Key Development Criteria

Archaeology

Applications involving groundworks should be supported by desk-based

assessment, and may require evaluation trenching.

Visual amenity

Careful attention would be needed to avoid adverse impact on sensitive

receptors formed by residential area at Wells House Road (East).

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Site Name

Council Depot, Forward Drive

Site Ref. No.

222

Locational Information

35

Borough

Harrow

Site Area
(hectares)

1.83

Easting

TQ 15830

Northing

89266

Harrow Council Depot, Forward Drive, Harrow, HA3 8NT

60T

Site Location

The site is located directly adjacent to the Forward Drive Civic Amenity (CA)
Site.

Neighbouring Uses
(within 250 metres)

A residential area of two storey dwellings lies immediately to the north of the
site. To the east there is a religious temple and a school across Kenmore
Avenue. To the south is a railway line which runs on an embankment above
the level of the site. Beyond the railway line are prominent industrial units.

Planning Status

Various permissions depending on Unit No and inclusion of adjacent CA

site. Secure Parking Area On Site Of Garages & Loading Platform With
Fencing & Lighting EAST/477/01/LA3 Granted 09/07/2001. (Unit 1). Change
Of Use: Warehouse Storage To Training Facility And Alterations Including:
Fire Escape Canopy Disabled Ramps Bin Enclosure & New Pedestrian
Access To Kenmore Avenue (unit 4) Granted 11/02/2005.

35

This represents the portion of the depot site which may be redeveloped with the CA/WTS site immediately to the
west.

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Allocation in Borough
Local Plan

Allocated for waste management and depot functions.

Current Use

The site comprises a current council works depot and base for other Harrow
Council services. The site has a mixture of vehicle workshops, open hard
stand areas, car parking, office blocks and other buildings varying in size
and construction.

Current Vehicle
Movements

The site is very busy and there is a range of HGVs entering the site as well
as school buses and private vehicles. At peak periods vehicles visiting the
adjacent household waste recycling site queue back to the main road which
hinders access to the depot.

Current Waste Inputs

The Depot site has a registered exemption which recognises existing limited
waste inputs.
The household waste site and WTS component input tonnage of 25,780 tpa
is already counted toward the apportionment so is discounted from overall
capacity contribution.
S

Nominal potential
throughput (tpa)
(based on 65,000 per
hectare)

124,370tpa

Environmental Considerations
Access/Highway

The nearest strategic road is the A409 with the routing via
residential/commercial areas. Emergency access is from Kenmore Avenue.

Archaeology/Historic
Interest

No internationally or nationally designated site present.

CCHP Potential

There are industrial areas adjacent to the site.

Ecology/HRA

The site is greater than 1km from any internationally/nationally designated

site.

Flood Risk/Water
Protection

There are no open water bodies in proximity to the site.

Green Belt

The site is not in or near Green Belt.

Landscape/Visual
Impact

The site is generally well screened. Acoustic screening has been erected
between the residential area in the north and the adjacent CA site. This
screening does not currently extend along the northern boundary of the

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depot where normal fencing is in place.

Public Rights of Way

There are no PRoW crossing or immediately adjacent to the site.

Key Development Criteria

Local amenity

Development of a waste facility on site would need to result in an overall

improvement to the existing levels of amenity (noise, odour and dust
emissions) experienced by neighbouring uses, especially the residential
area to the north of the site, through enclosing any new facility, as well as
the existing civic amenity facility.

Access

Redevelopment of the site would need to take into account the cumulative
congestion created by vehicles entering the depot and the adjacent
household waste recycling site. Proposals would need to provide for
adequate circulation arrangements within the site. There is scope for one
way routing to be established on approach roads for HGVs.

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Site Name

Rigby Lane Waste Transfer Station

Site Ref. No.

331

Locational Information

Borough

Hillingdon

Site Area (hectares)

0.91

Easting

TQ 082

Northing

798

Site Address

SITA UK Ltd, 1 Rigby Lane, Hayes, Middlesex, UB3 1ET

Site Location

The site is located within an established industrial estate approximately

1.3 kilometres south west of Hayes town centre, 1.3 kilometres north of
the M4 Motorway and south of the Grand Union Canal.

Neighbouring Uses
(within 250 metres)

The site is surrounded immediately to the north, east and west by

commercial/industrial units. To the south it adjoins an elevated section of
land occupied by Crossrail and the existing railway. To the north of the
site is the Grand Union Canal. The nearest residential housing is
approximately 70m away beyond the railway embankment. The northern
boundary of the site faces onto the main access road (Rigby Lane) to the
industrial estate. Across the road is an industrial unit and beyond that a
band of trees shields the Grand Union Canal from view. The surrounding
building heights vary greatly between 3-35m high with a concrete
batching plant circa 15m high in view from the site.

Planning Status

Planning permission exists for waste management comprising a Waste

Transfer Station and overnight parking for goods vehicles. The existing
permission also consents operation of a Civic Amenity Site (CA) in the
north-western corner of the site, although this has not been
implemented.

Allocated in Borough

No

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Local Plan
Current Use

The site currently operates as a waste management facility comprising a

Waste Transfer Station (WTS). The Transfer Station building is
approximately 8 metres in height. There is also an office building and
weighbridge on site. The site has been operating as a waste facility for
over two decades and did until 2008 operate a dual facility including a
CA site for members of the public.

Current Vehicle
Movements

The site is accessed by HGVs and employee's private vehicles.

N.B. There is no planning condition that limits the number of vehicle
movements that may be used to deliver waste.

Current Waste Inputs

Input tonnage 25,280 tpa counted in existing capacity.

Existing planning condition limiting daily inputs to 1,030 tonnes.

Nominal potential
throughput (tpa) (based
on 65,000 per hectare)

33,870 tpa (after deduction of existing capacity contribution).

Environmental Considerations
Access/Highway

Vehicular access to the site is from three priority junctions that connect
onto Rigby Lane at the sites north-eastern and north-western
boundaries. The north-eastern boundary of the site is currently designed
to accommodate vehicular traffic movements associated with the WTS
whilst the north-western access combines public access to the
consented (as yet unbuilt) CA alongside HGV ingress for permitted CA
collections. Egress by HGVs collecting from the CA occurs from the WTS
access.

Archaeology/Historic
Interest

Lies in vicinity of significant Palaeolithic finds.

CCHP Potential

There are industrial areas adjacent to the site.

Ecology/HRA

The site is greater than 1km from any internationally/nationally

designated site.

Flood Risk/Water
Protection

There are no open water bodies in proximity to the site. Grand Union
Canal across the road & Stockley Road lake is to south west.

Green Belt

The site is near (55m) to Green Belt north of the Grand Union Canal.

Landscape/Visual
Impact

The site is not overlooked by sensitive receptors. Tall structures

including concrete batching plant visible from site.

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Public Rights of Way

The pedestrian pavement of Rigby Lane runs alongside the road

adjacent to the main access road.

Key Development Criteria

Archaeology

Proposals should be supported by a desk-based assessment unless

agreed with English Heritage

Landscape/Visual
Impact

The site falls within a height restriction zone with limits applied.

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Site Name

Twickenham Depot

Site Ref. No.

342

Locational Information

Borough

Richmond Upon
Thames

Site Area (hectares)

2.67

Easting

TQ 15163

Northing

73590

Site Address

Twickenham Central Depot,

Langhorn Drive, Twickenham Middlesex, TW2 7SG

Site Location

To the north is the Harlequins Rugby ground (The Stoop). The land
immediately abutting the northern edge of the Depot is an open tarmacked area
(used for a hospitality marquee by Harlequins Rugby stadium on match days).
To the North East is a 4 storey residential block fronting Langhorn Drive. To
the east is public open space including a childrens playground. To the south is
a railway line and across the railway line is open space. To the west is the
Duke of Northumberlands River (a branch of the River Crane) beyond which is
a residential area (Conservation Area).

Neighbouring Uses
(within 250 metres)

The site is immediately adjacent to the Harlequins Rugby ground and stadium.
A block of 4 storey residential apartments is located along Langhorn Drive to
the north, and Richmond upon Thames College lies to the north east. A playing
field with children's playground is located to the east. Allotments are just to the
south of the railway line. To the west of the site, a residential area of detached
houses is located on the opposite bank of the Duke of Northumberland's River
(branch of the River Crane).

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Planning Status

The Depot site has been, amongst other things, used for the following purposes
for in excess of 10 years:

Facilities for the parking of refuse and recycling vehicles

Material Recovery Facility and bulking facilities to support municipal
recycling services.

Allocation in Borough
Local Plan

The site is identified as a Proposals site in the London Borough of Richmond

Site Allocations Plan for Council Depot facilities and continued waste
management (TW 9). "To improve and rationalise the Councils existing depot
facilities, and repositioning, intensification and improvement of the waste and
recycling facilities." The adjacent Harlequins Site (TW8) and the Richmond
upon Thames College site (TW10) are also identified.

Current Use

Civic Depot hosting contractors for LB Richmond and some DSO staff and
services, including a number of waste related operations. Waste related use
includes bulking of: source separated and partially commingled kerbside
collected recyclables, arboriculture wood/ green wastes, street cleansing waste
and construction and demolition waste from pavement repairs. There are many
buildings on site including prefabricated offices, a Victorian brick building,
bulking bays, workshops and covered vehicle storage. There is a two storey
detached house (owned by LB Richmond and occupied by former employees)
located immediately adjacent to the boundary at the south of the site.

Current Vehicle
Movements

The site is currently accessed by employee's private vehicles and light vans
and HGVs of various sizes.

Current Waste Inputs

This site was recently permitted (May 2013) but contractors operate under
exemptions. Input tonnage not counted in existing capacity.

Nominal potential
throughput (tpa) (based
on 65,000 per hectare)

173,550 tpa.

Environmental Considerations
Access/Highway

Primary access to the site is from the A316 along Langhorn Drive which is also
used for access to Harlequins Rugby Club, Richmond College and residential
properties. Access may also be gained from Craneford Way through a
controlled gate.

CCHP Potential

The Site Allocations Plan identifies the Harlequins Site and the Richmond upon
Thames College site as proposals sites which will have significant power
requirements. A part of the site may be used for ancillary educational facilities
or limited residential development and this might provide a heat load
opportunity.

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Archaeology/Historic
Interest

There is a disused Victorian pump house in the middle of the site. This building
is designated as a Building of Townscape Merit which would need to be
retained, potentially constraining development. Lies within the Crane Valley
Archaeological Priority Area.

Ecology/HRA

The site is greater than 1km from any internationally/nationally designated site.
However parts of the Crane Valley are identified as a Local Site of Nature
Conservation Importance.

Flood Risk/Water
Protection

The site is not located within a Flood Zone. But as the site is greater than 1ha,
a flood risk assessment that focuses on the management of surface water runoff will be required for any re-development.

Green Belt/MOL

The site is not in or near Green Belt. There is MOL (Metropolitan Open Land) to
the south and east of the site and along the Duke of Northumberlands River to
the west.

Landscape/Visual
Impact

Existing buildings on the site range between 2 and 6 metres high. Apart from a
small raised area in the middle of the site, the site is level with the surrounding
area. There is a mixture of buildings, fencing and trees which offer partial or full
screening of the site from all directions.
Views of the site from the north would be from the Harlequins Rugby stadium,
and a new 4 storey block of residential apartments on Langhorn Drive, and
across open ground from Richmond College.
Views of the site from the east can be gained across the open space and the
access from Craneford Way. This may be obscured if the additional land on the
eastern portion of the site were to be developed.
Views of the site from the south would be screened by trees on the boundary
and the undeveloped land south of the railway line designated as Public Open
Space.
Views of the site from the west would be partially screened by the vegetation
and trees along the site boundary adjacent to the river.

Public Rights of Way

(PRoW)

There are no PRoW crossing the site.

The site is bounded by public footpaths including the River Crane path that
provides pedestrian access to the Harlequins Stadium.

Key Development Criteria

Archaeology

Proposals should be supported by a desk-based assessment unless agreed

with English Heritage

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Flood Risk/Water
Protection

Redevelopment of this site is likely to require a Stage 2 Flood Risk

Assessment. National Planning Practice Guidance advises that waste
treatment is compatible with Floodzone 3a. Although the site is not within a
Flood Zone, a flood risk assessment that focuses on the management of
surface water run-off will be required.
The Environment Agency has advised that a setback of a minimum of 8 metres
from the top of the bank of the River Crane - a tributary of the River Thames should be incorporated into any re-development proposals. Prior written
consent will be required from the Environment Agency for any works within 8
metres of the River Crane and the Duke of Northumberlands River; this is
irrespective of planning permission.

Access/Highway

Redevelopment of the site would need to pay particular attention to the site
access along Langhorn Drive which is shared with the occupiers of residential
dwellings and visitors to the rugby stadium (especially on match days). The
emerging LB Richmond Site Allocations Plan recognises that any intensification
of uses is likely to require the provision of a signalised junction between
Langhorn Drive and the A316, subject to TfL approval. Vehicular access from
Craneford Way should be kept to a minimum.

Archaeology/Historic
Interest

Any new scheme would be required to retain the Victorian pump house; result
in improvement and extension of the public open space adjoining the Duke of
Northumberland River and the backdrop to the Craneford Way playing fields;
and preserve or enhance the character or appearance of the Rosecroft
Conservation Area.

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Site Name

Western International Market

Site Ref. No.

2861

Locational Information
Borough

Hounslow

Site Area (hectares)

3.2

Easting

TQ 5109

Northing

1785

Site Address

Western International Market, Southall, UB2 5XH

Site Location

Site is located in an industrial area to the northeast of Junction 3 of the M4

motorway. The site is located to the south of Hayes Road and to the west of
Southall Lane. To the north of Hayes Road is Bulls Bridge Industrial Estate.

Neighbouring Uses
(within 250 metres)

There is a raised soil embankment on the southern site boundary and no

buildings currently overlooking the site. The land to the west has been
developed in association with the redevelopment of Western International
Market which sells food and horticultural produce, open land to south, and
industrial/retail areas to the east and north with the most proximal uses being
Costco and a data centre. The M4 is audible from the site.

Planning Status

In March 2006, planning permission was granted subject to a legal

agreement which provided for the demolition of buildings on the site and
development of a wholesale horticultural market with offices, food wholesale
facilities, loading bays, storage areas, associated buildings, ancillary facilities
and surface car parking to the west of the site. This included the provision of
a public weekend market and development of an employment building (B1,
B2, and B8 uses) with associated car parking, loading and access (Ref No:
01032/E/25).

Allocation in Borough
Local Plan

No

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Current Use

The large site comprises land which is level and undeveloped. The
international market has been demolished, so the site is clear of any
buildings or other structures.

Current Vehicle
Movements

None

Current Waste Inputs

None

Nominal potential
throughput (tpa)
(based on 65,000 per
hectare)

208,000 tpa

Environmental Considerations
Access/Highway

The site has very good access to strategic roads A312 and M4 via Hayes
Road which is primary road.

Archaeology/Historic
Interest

Major prehistoric/Saxon site excavated to northwest.

The Brentford Fountain Western International Market - a Grade II Listed
Monument is adjacent to the site.

CCHP Potential

There are industrial areas adjacent to the site.

Ecology/HRA

The site is greater than 1km from any internationally/nationally designated

site.

Flood Risk/Water
Protection

There are no open water bodies in proximity to the site.

Green Belt

The Site is adjacent to Green Belt

Landscape/Visual
Impact

The site is in an industrial/retail setting and so there are few sensitive

receptors. There is at least one gas holder in the vicinity of the site that forms
a prominent landmark and draws the eye when viewing the site from the
south.

Public Rights of Way

There are no PRoW crossing or immediately adjacent to the site.

Key Development Criteria

Archaeology

Applications involving groundworks should be supported by desk-based

assessment, and likely to require evaluation trenching.

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Flood Risk/Water
Protection

The site is greater than 1ha and so a flood risk assessment that focuses on
the management of surface water run-off will be required.

Visual amenity

Some screening of the site would be required depending on the nature and
scale of any development. Particular attention would need to be paid to
building siting, materials, height, design and landscaping so as to be
sympathetic to the adjacent Green Belt.

Neighbouring Land
Uses

Proposals should carefully consider existing and proposed neighbouring land

uses and ensure that any development will not result in any significant
adverse impact on these uses. In particular, such impacts, including those on
air quality, will include those which might arise from the construction and
operation of the site and the movement of vehicles associated with any
proposal.

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Appendix 7 - Relationship between WLWP

policies and previously adopted policies in
Boroughs' DPDs
The following tables show how the policies of the West London Waste Plan have
superseded previously adopted polices contained in the six constituent Boroughs'
Development Plan Documents.
London Borough of Brent
Superseded Policy in Core Strategy
(Adopted 2010)

Replacement West London Waste Plan

Policy

Policy No.

Policy Title

Policy No.

Policy Title

N/A

N/A

N/A

N/A

Brent Unitary Development Plan

(UDP), 2004 (Planning Policy
Relevant in Brent, June 2011) 36
Policy
Policy Title
No.

Replacement West London Waste Plan

Policy

W3

W4

New Waste
Management/
Manufacturing Proposals
Environmental and
Access Criteria
Waste Management /
Manufacturing Areas

Policy No.

Policy Title

WLWP 4

Ensuring High Quality

Development

WLWP 3

Location of Waste
Development
Safeguarding and Protection of
Existing and Allocated Waste
Sites
Location of Waste
Development

W5

Safeguarding of Waste
Facilities

WLWP 2

W6

Proposals for Waste

Management Facilities

WLWP 3

0B

36

Some of the policies in the Brent UDP (adopted in 2004) still make up part of the development plan for Brent. A
Development Management Development Plan Document (DPD) will replace the remaining saved UDP policies once
adopted. Consultation took place from 20 June to 31 July 2014. Development will need to be in accordance with the
relevant development management policies of the UDP policies and in due course the Development Management
DPD.

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W11

outside Waste
Management/Manufacturi
ng Areas
Waste Transfer
WLWP 4
Facilities/Waste to
Landfill

Superseded Policy in Site Specific

Allocations DPD July 2011

Ensuring High Quality

Development

Replacement West London Waste Plan

Policy

Policy No.

Policy Title

Policy No.

Policy Title

N/A

N/A

N/A

N/A

London Borough of Ealing

Superseded Policy in Local Plan Core
Strategy (Adopted April 2012)

Replacement West London Waste Plan

Policy

Policy No.

Policy Title

Policy No.

Policy Title

1.2 (i)

Delivery of the Vision

for Ealing 2026 (clause
(i))

WLWP 2

Safeguarding and Protection of

Existing and Allocated Waste
Sites

WLWP 3

Location of Waste Development

WLWP 4

Ensuring High Quality

Development

WLWP 5

Decentralised Energy

WLWP 6

Sustainable Site Waste

Management

WLWP 7

National Planning Policy

Framework: Presumption in
Favour of Sustainable
Development

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London Borough of Harrow

The table below lists the relevant waste policies of the Harrow Unitary Development
Plan (2004) that were deleted by the Secretary of State on 28th September 2007 and
those deleted upon the adoption of the Harrow Development Management Policies DPD
on 4 th July 2013.
P

Policy

Title

Date of Deletion

SEP3

Waste General Principles

28 th September 2007

EP16

Waste Management, Disposal and

Recycling

4 th July 2013

EP17

Waste Generating Activities

28 th September 2007

EP18

Landfilling

28 th September 2007

EP19

Aggregates

28 th September 2007

D8

Storage of Waste, Recyclable and

Reusable Materials in New Development

28 th September 2007

Superseded Policy in the Harrow

Core Strategy (Adopted 16th
February 2012)

Replacement West London Waste Plan

Policy

Policy No.

Policy Title

Policy No.

Policy Title

N/A

N/A

N/A

N/A

Superseded Policy in the Harrow

Development Management Policies
DPD (Adopted 4 th July)
P

Replacement West London Waste Plan

Policy

Policy No.

Policy Title

Policy No.

Policy Title

N/A

N/A

N/A

N/A

Superseded Policy in the Harrow &

Replacement West London Waste Plan

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Wealdstone Area Action Plan DPD

(Adopted 4 th July)
P

Policy

Policy No.

Policy Title

Policy No.

Policy Title

N/A

N/A

N/A

N/A

Superseded Policy in the Harrow Site

Allocations DPD (Adopted 4 th July)
P

Replacement West London Waste Plan

Policy

Policy No.

Policy Title

Policy No.

Policy Title

N/A

N/A

N/A

N/A

London Borough of Hillingdon

Superseded Policy in Local Plan
Strategic Policies (Adopted
November 2012)

Replacement West London Waste Plan

Policy

Policy No.

Policy Title

Policy No.

Policy Title

EM11

Sustainable Waste
Management

WLWP 2

Safeguarding and Protection of

Existing and Allocated Waste
Sites

WLWP 3

Location of Waste
Development

WLWP 4

Ensuring High Quality

Development

WLWP 5

Decentralised Energy

WLWP 6

Sustainable Site Waste

Management

WLWP 7

National Planning Policy

Framework: Presumption in
Favour of Sustainable
Development

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London Borough of Hounslow

Superseded Policy in Unitary
Development Plan (December 2003)

Replacement West London Waste Plan

Policy

Policy No.

Policy Title

Policy No.

Policy Title

ENV-P.2.2

Landfill

WLWP 3

ENV-P.2.1

Waste management

WLWP 6

ENV-P.2.3

Waste management
facilities

WLWP 2

Location of Waste
Development
Sustainable Site Waste
Management
Safeguarding and Protection of
Existing and Allocated Waste
Sites
1B

London Borough of Richmond

Saved Policy in the Unitary
Development Plan (Adopted 2005)

Replacement West London Waste Plan

Policy

Policy No.

Policy Title

Policy No.

Policy Title

CCE22

Waste Collection and

Disposal

WLWP 2

Safeguarding and Protection of

Existing and Allocated Waste
Sites

WLWP 3

Location of Waste development

WLWP 4

Ensuring High Quality

Development

WLWP 5

Decentralised Energy

WLWP 6

Sustainable Site Waste

Management

WLWP 7

National Planning Policy

Framework: Presumption in
Favour of Sustainable
Development

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Core Strategy (Adopted 2009)

Replacement West London Waste Plan

Policy

Policy No.

Policy Title

Policy No.

Policy Title

CP6

Waste

WLWP 2

Safeguarding and Protection of

Existing and Allocated Waste
Sites

WLWP 3

Location of Waste development

WLWP 4

Ensuring High Quality

Development

WLWP 5

Decentralised Energy

WLWP 6

Sustainable Site Waste

Management

WLWP 7

National Planning Policy

Framework: Presumption in
Favour of Sustainable
Development

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Agenda Item 9

Subject:

Draft
Statement
of
Community
Involvement

Meeting
date:

28
July
2015

Report
to:

Board

Report
of:

Chief
Executive
Officer



For
decision

________________________________________________________________________



This
report
will
be
considered
in
public

________________________________________________________________________



1
1.1

Summary


The
involvement
of
local
people
and
businesses
in
all
aspects
of
creating
new

neighbourhoods
in
Old
Oak
and
Park
Royal
is
central
to
the
success
of
OPDC.
Building

upon
the
principles
of
the
Community
Charter,
OPDC,
as
the
Local
Planning
Authority,

has
drafted
a
Statement
of
Community
Involvement
(SCI)
to
set
out
how
local
and

statutory
consultees
will
be
involved
in
the
planning
process.
The
draft
SCI
and

Community
Charter,
subject
to
comments
from
the
Planning
Committee
and
Board,
will

be
released
for
consultation
from
4
August
2015
to
13
October
2015,
with
a
view
to

seeking
adoption
of
the
SCI
and
Community
Charter
in
November
2015
by
OPDC

Board.



Recommendations

The
Board
is
invited
to:

2.1

Note
the
recommendation
from
the
Planning
Committee
on
the
15
July
2015
to

approve
the
proposed
consultation
on
the
draft
SCI
and
draft
Community
Charter

subject
to
minor
amendments
(listed
in
section
5).

2.2

Approve
consultation
on
the
draft
SCI
and
draft
Community
Charter
subject
to
minor

amendments.

2.3

Delegate
authority
to
the
Head
of
Planning
to
make
minor
amendments
to
the
draft

SCI
and
draft
Community
Charter
before
releasing
them
for
public
consultation
to

incorporate
from
OPDC
Board
and
OPDC
Planning
Committee.

3
3.1

Background

The
participation
of
local
people
in
the
planning,
delivery
and
operation
of
this
new

neighbourhood
is
central
to
the
future
success
of
Old
Oak
and
Park
Royal.
OPDC
is

committed
to
working
with
local
residents,
businesses
and
community
groups.
Local

Page 143

engagement
is
an
important
requirement
for
OPDC
and
we
will
work
hard
to
ensure

that
local
people
are
given
the
opportunity
to
have
their
voices
heard.

3.2

The
Planning
Committee
were
asked
to
provide
comments
on
the
draft
SCI
and
draft

Community
Charter
which
have
been
included
in
section
5
of
this
paper.
Subject
to
the

comments
of
the
Planning
Committee,
the
draft
SCI
and
draft
Community
Charter
are

proposed
for
approval
by
the
Board,
to
be
released
for
consultation
from
4
August
to

13
October
2015.




StatementofCommunityInvolvement

3.3

The
purpose
of
this
draft
SCI
is
to
set
out
OPDCs
commitments
for
community

involvement
in
the
production
of
planning
policy
documents
and
planning
applications.

3.4

The
SCI
sets
out
how,
when
and
where
the
OPDC
will
consult
local
and
statutory

stakeholders
in
the
process
of
planning
for
the
OPDC
area,
both
in
producing
the
plan

documents
and
in
carrying
out
the
development
control
function.
A
SCI
is
no
longer

considered
a
development
plan
document
and
is
therefore
not
subject
to
examination.



CommunityCharter

3.5

Alongside
the
SCI,
OPDC
is
also
committing
to
a
Community
Charter.
The
Charter

contains
a
broader
set
of
principles
on
how
OPDC
will
engage
with
businesses
and

residents
on
all
issues
not
just
planning
issues.
An
informal
consultation
has
been

conducted
on
the
Community
Charter
in
March
2015.
Some
of
the
key
comments

include,
request
for
more
specificity
regarding
existing
community
groups
and

stakeholders
within
the
OPDC
area,
support
for
a
Community
Champion
Working

Group,
and
clarity
around
the
governance
of
the
Working
Group.

3.6

The
principles
of
the
Charter,
and
the
comments
received
as
part
of
the
informal

consultation,
have
been
used
to
inform
the
draft
SCI.

4
4.1

OPDCS
draft
Statement
of
Community
Involvement
(SCI)

The
draft
OPDC
Statement
of
Community
Involvement
is
attached
in
Appendix
A
and

is
structured
into
the
following
sections:

1.

Explanatory
Note

explains
the
consultation
process
for
the
document

2.

Executive
Summary

summarises
how
the
community
will
be
involved
in

formation
of
planning
policy,
and
in
particular
development
of
the
Local
Plan,
as

well
as
Community
Infrastructure
Levy
(CIL)
and
planning
applications.

3.

The
Old
Oak
and
Park
Royal
Area

sets
out
the
characteristics
of
the
area
in

relation
to
the
community,
businesses
and
other
key
stakeholders

4.

Introduction

sets
out
the
context
for
the
SCI

5.

Planning
Policy

Consultation

details
how
community
involvement
in
planning

policy,
including
CIL
and
Neighbourhood
Planning,
will
be
achieved

6.

Planning
Applications

Consultation

details
how
community
involvement
in

planning
applications
(pre-application
and
full
application)
will
be
achieved

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7.

Assessment
and
monitoring

explains
how
the
effectiveness
of
consultation
will

be
assessed
and,
if
necessary,
changes
will
be
made
to
the
SCI.

8.

Appendices

this
includes:

an
overview
of
main
consultation
bodies,

methods
of
communication
and
consultation,

locations
where
policy
documents
will
be
made
available,

a
glossary

Planning
Committee
Recommendation

5.1

On
15
July
2015,
the
OPDC
Planning
Committee
considered
the
draft
SCI
and
draft

Community
Charter
and
made
a
recommendation
to
OPDC
Board
that
it
should
be

approved
for
consultation.

5.2

OPDC
Planning
Committee
would
also
like
to
present
the
following
comments
to
OPDC

Board
for
further
amendments/inclusions:

Explanatory
note:
produce
a
simple
summary
of
the
SCI
and
statutory
consultation

Pre-application
consultation:
in
addition
to
meeting
national
minimal
standards

there
will
be
an
expectation
that
the
OPDC
should
exceed
these
and
how
this
is

achieved
should
be
set
out
in
the
draft
SCI



Planning
fora
including
ward
panels:
further
clarification
should
be
included
within

the
draft
SCI
as
to
the
terminology
for
different
planning-related
meetings.

Communities
adjacent
to
the
OPDC
area:
the
OPDC
Planning
Committee

highlighted
the
importance
of
liaising
with
neighbouring
communities
and
that
the

SCI
should
more
clearly
define
what
adjacent
means.



Consultation
deadlines:
there
was
an
acknowledgement
that
deadlines
on
public

consultation
must
be
respected;
however
the
Chair
of
the
Planning
Committee

should
use
his
discretion
when
comments
are
submitted
after
the
deadline.


Appendix
1
Consultation
Bodies:
full
lists
are
not
included
and
are
stated
as
not

exhaustive,
however
the
following
group
will
be
added;
Wormwood
Scrubs

Charitable
Trust.

Appendix
2
How
the
OPDC
will
communicate:
clarification
will
be
given
on
which

websites/webpages
will
include
notifications
of
consultations

Appendix
3:
Planning
information
points:
further
locations
would
be
added
to
the

list
as
requested
during
the
consultation
period.

Page 145

Next
Steps

6.1

Following
the
OPDC
Planning
Committee
and
Board
meetings,
key
stakeholders
will
be

notified
of
the
forthcoming
consultation
on
the
draft
SCI
as
well
as
the
draft

Community
Charter.

6.2

The
consultation
on
these
documents
is
proposed
to
take
place
from
the
4
August


13
October
2015.
The
consultation
will
be
communicated
using
a
number
of
channels,

including
local
press
and
social
media.
There
will
also
be
a
consultation
event
and

requests
to
attend
community
group
meetings/events
to
capture
views
on
how
people

wish
to
engage
with
Old
Oak
and
Park
Royal
proposals.

6.3

The
OPDC
will
provide
a
response
to
comments
received.
Final
refinements
of
the
SCI

and
Community
Charter
will
be
made
with
the
final
documents
being
proposed
for

adoption
by
the
OPDC
Board
in
November.

Financial
Implications

7.1

There
are
no
direct
financial
implications
for
the
OPDC
arising
from
this
report.
All

costs
relating
to
consultation
arising
from
implementing
the
SCI
will
be
within
OPDCs

allocated
budget
for
Engagement.

Legal
Implications

8.1

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

legal
framework.

Appendices

Appendix
A

OPDC
draft
Statement
of
Community
Involvement

Appendix
B

OPDC
draft
Community
Charter

10

Background
papers

None





Report
originator:

Alexandra
Day,
Senior
Community
Engagement
Officer,
OPDC

Telephone:


020
7983
4909


Email:



alexandra.day@opdc.london.gov.uk

Page 146

AppendixA


OldOakandParkRoyalDevelopmentCorporation

DraftStatementofCommunityInvolvement



1. Explanatorynote..2

2. TheOldOakandParkRoyalArea..3

3. Introduction.5

4. ConsultationonPlanningPolicy8

5. ConsultationonPlanningApplications28

6. Assessmentandmonitoring..35

7. Appendices..36

































Page 147



1. Explanatorynote

1.1 Old
Oak
Common
is
the
only
place
where
High
Speed
2
meets
Crossrail.
The
potential

connectivity
provided
by
these
two
nationally
significant
transport
projects
represents

an
exceptional
opportunity
to
deliver
the
largest
regeneration
project
the
UK
has
seen

since
the
2012
Games.
This
once-in-a-lifetime
investment
creates
a
real
opportunity
to

deliver
an
exemplar
place,
to
transform
the
wider
area
into
a
sustainable
new
district
for

a
new
community
that
could
redefine
the
standards
of
place-making.
It
is
estimated

that
redevelopment
of
the
area
has
the
potential
to
secure
significant
benefits
in
terms

of
much
needed
housing,
jobs,
economic
and
community
benefits

including
the

delivery
of
24,000
new
homes
and
55,000
jobs
in
Old
Oak
and
1,500
new
homes
and

10,000
jobs
in
Park
Royal.



1.2 OPDC
will
put
people
at
the
heart
of
the
proposals
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.
OPDC
will
look
to
exemplars
to

emulate;
including
London
based
examples
such
as
the
London
Legacy
Development

Corporation,
and
wider.




1.3 One
part
of
community
involvement,
will
be
consultation
on
planning
matters
in
order

to
influence
specific
planning
decisions,
designs
and
policies.
It
is
important
to
set
out

how
this
consultation
will
be
carried
out.Old
Oak
and
Park
Royal
Development

Corporation
(OPDC)
is
required
to
have
a
Statement
of
Community
Involvement
in

Planning
(SCI)
by
the
Planning
and
Compulsory
Purchase
Act
2004.
This
SCI
also
takes

into
account
the
Localism
Act
2011,
the
requirements
of
the
Town
and
Country

Planning
(Local
Planning)
(England)
Regulations
2012,
the
Town
and
Country
Planning

(Development
Management
Procedure)
(England)
Order
2015
and
the
National

Planning
Policy
Framework
2012.



HowcanIcommentonthisdocument?

1.4 This
draft
SCI,
subject
to
Board
approval,
is
planned
to
be
published
for
consultation

from
4th
August

13th
October
2015.
If
you
wish
to
comment
on
the
draft
SCI,
the

document
may
be
seen
at
the
locations
outlined
in
Appendix
3
or
on
the
OPDC

website.
When
submitting
comments,
you
should
be
as
specific
as
possible
in
setting

out
what
paragraph
and
page
number
you
are
making
comments
on.




1.5 The
draft
SCI
can
be
made
available
in
alternative
forms,
including
Braille,
easy
read,

large
print
and
audio.
If
you
require
the
document
in
an
alternative
format
please

contact
us.



1.6 Please
note
that
any
representations
must
reach
us
by
5pm
on
13th
October2015




Representations
should
be
made
online
via
the
website,
by
email
to

alexandra.day@opdc.london.gov.uk
or
by
letter
to:



Senior
Community
Engagement
Officer


Old
Oak
and
Park
Royal
Development
Corporation

City
Hall

The
Queens
Walk

London

SE1
2AA

Page 148

1.7 OPDC
will
contact
all
consultees
who
responded
to
this
document
prior
to
its

adoption,
setting
out
OPDCs
response
to
comments
received
and
will
share
a
trackchanged
version
of
the
SCI
highlighting
the
changes
that
will
go
into
the
final

document.












Page 149



2. TheOldOakandParkRoyalAreaOverview


Current
population
at
Old
Oak
and
Park
Royal


1.8 Old
Oak
and
Park
Royal
currently
has
a
small
residential
population.
As
at
the
2011

Census,
approximately
5,000
residents
lived
in
1,900
households
in
the
area.
The

population
is
diverse,
with
a
large
proportion
of
residents
from
minority
ethnic
groups

compared
to
the
London
average.
Park
Royal
also
includes
residents
of
an
Irish
Traveller

community.1




1.9 Larger
numbers
of
people
work
in
the
area
day-to-day.
At
Park
Royal
alone,
estimates

suggest
there
are
over
31,000
employees
in
2150
workplaces.2



1.10
The
Old
Oak
and
Park
Royal
Opportunity
Area
(OA)
experiences
high
levels
of

income
and
employment
deprivation.3
The
area
has
a
high
rate
of
long
term

unemployment
4
(18.6
per
cent
against
the
London
average
of
11.5
per
cent),5
and
over

58
per
cent
of
children
live
in
income
deprived
homes.6
A
smaller
proportion
of
residents

work
in
professional
occupations
than
the
London
average
(19.1
per
cent,
compared
to

22.5
per
cent),
and
a
higher
proportion
of
people
are
employed
in
elementary

occupations
(12.6
per
cent
compared
to
9.6
per
cent).7




1.11
Key
information
about
the
area
is
being
refined
to
feed
in
to
evidence
base
for

the
Local
Plan.



Communities
around
Old
Oak
and
Park
Royal



1.12
The
wider
area
around
Old
Oak
and
Park
Royal
contains
some
of
the
most

deprived
communities
in
England.
Residents
within
2km
of
the
OA
have
lower

employment
rates
compared
to
the
London
average,
and
in
some
communities,
half
of

residents
face
significant
barriers
to
employment.8
Within
the
immediate
vicinity
of
Old

Oak
there
are
a
substantial
number
of
Super
Output
Areas
(SOAs)
classed
as
being

within
the
top
10
per
cent
deprived
nationally
and
a
significant
number
of
SOAs
within

the
top
20
per
cent.9
More
than
9
per
cent
of
residents
in
Harlesden,
7
per
cent
of

residents
in
Stonebridge
and
5
per
cent
of
people
in
the
College
Park
and
Old
Oak
were

claiming
Job
Seekers
Allowance
in
May
2014,
compared
to
a
national
average
of
2.4
per

cent.10
Communities
in
the
area
may
also
experience
poorer
outcomes
across
other

indicators,
such
as
access
to
housing
and
services,
and
the
quality
of
the
local
living

environment.11






















































1

Draft
Integrated
Impact
Assessment,
p.
77-78
for
draft
Old
Oak
and
Park
Royal
OAPF
2015


Draft
Integrated
Impact
Assessment,
p.
44
for
draft
Old
Oak
and
Park
Royal
OAPF
2015

3

Draft
Integrated
Impact
Assessment,
p.
51
for
draft
Old
Oak
and
Park
Royal
OAPF
2015

4

Draft
Integrated
Impact
Assessment,
p.
46
for
draft
Old
Oak
and
Park
Royal
OAPF
2015

5

Draft
Integrated
Impact
Assessment,
p.
72
for
draft
Old
Oak
and
Park
Royal
OAPF
2015

6

Draft
Integrated
Impact
Assessment,
p.
72
for
draft
Old
Oak
and
Park
Royal
OAPF
2015

7

Draft
Integrated
Impact
Assessment,
p.
47-48
for
draft
Old
Oak
and
Park
Royal
OAPF
2015

8

LB
Hammersmith
and
Fulham,
Old
Oak
Common

The
Transport
and
Regeneration
Case
for
a
HS2
Interchange

(December
2009),
p.
11

9

Draft
Old
Oak
and
Park
Royal
OAPF,
p.
124

10

Draft
Old
Oak
and
Park
Royal
OAPF,
p.
124

11

LB
Hammersmith
and
Fulham,
Old
Oak
Common

The
Transport
and
Regeneration
Case
for
a
HS2
Interchange

(December
2009),
p.
11

2

Page 150



1.13
Poor
connectivity
across
Old
Oak
and
Park
Royal
restricts
the
scope
for
existing

local
communities
to
access
the
full
potential
of
the
area.
For
example,
limited
vehicular

links
at
Old
Oak
provide
very
poor
north-south
and
east-west
connectivity.
There
are

east-west
pedestrian
connections,
but
these
are
poorly
overlooked,
creating
the

perception
of
being
at
risk
from
crime.
Similarly,
north-south
pedestrian
connections

along
heavily
congested
routes
make
travelling
by
foot
unattractive.
Part
of
plans
for

the
regeneration
of
the
site
will
include
proposals
for
new
high
quality
pedestrian
and

cycling
links,
including
connections
to
both
existing
and
proposed
routes
and
to
key

destinations
such
as
Harlesden,
White
City,
Park
Royal,
North
Acton,
Queens
Park
and

Ladbroke
Grove.12



Future
communities
at
Old
Oak
and
Park
Royal



1.14
Development
in
Old
Oak
and
Park
Royal
will
provide
new
neighbourhoods
which

will
be
connected
in
to
the
surrounding
communities.
OPDC
will
consider
how
the
OA

support
existing
local
communities
to
access
the
area
and
the
services,
employment,

and
training
opportunities
it
will
provide.13
For
example,
the
new
transport
hub,

including
the
planned
interchange
between
HS2
and
Crossrail,
and
new
Overground

stations
at
Old
Oak
Common,
will
improve
journey
times
into
central
London,
and
to

other
employment
centres
such
as
Canary
Wharf
and
Heathrow,
for
local
residents,14

increasing
local
access
to
the
wider
London
job
market.












































































































12

Old
Oak
and
Park
Royal
Draft
Opportunity
Area
Planning
Framework,
Transport
Strategy,
p.
94


Draft
Integrated
Impact
Assessment,
p.
82
for
the
Old
Oak
and
Park
Royal
OAPF
2015

14

Old
Oak

A
Vision
for
the
Future
(2013),
p.
40

13

Page 151



3. Introduction

Whygetinvolvedinplanning?
3.1 OPDC
will
put
people
at
the
heart
of
the
proposals
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.
One
part
of
community
involvement,

will
be
consultation
on
planning
matters
in
order
to
influence
specific
planning

decisions,
designs
and
policies.
The
planning
elements
of
the
proposals
are
key

components
which
will
shape
the
overall
regeneration
and
development
and
community

involvement
is
fundamental.




3.2 Old
Oak
and
Park
Royal
will
undergo
significant
change
over
the
next
30
years.
OPDC

want
to
ensure
that
OPDCs
planning
policy
helps
us
to
deliver
and
manage
positive
and

sustainable
change
that
benefits
local
communities.
This
means
delivering
a
range
of

benefits,
including
maximising
the
areas
accessibility
as
a
national
and
international

super-hub
and
improving
connections
between
the
area
and
local
centres.
OPDC
will

also
work
to
attract
new
jobs
to
a
new
commercial
and
office
hub
at
Old
Oak,
and

promote
a
new
neighbourhood
of
high
quality
design
to
house
a
new
residential

population
which
will
be
served
by
new
local
amenity
spaces.15




3.3 Planning
is
also
about
ensuring
that
development
respects
the
local
heritage
and

townscape
and
takes
account
of
the
impact
on
the
local
area
and
the
people
living
and

working
there.
OPDC
is
responsible
for
all
planning
functions,
including
developing
the

plans
and
policies
to
guide
development
as
well
as
determining
planning
applications

and
setting
Community
Infrastructure
Levy
(CIL)



3.4 OPDC
wants
to
engage
all
the
communities
in
the
three
boroughs
to
ensure
they
have

the
widest
level
of
opportunity
to
participate
in
the
planning
process.
OPDC
recognises

that
many
communities
in
and
around
Old
Oak
and
Park
Royal
are
likely
to
know
the

most
about
their
local
neighbourhood.
They
can
offer
detailed
local
knowledge
to
help

deliver
the
best
policies
and
most
appropriate
development
for
the
area,
and
therefore,

it
is
important
for
OPDC
to
hear
from,
and
involve,
all
groups
within
the
community.



OurCommunityCharter

3.5 OPDC
has
drafted
a
Community
Charter
to
demonstrate
its
commitment
to
meaningful

and
transparent
community
involvement
and
engagement
that
will
help
to
shape
the

regeneration
of
Old
Oak
and
protection
of
Park
Royal.
It
is
a
key
document
to
help
to

engage
with
existing
and
future
community
stakeholders
on
issues
wider
than
planning

process
issues.



3.6 The
Community
Charter
will
be
used
to
inform
the
SCI
which
has
a
focus
on
planning

issues.
The
Community
Charter
has
a
wider
focus
than
planning
policy.
The
principles

of
the
Community
Charter
are
fundamental
to
the
development
of
the
SCI.



3.7 The
principles
of
the
draft
Community
Charter
are
set
out
below
and
these
will
also

apply
to
the
SCI:























































15

Draft
OAPF,
p.
16

Page 152



1.
Commence
community
engagement
from
the
earliest
appropriate
opportunity
in

planning
processes.



2.
Deliver
transparent,
accessible
and
meaningful
community
engagement
that
is

proportionate
to
the
nature
of
the
planning
processes
being
undertaken
by:



a.
providing
information
in
an
accessible
format;



b.
notifying
community
stakeholders
in
a
timely
manner
through:

i.
letters
or
emails
to
those
on
the
contact
database;

ii.
local
publications;

iii.
OPDC
website
updates;
and

iv.
other
relevant
media.



c.
documenting
comments;
and



d.
responding
to
comments.



e.
respecting
and
addressing
comments



3.
Establish
a
Community
Champion
Working
Group
to
shape
the
development
of

planning
policy.



4.
Deliver
ongoing
open
two-way
engagement.



5.
Develop
and
manage
a
contact
database.




6.
Engage
and
support
Neighbourhood
Planning
Forums.





3.8 The
draft
Community
Charter
is
being
informed
by
discussions
with
community
groups,

national
guidance,
and
emerging
local
community
charters
including
the
Grand
Union

Alliances
Charter.
OPDC
has
carried
out
an
informal
consultation
on
the
Community

Charter
and
a
summary
of
the
responses
can
be
found
in
Appendix
4.
The
draft

Community
Charter
will
be
consulted
on
at
the
same
time
as
the
draft
SCI.

ThepurposeofthisdraftSCIdocument

3.9 The
draft
SCI
builds
upon
the
principles
of
the
Community
Charter
and
explains
how

and
when
the
community
can
be
involved
in
the
preparation
of
planning
policy

documents
(Section
3)
and
in
the
consideration
of
planning
applications,
including
preapplication
proposals
and
appeals
(Section
4).
Every
local
planning
authority
must

prepare
an
SCI,
which
is
a
means
of
improving
the
quality
of
the
planning
process

through
greater
involvement
of
the
whole
community.
The
draft
SCI
aims
to
ensure
that

the
appropriate
type
and
scale
of
engagement
is
undertaken
for
both
planning
policy

documents
and
specific
development
proposals
at
pre-application,
application
and

appeal
stages.
OPDC
will
assess
and
review
our
approach
to
community
involvement
in

planning,
as
outlined
in
Section
5
of
the
draft
SCI.




Page 153



Adutytoco-operate

3.10 In
compliance
with
Section
33A
(1)
(c
)
of
the
Planning
&
Compulsory
Purchase
Act

2004,
OPDC
is
under
a
duty
to
co-operate
with
other
authorities
and
agencies
when
it

reviews
its
planning
policies.
These
authorities
and
agencies
include
neighbouring

boroughs,
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).








Page 154



4. Consultationonplanningpolicy

4.1 This
section
outlines
how
OPDC
aims
to
involve
the
community
in
the
preparation
of
its

planning
policy
documents,
a
list
of
which
is
available
in
OPDCs
Local
Development

Scheme
(LDS)
which
is
available
online
and
at
City
Hall
(URL
to
be
inserted
once
LDS

uploaded
to
website).
The
LDS
sets
out
a
list
of
policy
documents
to
be
prepared
and
their

timetable
for
production.
It
will
be
reviewed
as
and
when
necessary
to
ensure
that
the

public
are
aware
of
documents
coming
on-line
and
have
the
chance
to
participate
in
their

preparation.



PlanningPolicy

4.2 OPDC,
as
the
local
planning
authority
for
Old
Oak
and
Park
Royal,
is
required
to
prepare

statutory
planning
policy
documents.
These
documents
include
policies
that
will
help
shape

the
future
development
of
Old
Oak
and
Park
Royal
and
guide
developers
in
preparing

applications
that
will
be
acceptable
in
planning
terms.
They
will
be
coordinated
with
the

strategies
of
the
London
Boroughs
of
Brent,
Ealing,
and
Hammersmith
and
Fulham,
and

those
of
wider
partners,
such
as
the
GLA
and
TfL.



4.3 The
policies
will
run
across
a
number
of
documents
and
they
will
be
prepared
in
compliance

with
national
and
regional
guidance.




4.4 Over
the
coming
years
OPDC
will
produce
a
series
of
policy
documents,
to
include:



LocalPlan:
this
is
the
plan
for
the
future
development
of
Old
Oak
and
Park

Royal.
In
law
this
is
described
as
a
development
plan
document
or
documents

(DPDs)
adopted
under
the
Planning
and
Compulsory
Purchase
Act
2004.
The

Local
Plan
will
be
developed
in
Autumn
2015

SupplementaryPlanningDocuments:
OPDC
will
prepare
Supplementary

Planning
Documents
(SPDs)
which
would
expand
on
the
policies
of
the
Local

Plan
and
provide
more
detailed
guidance.


CommunityInfrastructureLevy(CIL):
this
is
the
statutory
charge
to
be

levied
on
new
development.
OPDC
will
prepare
a
draft
charging
schedule
(DCS)

in
2015.
When
the
CIL
is
finalised
and
adopted,
it
will
operate
alongside
Section

106
obligations.



4.5 In
addition
to
policy
documents
developed
by
OPDC,
OPDC
will
provide
technical
support

to
designated
Neighbourhood
Forums,
where
required
or
requested,
in
developing

NeighbourhoodPlans.
Neighbourhood
Plans
are
prepared
by
these
Forums;
following

consultation,
an
independent
examination
and
endorsement
by
a
local
referendum
a

Neighbourhood
Plan
will
be
adopted
by
OPDC
and
form
part
of
the
Local
Plan.



TheTownandCountryPlanning(LocalPlanning)(England)Regulations2012


4.6 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
Local
Plan
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

Page 155



appropriate
community
involvement
as
set
out
in
this
document
to
ensure
that
all
groups

have
the
opportunity
to
engage
in
the
planning
process.



Engagementinthepreparationofourplanningpolicydocuments

4.7 The
minimum
consultation
requirements
for
Local
Plans
and
Supplementary
Planning

Documents
are

set
out
in
Regulations
18-26
and
12-14
respectively
of
the
Town
and

Country
Planning
(Local
Planning)
(England)
Regulations
2012.
Other
regulations
that

apply
are
the
Community
Infrastructure
Levy
Regulations
2010
(as
amended)
and
the

Neighbourhood
Planning
(General)
Regulations
2012.
In
addition
to
these
Regulations,
as
a

public
authority
OPDC
must
comply
with
the
Public
Sector
Equality
Duty
under
Section
149

of
the
Equality
Act
2010
to
have
due
regard
to
the
need
to:



1.
Eliminate
discrimination,
harassment,
victimisation
and
any
other
conduct
that
is

prohibited
under
the
Act;



2.
Advance
equality
of
opportunity
between
persons
who
share
a
relevant
protected

characteristic
and
persons
who
do
not
share
it;
and



3.
Foster
good
relations
between
persons
who
share
a
relevant
protected
characteristic

and
persons
who
do
not
share
it.



4.8 Having
due
regard
under
the
Equality
Act
2010
to
the
need
to
advance
equality
of

opportunity
involves:



5 removing
or
minimising
disadvantages
suffered
by
people
due
to
their
protected

characteristics;

6 taking
steps
to
meet
the
needs
of
people
from
protected
groups
where
these
are

different
from
the
needs
of
other
people;
and

7 encouraging
people
from
protected
groups
to
participate
in
public
life
or
in

other
activities
where
their
participation
is
disproportionately
low.



4.9 The
Equality
Act
states
that
meeting
different
needs
involves
(for
example)
taking
steps
to

take
account
of
disabled
peoples
disabilities.
It
describes
fostering
good
relations
as

tackling
prejudice
and
promoting
understanding
between
people
from
different
groups.
It

states
that
compliance
with
the
duty
may
involve
treating
some
people
more
favourably

than
others.



4.10 Because
consultation
is
an
exercise
of
one
of
OPDCs
functions,
OPDC
must
comply

with
the
Public
Sector
Equality
Duty.
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.



4.11 The
following
sections
of
the
draft
SCI
outline
how
OPDC
will
seek
to
engage
the

community
in
the
production
of
these
documents.
OPDC
aims
to
go
beyond
the
statutory

requirements
to
seek
the
full
and
active
engagement
of
all
groups
within
the
community,

especially
hard
to
reach
groups
that
often
do
not
get
involved
in
planning
matters.
OPDC

wants
to
give
more
power
to
local
communities,
including
engagement
in
review
of
the

Local
Plan.
Our
decision
to
include
community
and
business
representatives
on
our
board

from
the
start
is
an
example
of
our
commitment
to
community
involvement.



Page 156





LocalPlan


4.12 The
GLA
Opportunity
Area
Planning
Framework
(OAPF)
for
Old
Oak
&
Park
Royal
is

envisaged
to
be
adopted
in
Autumn
2015
to
supplement
London
Plan
policies.
The

OAPF
will
provide
guidance
for
the
development
of
the
area,
which
once
adopted

would
carry
considerable
weight
when
assessing
planning
applications.
The
OAPF

builds
on
the
Mayors
Vision
for
Old
Oak
Common,
published
in
2013,
and
the
Park

Royal
Opportunity
Area
Planning
Framework,
published
in
2011.








The
flow
diagram
below
shows
how
OPDC
will
develop
the
Local
Plan:



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.







Stage3Submission

Local
Plan
and
public
responses
submitted
to
Secretary
of
State
for
Communities


and
Local
Government,
who
appoints
a
Planning
Inspector.



Stage4Examination

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.





Stage5Adoption

The
recommendations
of
the
Inspectors
report
are
considered
and
OPDC
adopts


the
Local
Plan.



4.13 The
actions
that
OPDC
will
pursue
whenever
appropriate
to
ensure
that
all
the

community
are
involved
in
these
stages
are
set
out
in
table
A.




Page 157



TableA:KeystagesandcommunityinvolvementontheLocalPlan


Preparationof
Publicationof
LocalPlan
proposedLocalPlan
Whatarethe
No
fixed
period

Consultation
period
set
by



Government
is
6
weeks

timeframesfor
Minimum
of
6
weeks
and

community
maximum
of
3
months
to

involvement?
gather
information
to

address
policies

Page 158
Whatdocuments
willbeavailable?


Examination

The
Independent
Inspector

decides
the
scope
of
issues
to

be
covered
at
the
hearing
and

who
should
attend.




The
Inspector
examines
the

proposed
Local
Plan
and
can

recommend
changes
which

then
require
a
further
6
week

consultation



Notice
of
the
Public
Hearing

will
be
published
at
least
6

week
in
advance.



The
proposed
Local
Plan
Representations
made
at

and
supporting
evidence
previous
stage
and
evidence

base,
including
Integrated
submitted
to
the
Public

Impact
Assessment

Hearing
by
OPDC
and
others



(The
Inspector
decides
who

Summary
reports
on

appears
at
the
Public
Hearing)

previous
consultation.

Adoption
There
is
no
opportunity

for
comment
or
change

after
the
Inspectors

report
is
received.

Issues
and
options

The
Inspectors
report
and

documents

the
adopted
Local
Plan



A
summary
document
(if

appropriate)



Relevant
background

studies
in
the
evidence

base,
including
Integrated

Impact
Assessment

Howwilldocuments View
or
download
documents
from
OPDC
webpages,
at
Local
Plan
information
points,
and
available
at
City
Hall.


bemadeavailable?

Documents
will
be
sent
to
specific
consultation
bodies
identified
in
the
regulations
and
with
whom
OPDC
has
a
duty

to
cooperate,
as
well
as
made
available
as
appropriate
at
any
forums,
workshops
or
other
consultation
event
that

WhowillOPDC
consult/notifyand
how?
Page 159

OPDC
establishes
(see
Appendix
2
for
examples
of
these).




The
documents
can
be
made
available
in
alternative
forms,
including
Braille,
easy
read,
large
print
and
audio
on

request
where
appropriate.



All
comments
and
any
other
documents
received
as
part
of
consultation
will
be
scanned/copied
and
made
available

for
others
to
see
at
Local
Plan
information
points
as
appropriate
(listed
in
Appendix
2).




All
evidence
submitted
to
the
Public
Hearing
will
be
made
available
electronically
and
in
the
Public
Hearing
library.

OPDC
will
encourage
everyone
to
submit
documents
electronically
so
that
they
can
be
easily
made
available
on
our

website.
General
public
via
website
and,
if
appropriate,
local

OPDC
will
also
email
or
write
All
those
who
OPDC
have

press
(including
links
on
partner
websites
where

to
those
OPDC
have

previously
consulted,
or

appropriate)

previously
consulted

made
representations
on





the
Local
Plan
or
who

Consultation
bodies
will
be
contacted
by
email
and/or
The
Inspector
may
arrange
a

took
part
in
the
Public

letter
(see
a
list
in
Appendix
1)
and
where
required
will
pre-meeting
to
explain
the

Hearing
will
be
notified
of

be
invited
to
a
meeting

process
for
the
Public
Hearing
the
adoption
of
the
Local





Plan
Mailing
list
of
those
who
inform
us
they
wish
to
be

The
Inspectors
programme

consulted
or
notified
on
a
particular
subject
and
those
officer
will
contact
all
those

who
have
commented
at
previous
stages,
who
will
be
whom
the
Inspector
would
like

contacted
by
email
and/or
letter

to
make
representations
on



the
Local
Plan





OPDC
will
endeavour
to
provide
the
opportunity
to

Any
major
modifications

take
part
in
consultation
on
planning
documents

proposed
by
the
Inspector
will

available
to
all
community
groups,
including
those
that
be
advertised
and
further

are
more
likely
to
be
under-represented
in
public
life,
consultation
carried
out
as

such
as
women,
disabled
people,
and
black
and

appropriate
or
as
advised.

minority
ethnic
groups.



OPDC
will
take
into
consideration
different
needs,
to

Page 160

Howcanyouget
involvedandgive
OPDCyourviews?

encourage
participation
from
different
groups
and

help
foster
good
relations
between
different
groups.

This
will
include
taking
account
of
access
to
meeting

venues,
the
timing
and
format
of
meetings.

OPDC
is
proposing
to
establish
a
Community

Champions
Working
Group
through
which
groups

could
be
engaged
in
the
Local
Plan
process.
However,

OPDC
will
also
look
to
utilise
existing
forums
and

existing
community
network
organisations,
such
as
the

Grand
Union
Alliance
to
engage
in
the
process
and

help
to
pass
on
information
and
encourage
responses.





Written
comments
can
be
sent
by
email
or
post
or

made
through
website.




Where
people
are
unable
to
provide
written
comments,

OPDC
officers
will
liaise
with
those
people
to
ensure

their
views
are
captured
and
included
in
the

consultation
process.




OPDC
will
send
you
an
acknowledgement
of
your

comments
within
5
working
days
of
receipt.
OPDC
will

not
respond
to
individual
comments
at
this
stage



OPDC
will
take
notes
of
what
is
said
at
public
events,

but
these
cannot
be
used
as
formal
comments
unless

agreed
by
the
individual
making
the
comments.








The
format
for
the
public

hearing
is
a
round
table

discussion.




The
Inspector
will
decide
the

issues
to
be
discussed
at
the

hearings
and
will
choose
who

to
invite
to
the
hearing

sessions.
OPDC
will
ensure

that
venues
are
accessible
and

inclusive.



If
you
are
invited
to
attend
a

hearing
session
your

comments
can
be
supported

by
written
statements.

Alternatively
you
can
submit
a

written
statement
and
not

appear.

There
is
no
further
scope

for
comments
on
the

Inspectors
Report,
which

will
make

recommendations
on
any

changes
necessary
for
the

Local
Plan
to
be
sound

and
legally
compliant.



There
is
also
the
potential

for
judicial
review
of
the

plan
within
a
specified

period
after
adoption.



HowwillOPDC
consideryour
commentsandhow
willOPDCgiveyou
feedbackonyour
comments?

Page 161

The
comments
received
at

each
stage
will
be
taken

into
account
in
preparing

documents
for
the
next

stage.



A
summary
of

consultation
responses

and
OPDC
responses
will

be
reported
to
OPDC

Planning
Committee.
This

report
will
be
made

available
on
OPDC

webpages
and
at
City

Hall.
These
will
also
be

available
at
the

information
points
listed

in
Appendix
3.
This
will
be

done
before
the
start
of

the
next
stage.



OPDC
will
offer
to
meet

with
consultation
bodies

to
discuss
comments.

(Listed
in
Appendix
3).









The
comments
received
at

each
stage
will
be
taken

into
account
in
preparing

documents
for
the
next

stage.



A
summary
of

consultation
responses

and
OPDC
responses
will

be
reported
to
OPDC

Planning
Committee.
This

report
will
be
made

available
on
OPDC

webpages
and
at
City

Hall.
These
will
also
be

available
at
the

information
points
listed

in
Appendix
3.
This
will
be

done
before
the
start
of

the
next
stage.



OPDC
will
email
or
write

to
all
participating

consultees
to
inform
them

in
time
for
preparation
of

evidence
for
the
Public

Hearing.




The
Inspector
will
consider

comments
made
at
the

submission
stage
together

with
additional
written

statements
at
the
Public

Hearing.



OPDC
will
contact
all

participating
consultees
with

details
of
the
result
of
the

examination.
The
Inspectors

Report
will
be
published
on

OPDC
website

The
Inspectors

recommendations
for

revisions
for
soundness

and
legal
compliance
will

be
incorporated
into
the

adopted
Local
Plan.



OPDC
will
contact
all

participating
consultees

with
details
of
the
result

of
the
examination.
The

Inspectors
Report
will
be

published
on
OPDC

website



SupplementaryPlanningDocuments
4.14 Supplementary
Planning
Documents
(SPDs)
add
detail
to,
and
further
explain,
the

policies
and
proposals
set
out
in
the
Local
Plan,
without
adding
new
policy.
SPDs
are

only
produced
when
OPDC
considers
them
necessary
to
provide
additional
guidance.

Consultation
for
these
documents
normally
involves
publishing
a
draft
for
comment

and
using
the
comments
received
in
producing
the
final
version.
It
may
on
occasion
be

appropriate
for
preliminary
consultation
to
take
place,
depending
on
the
scope
and

level
of
complexity
of
the
SPD
being
prepared.
Where
SPDs
are
area
based,
OPDC
will

target
the
community
in
those
areas,
and
where
they
are
topic
based
OPDC
will
target

any
groups
that
are
particularly
affected.





OptionalStage:PreliminaryConsultationonpreparationofSPD


Where
necessary,
identify
the
main
areas
that
the
draft
SPD
needs
to
address.





Stage1:PublicationofthedraftSPD

Draft
SPD
published
with
a
minimum
6
week
period
for
consultation.






Stage2:ConsiderationofCommentsReceived

 OPDC
considers
comments
made
to
the
draft
SPD
and
makes
any
necessary
changes.



Stage3:Adoption

OPDC
adopts
SPD
as
a
Local
Development
Document
and
prepares
adoption


statement.



























Page 162



TableB:KeystagesandproposedconsultationmethodsforSupplementaryPlanningDocuments




Whatcanyou
do?


Page 163

OptionalStage:PreparationofSPD
Comment
on
all
documents
that
are

published
and
take
part
in
discussions

held
at
this
stage
to
inform
the

production
of
the
draft
SPD.


Howlongis
Varies
on
the
SPD
subject
and
level
of

complexity.

eachstage?


Whowill
Where
appropriate
OPDC
will
informally

consult
consultation
bodies
(as
listed
in

OPDC
consult/notify Appendix
1)



andhowwill
OPDCdothis? Drop-in
sessions
may
be
held
during
the

6-week
public
consultation.




Stage1:DraftSPD
Comment
on
the
draft
SPD.



Stage3:Adoption
A
judicial
review
challenging
the

decision
to
adopt
can
be
lodged

within
3
months
of
the
decision



OPDC
will
ordinarily
consult
for
a


minimum
of
six
weeks.


OPDC
will
consult:
relevant
specific

Within
10
working
days
OPDC
will

consultation
bodies,
relevant
general
notify
relevant
statutory
consultees

consultation
bodies
depending
on
the
and
all
consultation
participants.

draft
SPD
subject
matter,
relevant

mailing
list
organisations
and
the

general
public
in
the
same
way
as
for

the
Local
Plan.
(As
listed
in
Appendix

1).


Howwill
Documents
will
be
available
to
view
or
download
on
OPDC
website,
at
Local
Plan
information
points,
and
available
at

documentsbe City
Hall.
Documents
will
also
be
sent
to
relevant
specific
consultation
bodies
and
those
with
whom
OPDC
has
a
duty
to

cooperate,
as
well
as
made
available
at
any
exhibitions,
workshops
or
other
consultation
event
that
OPDC
undertakes

made
(see
Appendix
2
for
examples
of
these).

available?


The
documents
will
be
made
available
in
alternative
forms,
including
Braille,
easy
read,
large
print
and
audio
on
request

where
appropriate.


Howyoucan Where
appropriate
and
when
requested
OPDC
will

Officer
contacts
will
be
available
Officer
contacts
will
be

hold
meetings
with
relevant
general
consultation

to
provide
information
by

available
to
provide

getmore
information
by
telephone

informationor bodies
and
other
organisations
and
individuals
in


telephone
and
email
during

accessible
and
inclusive
venues,
at
times
of
the
day

normal
working
hours.
If
an

and
email
during
normal

takepartin



discussions?

Page 164

Howcanyou
giveusyour
views?
Howwill
OPDC
consideryour
comments?

that
facilitate
participation.

officer
is
not
available
to
answer
working
hours.
If
an
officer

your
enquiry
an
appropriate

is
not
available
to
answer

officer
will
contact
you
by
email
your
enquiry
an
appropriate

or
phone,
as
requested,
within

officer
will
contact
you
by

24
hours.

email
or
phone,
as



requested.

Meetings
to
provide
information

on
this
stage
will
be
arranged

where
requested.

Written
comments
by
email,
post
or
through
the
website.
OPDC
will
endeavour
to
send
you
an
acknowledgement
of
your

comments
within
5
working
days
of
receipt.
OPDC
will
not
respond
to
comments
at
this
stage.
OPDC
will
take
notes
of

what
is
said
at
any
public
events,
but
they
will
not
be
treated
as
separate
formal
submissions.

Comments
made
at
this
stage
will
be
taken
into

OPDC
will
consider
all
comments
OPDC
will
contact
all

account
in
preparing
the
draft
SPD.
OPDC
will
prepare
and
the
need
for
revisions.
All

participating
consultees

a
statement
setting
out
the
names
of
those
OPDC

comments,
with
their
proposed
with
details
of
the
adoption

consulted,
a
summary
of
the
issues
raised
and
how

response,
will
be
reported
to
the
and
prepare
an
adoption

these
were
addressed
in
the
SPD.

board.
OPDC
will
prepare
a

statement
in
accordance

summary
of
all
comments

with
Regulations.
The

received
at
the
end
of
the

adoption
statement
will
be

consultation
period,
together

sent
to
any
person
who
has

with
responses
and
action
taken,
asked
to
be
notified
of
the

and
make
this
available
for

SPD
adoption.

inspection.





















CommunityInfrastructureLevy(CIL)

4.15 The
Community
Infrastructure
Levy
(CIL),
for
which
provision
was
made
in
the

Planning
Act
2008
and
updated
in
the
Localism
Act
2011
is
a
statutory,
nonnegotiable
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.








Stage1:Preliminarychargingschedule(PDCS)


PDCS
published
with
a
minimum
6
week
period
of
consultation







Stage2:Draftchargingschedule(DCS)

Draft
Charging
Schedule
published
with
a
minimum
6
week
period
of
consultation







Stage2*:Submissionofdraftchargingschedule(DCS)

 OPDC
considers
comments
made
to
the
draft
Charging
Schedule,
makes
any
necessary

changes
and
OPDC
submits
to
the
Secretary
of
State,
who
appoints
a
Planning


Inspector




Stage3:Examination

The
Charging
Schedule
is
examined
by
the
planning
inspector
at
public




examination.









Stage4:Adoption
OPDC
adopts
SPD
as
a
Local
Development
Document
and
prepares
adoption

statement.

4.16
Possible
community
involvement
for
each
of
these
stages
is
detailed
in
table
C:









Page 165



TableC:KeystagesandcommunityinvolvementontheCommunityInfrastructureLevy(CIL)ChargingSchedule


Stage1
Stage2
Stage2*
Stage3
Preliminarydraftchargingschedule
Draftcharging
Submissionof
Examination
(PDCS)
schedule(DCS)
DCS
Whathappens
atthisstage
andhowlongis
it?

Consultation
for
at
least
6
weeks
and

representations
on
OPDC's
initial

proposals
for
CIL.

Page 166

WhatOPDCwilldo
What
PDCS,
Infrastructure
Plan
(including
the

documentswill Infrastructure
Planning
Schedule
(IPS)),

beavailableand Viability
Assessment
and
Equalities
Impact

howwilltheybe Assessment
(EqIA)
available
on
the

madeavailable? website
and
at
Local
Plan
information

points
(Appendix
2).

Consultation
for
at

least
6
week
and

representations
on

OPDC's
firm

proposals
for
CIL.

Submission
of

firm
proposals
for

CIL
to
an

independent

examiner.

Independent

examiner
to

determine

procedures
and

timescales.

The
draft
charging

schedule
and
all

other
prescribed

documents
relating

to
this
consultation

phase
will
be
made

available
on

website
and
at

Local
Plan

information
points

(Appendix
2).

After
submission,

the
draft

charging

schedule,
a

summary
of
the

main
issues
raised

in
representations

and
all
other

prescribed

documents
will

be
made
available

on
OPDC
website

and
at
Local
Plan

information

points
(Appendix

2).


Documents

published
for
the

All
relevant

examination

documents

available
on

website

(examination

library??).

Stage4
Adoptionof
Charging
Schedule(CS)
Examiners
Report

may
reject,
modify

or
approve
the

charging
schedule,

give
reasons
and

make

recommendations

which
OPDC
may

have
to
follow.

After
receipt
of
the

Examiners
report

and
board
approval

of
the
charging

schedule,
in

addition
to

complying
with

statutory

requirements,

OPDC
will
make

both
reports

available
on
OPDC

website
and
at

Local
Plan

information
points

and
notify
persons

who
have

Page 167

WhowillOPDC
consult/notify
andhowwill
OPDCdothis?

previous

requested
to
be

consultation

notified
of
these

phase
and

developments.

OPDC's
response

to
it

will
remain

available
on

website.

All
comments
and
any
other
documents
received
as
part
of
consultation
will
be
made
available
for
others
to
see
on
OPDC

website
and
at
Local
Plan
information
points
(Appendix
2).
All
evidence
submitted
to
the
Examination
will
be
made
available
in

the
examination
library.
OPDC
will
encourage
everyone
to
submit
documents
electronically
so
that
they
can
be
easily
made

available
on
our
website.
The
documents
will
be
made
available
in
alternative
forms,
including
Braille,
easy
read,
large
print
and

audio
on
request
where
appropriate.

OPDC
will
consult:

OPDC
will
consult
After
Submission,
At
least
4
weeks
As
soon
as










Local
residents
and
communities

all
as
in
the

OPDC
will
give

before
an

practicable
after










Local
businesses
and
business

previous
stage
as

notice
by
letter

examination

receipt
of
the

bodies

well
as:
those
who
and/or
email
to

hearing
takes

Examiners
report,










Local
voluntary
bodies

commented
at
the
those
who

place
(or
at
least
OPDC
will:










Local
stakeholders

PDCS
stage

requested

2
weeks
if
a










Notify
those










Neighbouring
authorities
and



notification
at

Statement
of

who
requested
to

bodies
such
as
the
Homes
and

OPDC
will
do
this

the
DCS
stage.

Modifications
has
be
notified

Communities
Agency

using
letters,

been
published)












Specific
consultation
bodies
under
emails,
the

OPDC
will:

After
the
board

the
duty
to
co-operate,
including

Planning
Agents










Place
on

approves
the

neighbouring
local
planning
authorities

Forum
and
local

our
website
and

charging
schedule,

and
any
other
prescribed
body
including
advertisement

publish
a
notice

OPDC
will:

theEnvironment
Agency,
Historic
England
notice.
of
the
time
and










Notify
those

and
Natural
England.

place
of
the

who
requested
to










Landowners

examination

be
notified










Statutory
bodies










Notify










Send
a
copy



those
who
have

to
relevant

OPDC
will
use
emails,
letters
and
the

made

authorities

Planning
Agents
Forum
as
appropriate.

representations
or









Publish
a



a
request
to
be

local
advertisement

HowwillOPDC
consideryour
comments?
Page 168

Whatyoucando
Howcanyouget
more
informationor
takepartin
discussions?

OPDC
will
endeavour
to
contact
all

community
groups,
including
those
that

are
more
likely
to
be
under-represented
in

public
life,
such
as
women,
disabled

people,
and
black
and
minority
ethnic

groups.
OPDC
will
also
target
particular

areas
to
gauge
opinion
on
planning

proposals
so
that
they
may
be
taken
into

account.



OPDC
will
consider
representations
received
in
light
of
statutory
No
opportunity

legislation
and
guidance
to
inform
the
next
stage.
OPDC
will

for
comments
at

publish
a
summary
of
the
representations
received
and
OPDC's
this
stage.

response.

heard
at
the
DCS

stage.



Officers
will
be
available
to
provide

information
by
telephone
during
normal

working
hours.
If
an
officer
is
not

available
to
answer
your
enquiry
an

appropriate
officer
will
contact
you
by

email
or
phone.
Contact
details
will
be

available
on
all
documents
that
OPDC

produce.

See
DCS
stage.

The
Statement
of

No
opportunity

the

for
comments
at

Representations

this
stage.

Procedure
will
set

out
information
on:












Time
period

for
representations










Address
for

representations










How
to

request
a
right
to

be
heard
at
the

Examination;
to
be

notice.

The
examiner
will
No
opportunity
for

consider

comments
at
this

representations

stage.

received
as
part
of

the
DCS
and
the

examination

hearing.

No
opportunity
for

comments
at
this

stage.



notified
at
the

Submission
stage;

to
be
notified
of

the
examiners

recommendations;

and
how
to
request

to
be
notified
of

the
final
approval.

Howcanyou
giveusyour
views?

You
can
give
your
views
by
emailing

localplan@opdc.london.gov.uk
or
by
post.
Where
people
are

unable
to
provide
written
comments
OPDC
will
consider

requests
to
provide
comments
in
other
formats.
OPDC
will

acknowledge
receipt
if
received
electronically.

Page 169



No
opportunity

for
comments
at

this
stage.

See
DCS
stage.

No
opportunity
for



comments
at
this

The
format
for

stage.

the
public
hearing

is
round
table

discussions
and

written

representations,

where
your

comments
can
be

made
either

verbally
(when

appropriate)
or

written.
Venues

will
be
accessible

and
inclusive.



NeighbourhoodPlanning

4.17
The
Town
and
Country
Planning
Act
1990,
as
amended,

allows
for
the
preparation
of

Neighbourhood
Plans
and
is
supplemented
by
Neighbourhood
Planning
Regulations.
Whilst

previously
all
development
plan
documents
were
produced
by
local
planning
authorities,

designated
Neighbourhood
Forums
now
have
the
opportunity
to
prepare
their
own

Neighbourhood
Plan.
The
Neighbourhood
Plan,
following
consultation,
an
independent

examination
and
endorsement
through
a
local
referendum,
will
become
part
of
the

development
plan
for
the
respective
area.
This
document
can
provide
planning
policies

complementing
the
Local
Plan
to
help
shape
the
growth
and
development
of
Old
Oak
and

Park
Royal.



Before
a
Neighbourhood
Plan
can
be
developed,
community
groups
need
to
apply
to
OPDC

to
designate
a
Neighbourhood
Area
and
Neighbourhood
Forum.
Should
the
proposed
area

cross
local
planning
authority
boundaries,
applications
need
to
be
submitted
to
both

authorities.
Following
designation
of
the
Area
and
Forum,
the
Forum
can
commence
the

development
of
a
Neighbourhood
Plan
for
its
Area.
A
Forums
designation
lasts
for
5-years.




A
summary
of
the
Neighbourhood
Plan
development
process
can
be
found
below:



ApplytotheOPDCfordesignationofaNeighbourhoodAreaandasa
NeighbourhoodForum

DesignationofNeighbourhoodAreaandNeighbourhoodForum




PrepareaNeighbourhoodPlanwhichisingeneralconformitywiththe
OPDCsLocalPlan.



Carryoutpresubmissionconsultationandpublicityfortheproposed
NeighbourhoodPlan



SubmittheNeighbourhoodPlantotheOPDCforapproval,includingdetails
ofthelocalconsultationthathasbeencarriedout

OPDCwillconsultontheproposedNeighbourhoodPlan

OPDCwillsubmittheproposedNeighbourhoodPlanforexaminationand
organiseexamination

Page 170

ExaminerwillexaminethePlanandconsiderwhethertorecommendthe
NeighbourhoodPlanissubjecttoalocalreferendum.

OPDCconsiderstheexaminersrecommendations

Ifapproved,theOPDC&relevantboroughundertakeareferenduminthe
localarea.Providingmorethan50%ofthosevotingsupportthePlan,itwill
beadoptedbytheOPDCaspartofitsDevelopment

ANeighbourhoodPlan


4.18 Consultation
requirements
for
a
Neighbourhood
Plan
are
set
out
in
the

Neighbourhood
Planning
(General)
Regulations
2012
amended
in
2015.
OPDC

recommends
that
any
Neighbourhood
Forum
preparing
a
Neighbourhood
Plan

consider
using
the
methods
of
community
involvement
set
out
in
this
draft
SCI
as
the

basis
for
their
own
consultation
on
the
preparation
of
their
proposed
Neighbourhood

Plan.



4.19 The
full
procedure
that
OPDC
will
take
throughout
the
stages
of
preparation
of
a

Neighbourhood
Plan
is
set
out
in
the
Regulations.
This
does
not
preclude
support
on
a

more
informal
basis
that
OPDC
is
required
to
offer
once
the
Neighbourhood
Area
is

designated.




4.20 Further
information
can
be
found
on
the
Planning
Practice
Guidance
website
and

Planning
Advisory
Service
regarding
what
assistance
is
available
for
the
development

of
a
Neighbourhood
Plan.

















Page 171

Page 172

TableD:KeystagesofNeighbourhoodForumdesignation


APPLICATIONFOR
APPLICATIONFOR
DESIGNATIONOFA
DESIGNATIONOFA
NEIGHBOURHOOD
NEIGHBOURHOOD
AREA
FORUM
Whathappensatthis
On
receipt
of
a
valid

On
receipt
of
a
valid

application,
OPDC
will
as

stageandhowlongis application,
OPDC
will
as

soon
as
possible
publicise
soon
as
possible
publicise

it?
on
OPDC
website
the

on
OPDC
website
a
copy

intention
and
name
of
the
of
the
application,
with

area
proposed
for

details
of
how
to
make

designation,
a
map
of
the
representations
with
the

area
and
the
name
of
the
date
that
these
must
be

relevant
body
that
applied
received.

Where

for
the
designation.
OPDC
appropriate,
OPDC
will

will
explain
how
to
make

notify
members
of
the

representations.
Where

community
by
email
or

appropriate,
OPDC
will

letter.

notify
members
of
the



community
by
email
or

A
minimum
of
6
weeks
to

letter.

gather
responses
from
the



community.

A
minimum
of
6
weeks
to


gather
responses
from
the
OPDC
will
publish
the

community.

decision
as
soon
as



possible
on
website.
If
the

Within
8
weeks
of
the

application
is
approved,

publication
of
the

OPDC
will
publish
the

application
(20
weeks
for
name
of
the
Forum,
a
copy

an
area
falling
within
2
or
of
the
written
constitution,

more
local
planning

the
name
of
the

authorities),
OPDC
will

Neighbourhood
Area
the

NEIGHBOURHOOD
DEVELOPMENTPLANS

NEIGHBOURHOOD
PLANREFERENDUM

OPDC
will
publicise
the

proposed
Neighbourhood

Plan
on
OPDC
website

along
with
details
where
it

can
be
inspected
and

details
on
how
to
make

representations
with
the

date
that
these
must
be

received.

Where

appropriate,
OPDC
will

notify
members
of
the

community
by
email
or

letter.



A
minimum
of
6
weeks
to

gather
responses
from
the

community.



OPDC
will
notify
all

consultation
bodies
that

requested
to
be
notified

and
bodies
referred
to
in

the
Forums
consultation

statement.



OPDC
will
check
that
the

appropriate

OPDC
will
work
with
the

relevant
local
borough(s)

to
arrange
for
a

referendum
to
take
place

in
the
area
and
will
ensure

that
the
information

statement
and
specified

documents
are
published

on
OPDC
website
during

the
referendum
period.



OPDC
may
contact
any

other
members
of
the

community
and
wider
area

that
it
considers

appropriate
along
with

those
that
have
requested

to
be
notified.



If
the
referendum
results
in

more
than
half
those

voting
in
favour
of
the

proposal,
OPDC
will
adopt

the
Plan
as
soon
as

reasonably
practical
unless

is
considers
this
would

breach
or
be
incompatible

Page 173

publish
the
decision
on

whether
to
designate
a

Neighbourhood
Area
on

website.
If
the
application

is
approved,
OPDC
will

publish
the
name
of
the

Area,
map
of
the
Area
and

name
of
the
group

submitting
the
application.


If
the
application
is

refused,
OPDC
will
publish

on
website
the
decision

and
statement
of
reasons

and
where
documents
may

be
inspected.
OPDC
will

also
contact
the
group

applying
for
the

Neighbourhood
Area

designation
and
anyone

that
has
requested
to
be

notified.

application
relates
to
and

the
contact
details
of
at

least
one
member
of
the

Forum).
If
the
application

is
refused,
OPDC
will

publish
the
refusal

statement
detailing
the

reasons
for
refusal
and

where
this
may
be

inspected.
OPDC
will
also

notify
the
applicant.







OPDC
will
withdraw
an

application
if
it
is

requested
by
the
proposed

forum
at
any
time.

documentation
submitted

complies
with
statutory

requirements
and
notify

the
Forum
whether
or
not

OPDC
is
satisfied.
Once

satisfied,
OPDC
appoint
an

independent
examiner
with

the
consent
of
the
Forum.

Once
the
examiner
is

appointed,
OPDC
will

submit
the
plan
to
the

examiner
as
soon
as

possible
after
receipt
with

any
representations
and

any
other
documents

submitted
with
the
Plan.



Following
the
publication

of
the
examiners
report,

recommending
whether
a

local
referendum
should
be

undertaken,
OPDC
will

consider
and
respond
to

each
recommendation
and

determine
whether
the

draft
Plan:

a. meets
the
basic

conditions
of
the
Act;

b. is
compatible
with
the

Convention
Rights;
and


c. complies
with
the

definition
of
an

Neighbourhood
Plan

with
any
EU
obligation
or

any
of
the
Convention

Rights.
OPDC
will

subsequently
publicise
the

decision
and
reasons
for

decision
alongside
details

of
where
and
when
this

can
be
inspected.


OPDC
will
send
a
copy
of

the
decision
to
the
Forum

and
anyone
who
asked
to

be
notified
of
the
decision.

OPDC
will
also
publish
the

Plan,
details
of
when
and

where
it
can
be
inspected

and
notify
anyone
who
has

asked
to
be
notified
that
it

has
been
made
and
where

and
when
it
may
be

inspected.



If
an
environmental
report

was
produced,
OPDC
will

inform
the
consultation

bodies.

Page 174

Then
a
local
referendum

will
be
held.
As
part
of

OPDCs
response,
it
can

make
modifications
to

correct
errors
or
to
make

the
Plan
comply
with
a-c

above.



As
soon
as
possible
after

considering
the
examiners

recommendations
and

deciding
to
take
forward

the
Plan,
OPDC
will

publish
the
decision

statement,
details
of
where

and
when
this
report
and

the
examiners
report
can

be
inspected.
OPDC
will

send
a
copy
of
the

statement
to
the
Forum

and
anyone
who
asked
to

be
notified
of
the
decision.







5


Consultationonplanningapplications
5.1 OPDC
will
take
a
positive
and
pro-active
approach
to
engaging
the
community
and

applicants
in
the
planning
process.
This
will
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.


Pre-applicationConsultation
5.2 Developers
for
all
major
schemes
will
be
expected
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.



5.3 OPDC
will
offer
a
pre-application
advice
service.
However
any
advice
given
is
without

prejudice
to
future
decisions
of
OPDC.
Where
necessary,
internal
and
external

consultees
may
be
asked
for
their
comments
on
proposals.



5.4 Applicants
for
all
major
schemes
are
expected
to
engage
with
the
community
before

submitting
a
planning
application.
There
are
a
number
of
ways
in
which
OPDC
will

expect
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.



Planningfora

OPDC
may
consider
it
necessary
to
arrange
planning
for
a
for
significant

development
proposals
at
the
pre-application
stage.
These
for
a
should
include

representatives
from
local
resident
and
amenity
groups,
and
community
network

organisations,
and
ward
councillors
are
invited
to
participate
in
a
round
table
discussion

with
the
applicants,
facilitated
by
an
independent
chair
person.
Planning
fora
enable
local

resident
groups
and
others
to
discuss
proposals
directly
with
the
applicant
and
to
make

suggestions
about
how
schemes
could
be
improved.
OPDCs
planning
officers
will
not

participate
in
the
discussion
or
give
a
view
as
to
the
acceptability
of
the
proposals.


5.5 Pre-application
consultation
will
not
remove
the
need
for
involvement
and
scrutiny
of

any
subsequent
planning
application.



Planningapplications
5.6 The
scope
and
extent
of
community
involvement
that
is
possible
in
an
individual

planning
application
will
vary
according
to
the
significance
and
scale
of
the
proposal.



5.7 OPDC
encourages
applicants
to
prepare
a
statement
setting
out
how
it
will
involve
the

whole
community
in
line
with
the
principles
of
the
SCI.
The
results
of
any
community

consultation
should
be
made
available
to
OPDC
to
assist
in
understanding
local
views

and
identifying
particular
areas
of
concern
raised
by
residents.
The
results
should

Page 175



normally
be
made
available
by
the
applicant
to
residents,
so
that
they
can
see
how

their
comments
were
considered.



5.8 OPDC
cannot
refuse
to
accept
a
valid
application
because
it
disagrees
with
the
way
in

which
an
applicant
has
consulted
the
community.
However,
OPDC
would
encourage

applicants
to
engage
with
the
community
in
line
with
OPDCs
Community
Charter.




5.9 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
consultation

period
of
21
days.
The
methods
of
consultation
include:

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
SiteNoticesandPressNotices:-
where
required,
a
site
notice
will
be
put
up
near
the

site
and
a
public
notice
will
be
placed
in
the
local
press,
and/or

PressNotices:-where
required
a
public
notice
will
be
placed
in
the
local
press

5.10 In
some
cases,
the
consultation
period
may
be
extended
or
new
periods
granted
at
the

discretion
of
OPDCs
case
officer.

5.11 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.



5.12 For
some
large
schemes,
OPDC
may
also
produce
a
specific
webpage
with
information,

and
updates,
as
well
as
a
link
to
the
consultation
page.



5.13 Consultation
on
the
pre-application
and
application
stage
is
set
out
in
Table
E.



Appeals

5.14 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.



5.15 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.







5.16 The
exact
consultation
methods
appropriate
to
specific
planning
applications
will

depend
on
the
complexity
of
the
proposals.
An
outline
is
set
out
in
Table
F.







Page 176

Page 177

TableE:Consultationonpre-applicationsandplanningapplications


Pre-application
Whatconsultationwilltherebe?
OPDC
expects
applicants
to
engage
the

community/residents
at
an
early
stage
in
the

formulation
of
any
scheme.



For
all
major
applications,
the
applicant
will
be

expected
to:



1. Hold
a
public
exhibition
at
an
accessible

time
and
in
an
appropriate
location

2. Participate
in
planning
fora





Whowillbenotifiedandhow?
Public
exhibitions
are
organised
by
the

applicant.
For
planning
fora,
OPDC
will
invite

representatives
from
all
known
active
resident

groups
and
associations
relevant
to
the

proposals.



Further
details
on
the
process
of
consulting

with
ward
panels
will
be
available
as
they

become
established.












Planningapplications
All
planning
applications
are
subject
to
a
formal

consultation
period.

Notifications
of
planning
applications
will
be

sent
to
properties
that
are
immediately

adjacent
to
an
application
site
and
directly

affected
by
an
application.



Where
statute
requires,
a
site
notice
will
be
put

up
near
the
site
and
a
public
notice
will
be
put

into
the
local
press.
Details
of
all
applications

received
and
associated
plans
and
documents

will
also
be
made
available
to
view
on
OPDCs

website.
Special
web
pages
are
created
for

certain
major
applications.




Howcanyoucomment?

Howlongwillyouhavetocomment?

Whatkindofcommentscanyoumake?

Page 178

WhatwillOPDCdowithyourcomments?

At
Public
Exhibitions,
applicants
are
usually
on

hand
to
receive
comments.



At
planning
fora,
representatives
from
resident

groups
and
associations
can
express
views
on

proposals
during
a
round
table
discussion.
Comments
can
be
made
directly
to
the

applicants
at
public
exhibitions.



Planning
forums
are
usually
2
hours
long
and

comments
are
made
during
this
time.
You
can
usually
provide
any
comments
to
the

applicant
at
public
exhibitions.
At
planning

forums,
the
chairperson
will
facilitate
a

discussion
on
topics
agreed
by
the
participants

at
the
table.
These
should
be
limited
to
matters

relevant
to
planning.

Notes
will
be
taken
at
planning
forums
and
sent

to
all
participants,
including
the
applicant.
The

applicant
is
encouraged
to
take
comments
from

both
public
exhibitions
and
planning
forums

into
account
where
possible
before
submitting

the
formal
planning
application.



OPDC
encourages
applicants
to
produce
a

statement
setting
out
how
comments
have

been
taken
on
board
and
submit
this
as
part
of

any
subsequent
planning
application.

Comments
can
be
submitted
through
the

website,
or
when
necessary
submitted
by
letter.

Each
application
has
an
initial
consultation

period
4-6
weeks
depending
on
the
scale
of
the

application.
In
some
cases
the
consultation

period
may
be
extended
or
new
periods
granted

at
the
discretion
of
the
case
officer.

You
can
comment
on
anything
to
do
with
the

application,
however
only
planning
matters
can

be
taken
into
account.

The
case
officer
for
an
application
will
take
all

comments
received
into
consideration
when

preparing
his
or
her
report
on
the
application.

For
committee
level
decisions,
all

representations
will
also
be
made
known
to
the

Planning
and
Development
Control
Committee

(PDDC).



People
and
any
existing
ward
panels
that
have

commented
on
an
application
in
support
or

against
it,
may
be
permitted
to
speak
at
the

PDDC
meeting
(Public
Speaking
is
subject
to
a

separate
protocol).



If
an
appeal
is
made
against
any
decision,

comments
received
will
also
be
forwarded
to

Page 179

the
Planning
Inspectorate.

Whenwilladecisionbemadeandhowwill No
decisions
are
made
at
pre-application
stage.
OPDC
will
aim
to
determine
delegated
decisions

within
8
weeks
of
receipt
of
the
application,

youbenotified?
and
committee
level
decisions
within
13
weeks.

However,
these
timescales
may
vary
depending

on
the
particulars
of
the
application.
Everyone

that
was
consulted
about
the
application
will
be

notified
of
the
decision,
and
the
decision
notice

will
be
made
available
on
the
website.



Anyone
can
be
notified
of
the
outcome
of
any

planning
application
by
tracking
any
application

on
the
OPDC
website.

























TableF:Consultationonappeals



WrittenRepresentations
What
will
OPDC
notify
you
of
and
OPDC
will
notify
interested
parties

how?

by
letter
within
2
weeks
of
the

receipt
of
the
appeal.

Page 180

Whatcanyoucommentonand
how?

InformalHearings
OPDC
will
notify
interested
parties

by
letter
within
2
weeks
of
the

receipt
of
the
appeal.



Interested
parties
will
also
be

notified
of
the
date
and
venue
of

the
hearing
at
least
2
weeks
before

the
hearing.



You
can
write
to
the
Planning

You
can
write
to
the
Planning

Inspectorate
by
post,
email
or

Inspectorate
by
post,
email
or

through
the
planning
portal

through
the
planning
portal

website.
You
can
comment
on

website.
You
can
comment
on

anything
that
is
relevant
to

anything
that
is
relevant
to

planning.
You
do
not
need
to

planning.
You
do
not
need
to

repeat
any
comments
you
made
at
repeat
any
comments
you
made
at

application
stage
as
OPDC
will

application
stage
as
OPDC
will

forward
these
to
the
Planning

forward
these
to
the
Planning

Inspectorate.

Inspectorate.
You
can
also

participate
in
the
informal
hearing

by
turning
up
on
the
day
and

letting
the
Inspector
know
that

you
would
like
to
speak.
You
can

also
attend
the
Inspectors
site
visit

and
request
that
the
Inspector

views
the
application
site
from

your
property
if
you
wish.

PublicInquiries
OPDC
will
notify
interested
parties

by
letter
within
2
weeks
of
the

receipt
of
the
appeal.



Interested
parties
will
also
be

notified
of
the
date
and
venue
of

the
Inquiry
(which
will
be

accessible
to
all)
at
least
4
weeks

before
the
Inquiry.

You
can
write
to
the
Planning

Inspectorate
by
post,
email
or

through
the
planning
portal

website.
You
can
comment
on

anything
that
is
relevant
to

planning.
You
do
not
need
to

repeat
any
comments
you
made
at

application
stage
as
OPDC
will

forward
these
to
the
Planning

Inspectorate.
You
can
also

participate
in
the
Inquiry
by

turning
up
on
the
day
and
letting

the
Inspector
know
that
you
would

like
to
speak.
You
can
also
attend

the
Inspectors
site
visit
and

request
that
the
Inspector
views

the
application
site
from
your

property
if
you
wish.

Page 181

Howlongdoyouhaveto
comment?

You
have
6
weeks
from
the
start

You
have
6
weeks
from
the
start

date
of
the
appeal
process
to
make
date
of
the
appeal
to
make
your

your
comments.

comments.
If
you
want
to
speak
at

the
hearing,
the
Inspector
will

invite
you
to
speak
during
the

hearing.

You
have
6
weeks
from
the
start

date
of
the
appeal
to
make
your

comments.
If
you
want
to
speak
at

the
Inquiry,
the
Inspector
will

invite
you
to
speak
during
the

inquiry.

Whatwillhappentoyour
comments?

The
Planning
Inspector
will
take
all

comments
into
account
when

making
his
or
her
decision
on
the

Appeal.
They
will
also
be
sent
to

the
Appellant
and
OPDC.

The
Planning
Inspector
will
take
all

comments
into
account
when

making
his
or
her
decision
on
the

Appeal.
They
will
also
be
sent
to

the
Applicant
and
OPDC.

The
Planning
Inspector
will
take
all

comments
into
account
when

making
his
or
her
decision
on
the

Appeal.
They
will
also
be
sent
to

the
Appellant
and
OPDC.

The
Inspectorate
aims
to
issue
a

decision
within
7
weeks
of
the

hearing
and
the
decision
will
be

made
available
on
the
Appeal

pages
of
the
planning
portal

website.

The
Inspector
will
indicate
a
likely

timescale
for
the
decision
at
the

end
of
the
Inquiry
and
the
decision

will
be
made
available
on
the

Appeal
pages
of
the
planning

portal
website.

Whenwillthedecisionbemade The
Inspectorate
aims
to
issue
a

decision
within
5
weeks
of
the

andhowwillyoubenotified?
hearing
and
the
decision
will
be

made
available
on
the
Appeal

pages
of
the
planning
portal

website.






6. Assessmentandmonitoring

6.1 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.



6.2 As
and
when
necessary,
the
SCI
will
be
reviewed
and
updated
to
reflect
any
changes

required
as
identified
through
this
monitoring
as
well
as
through
any
changes
to
national

legislation.
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 182



Appendices

Appendix1

Categoriesofgeneralconsultationbodies*
Amenityandenvironmentalorganisations
Representing
people
with
an
interest
in
planning,
conservation
and
environmental
sustainability

issues
in
the
borough
or
parts
of
it
(including
parks).
Examples
include
but
are
not
limited
to:

Grand
Union
Alliance
and
the
Friends
of
Wormwood
Scrubs.

BusinessorganisationsoperatingintheMayoralDevelopmentCorporationarea
Representing
businesses
within
particular
areas
or
with
a
common
type
of
business,
including

the
development
industry,
major
land
owners
and
registered
social
landlords.
Examples
include

but
are
not
limited
to:
Park
Royal
Business
Group
and
West
London
Business
Group.

Communityorganisationsandnetworks
Representing
people
from
particular
black
and
minority
ethnic
communities,
people
of
a

particular
age,
gender
or
gender
orientation,
faith
groups,
disabled
people
and
refugees.
There

is
a
well-developed
Community
and
Voluntary
Sector
Network
of
area
and
community
of

interest
forums
in
the
local
area.

Specialinterestorganisations
Representing
people
with
a
common
interest
in
topics
such
as
sport
or
other
activities.

Examples
include
but
are
not
limited
to:
Thames
Valley
Harriers.


TenantsandResidentsAssociations
Representing
the
broad
interests
of
tenants
and
residents
within
estates,
streets,
small
areas
or

wards.
Examples
include
but
are
not
limited
to:
Wells
House
Road
Residents
Group,
Midland

Terrace
Residents
Association
and
The
Island
Triangle
Association.


*
See
also
Town
and
Country
Planning
(Local
Planning)
(England)
Regulations
2012.


Appendix2

HowOPDCwillcommunicate
Letters
OPDC
will
send
letters
by
post
or
hand
deliver
door
to
door
where
this
is
appropriate
in
small

areas.
Where
there
are
issues
directly
affecting
people
in
specific
areas
of
the
borough
(e.g.

individual
sites/streets/estates)
OPDC
will
use
targeted
methods
of
notification,
such
as
direct

mailing
or
door-to-door
delivery.
For
planning
applications,
or
pre-application
consultation,
the

extent
of
notification
will
vary
depending
on
the
nature
of
the
application
and
the
likely
extent

of
its
impact.
OPDC
will
seek
to
notify
those
people
or
organisations
that
have
previously
made

representations
on
a
site
or
application.

E-alerts
OPDC
is
exploring
whether
people
can
sign
up
e-alerts
and
receive
news
of
submitted
planning

applications.
You
can
specify
a
search
area
and,
when
the
council
receives
a
planning
or

licensing
application
in
that
area,
you
will
receive
an
email
of
it.

Email
If
you
tell
us
that
you
would
prefer
to
be
contacted
and
receive
information
on
planning
policy

matters
by
email,
OPDC
will
use
that
method.

Page 183



OPDCWebpages
Wherever
possible
OPDC
will
use
electronic
methods
for
providing
information
alongside
a
hard

copy.
OPDC
will
use
the
webpages
to
provide
more
information
for
the
Local
Plan
with
copies

of
written
documents
and
summaries.

Localnewspapers
In
accordance
with
the
Regulations,
public
notices
will
be
placed
in
local
newspapers

concerning
consultation
on
the
Local
Plan
and
planning
applications.
Press
releases
will
also
be

issued
where
appropriate.

Informationpoints
For
Local
Plan
consultation,
OPDC
will
aim
to
use
venues
that
are
accessible,
such
as
local

libraries
and
civic
buildings
to
distribute
information
about
the
process
and
copies
of

documents
(see
Appendix
2).
Where
appropriate
OPDC
will
provide
information
at
locations

such
as
schools,
colleges,
doctors
surgeries,
faith
centres,
shopping
centres
and
other

community
meeting
places.

Partnerwebsites
OPDC
will,
where
appropriate,
invite
partners
and
Registered
Social
Landlords
to
have
links
to

our
website
for
the
Local
Plan
process.

Usingaccessibleformats
It
may
often
be
important
to
make
summaries
of
relevant
information
available
in
accessible

formats,
for
example:
audiotape,
Braille,
large
print
versions,
hard
copies
for
those
without

Internet
access
and
summaries
in
another
language.
Using
interpreters
and
signers
at
meetings

may
be
appropriate.
Where
public
meetings,
exhibitions,
workshops
and
other
methods
of

community
engagement
are
arranged,
these
will
be
in
accessible
buildings
in
safe
locations
and

at
convenient
times.

SocialMedia
OPDC
will
explore
ways
in
which
Social
Media
can
be
used
to
communicate
information
to
new

and
existing
audiences.
Examples
include
but
are
not
limited
to:
Twitter.

Quantitativemethods
Opinionsurveys
These
are
surveys
designed
to
obtain
views
on
a
particular
subject,
normally
from
a

representative
sample
of
the
population.
For
example,
as
part
of
the
evidence
gathering
process

for
the
Core
Strategy
OPDC
carried
out
a
major
survey
of
residents
views
on
shopping
in
the

borough.
General
surveys
of
satisfaction
with
council
services
are
carried
out
regularly
and
can

identify
issues
to
be
dealt
with
in
the
development
plan
process.
Opinion
surveys
can
be
useful

for
pre-application
consultations
but
need
to
be
carried
out
carefully
to
avoid
bias.
The
time
it

takes
to
carry
out
these
surveys
normally
makes
them
unsuitable
for
consideration
of
planning

applications.

Qualitativemethods
Exhibitions
These
are
most
useful
when
explaining
particular
development
proposals
at
a
pre-application

stage
or
dealing
with
local
planning
proposals.
They
can
be
used
effectively
with
drop-in

sessions
where
officers
are
available
to
deal
with
ad-hoc
queries.
Small
displays
at
information

points
and
centres
can
alert
passing
members
of
the
public
to
proposals.
Exhibitions
may
also

be
held
by
developers
as
part
of
pre-application
consultation.

Workshopsandfocusgroups
These
are
methods
of
engaging
with
a
smaller
number
of
stakeholders
or
community

representatives
to
explore
particular
planning
issues
in
more
depth
than
is
often
possible
at
a

Page 184



general
public
meeting.
OPDC
will
use
these
as
part
of
consultation
on
the
local
development

plan
documents.
They
may
also
be
useful
in
the
early
stages
of
discussion
on
development

proposals
at
pre-application
stage,
but
not
when
schemes
have
been
finalised
as
part
of
a

planning
application.

Publicmeetings

Public
meetings
can
sometimes
be
effective
ways
of
providing
an
introduction
to
particular

proposals.
However,
there
are
limits
to
their
effectiveness
in
gauging
a
wide
range
of
opinion

on
all
relevant
issues,
or
engaging
sufficiently
wide
community
representation.
They
are
not

normally
suitable
for
in
depth
discussions.
Public
meetings
could
be
held
as
part
of
the

consideration
of
some
very
major
planning
applications
at
the
pre-application
stage
to
inform

people
about
proposals
and
to
enable
clarification,
but
it
is
for
the
applicant
to
present
their

proposals.

CommunityInitiatives
These
could
include
local
evidence
or
survey
work
carried
out
by
local
communities
and
interest

groups.





































Page 185



Appendix3Planningpolicydocumentinformationpoints

Planning
policy
documents
will
be
available
to
view
at:



City
Hall,
The
Queens
Walk,
More
London,
London
SE1
2AA

Harlesden
Library,
NW10
8SE

Old
Oak
Community
Centre,
Braybook
Street,
W12
0AP



As
well
as
designated
locations
as
part
of
series
of
workshops/events
that
will
be
advertised.












































Page 186



Appendix4Glossary

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 187



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
the
councils

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 188



Appendix5DraftOPDCCommunityCharterSummaryofResponses


Respondents:

1. Grand
Union
Alliance

2. The
Island
Triangle
Residents
Association

3. Wells
House
Road

4. Mark
Walker

5. LB
Brent

6. Member
of
Public

7. Friends
of
Wormwoods
Scrubs

8. Member
of
Public



1. Doyouagreewiththeproposedconsultationmeetings?

Information
should
be
provided
regarding
the
format,
length
of
workshops
and
envisaged
use
of

outputs.

The
Charter
should
enable
the
potential
for
additional
meetings
to
be
carried
out.


2. DoyouagreewiththeproposedmembershipoftheCommunityChampionWorking
Group?

The
Charter
should
make
reference
to
existing
community
groups
within
the
OPDC
area
(including

residents
and
business
groups)
and
groups
to
the
south
of
the
area.

Existing
residents
and
small
businesses
within
the
OPDC
should
have
a
dedicated
seat
within
the

CCWG
with
resident
groups
views
having
primacy
over
other
groups.

Target
hard
to
reach
groups
to
address
any
engagement
gaps
(potentially
by
liaising
with
local

places
of
worship).

Clarity
needs
to
be
provided
regarding
the
eligibility
and
monitoring
of
membership.

The
Grand
Union
Alliance
is
proposed
to
be
the
CCWG.


3. DoyouagreewiththenumberofproposedCommunityChampionWorkshops?

Support
for
the
number
of
workshops
as
a
minimum.

Engagement
should
be
open
ended
and
ongoing.



4. Doyouagreewiththeproposedcommunicationmethods?


Considered
to
be
acceptable
as
a
minimum
in
addition
to
addressing
the
needs
of
specific
groups.

Support
for
a
drop-in
shop
front
unit.

Additional
other
suggested
methods
include:



o Distribution
of
material
through
community
networks

o Use
of
plain
English
in
documents

o Development
of
an
OPDC
Communications
Steering
Group

o Continuing
face-to-face
meetings

o Use
of
local
businesses
and
shops
windows

o Use
of
building
hoardings
for
advertisements

o Use
of
Local
Radio
Station
(Bang
Edutainment)

o Utilising
local
Safer
Neighbourhoods
Teams

o Support
a
Joint
Community
Forum


o Coordinate
with
boroughs
consultation
officers

Page 189



5. CanyousuggestsuitableaccessiblemeetingvenueswithinandneartoOldOakandPark
Royal?


Suggestions
included
Holiday
Inn
Express
Park
Royal,
Holiday
Inn
West,
All
Souls
Church,
Nash
House

(from
September
2015)
and
the
Old
Oak
Community
Centre.


Othercomments



Other
comments
were
made
relating
to
the
following
themes:


Funding
and
assistance


Funding
should
be
provided
to
train
local
people
in
planning
matters
and
to
support
administration

activities.



Governance
of
CCWG

Additional
information
regarding
the
nature
and
composition
of
the
CCWG
was
requested.

The
CCWG
was
suggested
to
be
independent
of
OPDC
and
accountable
to
its
members

A
sunset
clause
was
suggested
in
the
functioning
of
the
Charter
to
enable
long-term
flexibility.

Additional
clarity
was
sought
regarding
how
the
activities
of
the
CCWG
will
be
monitored
and

evaluated.



Influence
of
CCWG

Further
clarity
of
how
the
CCWG
will
function
with
the
OPDC
Board
and
how
it
would
influence
the

Local
Plan
development
process
was
requested.



Ongoing
engagement

Role
of
Statement
of
Community
Involvement

Guidance
for
Neighbourhood
Planning
and
Neighbourhood
CIL

Page 190

$SSHQGL[%

Community
Charter (draft)
Proposed Old Oak & Park Royal Development Corporation
What is the role of the Community Charter?
The proposed Old Oak & Park Royal Development Corporation (OPDC) has produced this draft Charter to
demonstrate its commitment to meaningful and transparent community engagement that will help to shape the
regeneration of Old Oak and protection of Park Royal.
The draft Charters role is to set out when and how community engagement will be carried out. It is a
key document to help to engage with existing and future community stakeholders and aspires to foster a
SDUWLFLSDWRU\DSSURDFKWRHQVXUHORFDOSHRSOHDUHHPSRZHUHGWRGLUHFWO\LQXHQFHWKHGHYHORSPHQWRISODQQLQJ
policy and the future of the area. Should the proposed OPDC be established, the Charter will be used to inform
the development of the Statement of Community Involvement.

How is it being developed?

N
O
I
S
S
U
C

The draft Charter is being informed by discussions with community groups, national guidance and the three
boroughs Statements of Community Involvement alongside emerging local community charters, including the
Grand Union Alliances Charter.

S
I
D
R

What is the Community Champions Working Group?

O
F
T

The Community Champions Working Group is a group envisaged to primarily lead the communitys involvement
in informing planning issues. It is recognised that its roles may evolve to expand into non-planning matters. It
is proposed that the group could comprise of representatives from local community groups including Friends
of Wormwood Scrubs, Grand Union Alliance, Harlesden Town Team, Harlesden Neighbourhood Forum and Park
Royal Business Group.

F
A
DR

Who is the Community Charter for?

7KH&RPPXQLW\&KDUWHUKDVEHHQVSHFLFDOO\GHYHORSHGWRVHWRXWKRZWKHSURSRVHG23'&ZLOOHQJDJHZLWK
the following community stakeholders:

Residents

Community
& interest
groups

Business
groups

Page 191

Hard to
reach
groups

Elected
representatives

How will the proposed OPDC engage with the community?

Our commitments to the community are to:
1. Commence community engagement from the earliest appropriate opportunity in planning processes.
2. Deliver transparent, accessible and meaningful community engagement that is proportionate to the nature
of the planning processes being undertaken by:
a. providing information in an accessible format;
b. notifying community stakeholders in a timely manner through:
i.
ii.
iii.
iv.

letters or emails to those on the contact database;

local publications;
OPDC website updates; and
other relevant media.

c. documenting comments; and

d. responding to comments.
3.
4.
5.
6.

O
F
T

S
I
D
R

N
O
I
S
S
U
C

Establish a Community Champion Working Group to shape the development of planning policy.
Deliver ongoing open two-way engagement.
Develop and manage a contact database.
Engage and support Neighbourhood Planning Forums.

F
A
DR

When will the proposed OPDC engage with the community?

The proposed OPDC will engage with community stakeholders:

Jan

Feb

Mar

Consultation meetings

Local Plan
introduction

OAPF
Consultation

Consultation
with individual
groups

1. through the development of the Community Charter and Statement of Community Involvement;
2. through ongoing engagement attending meetings as required including during the forthcoming OAPF
consultation; and
3. by arranging and attending public consultation meetings and the Community Champions Group workshops
in 2015:

Apr

May

Jun

Community Champion Workshops

Jul

Page 192

Aug

Sept

Oct

Nov

Dec

How can you get in contact?

The OPDC can be contacted:
By email:
info@opdc.london.gov.uk
By post:
Old Oak & Park Royal Development Corporation,
Greater London Authority,
City Hall,
Queens Walk,
More London Riverside
London
SE1 2AA

Questions
1.
2.
3.
4.
5.

Do you agree the proposed consultation meetings?

Do you agree with the proposed membership of the Community Champion Working Group?
Do you agree with the number of proposed community champion workshops?
Do you agree with the proposed communication methods?
Can you suggest suitable accessible meeting venues within and near to Old Oak and Park Royal?

F
A
DR

O
F
T

S
I
D
R

Page 193

N
O
I
S
S
U
C

This page is intentionally left blank

Page 194

Agenda Item 10

Subject:

Greater
London
Authority
Old
Oak
and
Park
Royal
Opportunity

Area
Planning
Framework
Consultation
Responses

Meeting
date:
28July2015
Report
to:
Board
Report
of:

ChiefExecutiveOfficer

For
noting

________________________________________________________________________



This
report
will
be
considered
in
public

________________________________________________________________________


1

Summary

1.1

ThisreportandAppendixAprovidesasummaryoftheGLAsproposedresponsesto
thecommentsreceivedaspartofthepublicconsultationonthedraftOldOakand
ParkRoyalOpportunityAreaPlanningFramework(OAPF).Thispublicconsultationran
fora6weekperiodfrom27February14April2015.

1.2

Atthisstage,OPDCPlanningCommitteeisbeinginvitedtocommentontheGLAs
proposedresponsetothepublicconsultation.CommentsprovidedbyOPDCPlanning
CommitteeandBoardwillbeconsideredbytheGLAwhomaymakerevisions.The
GLAsfinalversionoftheOAPFwillbere-submittedtoOPDCBoardviaOPDC
PlanningCommitteeforconsiderationandendorsementinSeptember.Subjecttothis
endorsement,theMayorofLondonwouldbeaskedtoadopttheOAPFinOctober
2015asSupplementaryPlanningGuidance(SPG)totheLondonPlan.

1.3

OPDCcannotdirectlyadopttheOAPFasaSupplementaryPlanningDocument(SPD)
untilithasadopteditsownLocalPlan.

1.4

OPDCofficershaveconsideredtheGLAsproposedresponses.OPDCofficersagree
withtheproposedGLAresponsesandamendmentstotheOAPFandrecommendthat
theGLAresponsesandamendmentsaresupportedbyOPDCBoard.

Recommendations

TheBoardisinvitedto:

2.1

Note
thecommentsofOPDCplanningcommitteeon15July2015regardingthe
GLAs
proposedresponsestothecommentsreceivedaspartofthepublicconsultation
onthedraftOldOakandParkRoyalOpportunityAreaPlanningFramework(OAPF);
and

Page 195

2.2

Comment
on
theGLAsproposedresponsestothecommentsreceivedaspartofthe
publicconsultationonthedraftOldOakandParkRoyalOpportunityAreaPlanning
Framework(OAPF).



Background

3.1

In2013,theGLA,incollaborationwithTransportforLondon(TfL)andtheLondon
BoroughsofBrent,EalingandHammersmithandFulhamconsultedonOldOakA
VisionfortheFuture,whichdemonstratedhowlandaroundtheplannedOldOak
Commonstationcouldberedeveloped.Thisdocumentwasnotaplanningpolicy
documentbutitdidsetoutanearlysharedvisionastohowthisareacoulddevelopas
aresultofsignificantnewtransportinfrastructure.

3.2

TheLondonPlanconsolidatedwithalterationssince2011waspublishedbytheMayor
inMarch2015.AnnexOnetotheLondonPlanidentifiesOldOakCommonasan
OpportunityAreawiththecapacitytodeliveraminimum24,000homesand55,000
jobs,andidentifiestheParkRoyalOpportunityAreaashavingthecapacitytodelivera
minimum1,500homesand10,000jobs.


3.3

TheGLAsdraftOldOakandParkRoyalOAPFhasbeendevelopedoverthepastyear,
coveringboththeOldOakCommonOpportunityAreaandParkRoyalOpportunity
Area.TheOAPF:

3.4

3.5

providesguidanceondesiredlanduses,infrastructurerequirementsandurban
designmeasuresnecessarytodeliveraqualitynewneighbourhood;
looksatwaystomaximisetheconsiderableinvestmentpresentedbythedelivery
ofasignificantnewHS2/Crossrailinterchange,tofacilitatelargescale
regenerationofthisarea;
exploreshowtheOldOakCommonHighSpeed2stationandsurrounding
developmentcouldbeproperlyintegratedwithsurroundingneighbourhoods,
communitiesandtowncentres;and
helpstofosternewandimprovedpartnershipworkingbetweentheMayor,local
Councils,transportproviders,centralGovernment,landowners,localresidentsand
businessesandpotentialinvestorstoensurethepreparationofarobustand
deliverableplan.


TheOAPFhasbeenproducedbytheGreaterLondonAuthority(GLA)as
SupplementaryPlanningGuidance(SPG)totheLondonPlan(2015).TheMayorplans
toadopttheOAPFaslaterthisyear.ThiswouldgivetheOAPFsubstantialmaterial
weightinthedeterminationofplanningapplicationsintheOldOakandParkRoyal
area.OPDCcouldinthefutureadopttheOAPFasaSupplementaryPlanning
Document(SPD),butitwouldnotbeabletodothisuntilithasadopteditsLocalPlan,
whichisnotprogrammedforadoptionuntilearly2017.
TheGLAconsultedonthedraftOAPFfora6weekperiodfrom27February14April
2015.Toensurethatallinterestedstakeholderswereinformedoftheconsultation,the
documentwaspublishedontheGLAswebsite,interestedpartiesandinterestgroups

Page 196

ontheGLAsconsultationdatabasewereemailed,apublicnoticewaspublishedin
localnewspapersanddropinsessionswereorganisedinthesurroundingarea.
3.6

Therewereatotalof3,516responsestotheconsultationonthedraftOAPF.Ofthese
3,414responseswerereceivedfromsupportersofQPRintheformofastandardised
response.

3.7

ConsulteesrespondedonanumberofissuesrelatingtotheOAPFwhichwere
summarisedintheConsultationSummaryReportasnotedbytheOPDCBoardon18
May2015.


4

4.1



GLA
response
to
public
consultation

TheGLAsresponsetocommentsreceivedduringthepublicconsultationarein
AppendixA:Responsestocommentsreceivedduringthepublicconsultationonthe
draftOldOakandParkRoyalOpportunityAreaPlanningFramework.Thatreportis
splitintotwosections:

Section1providesresponsestoeachoftheissuesraisedbytheLondonBoroughs
ofBrent,EalingandHammersmith&Fulham;and


4.2

Section2providesabroaderresponsetoallissuesraisedduringtheconsultation

Thedetailedreportcoversissuesraisedinrelationtothefollowingthemes:

a. Generalcomments


b. Consultationandengagement


c. Introductionchapter


d. Vision


e. Objectives
Landuse
Housing
Retail
Employmentandtraining
Regenerationcatalyst


f. Design
Publicamenityspace
Streetsandpublicrealm
Buildingheightsanddensities
Builtheritage
Placesandplacemaking


g. OldOak
OldOakNorth
OldOakSouth
OldOakHighStreet
OldOakCommonStation
Page 197

NorthActon
GrandUnionCanal
ScrubsLane
OldOakLane

h. ParkRoyal
Landuse
Improvinginfrastructure
Design
HeartofParkRoyal
WesleyEstate
FirstCentralsite


i.

WormwoodScrubs

j.

Transportchapter
Rail
Roads
Carparking
Buses
Walkingandcycling
Construction

k. EnvironmentStrategy
Water
Waste
Airquality
Energy
Greeninfrastructure
Landcontamination


l.

Delivery
Phasing


m. Publicdrop-insessionsandothereventattendance


n. QPRsupporterssummary


o. Appendices


p. Supportingenvironmentalstudies

5
5.1

Summary
of
key
issues
raised
during
public
consultation
and
the
GLAs

proposed
responses

Informedbytheconsultationresponses,thefollowingsectionsummarisesthekey
issuesraisedinrelationtothedraftOAPFandtheGLAsresponseandproposed
alternations.

Page 198


i.

Consultation

Consultees
raised
concerns
regarding
the
extent
of
public
consultation
and
in

particular,
the
level
of
engagement
with
the
London
Boroughs
of
Brent,
Ealing
and

Hammersmith
and
Fulham.

TheGLAstatesthatthethoughtprocessbehindtheOAPFhasbeenin
developmentoverthepast4years.Thisprocessstartedwiththeproductionofthe
VisionforOldOak,whichwasconsultedonjointlybytheGLA,TfLandthethree
localauthoritiesin2013.That2013Visionhasformedthestartingpointforthis
draftOAPF.
PrepublicconsultationworkontheOAPFtookplaceduring2014andearly2015
andkeystakeholderswereinvolvedinthedocument'sdraftingduringthisperiod.

TheGLAheldweeklyprojectgroupmeetingswiththethreeboroughsto
discussthecontentoftheOAPF.

Otherkeystakeholdershavealsohadopportunitytocommentonpre-draft
OAPFreportsincludinggroupssuchasNetworkRail,HighSpeed2,the
DepartmentforTransport,TransportforLondon,EnvironmentAgency,
HistoricEnglandandlandowners.

TheGLAresponsestatesthatthelevelofconsultationundertakenontheOAPFis
appropriateandgoeswellbeyondstatutoryrequirements.Thepublicconsultation
onthedraftOAPFwasrunoverasixweekperiod.TheOAPFanddetailsof
consultationeventswasmadeavailableontheGLAwebsite.Publicnoticeswereput
inlocalnewspapersandapressreleasewasissueduponthelaunchoftheOAPF.
Fourpublicdrop-insessionswereheldinthelocalareaatdifferentvenuesandat
differenttimestoensurethatasmanypeopleaspossiblewereabletoattend.Hard
copiesoftheOAPFwereprovidedatlocationssuchasHarlesdenLibraryandOld
OakCommunityCentreforreview.Officersalsoattendedmeetingswithlocal
residentandbusinessgroupssuchastheWestActonResidentsAssociation,the
GrandUnionAlliance,BrentCouncilsHarlesdenAreaForumandtheParkRoyal
BusinessGroup.
ii. The
role
of
the
OAPF
versus
OPDCs
Local
Plan

Consultees
questioned
the
need
for
an
OAPF
in
advance
of
OPDCs
Local
Plan
and

requested
further
clarity
on
what
themes
OPDCs
Local
Plan
cover
and
what

evidence
papers
would
be
developed
in
support
of
it.

TheGLAstatethatapolicyframeworkisnecessarytoenablethedeterminationof
planningapplicationsinadvanceofthedevelopmentofOPDCsLocalPlan.The
OAPFprovidesadditionalplanningguidancetoexistingLondonPlanpolicyforOld
OakandParkRoyal.
TheGLAnotesthattheOAPFwillhelpshapeemergingplanningpolicyduringthe
productionoftheOPDCsdetailedLocalPlanoverthecoming18months.TheGLA
proposetoincludeasectionintheOAPFprovidingfurtherclarityonwhatwillbe
coveredaspartofOPDCsLocalPlanandlistingthesupportingstudiesthatwill
supporttheproductionofaLocalPlan.

Page 199



iii. Vision
and
Objectives

Consultees
requested
alterations
to
the
vision
and
objectives
to
make
greater

reference
to;
the
need
for
development
to
be
sustainable;
requiring
development
to

sensitively
enhance
amenity
asset;
promote
catalyst
uses;
and
to
clarify
the

timescales
for
delivery
of
development.

TheGLAsproposetomakechangestothevisionandobjectivestoreflectthe
commentsreceived.Thisincludesstrongerreferencesto;theneedforsustainable
developmentandhowthiscanbeachieved;hownewdevelopmentneedstobe
designedinensureOldOakandParkRoyaliseffectivelyintegratedintoits
surroundingsandinparticularaddressessensitivenearbyamenityassets;and
promotestheroleofcatalystusesforbringingforwarddevelopment.

TheGLAalsoproposestoprovidefurtherillustrationstomoreeffectively
demonstratehowfuturedevelopmentatOldOakandParkRoyalwillbeshaped
withtheaimofbuildingfurtherconfidenceandexcitementinthefutureplans.
iv. Housing

Consultees
requested
that
the
OAPF
be
clearer
on
the
approach
that
will
be
taken
in

securing
affordable
housing
and
that
affordable
housing
provision
should
be
based

on
housing
need,
not
housing
viability.
Consultees
also
raised
concerns
about

international
investors
buying
homes
at
the
expense
of
meeting
Londons
growing

housing
need.

TheGLAsproposetomoreclearlystateintheOAPF,thattheOAPFprovides
additionalplanningguidancetoexistingLondonPlanpolicy.AdoptedLondonPlan
policiesonhousingandaffordablehousingwillbeappliedtoallnewdevelopments.
OPDChascommencedproductionofitsownLocalPlanandassociatedevidence
baseanditisprogrammedforthistobeadoptedinearly2017.TheLocalPlanwill
settheaffordablehousingtargetfortheareaandthatthiswillbebasedonhousing
needaswellaseconomicviabilityandwillbeproducedinlinewithallnationaland
regionalplanningpolicyrequirements.Theaffordablehousingpolicieswillbe
consultedonduringtheproductionoftheLocalPlanandwillalsobeexaminedin
publicbythePlanningInspectoraspartoftheadoptionprocess.
Withregardtointernationalinvestors,theGLAsresponsestatesthattheOAPFwill
beamendedtoencouragedeveloperstosignuptotheMayoralConcordat,which
requiresdeveloperstomarkettheirpropertiesintheUKatthesametimeorin
advanceofmarketingthemabroad.
v. Regeneration
Catalyst

Consultees
were
generally
supportive
of
the
potential
for
large-scale
uses
to
act
as

catalysts
for
regeneration,
whilst
others
raised
concerns
about
the
potential
impact

such
as
use
would
have
on
amenity
and
the
delivery
of
homes
and
jobs
in
the
area.

Page 200

TheGLAproposethattheOAPFwillstateitssupportforcatalystusesinhelpingto
unlockearlyregeneration.
TheOAPFcanstatethatsuchacatalystusecouldincludeasportsand/orleisure
use.
TheGLAalsoproposetoinsertwordingonthepotentialforsmallerscaleusestoact
ascatalystuses.
Newwordingwillalsobeinsertedclarifyingthattheprovisionofcatalystuses
shouldnotbeattheexpenseofthedeliveryofhomesandjobs.
TheacceptabilityofanycatalystusewouldneedtobejudgedagainstDevelopment
Planpoliciesandthatthereforeanyimpactonthesurroundingcontext(including
thetransportnetworkandthebuiltenvironment)wouldbeakeyconsiderations.

vi. Waste

Consultees
requested
further
clarity
regarding
the
approach
that
OPDC
will
take
to

managing
the
waste
apportionment
targets
in
the
London
Boroughs
of
Brent,
Ealing

and
Hammersmith
and
Fulham.
Consultees
also
stated
that
any
relocated
waste

sites
should
be
carefully
planned
and
separated
from
residential
uses.

TheGLAsresponsenotedthatboroughwasteapportionmenttargetswouldbe
dealtwithindetailaspartofOPDCswasteplanningpoliciesandassociated
evidencebase.
TheresponsenotesthatOPDCproposestoadopttheWestLondonWastePlanand
thattheadoptionofthisplanwouldhelpmeettheLondonBoroughsofBrentand
Ealingsapportionment.
Inaccordancewithparagraph5.80oftheLondonPlan,OPDCwillcooperatewith
HammersmithandFulhaminordertoensurethattheboroughswaste
apportionmenttargetsaremetandworkonthiswillbeprogressedthroughOPDCs
LocalPlan.
TheGLAstatedthatanyproposalsfornewwastesiteswouldneedtobeconsidered
againstexistingLondonPlanpolicyandtheimpactofresidentialamenitywouldbe
akeyconsideration.
vii. Park
Royal

Consultees
requested
that
there
be
greater
clarity
regarding
the
vision
for
Park

Royal,
the
approach
to
land
use
and
infrastructure
provision
in
Park
Royal
and
that

a
lot
of
the
detail
contained
in
the
previous
Park
Royal
OAPF
(2011)
is
missing
from

the
draft
Old
Oak
and
Park
Royal
OAPF
(2015).

TheGLAproposetostrengthenthevisionforParkRoyalandtoidentifyhowOPDC
willworktosecuretheregenerationofthisimportantindustrialarea.Inparticular
theOAPFwillexpandonlanduses(includingforstrategicsites),opportunitiesfor
intensification,transportmanagementandconnectivityrequirements,utilityand
broadbandneeds,anddesignquality.
Inaddition,theGLAproposetoexpandtheParkRoyalsectionofthisOAPFto
reflectguidancestatedelsewhereintheadoptedParkRoyalOAPF(2011)

Page 201

specificallywithregardtodesignandroutes,infrastructure,connectionsandthe
roleoftheHeartofParkRoyal.

viii. Building
heights
and
massing

Consultees
stated
that
the
OAPF
was
too
vague
in
its
approach
to
building
heights

and
massing.
Concerns
were
expressed
that
development
would
be
of
too
high
a

density
and
that
tall
buildings
could
have
a
negative
impact
on
their
surroundings.

TheGLAstatesthattheLondonPlanidentifiesOpportunityAreasasappropriate
locationsforhighdensitydevelopment.LondonPlanAnnexAidentifiesOldOak
Commonasbeinganappropriatelocationforhighdensitydevelopmentwhich
couldincludeaclusteroftallbuildingsaroundOldOakCommonstation.

TheGLAhasbeenworkingwiththeMayorsDesignAdvisoryGroup(MDAG)to
reviewthecontentofthedraftOAPFandthreespecificdesignreviewsessionsare
takingplace.AdviceprovidedbyMDAGwillbeincorporatedintothefinalOAPF.


ThefirstreviewwasinMarch2015andMDAGconsideredthegeneralapproach
proposedintheOAPF.

ThesecondreviewwasinJune2015andconsideredbuildingheightsand
density.

ThethirdreviewwillbeheldinJuly2015andwillconsiderconnectivitywith
thewiderarea,streets,publicrealm,andamenityspaces.


TheGLAisdevelopingtheevidencebaseforatallbuildinganddensitystrategyand
additionalevidenceonthiswillbeprovidedalongsidethefinalOAPF.

TheOAPFwillincludeadditionalguidanceonstrategicplanninganddesignaspects
suchastheneedtosecurethehighestqualitydesignstandards,therationalefor
theproposedbuildingheightsstrategy,howtheareacanaccommodatethe
proposedlevelofdevelopment,guidanceondensitiesandtheneedfornew
developmenttorespectthesurroundingareas.

TheGLAalsorecognisesthatthisworkwillcontinuetoberefinedanddeveloped
throughtheproductionofOPDCLocalPlanandthiswillincludedetailed3D
modellingworktofurtherinformtallbuildingdesignandlocation.

ix. Public
Open
Space

Consultees
were
concerned
that
the
quantity
of
public
open
space
proposed
within

the
OAPF
would
be
inadequate
and
would
place
increased
demand
on
existing
open

spaces
in
the
surrounding
area.

TheGLAproposethattheOAPFberevisedtoprovidefurtherclarityand
backgroundinformationregardingtheapproachtakentopublicopenspace
provision,relatingtheprovisionofopenspacebacktoLondonPlanpolicy.

Page 202

TheGLAisdevelopingtheevidencebaseforapublicrealmandamenityspace
strategyandthisevidencewillhelprefinetheproposedapproachintheOAPFand
willbeprovidedalongsidethefinalOAPF.

TheGLAalsorecognisesthatthisworkwillcontinuetoberefinedanddeveloped
throughtheproductionofOPDCLocalPlanandthiswillincludeproductionofan
SupplementaryPlanningDocument(SPD)thatwillprovideguidanceonthedesign
andmanagementofstreets,publicrealmandamenityspace.

x. Wormwood
Scrubs

Consultees
requested
that
the
OAPF
provide
further
clarity
on
the
approach
to
be

taken
to
Wormwood
Scrubs,
the
involvement
of
stakeholders
in
its
planning
and
that

development
and
access
points
should
be
sensitive
to
its
ecological
value.

TheGLAproposetotheincludefurthertextintheWormwoodScrubssection
providingfurthercertaintyontheroleandneedtoprotectWormwoodScrubsasan
importantamenityspaceandthatdevelopmentandaccesspointsshouldbe
sensitivetoitsecologicalvalue.TheGLAalsoproposetosetoutmoreclearlythe
needforjointworkingwithkeystakeholderssuchastheWormwoodScrubs
CharitableTrust,FriendsofWormwoodScrubs,theGrandUnionAllianceandlocal
residentandbusinessgroupsfortheplanningandmanagementofWormwood
Scrubs.

xi. References
to
London
Plan
Policy

Generally,
consultees
felt
that
was
light-touch
in
relation
to
a
number
of
policy

issues
such
as
affordable
housing,
high
quality
design,
air
quality
and
noise
quality.

TheGLAsresponsestatesthataspartoftheDevelopmentPlanforthearea,
LondonPlanpolicywouldapplytoapplicationsandthatitisnotnecessaryto
repeatLondonPlanpolicyintheOAPF.However,theGLAdidproposethatwhere
relevant,specificreferencewillbemadetoLondonPlanpolicyintheOAPF,to
improveclarityandconsistencywiththeLondonPlan,thisisparticularlyrelevantin
relationtohousing,affordablehousinganddesign/architecture.
xii. Transport


Concerns
were
expressed
about
the
ability
of
the
transport
network
to
accommodate

the
proposed
level
of
development
and
how
the
level
of
traffic
would
be
mitigated.

This
was
a
big
concern
for
local
businesses
and
residents
and
in
particular
during
the

construction
phases.

TodateTfLhasproducedatransportmodelforOldOaktounderstandwhat
infrastructurerequirements,publictransportinterventionsandparkingstandards
arenecessarytoensurethedeliveryofaneffectivetransportnetwork.Thisworkhas
informedthedraftOAPFincludingsuchproposalsastheneedfortwonewLondon
Overgroundstations.
AParkRoyaltransportstudyandtransportmodellingworkisnowbeingproduced
andthiswillinformtheproductionofOPDCLocalPlan.Thiswillidentifyfuture
transportinterventionswithinParkRoyal.

Page 203

GLAandTfLwillcontinuetorefinethetransportproposalsintheOAPFinparticular
aroundthebusandcyclenetworks.Workwillalsobeundertakentounderstandthe
needforimprovementstoothertubeandLondonOvergroundstationsinthearea.
ItisrecognisedthatparkingstandardsaresetoutinexistingLondonPlanpolicy
andwouldbeprogressedthroughtheproductionofOPDCsLocalPlan.
GLAandTfLunderstandtheimportanceofsuccessfullyplanningforandmanaging
constructiontraffictoensurethesurroundingareacanoperateeffectively.A
detailedconstructionandlogisticsmanagementplanwillbeproducedandwill
informtheOPDCLocalPlan.Thiswillbeproducedinconsultationwithlocal
stakeholders.
xiii. Delivery

Consultees
requested
greater
clarity
on
the
approach
that
will
be
taken
to
securing

infrastructure
and
that
further
detail
should
be
provided
on
infrastructure

requirements
in
Park
Royal.
Consultees
also
requested
greater
clarity
on
the
social

infrastructure
requirements
arising
from
development
in
the
area
and
the
need
for

service
providers
to
be
engaged
early
in
discussions
on
any
infrastructure
provision.

TheGLAstatethatOPDCsLocalPlanandCommunityInfrastructureLevywillbe
accompaniedbyaDevelopmentInfrastructureFundingStudy(DIFS)whichwill
providedetailedevidencefortheinfrastructurerequirementsforOldOak.
TheGLAnotethatOPDCareundertakingfurtherworkoninfrastructureinPark
RoyalandthiswillinformOPDCsLocalPlan.TheGLAproposetoinsertfurther
wordingontheneedfordetaileddiscussionswithpublicserviceprovidersandthe
councilswhennegotiatinginfrastructureprovision.
ThefutureuseofCPOpowerswillbeamatterforOPDCtotakeadecisionon.
However,OPDCdoeshaveCPOpowersandmaybepreparedtousethesepowers
whereitisconsiderednecessarytosecurethecomprehensiveregenerationofthe
area.
6
6.1

6.2

Comments
from
OPDC
Planning
Committee
and
OPDC
Officers

OPDCPlanningCommitteehaveconsideredtheGLAsproposedresponses.The
PlanningCommitteehaveagreedwiththeproposedapproachandhave
commendedtheworkcompletedtodate.
InadditiontotheproposedapproachsetouttheGLAsreport,OPDCPlanning
CommitteemakethefollowingcommentstoOPDCBoardontheproposed
responses:
TheOAPFshouldprovidefurtherguidanceontheimportanceofplace-making
(landuse,publicrealm,amenityspaceandearlyinterventions)inplayinga
centralroleindeliveringanexemplarregenerationproject.Workshouldbe
carriedouttoincorporateplacemakingprinciplesacrosstheVision,Objectives
anddetailedguidanceintheOAPF.


ThePlanningCommitteesupportstheproposedapproachofimplementingthe
MayoralConcordatinrelationtomarketingnewhomesinLondontoLondoners,

Page 204

withinOPDC,butwouldencourageOPDCBoardtogofurtherthantheMayoral
Concordatwherepossible,wherepossible.


ThePlanningCommitteehighlightedtheneedtodevelopaclearanddeliverable
visionfortheParkRoyalareaandfortheOAPFtoexplainhowthiswouldbe
achieved.


Theproposedlevelofretailshouldmeettheneedsofthedevelopmentandalso
enablethisnewcentretoplayitsroleinthewiderretailhierarchy.Assuchitwas
recommendedthatthefinalquantumofretailshouldnotbesetnowtoserve
solelythedevelopmentwithintheOAPFarea.Amoredetailedevidencebaseis
requiredtosupportthefinalproposedlevelofretail.Thisevidenceshould
considertheimpactofdifferentretaillevelsonbothsurroundingandLondon
wideretailcentres.Thisevidenceshouldprovideguidanceonthenature,form
andtypeofthisretail.ThisevidenceshouldsupportpoliciesintheLocalPlan.


PlanningpolicyisnottheonlytoolopentoOPDCtohelpmanagebusiness
relocationsacrossthearea.ThePlanningCommitteerecommendedthatOPDC
BoardshouldgivemoredetailedconsiderationtohowtheCorporationshould
worktosupportbusinessrelocationsandconsidertheavailabilityofsuitablesites
tosupportthis.


TheevidencebasegeneratedbytheParkRoyalAtlasshouldbefurther
supplementedwithlandownership(landregistry)information.


ThePlanningCommitteehighlightedtheimportanceofintegratingthedesignof
theproposedHighSpeed2stationintoitssurroundingareaandtheimportance
ofthisincreatinganintegratedplace.


TheOAPFshouldmorecarefullydemonstratehowhealthandwell-beingcanbe
promotedaspartofthedesignandlayoutofstreetsandamenityspacesand
shouldclarifyhowthisareacansupportdeliveryofaHealthyNewTown.


ThePlanningCommitteesupportedthedeliveryofanetworkofnewstreetsto
connectthisareaintoitssurrounding,buttheOAPFshouldalsomoreclearly
demonstratehowtheproposedlayoutcansupportdeliveryoftheAllLondon
GreenGrid.


ThePlanningCommitteenotedtheimportanceofdeliveringasufficientamount
andmixofamenityspacetypes(suchashardandgreenlandscaping)thatoffera
varietyofusesandactivities,andwhichcansupportLifetimeNeighbourhoods.


Concernswereexpressedregardingtheimpactoftallbuildingsonsurrounding
sensitivelocations.ThePlanningCommitteehighlightedtheimportanceofhigh
qualitydesignintheselocations.


ThePlanningCommitteesupportsearlydevelopmentwhereitdemonstrateshow
itisdeliveringtherequirementsoftheOAPF,butthatspecificlandowners
shouldnotbereferenced.


Furtherresearchintobestpracticedesignandsettingofcanalsshouldbe
extendedtootherUKcitiesandthisworkshouldbereflectedinthefinalOAPF.


Page 205

 TheOAPFshouldincludesupportfornewwaterbasinsalongthecanal,should
thisbefeasible.


TheHighSpeed2worksitesalongOldOakLaneshouldberetainedasSIL.
Considerationshouldbegivenastohowthesesitescouldsupportthe
developmentofanemploymentinnovationcentre.


ThePlanningcommitteenotedtherealriskofresidentialencroachmentonthe
successfulfunctioningoftheStrategicIndustrialLandandthepotentialnegative
impactthiscouldhaveonthesuccessofParkRoyalbusinesses.


OPDCPlanningCommitteewerealsokeentoexpresstheimportanceofplanning
forutilitiesandtransportacrossParkRoyaltoensurethatthisareacanbea
successfulandfunctioningtheindustrialestate.Itwasrecommendedthatfurther
clarificationbeprovidedintheOAPFonthescopeoftheutilitywork.



Next
Steps

7
7.1

TheGLAwillamendtheConsultationSummaryandResponseReport,havingregard
tocommentsreceivedfromOPDCBoardandOPDCPlanningCommittee.The
revisedtracked-changeversionoftheOAPFwillbereportedtoOPDCPlanning
Committee(2September)andOPDCBoard(15September)forendorsement.

7.2

Followingendorsement,GLAofficerswouldthenfinalisetheOAPF.Thiswillinclude
changestographicsandtexttoreflecttheseearliercommentsreceivedbyOPDC
PlanningCommitteeandBoard.Thisworkwillalsoinvolvethecompletedesktop
publishingoftheOAPF.

7.3

OncecompletetheGLAwouldthenfollowthebelowprocedure:
i. SeekapprovaloftheDeputyMayorforPlanningofthefinalversionoftheOAPF
andagreementtotakethefinalOAPFtothenextavailableMayorsPlanning
meeting
ii. PrepareMayorsreportforadoptionoftheOAPFasSupplementaryPlanning
GuidancetotheLondonPlan.


8

Financial
Implications

8.1

TherearenodirectfinancialimplicationsfortheOPDCarisingfromthisreport.


9
9.1

Legal
Implications
NolegalimplicationsarisefromthereportanditisconsistentwiththeCorporations
legalframework.


10

Appendices
AppendixAConsultationSummaryandResponseReportincludingdetailed
responsestoeachissueraisedbytheLondonBoroughsofBrent,Ealingand
HammersmithandFulham.
Page 206

11

Background
papers
None






Report
originator:

MichaelMulhern,HeadofPlanning,OPDC
Telephone:


02079836535

Email:



michael.mulhern@opdc.london.gov.uk




Page 207

This page is intentionally left blank

Page 208

AppendixA

Greater London Authority

Responses to comments received during the public
consultation on the draft Old Oak and Park Royal
Opportunity Area Planning Framework
Overview
In accordance with the Greater London Authority Acts 1999 (as amended), Greater
London Authority (GLA) undertook a public consultation on the draft Old Oak and
Park Royal Opportunity Area Planning Framework (OAPF) for a period of 6 weeks
from 27 February 14 April 2015.
This report provides a summary of the issues raised during the public consultation
and the responses by the Greater London Authority to these comments. This report
will be presented to Old Oak and Park Royal Development Corporation (OPDC)
Planning Committee and OPDC Board in July for consideration and discussion
before returning to OPDCs Planning Committee and Board later during summer
2015 for endorsement.
The OAPF is a Mayoral document and would be adopted by the Mayor of London as
Supplementary Planning Guidance (SPG) to the Mayors London Plan, in
accordance with the Greater London Authority Acts 1999 (as amended). OPDC
cannot adopt the OAPF as a Supplementary Planning Document (SPD) as there is
no Local Plan in place. However, the OAPF would still carry significant material
weight in the determination of planning applications in the OPDC area, as SPG to
the London Plan, which forms part of OPDCs Development Plan.
This report is split into two sections. The first section covers the comments received
by the London Boroughs of Brent, Ealing and Hammersmith and Fulham and HS2
Ltd in a schedule showing their comments and the GLAs response. The second
section is structured by theme and covers all other respondents to the OAPF and the
GLAs response.
SECTION 1: Comments by the London Boroughs of Brent, Ealing and
Hammersmith and Fulham and HS2 Ltd
Appendix A provides a schedule of the comments received by the London Boroughs
of Brent, Ealing and Hammersmith and Fulham and the GLAs response.
SECTION 2: Comments by other stakeholders
This section is structured around the following key themes:
1.
2.
3.
4.
5.

General comments
Consultation and engagement
Introduction chapter
Vision
Objectives
1

Page 209

6.

7.

8.

9.

10.
11.

12.

13.
14.
15.
16.
17.

Land use
a.
Housing
b.
Retail
c.
Employment and training
d.
Regeneration catalyst
Design
a.
Public amenity space
b.
Streets and public realm
c.
Building heights and densities
d.
Built heritage
e.
Places/placemaking
Old Oak
a.
Old Oak North
b.
Old Oak South
c.
Old Oak High Street
d.
Old Oak Common Station
e.
North Acton
f.
Grand Union Canal
g.
Scrubs Lane
h.
Old Oak Lane
Park Royal
a.
Land use
b.
Improving infrastructure
c.
Design
d.
Heart of Park Royal
e.
Wesley Estate
f.
First Central site
Wormwood Scrubs
Transport chapter
a.
Rail
b.
Roads
c.
Car parking
d.
Buses
e.
Walking and cycling
f.
Construction
Environment Strategy
a.
Water
b.
Waste
c.
Air quality
d.
Energy
e.
Green infrastructure
f.
Land contamination
Delivery
a.
Phasing
Public drop-in sessions and other event attendance
QPR supporters summary
Appendices
Supporting environmental studies

Number of respondents and responses

2

Page 210

In total 3,517 respondents provided responses:

Respondents
Borough
Business
Group business
Group interest
Residents (individuals & groups)
Land owner or utility provider
Political party
Stakeholder statutory and other
Queens Park Rangers supporters
Total

5
1
2
10
64
12
2
7
3,414
3,517

Of the responses, 10,979 comments have been identified:

Responses
Borough
Business
Group business
Group interest
Residents (individuals & groups)
Land owner or utility provider
Political party
Stakeholder statutory and other
Queens Park Rangers supporters
Total

147
1
152
162
1456
170
42
45
8,804
10,979

Key issue themes

In summary, respondents showed broad support for the draft Opportunity Area
Planning Framework; however, respondents did raise specific issues, and/or
recommend changes to the OAPF. The key issues are shown below.
Key issue theme
Lifetime Neighbourhoods
Housing
Employment and training
Regeneration catalyst

Further commitment to deliver

Lifetime Neighbourhoods
Provision of affordable and family
housing
Securing local employment and
training
Support for a cultural or
education use catalyst
Stated support for QPR stadium
relocation

Number of
respondents
37
11
23
12
3,336
3

Page 211

Public amenity space

Building heights
Old Oak High Street
North Acton
Grand Union Canal

Park Royal

Wormwood Scrubs

Transport

Waste
Waste facilities should be
relocated from Old Oak and
should protect residential
amenity

Did not support relocation of QPR

stadium
Justification for amount of open
space
Concerns regarding building
heights
Concerns regarding the height of
buildings along the high street
Concerns regarding scale of
existing and future development
Tow path improvements for
movement
Heritage and biodiversity
Stronger vision sought
Improvements to infrastructure
and services required
Concerns regarding impact of
development and protection of
Wormwood Scrubs
Opposition to the widening of
Victoria Road
Traffic congestion created by
construction and new
development will negatively
impact on local transport network
Impact of construction transport
on residential amenity
Waste facilities should be
relocated from Old Oak and
should protect residential amenity

86
13
41
20
19
15
20
18
17

80

5
33

10
21

Summary of comments and GLA response

This section summarises the response from consultees by theme and then highlights
in red the response from the Greater London Authority (GLA).
1. General comments
Overview: Generally, the production of the OAPF was welcomed by consultees and
the further clarification and guidance that it will provide for development within the
area. The levels of supporting and non-supporting comments are:
Broad
support
No clear
position

36
43

Page 212

Broad
objection

23 (11 of which are stock responses relating to concerns regarding

the potential impact on Wormwood Scrubs)

A few consultees raised concerns with the overall approach taken with the OAPF
and these concerns are set out below.
The Wormwood Scrubs Charitable Trust raised concerns that the drafting of the
OAPF had been rushed.
The GLA disagrees that the production of the OAPF has been rushed. Developing a
plan for Old Oak has been underway since 2011. This work started with the joint
production of the Vision for Old Oak, which was publicly consulted on by the GLA,
TfL and the three local authorities in 2013. The responses received as part of that
consultation have informed this updated OAPF 2015. As part of this work, a broad
range of stakeholders have been involved. Since 2012, the GLA has held weekly
project group meetings with TfL, and the three local boroughs to discuss the content
and direction of the OAPF. In addition, other key stakeholders have also been
consulted prior to formal public consultation including, Network Rail, Department for
Transport, HS2, London and Continental Rail, Historic England, the Environment
Agency, Canals and River Trust, existing landowners, resident and business groups
in the surrounding areas, Brent Councils public forums, Grand Union Alliance, the
Friends of Wormwood Scrubs and the Wormwood Scrubs Charitable Trust..
Aurora Property Group stated that the OAPF should be clear that the GLA and
OPDC would welcome development proposals that accord with the OAPF to come
forward in advance of the OPDC Local Plan adoption.
The GLA disagrees that it is necessary to include a statement welcoming
development proposals that accord with the OAPF coming forward in advance of the
OPDC Local Plan adoption. The London Plan forms part of OPDCs Development
Plan and as Supplementary Planning Guidance (SPG) to this, once adopted the
OAPF would have substantial material weight in the determination of planning
applications within the OPDC area. The presumption in favour of sustainable
development in the National Planning Policy Framework also requires local planning
authorities to determine applications that accord with the development plan without
delay.
Essential Living request that the OAPF provide clear timescales for the progression
of OPDCs Local Plan, Growth Strategy and Development Infrastructure Funding
Study.
The GLA agrees that the OAPF should be clearer on timescales for the OPDCs
Local Plan and supporting evidence. The final OAPF will include indicative
timescales for these documents, which would be kept updated through OPDCs
Local Development Scheme.
2.

Consultation and Engagement

Page 213

Overview: Generally consultees welcomed being consulted on the draft OAPF.

Some respondents had specific comments on the approach to consultation and
engagement, which are set out below.
The Royal Borough of Kensington and Chelsea requested that OPDC adhere to the
Duty to Co-operate and continue to engage with them as plans for OPDC progress.
The GLA agrees that under the duty to cooperate, OPDC should continue to engage
with the boroughs as they progress their Local Plans and understands that meetings
between officers at OPDC and the Royal Borough have already taken place.
The London Assembly Labour Group expressed concerns regarding the extent and
type of consultation activities undertaken.
The GLA considers that the level of consultation undertaken on the OAPF was
appropriate. The information was made available on the GLA website. Public notices
were put in local newspapers and a press release was issued upon the launch of the
OAPF. Four public drop-in sessions were held in the local area at different venues
and at different times to ensure that as many people as possible were able to attend.
Hard copies of the OAPF were provided at locations such as Harlesden Library and
Old Oak Community Centre for review. Officers also attended meetings with local
residents groups such as the West Acton Residents Association and the Grand
Union Alliance.
The Regents Network stated that the consultation had been unlawful.
The GLA disagrees that the OAPF consultation was unlawful and considers that the
OAPF has been produced and consulted on in accordance with the Greater London
Authority Acts 1999 and 2007.
Residents requested that a community cohesion strategy be developed for future
development.
The GLA agrees that there is a need for community engagement as part of OPDCs
plan making and understands that OPDC has appointed a community engagement
officer to drive forward programmes and policies for engaging key stakeholders.
3.

Introduction chapter

Overview: The Introduction chapter to the OAPF sets out the status and purpose of
the OAPF, including the OAPFs relationship with other documents such as the Old
Oak Vision and HS2 Hybrid Bill. There were some detailed comments on the
Introduction chapter, outlined below.
LB Hounslow welcomed the reference to the Golden Mile in the OAPF and the
potential benefits that London Overground connections would bring for the area.
Noted.

Page 214

HS2 Ltd welcomed the inclusion of para 1.10, which referenced Schedule 16 of the
HS2 Hybrid Bill, but considered that the implications of this paragraph had not been
carried through in the rest of the OAPF.
Noted. The GLA acknowledges that the HS2 Hybrid Bill, in effect sets outline
planning permission for the Old Oak Common station, but considers the design
guidance within this OAPF to be of relevance to the detailed Schedule 16
applications that would subsequently come forward, if the HS2 Bill is enacted.
Segro requested that tweaks be made to para 1.8, which outlines how OPDCs
future Local Plan would deal with the de-designation of Strategic Industrial Location,
to clarify that future de-designation of Strategic Industrial Location (SIL) land would
relate to the Old Oak area, Heart of Park Royal and non-SIL areas.
Disagree. The GLA understands that the OPDC is yet to determine the extent of SIL
de-designation through its plan making process and it would be wrong for the OAPF
to identify the specific sites.
Residents requested that reference is made to the role of Neighbourhood Plans and
that further references are provided to the role that Harlesden and Neasden play as
centres for the existing community that development in the OAPF area should
connect to.
Agree that reference should be made in this section to the role of neighbourhood
plans and this will be reflected in Figure 3.
4.

Vision

Overview: A number of consultees made suggestions to amend the OAPFs

proposed vision, which are set out below.
RB Kensington and Chelsea requested that the vision references the importance of
connecting to other nearby Opportunity Areas.
Agree. The OAPF vision will reference the importance of being connected to nearby
opportunity areas.
The London Assembly Labour Group stated that the OAPF should encourage the
regeneration of the opportunity area as an exemplary sustainable area striving for
sustainable growth economically, environmentally, and socially and in an integrated
way.
Agree. The vision will clarify that development should be socially, economically and
environmentally sustainable.
Cargiant stated that the vision would be clearer if it was made more explicit that new
homes and jobs would be served by a broad range of ancillary services and facilities
such as recreation, arts, leisure, education and health related uses.

Page 215

Agree. The vision will be amended to make it clear that the new development should
be supported by a wide range of ancillary uses.
Residents requested that Lifetime Neighbourhoods be referenced within the vision,
along with a stronger emphasis on delivering affordable housing, provision of a mix
of employment uses for local people and a commitment to addressing deprivation.
Residents also noted that Old Oak should not be considered as a New Town and
that smart regeneration is explained and defined.
Agree. Affordable housing will be addressed as part of OPDCs Local Plan.
Reference will however be made to the role that regeneration at Old Oak can play in
helping to regenerate the wider hinterland.
5.

Objectives

Overview: Generally, consultees welcomed the objectives. Some amendments to the

objectives were suggested by consultees, which are set out below.
RB Kensington and Chelsea requested that Objective 2 be altered to specifically
reference the importance of connecting to other Opportunity Areas by rail.
Disagree, the Vision will be amended to reference the need to connect to nearby
opportunity areas but it will not be explicit that this should be specifically by rail.
Aurora Property Group requested that the objectives make the pressing need for
residential development more explicit.
Disagree. It is felt that objective 1 adequately covers the need for an additional
minimum 24,000 homes in Old Oak and 1,500 homes in Park Royal.
Quattro suggested some further wording be added to the consolidate objective to
clarify the OAPFs approach to business relocations. Segro requested that
Wormwood Scrubs be put into a separate objective from Park Royal to avoid
confusion.
Disagree. These objectives are high level and the approach to business relocations
is outlined in detail in the land use chapter of the OAPF. The GLA proposes to
provide clearer wording on the approach to Wormwood Scrubs in the consolidate
objective, to clarify that Wormwood Scrubs and The Grand Union Canal will be
enhanced as a result of regeneration in Old Oak and Park Royal.
QPR requested that the objectives specifically encourage the development of an
early major catalyst use.
Agree. The OAPF vision will be amended to encourage the development of an early
major catalyst use.
Hammersmith and Fulham Historic Buildings Group suggested that Objective 4 could
be strengthened to give heritage-led development a stronger emphasis and that
objective 3 should reference the importance of training for local people.
8

Page 216

Disagree. Objective 4 references the need for development to safeguard nearby

heritage assets and reference for the need for development to enhance these assets
will also be added.
Agree. Objective 3 will be amended to reference the potential for local employment
and training initiatives.
Residents requested that objectives seek to deliver sustainable development and
Lifetime Neighbourhoods. There was broad support for a multi-use focal point with
examples of cultural venues and universities stated. Requests were also stated for
wording around protecting and enhancing existing communities and town centres,
alongside committing to prioritising training and employment opportunities for local
people and defining affordable housing targets.
Agree. The 1st objective references the need for communities to be sustainable. The
vision will be amended to reference the potential for large-scale catalyst uses, which
could include cultural venues or educational uses. Wording will be inserted into the
3rd objective referencing the potential for local employment and training initiatives.
Affordable housing would be dealt with as part of OPDCs Local Plan.
6.

Land use

Overview Respondents were generally supportive of the approach taken to land use
in the OAPF. There was particular support from local interest groups.
Responses on specific land use types are provided below. This section focusses on
land use issues relating to the entire OAPF area or specifically to Old Oak. More
detailed comments on land use in Park Royal are covered in Section 9.
a.

Housing

Overview A number of consultees felt that the OAPF should provide greater clarity
on the approach that should be taken to housing and in particular, affordable
housing.
The Hammersmith & Fulham Liberal Democrats requested that housing should be
provided by local authorities and housing associations and stated a preference for
additional housing over new jobs.
Noted. Although the jobs target is higher than the homes target, the amount of
floorspace allocated to homes is greater than that to jobs. The quantum of housing
for Old Oak and Park Royal is set out in the London Plan. The GLA recognises the
importance of housing delivery to the capital.
The London Assembly Labour Group requested a stronger policy for delivering
affordable housing, including ensuring that affordable housing is priced into the land
value. A minimum 50% affordable housing target was also requested with 60:40 split
for social rent and intermediate tenures.

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Local interest groups wished to see greater clarity on the approach to be taken
towards affordable housing in the area.
Residents requested that the amount of housing should be justified and that further
guidance on affordable housing should be provided with regard to affordable housing
targets, tenure and mix.
Noted. London Plan policy on affordable housing would apply to the area and the
OPDC would develop its own affordable housing targets through its Local Plan,
which would be based on need and viability. The OAPF will clarify that any OPDC
affordable housing policy and evidence base would need to accord with national and
regional policy and that any affordable housing policy would have to be based on
need, as well as the viability.
Residents requested housing targets for all the places which are defined in the
document as specific geographical areas with their own visions and objectives.
Requests were made for these to be based on delivering Lifetime Neighbourhoods.
Disagree. It would not be appropriate for each place to have its own housing target
as many of the places overlap. However, the OPDC Local Plan would be supported
by a Strategic Housing Land Availability Assessment (SHLAA), which would need to
consider the capacity across the Opportunity Area and this could be broken down to
a finer grain geography.
Residents sought a definition of affordable housing to be provided. Residents also
considered that the affordable housing alone will not address local deprivation.
Disagree. It is not considered appropriate for the OAPF to define affordable housing
as the OAPF does not set policy on affordable housing. London Plan affordable
housing policy will be applied. The GLA agrees that affordable housing alone will not
overcome deprivation in the local area and, but the other policy approaches outlined
in the OAPF are considered to go some way towards tackling deprivation, such as
securing employment and training for local people and improving transport
accessibility and by virtue, access to employment.
b. Retail
Overview: Generally, consultees felt that further justification and evidence should be
undertaken on retail.
RB Kensington and Chelsea requested that the OAPF provide further clarity on the
appropriate quantum of retail in the area and nature of any retail centres, LBHF and
LB Brent requested that the Table on page 35, which shows retail floorspace in
comparable Opportunity Areas, should be further justified or removed.
Noted. The GLA understands that OPDC has commissioned a Retail and Leisure
Needs Study and that the London Boroughs of Brent, Ealing, Hammersmith and
Fulham and Royal Borough of Kensington and Chelsea have been invited to steering
group meetings. This study will inform the level and type of retail floorspace that will
be set through OPDC local plan.
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Residents and businesses requested that nearby existing town centres should be
protected and enhanced. Retail uses around the proposed new London Overground
Station on Hythe Road were proposed and retail uses within the Heart of Park Royal
supported. Residents also supported the encouragement of independent retail.
Noted. The Retail and Leisure Needs Study will be identifying the quantum of retail
that can be provided in Old Oak and Park Royal to minimise negative impact on
existing centres. This Study will recommend the spatial distribution of retail including
the potential for retail around the new London Overground stations. The study will
also recommend qualitative measures that could be taken, such as supporting
independent retailers. This Study will inform OPDC Local Plan policy.
c. Employment and training
Overview: The approach to employment and training in the OAPF was generally
supported. A number of consultees made detailed representations which are set out
below.
Quattro asserted that OPDC should provide a commitment that it will support
businesses requiring relocation. They also stated that the plan as currently written
does not appear to support the relocation of non-office/light industrial uses. Segro
requested that any business relocations would need to undergo full and proper
consultation with existing businesses.
Noted. The OAPF states in para 5.9 that the GLA and future OPDC will work with
applicants and landowners to support the relocation of businesses to alternative
sites. This text will be amended to also state that the GLA and OPDC will work with
the businesses themselves. The OAPF supports the relocation of employment uses,
which would include non-office and light industrial uses.
The Hammersmith & Fulham Liberal Democrats stated support for the retention of
industrial premises and jobs.
Noted.
The London Assembly Labour Group requested that further information was
provided for where space for displaced employment floorspace will be located and
that a stronger commitment to protecting industrial land is stated (including a no net
loss of industrial land). The Group stated that the impact of development on Park
Royal must be managed and requested that further studies on future growth sectors
are delivered. Support was also shown the delivery of data centres.
Noted. The OAPF sets out a sequential process for the provision of space for
displaced businesses, which defines in board terms where the space would be
located. Principle PR1 on page 70 is clear that in Park Royal, SIL will continue to be
safeguarded. The GLA understands that OPDC will be commissioning a Future
Growth Sectors study.

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Local interest groups supported the proposals for economic growth in Old Oak and
continued protection of SIL in Park Royal. There was some concern about the
potential impact that relocated businesses in Old Oak may have on businesses in
Park Royal. Just Space proposed a minimum target of 30% of new jobs to go to local
people. The We Care Foundation felt that many industrial units in the area were
currently vacant and that there should be review of industrial land at the Park Royal
Junction, Abbey Road and Premier Park area.
Noted. The sequential approach outlines in para 5.8 recognises that it may not be
possible for all businesses to be relocated in Park Royal and part of the
consideration for this would be the impact on existing businesses.
Noted. The OAPF objectives will be amended to reference the need for employment
and training initiatives; however, it is premature to set targets for this. OPDC would
need to consider employment and training and potential targets as part of the
development of its Local Plan.
The GLA does not propose the designation of any Strategic Industrial Location (SIL)
land in Park Royal.
The Park Royal Business Group supported the approach that the OAPF has taken to
employment creation in the area. In contrast, the Regents Network objected to the
loss of any industrial land in the Old Oak and Park Royal area.
Disagree. The London Plan (2015) identifies that Old Oak Common needs to
accommodate a minimum additional 24,000 homes and de-designation of Strategic
Industrial Location (SIL) will therefore be necessary; however, the OAPF notes in
para 5.3 that any SIL de-designation would need to occur through the OPDCs future
Local Plan.
Residents requested that employment and training opportunities (including
apprenticeships) should be maximised (with 30% for local people as per the Just
Space submission) and commitments made for local people during the construction
and operational phases of development. Further guidance was requested for targets
to monitor local employment and training, the amount and types of employment and
the breakdown of figures for construction and operational jobs. An employment
strategy setting out how local people will secure employment and training was also
suggested.
Noted. The OAPF objectives will be amended to reference the need for employment
and training initiatives; however, it is premature to set targets for this. OPDC would
need to consider employment and training and potential targets as part of the
development of its Local Plan.
Residents also requested further protection of existing businesses and support for
new employment and relocated businesses from Old Oak to Park Royal. Concerns
were raised regarding the lack of clarity for how local businesses within Park Royal
will be supported. A request for the removal of the Metroline Bus Depot at Willesden
Junction from Strategic Industrial Location (SIL) land was also stated.

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Noted. The OAPF states in PR1 that the GLA will continue to safeguard existing
Strategic Industrial Locations (SIL) in Park Royal.
Disagree. The GLA does not propose to remove the Metroline Bus Depot at
Willesden Junction from Strategic Industrial Location (SIL) land.
d. Regeneration Catalyst
Overview: 3,414 responses were received from supporters of QPR in the form of a
standardised response. The vast majority of these were in support of a football
stadium acting as a catalyst for regeneration in Old Oak. Responses from QPR
supporters are dealt with in section 15. Of the non QPR supporters who responded,
there was general support for regeneration catalysts.
QPR supported the reference in the OAPF to the potential for a large-scale use
acting as a catalyst for regeneration. QPR assert that a new stadium would be an
ideal large-scale catalyst for the regeneration of the area and that such a use would
be a beating heart and identifier for the area. QPR request that the OAPF in principle
OO1 make specific reference to the provision of a sports facility/football stadium as
part of the mix of land uses. In response to Question 4, QPR note that the catalyst
use should be identified as a sports stadium.
Agree. The OAPF references the potential for a sports use to act as a catalyst for
regeneration at paragraph 5.14 of the OAPF. Principle OO1 will be amended to
make specific reference to the potential for new leisure and sports facilities to act as
a catalyst.
Cargiant considered that the emphasis that the OAPF gave to large-scale uses
acting as catalysts for regeneration was being overplayed. Further, Cargiant
suggested that rather than large-scale catalyst uses, a range of smaller scale uses
and facilities could actually provide better resilience and integration with a
predominantly residential and employment led neighbourhood. In addition, Cargiant
alleged that imposing large-scale facilities such as football stadia on the Old Oak
area could potentially damage the emerging character of the area and such uses
would also reduce the ability of the area to deliver much needed new homes and
jobs.
Agree. The OAPF will make reference to the potential for smaller scale uses to act
as catalysts for regeneration as well as larger scale uses.
Agree. The OAPF will be revised to make it clear that the provision of any large scale
catalyst uses should not be at the expense of delivering new homes and jobs in the
area.
The London Civic Amenity Society stated that they did not support proposals to build
a football stadium in Old Oak and that such a use would be incompatible with the
objectives of the OAPF.

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Noted. The GLA considers that such a use could act as a catalyst for the
regeneration of the wider area; however, the acceptability of a football stadium would
need to be considered against London Plan policy and the guidance in this OAPF.
Residents supported the delivery of a regeneration catalyst, or focal point, if it was a
cultural or education use to help deliver the principles of Lifetime Neighbourhoods
and reflected the local character. Some support from residents was shown for a
stadium.
Noted.
7.

Design

Overview: There were a substantial number of comments on design from consultees.

A number of interest groups replicated this concern stating that high rise buildings
should not be of low quality architecture.
Agree. The GLA agrees that the OAPF should be clearer in its aspirations for high
quality architectural design, specifically with regard to tall buildings, and will amend
the OAPF accordingly.
Historic England (formerly English Heritage) supported the collaborative approach
undertaken between the GLA/OPDC and Historic England to date.
Noted. The GLA looks forward to continuing to work closely with Historic England
during the progression of the OAPF.
HS2 Ltd raised concerns with principle D2d, which supports the use of TfLs Station
Public Realm Design Guidance and that this principle is unlikely to be appropriate for
the needs of a high speed station.
Disagree. The GLA considers that that guidance set out in D2d is appropriate for the
development of the Old Oak Common High Speed 2 station to support connections
in and around the area. The GLA and OPDC will seek to work closely with HS2
during the development of the detailed design of the station and how it sits within the
wider area.
Residents requested that greater emphasis on Lifetime Neighbourhoods and high
quality design is provided to ensure Old Oak defines London architecture for the 21
century.

st

Agree. Additional emphasis on Lifetime Neighbourhoods and high quality design will
be made in the OAPF.
a.

Public amenity space

Overview: A number of consultees made representations on the amount and quality

of open space that should be provided within the OAPF area.

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QPR asserted in their representations that the quantum of public amenity space
shown in the masterplan is too large.
Disagree. The GLA considers that the quantum of public amenity space shown in the
illustrative maps is broadly appropriate for level of development and the role of the
OAPF as Supplementary Planning Guidance to the London Plan. However, the GLA
understands that OPDC will be undertaking additional detailed work related to public
amenity space provision in terms of quantum and function that will be addressed in
greater detail in OPDC Local Plan.
Local interest groups supported the identification of green amenity space in the
OAPF but felt that more spaces and a greater variety of spaces in terms of size and
function. Interest groups such as the Friends of Wormwood Scrubs, Grand Union
Alliance and Civic Amenity Society noted the importance of protecting Wormwood
Scrubs as part of the approach to amenity space. The Friends of Wormwood Scrubs
requested that Wormwood Scrubs should not contribute to public amenity space
provision for the development in Old Oak and that additional amenity spaces should
be shown on relevant maps.
Noted. The GLA considers that the quantum of public amenity space shown in the
illustrative maps is appropriate for level of development and the role of the OAPF as
Supplementary Planning Guidance to the London Plan. The GLA understands that
the OPDC will be undertaking additional detailed work related to public amenity
space provision to support the OPDC Local Plan. With regard to concerns relating to
the potential contribution of Wormwood Scrubs to public amenity space provision for
development in Old Oak, D1 and OO2 set out how the GLA expects proposals to
deliver new public amenity space in addition to Wormwood Scrubs. The GLA
understands that the OPDC Local Plan will provide further detailed guidance for how
development will be expected to deliver new public amenity space supported by an
Open Space Strategy.
Residents expressed strong concerns for any potential development on Wormwood
Scrubs. Residents supported the green grid and the maximum delivery of open
space that enabled multiple uses. Requests were made that local people should help
to inform the design of new public open spaces and that open spaces are identified
on maps. Suggestions for the use of plain English and combining guidance D1 and
D2 were presented. Proposals for extending the green grid to Victoria Road, Old Oak
Lane and Old Oak Common Lane were also made.
Noted. The OAPF considers that the guidance set out in WS1 provides a clear
direction for the protection of Wormwood Scrubs and exploration of appropriate
sensitive improvements with the Charitable Trusts in accordance with the
Wormwood Scrubs Act, 1879, the Commons Act 2006 and its designations as
Metropolitan Open Land in the London Plan.
Residents also requested that existing canal open spaces and Victoria Road open
spaces and street planning should be protected with the Metroline depot at
Willesden Junction identified to potentially provide new public open space. The need
for an open space needs assessment was identified and that the amount of open
space should be identified (including for each place) and justified while linked to
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housing delivery. In calculating public open space, Wormwood Scrubs and street
greening was asked to be excluded.
Noted. Residents will be able to comment on the design of public amenity spaces set
out in the Local Plan and detailed design of spaces during the development
management process.
Noted. Residents support for the green grid is welcomed.
Agree. The GLA will provide definitions for relevant terminology in D1 and D2.
Agree. The indicative map of the green grid will be amended to include Victoria
Road, Old Oak Lane and Old Oak Common Lane.
Noted. The GLA considers that D1(a)(iii) provides sufficient guidance relating to
protecting, improving and connecting existing open spaces.
Disagree. The Metroline depot is within a designated Strategic Industrial Location as
such the GLA does not consider it appropriate to identify it to potentially provide new
public amenity space.
Noted. The GLA understands that the OPDC will be undertaking an Open Space
Strategy which will include an open space needs assessment and will explore how
the level of need is quantified.
b. Streets and public realm
Overview: There was general support for the approach taken to public realm and
streets in the OAPF.
The London Assembly Labour Group requested that a stronger commitment to high
quality urban design is stated.
Agree. The GLA agrees that the OAPF should state a stronger commitment to high
quality urban design and will be amending the OAPF accordingly.
The Grand Union Alliance interest group raised concerns about Grand Union Street
and the potential impact this would have on existing residential communities.
Noted. The GLA acknowledges that potential impact of development on local
residents and understands that the OPDC will be seeking to engage with local
residents to identify potential risks, issues and solutions. The proposed indicative
street network is aimed at integrating this site into its surrounding areas. Specifically,
the GLA understands that the OPDC will be developing a Construction & Logistics
Strategy and a Public Realm Strategy to inform the OPDC Local Plan which will both
be subject to public consultation.
Residents provided general support for improving the public realm and specifically
requested that walking and cycling routes should be segregated, permeability of the

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area is balanced with safety and that the street greening along Victoria Road is
protected. Residents also asked for a clearer definition of green streets.
Noted. Guidance stated within T6 seeks to deliver a cycle network with a high level
of segregation recognising that separation may not be possible due to restrictions or
conducive to placemaking aspirations.
Noted. Guidance in the OAPF relating to permeability will be implemented alongside
London Plan Policy 7.3 which seeks to design out crime.
Noted. The GLA considers that D1(a)(iii) provides sufficient guidance relating to
protecting, improving and connecting existing open spaces.
Agree. The GLA will provide definitions and precedents for green streets.
c. Building heights and densities
Overview: A number of consultees made representations on the OAPFs approach to
building heights and densities.
RB Kensington and Chelsea request that further work is undertaken to justify any tall
buildings. In particular, RB Kensington and Chelsea raise concerns about the
potential impact of tall buildings on Kensal Cemetery and the need for this to be
further considered.
Agree. The GLA will publish background information utilised to support the approach
for tall buildings and densities including how built form would respond to sensitive
locations, such as heritage assets and existing residential communities, and
destinations such as public transport nodes.
Noted. The GLA has worked closely with Historic England to deliver guidance
relating to building heights and local views which it considers appropriate for the
level of guidance suitable for the OAPF as Supplementary Planning Guidance for the
London Plan. The GLA understands that the OPDC will continue to work with
Historic England in the development of relevant guidance to manage the impact of
development on the Grade I registered Park and Garden of Historic Interest at
Kensal Green Cemetery.
RB Kensington and Chelsea requested that the OAPF provides further clarity on the
approach that should be taken next to sensitive areas.
Agree. The GLA will publish background information utilised to support the approach
for tall buildings.
Historic England expressed concern regarding the promotion of tall buildings and the
impact on heritage assets.
Noted. The GLA has worked closely with Historic England to deliver guidance
relating to building heights and local views which it considers appropriate for the
level of guidance suitable for the OAPF as Supplementary Planning Guidance for the
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London Plan. The GLA understands that the OPDC will continue to work with
Historic England in the development of relevant guidance to manage the impact of
development heritage assets.
The Hammersmith & Fulham Liberal Democrats stated support for high density
development if supported by appropriate management and levels of open space.
Noted. These elements are considered to be integral to the delivery of high density
development and are managed by the London Plan and supplemented by the OAPF
and Housing SPG. Further guidance on management of new high density
development will be included in the final OAPF.
The London Assembly Labour Group supported building heights of 20 storeys for
commercial uses but not for affordable or family housing and that where no better
alternative is available, we recognise that tall buildings will play a role in the
opportunity area. Further guidance for heights and the sustainability of tall buildings
was requested alongside a maximum height limit with low-rise high-density
typologies the preferred norm. The Group also suggested that guidance should state
that tall buildings cluster around transport nodes and then taper down to surrounding
areas. Support for a local urban design scrutiny team to assess tall building
proposals was stated.
Noted. The Housing SPG provides information regarding the delivery of affordable
and family housing in high density development which the OAPF does not seek to
repeat.
Agree. The GLA will provide further clarity within the OAPF with regard to building
heights and densities and will publish background information utilised to support the
approach for tall buildings.
Disagree. The OAPF provides guidance on broadly where tall buildings should be
located and how building form should be distributed across the area. Without
specific, detailed evidence the OAPF should not set specific maximum heights.
Noted. The GLA will publish background information utilised to support the broad
approach for tall buildings.
Agree. The GLA understands that the OPDC will be establishing an independent
Place Review Group.
QPR considered that transitions between building heights need not necessarily be
gradual and that the wording in the OAPF should instead refer to appropriate
transitions between building heights.
Noted. The reference to gradual transition relates to entrance points. In response to
concerns raised by other stakeholders, guidance and information for entrance points
will be removed. Guidance OO4(b) requires that proposals demonstrate how they
provide a transition in scale between adjacent building height and density locations
which is considered to be appropriate.

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Aurora Property Group requested that an entrance point be identified at the junction
of the Grand Union Canal with Scrubs Lane and that a further entrance point should
be identified at the junction of Hythe Road with Scrubs Lane.
Noted. Following concerns raised by respondents in relation to entrance points and
further clarification being provided for the approach to building heights, the OAPF will
not be providing guidance in relation to entrance points. The final OAPF will provide
evidence to support the proposed building heights and form.
One local interest group stated that Government should order the closure of RAF
Northolt to avoid restrictions on building heights. Other local interest groups were
concerned about the scale and density of proposals in the OAPF. A few local interest
groups were calling for height limits of 10 storeys and stronger limits along Old Oak
High Street (5 storeys) and along the Grand Union Canal (3 storeys).
Disagree. The GLA does not consider it appropriate to ask the Government to order
the closure of RAF Northolt.
Noted. The GLA will provide further clarity within the OAPF with regard to building
heights and densities and will publish background information utilised to support the
approach for tall buildings. The GLA understands that the OPDC will develop further
detailed evidence base to inform the Local Plan with regard to building heights and
responses to sensitive locations.
Residents requested the justification for the level of development and densities
suggesting that identified densities across the area are too high. Scenarios for less
dense development were requested. Residents also stated that high density
development does not need to be high rise and suggested the use of mansion
blocks.
Noted. The GLA will provide further clarity within the OAPF with regard to building
heights and densities and will publish background information utilised to support the
approach for tall buildings. The density of development responds to the minimum
housing and employment targets set out in the London Plan.
Noted. The GLA acknowledges that high density lower-rise typologies can contribute
to meeting the London Plan housing targets.
Residents requested that building heights should be clearly stated and identified for
each place using 3D modelling. Concerns were raised regarding guidance providing
contradicting information regarding general increase in building heights and
integrating with the surrounding area.
Noted. The GLA will provide further clarity within the OAPF with regard to building
heights and densities and will publish background information utilised to support the
approach for tall buildings.
Residents asked for references to greater height to be removed and that the average
building height should be 5-6 storeys or 8-10 storeys and that building heights of 4050 storeys are not supported. They also requested that tall buildings must not impact
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on local communities and should be located away from existing residential

communities while stepping down from the tall building clusters. Residents
specifically requested that the OAPF should commit to safeguarding the amenity of
local communities.
Disagree. The GLA considers the guidance set out in the OAPF for potential
locations for taller buildings OO4 is appropriate in responding to access to public
transport and meeting the London Plan housing target for Old Oak. The draft OAPF
only included f a guide for building heights along the High Street, however, this figure
will be removed.
Noted. The GLA will provide further clarity within the OAPF with regard to building
heights and densities and will publish background information utilised to support the
approach for tall buildings.
Agree. The OAPF will be amended to reference London Plan policy 7.7(D)(a) with
regard to residential amenity.
Residents also asked for development close to Wormwood Scrubs to be low rise and
that building heights should reflect the low rise residential area north of Willesden
Junction station. Specifically, Wells House Road residents were concerned that tall
buildings may block views from first floor windows on Wells House Road. Both West
Acton and the area north of the freight liner terminal were asked to be designated as
a sensitive area.
Noted. The GLA will provide further clarity within the OAPF with regard to building
heights and densities and will publish background information utilised to support the
approach for tall buildings.
Noted. The OAPF will be amended to reference London Plan policy 7.7(D)(a) with
regard to residential amenity.
Residents identified an entrance point at the junction of Station Road and Old Oak
Lane but also stated that tall buildings may not be appropriate at entrance points.
Noted. Following concerns raised by respondents in relation to entrance points and
further clarification being provided for the approach to building heights, the OAPF will
not be providing guidance in relation to entrance points.
d. Built heritage and local views
Overview: A number of consultees requested greater clarity on the approach to
heritage and local views.
Historic England requested that amendments are made to the OAPF to ensure
compliance with national guidance in relation to the setting of heritage assets. Strong
support was expressed for additional work to be undertaken to inform local views.
Historic England also request that further information was provided to ensure how
development reflects the local character and materials.

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Agreed. The OAPF will be amended in relation to the setting of heritage assets.
Noted. The GLA understands that the OPDC will continue to work with Historic
England to develop the Heritage and Local Views Study to inform the OPDC Local
Plan.
Noted. The GLA will publish background information in relation to character utilised
to support the approach for building heights and densities. With regard to materials,
the GLA understands the OPDC will be undertaking additional evidence base to
inform the OPDC Local Plan and supplementary guidance.
Aurora Property Group noted that an appropriate methodology for selecting identified
views will be necessary.
Noted. The GLA understands that the OPDC will produce a Heritage and Local
Views Study to inform the OPDC Local Plan. Agreeing specific views for sites will
also need to be carried out at pre-application stage.
Local interest groups considered that there should be a greater emphasis on
heritage. The Grand Union Alliance felt that North Acton Cemetery should be
referenced as a heritage asset in the OAPF and that consideration could be given to
the industrial heritage along the Grand Union Canal. A number of interest groups
supported the protection of Wormwood Scrubs as a heritage asset. Groups also
requested that local views acknowledge that the Scrubs' character is sensitive to tall
development in Old Oak.
Agree. The OAPF will be amended to make reference to London Plan policy 7.8 in
relation to heritage assets. The GLA understands that the OPDC will continue to
work with Historic England to develop the Heritage and Local Views Study to inform
the OPDC Local Plan.
Noted.
Noted. This suggestion will be used to inform the Heritage and Local Views Study to
inform the OPDC Local Plan
Residents requested that built heritage is used to inform placemaking and a survey
of heritage assets is undertaken. Specific comments for preserving the heritage of
canal, railways and industry were provided.
Noted. The GLA has worked with Historic England to develop the Old Oak Outline
Historic Assessment which provides an overview of heritage assets within Old Oak.
The GLA understands that the OPDC will continue to work with Historic England to
develop a similar assessment for Park Royal for the Heritage and Local Views Study
to inform the OPDC Local Plan. The GLA understands that this information will be
used by the OPDC to inform placemaking elements of the OPDCs Local Plan and
also OPDCs historic assets list.
Residents asked for Wells House Road, West Acton and Midland Terrace to be
designated as view points.
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Noted. These suggestions will be used to inform the Heritage and Local Views Study
to inform the OPDC Local Plan
e. Places/Placemaking
Overview: Consultees were generally supportive of the approach to placemaking.
Residents requested further emphasis and detail on how the OAPF will help to
deliver Lifetime Neighbourhoods. They also requested that each place section
provides guidance for amount of housing, open space and building heights.
Agree. The GLA considers that additional emphasis on Lifetime Neighbourhoods
should be made in the OAPF and will be amended accordingly.
Disagree. The GLA considers that the OAPF provides the level of guidance for the
each of places appropriate for Supplementary Planning Guidance to the London
Plan.
8.

Old Oak

Overview: The Old Oak chapter of the OAPF included within it 7 places which had
their own vision, objectives and guidance. There were a number of comments from
consultees on each of these places and these comments are outlined below.
a.

Old Oak North

QPR requested that specific reference should be made in Old Oak North to the
potential football stadium to be located here as a catalyst for regeneration.
Noted. Objective 3 already lists a football stadium as a potential catalyst use in Old
Oak North.
Residents requested that guidance to deliver new public open space be provided
and linked to level of housing delivery. There were also requests for Old Oak Square
to be at the heart of Old Oak North.
Agree. The GLA considers that the delivery of public open space to be central to
creation of sustainable communities and a successful new urban neighbourhood.
The OAPF sets out the principles for delivering new open spaces which are
appropriate to the role of an OAPF. The GLA understands that the OPDC will be
developing an Open Space Strategy to support the quantity and quality of open
space to be provided by development within the Local Plan. Text will be added to
paragraph 5.36 stating that Old Oak Square should be at the heart of the approach
to placemaking in Old Oak North.
Residents showed support for a focal point but concerns were raised about this
being a football stadium. Residents also proposed that where possible new roads
are built underground and the Hythe Road Station is delivered on a viaduct. Greater

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emphasis on delivering Lifetime Neighbourhoods was requested specifically in

relation to social infrastructure.
Noted. The GLA considers that a football stadium could act as a catalyst for
regeneration in the area but the acceptability of any proposal would need to be
judged against London Plan policy and the guidance contained in the OAPF.
Noted. As detailed proposals come forward, the GLA and OPDC would have to
assess the merits of connections through the rail infrastructure being achieved
through an underpass or an overbridge and this would consider their impact on the
surrounding context. The GLA supports improvements to permeability within the
Opportunity Area and this could be achieved through delivering the Hythe Road
station on a viaduct; however, the viability of providing this would have to be
assessed.
Agree. Additional emphasis on Lifetime Neighbourhoods and high quality design will
be made in the OAPF.
Residents requested that waste sites are removed from the area.
Noted. The waste section of the OAPF sets out the approach to the waste sites. The
section notes that all waste sites within the Opportunity Area could be relocated but
also notes that the Powerday waste site could remain and act as an important waste
recycling, treatment and waste to energy site for the Opportunity Area.
b. Old Oak South
RB Kensington and Chelsea requested that the OAPF makes reference here to
Kensal Canalside Opportunity Area and the potential for future synergy between
these areas.
Agree. Reference to Kensal Canalside Opportunity Area and potential for
connections to this and synergy between the two Opportunity Areas will be included.
HS2 Ltd noted that the eastern connection over the Grand Union Canal but that the
OAPF is not clear on its funding.
Noted. The GLA understands that OPDC are undertaking a separate exercise
looking at the funding and financing of infrastructure within the OPDC area and
greater clarity would be provided on this as part of OPDCs Local Plan.
QPR requested that reference be made in Old Oak South to the potential for the
early delivery of the Genesis site. QPR also requested that two new objectives be
added:
1. The importance of securing links between Old Oak South and Old Oak North;
and
2. Encourage the early development of available sites.
Agree. Reference will be made to the potential for the early delivery of the Genesis
site.
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Agree, these two new objectives will be added.

Residents raised concerns for the impact of development on residential amenity and
sought that 50% of housing should be affordable.
Noted. London Plan policy on affordable housing would apply. The OPDC will be
producing its own policy on affordable housing as part of its Local Plan. This policy
would be informed by housing need and development viability.
c. Old Oak High Street
QPR requested that greater emphasis be given to the potential for Old Oak High
Street to go over rather than under the West London Line.
Disagree. The OAPF already acknowledges in paragraph 5.47 that a connection
over the West London Line could be supported. The GLA does not wish to set out a
preference in the OAPF and any detailed proposal would be considered on its
individual merit.
Residents requested that new public open spaces are active and usable and that
continental boulevards are used as inspiration. They also asked that building heights
should be no greater than 5 storeys or 10 storeys. Requests for the High Street to
have only public transport and walking and cycling and access were presented.
Support was shown for segregated cycle access.
Noted. Para 5.46 notes that the public realm should be accessible.
Disagree. The GLA considers the guidance set out in the OAPF for potential
locations for taller buildings OO4 is appropriate in responding to access to public
transport and meeting the London Plan housing target for Old Oak. The draft OAPF
only included a guide for building heights along the High Street, however, this figure
will be removed.
Disagree. It may be appropriate for all or parts of Old Oak High Street to be vehicular
to provide through connects for buses and private vehicles. However, any proposals
for all or part of the High Street to be vehicular would have to be thoroughly
assessed, as noted in paragraph 5.46 of the OAPF.
d. Old Oak Common Station
HS2 Ltd raised a number of concerns relating to this section; principally:
That the OAPF promotes over station development but that this is not being
proposed by HS2;
That HS2 are not proposing an unpaid link through the station and that
showing such a link is unsound; and
That there are not currently any proposals to relocate the IEP depot and that
showing this redeveloped and a link through it is therefore unsound.

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Disagree. The GLA are in discussions with HS2 Ltd regarding a study to investigate
the potential for over station development and that the outcomes of this study would
require amendments to the HS2 Bill to provide enabling works, which over station
development is proven to be deliverable and viable.
Disagree. The GLA are in discussions with HS2 Ltd regarding a study to investigate
the provision of an uncharged access through the station to provide passive
provision for a future access to Wormwood Scrubs and that the Bill would
incorporate amendments to provide for this passive provision.
Noted. The GLA are in discussions with the Department for Transport regarding the
potential relocation of the IEP Depot, although it is recognised that relocation is likely
to be some way off.
HS2 Ltd also requested that Objective 5 be reworded to clarify whether the station
should be designed to support mixed use development or whether mixed use
development is sought in support of the station. HS2 Ltd asserted that the stations
primary function is an operational station and not a retail centre.
Agree. The wording will clarify that the GLA would support mixed use development in
this location and not that the station design should support mixed use development
or the mixed use development should support the station.
On over station development, HS2 Ltd requested that some text be inserted
clarifying that OPDC is working with HS2 at exploring ways that such development
could be provided without affecting the cost and programme of HS2.
Noted. The GLA are in discussions with HS2 Ltd regarding a study to investigate the
potential for over station development and that the outcomes of this study would
require amendments to the HS2 Bill to provide enabling works, which over station
development is proven to be deliverable and viable. There are ongoing discussions
between HS2 Ltd, OPDC and Central Government relating to the funding of these
enabling works.
HS2 Ltd stated that a lot of the detailed design points in the OAPF on issues such as
station access would be determined through the Schedule 16 planning process.
Noted. The GLA acknowledges the considerations that form part of Schedule 16.
The GLA considers that the Old Oak Common station will be a gateway to London
and will shape many peoples first impression of the city. It is therefore imperative
that the station is of a world class design.
Access to Wormwood Scrubs was not supported by a number of residents and
groups.
Disagree. The Wormwood Scrubs Act (1879) states that Wormwood Scrubs should
be held upon trust for the perpetual use thereof of the inhabitants of the metropolis
for exercise and recreation. Providing access to the Scrubs for the new residents
and workers within the Old Oak Common Opportunity Area accords with the Act.

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However, any access into the Scrubs would need to be sensitively designed, in
accordance with paragraph 7.5 of the OAPF.
Residents requested that the main vehicular entrance to the station should be
provided from Scrubs Lane to the east to mitigate impact on Old Oak Common Lane.
Noted. The GLA agrees that access to the east, particularly for pedestrians, cyclists
and buses is imperative in order to minimise impacts on Old Oak Common Lane.
The Friends of Wormwood Scrubs supported the proposal for a footbridge over Old
Oak Common Station rather than an underpass.
Disagree. The GLA considers that further work should be undertaken to understand
the feasibility of an underpass and considers that an underpass would have less of a
visual impact on Wormwood Scrubs.
e. North Acton
Essential Living, the owners of the Perfume Factory site requested that the Perfume
Factory site be identified as a location for a potential catalyst for regeneration.
Essential Living also requested that the Perfume Factory site should be identified as
falling within the higher or highest density categories in principle OO4 and that the
document should be clearer about the GLAs intentions for the area identified as
open space to the north of the Perfume Factory site. Essential Living also raised
concerns about how upgrades to North Acton station would be paid for.
Agree. The GLA agrees that the Perfume Factory site could potentially be an
acceptable location for a potential catalyst for regeneration and Figure 42 will be
amended to reflect this.
Residents and local interest groups did not consider the existing development of
North Acton to be of an appropriate quality or density and viewed it to be
unsympathetic to local neighbourhoods. Requests were made for a green corridor
from North Acton to Old Oak to be formally established and current street greening
protected. Amendments to the gyratory system were proposed to improve the public
realm alongside requests for future development to integrate with the surrounding
area and not provide a cliff-edge.
Noted. The GLA considers that given North Actons public transport accessibility, it is
an appropriate location for medium to high density. Any proposals for tall buildings
would need to be assessed on their individual merit and with regard to their impact
on the surrounding context.
Residents identified the need to protect Acton Cemetery and suggested the area
delivers advanced manufacturing and educational uses.
Noted. Objective 4 states that development should be sensitive to North Acton
Cemetery. In terms of future employment uses, the GLA understands that OPDC are
undertaking a Future Employment Sectors study and that this will inform future Local
Plan policy developed by OPDC.
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Concerns were also raised regarding the Old Oak and Park Royal Development
Corporations scheme of delegation with the London Borough of Ealing.
Noted. The Scheme of Delegation has now been adopted by OPDC and any
amendments to this are a matter for consideration by OPDC Board.
f. Grand Union Canal
The Canals and River Trust welcomed the Grand Union Canal being at the forefront
of the OAPF. The Canals and River Trust had a number of detailed points in relation
to the canal, including:

Making reference to it being a key east-west sustainable transport corridor;

Being engaged in the location, delivery and maintenance strategy for any
bridges crossing the canal;
Referencing the Canals various environmental and heritage designations;
Concerns regarding the provision of a path on the northern edge of the canal;
Recognising the canals designation as a Cycle Quietway; and
Emphasising the potential use of the canal for freight.

Noted. The OAPF will be amended to in relation to the east-west transport corridor,
engaging with the Trust with respect to the location, delivery and maintenance for
bridges, referencing environmental and heritage designations and Cycle Quietway
and emphasising the potential of the canal for transport of freight.
The Canals and River Trust were particularly supportive of the OAPFs aspirations
to increase the use and access on the canal and provide the potential for new
waterspaces and moorings in the area.
Noted.
QPR noted that asset that the canal provides the area and stated that use of the
corridor would need to be carefully controlled so that all residents, employees and
visitors can enjoy its unique amenity.
Noted.
The London Civic Amenity Society was supportive of proposals to use the Grand
Union Canal for the movement of freight.
Noted.
Residents requested that guidance for the canal should require development to be
set back from the canal edge and the tow paths have segregated cycling paths and
lighting. They also asked that building heights should be no higher than 3 storeys
and that historic buildings are protected
Noted. The OAPF will be amended to provide guidance reflecting the potential for
buildings to be set back from the canal edge. With regard to segregated cycle paths
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this will be subject to the width of towpath which may not be able to accommodate
segregated paths along the duration of the route.
Disagree. The OAPF will not provide definitive building heights. The GLA will provide
further clarity within the OAPF with regard to building heights and densities and will
publish background information utilised to support the approach for tall buildings.
The GLA understands that the OPDC will develop further detailed evidence base to
inform the Local Plan with regard to building heights and responses to sensitive
locations.
Noted. Guidance for managing built heritage is set out in D4.
Residents also identified the importance of the biodiversity of the canal alongside
using the canal for freight movement.
Noted. The importance of the canal as an asset of biodiversity value will be emphasised.

g. Scrubs Lane
Aurora Property Group stated that the OAPF should not preclude the potential for tall
buildings to the east of Scrubs Lane.
Disagree. The GLA does not consider it appropriate for there to be tall buildings to
the east of Scrubs Lane. This would be adjacent to St. Marys Cemetery, which is
identified as a Conservation Area, a Registered Historic Landscape and has
structures within it that are Grade 1 listed buildings.
QPR stated that the Scrubs Lane section should make it clear that the
redevelopment of Old Oak North will be beneficial in terms of reducing the number of
HGV movements along the road with approximately 50% of HGV movements
currently being generated by the waste sites.
Agree. The OAPF will make reference to the fact that the redevelopment of the
waste sites within Old Oak North would be likely to result in a reduction in the
number of HGV movements along Scrubs lane post-construction.
Residents asked that Scrubs Lane be developed as a boulevard and stated that tall
buildings are not suitable. Suggestions were also made for a key access route to be
provided into Old Oak from Scrubs Lane and that existing businesses are protected.
Support for retaining and activating the historic buildings in this area was stated.
Noted. Objectives 4 and 5 promote improvements to the public realm and street
greening along Scrubs Lane. The GLA will provide further clarity within the OAPF
with regard to building heights and densities and will publish background information
utilised to support the approach for tall buildings.
h. Old Oak Lane
HS2 Ltd requested that illustrations of the HS2 work sites should be consistent with
the limits of deviation in the HS2 Hybrid Bill.
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Agree. Figure 46 will be revised to ensure that the HS2 work sites reflect the limits of
deviation in the HS2 Hybrid Bill.
Just Space interest group proposed that a new north-south street should be
proposed to provide relief to Old Oak Lane.
Noted. The GLA recognises that it may be possible for a road to be provided as part
of any longer term development on the HS2 work sites. The feasibility of such a link
would need to be investigated as part of further work undertaken on transport
connections in Park Royal in association with OPDCs Local Plan.
Residents stated supported for the Harlesden Bypass a proposal for a new road
running east-west through the core development area at Old Oak. Residents also
requested that the area north of the freightliner terminal is identified as a sensitive
location.
Noted. The potential for further east-west connections from Old Oak to Park Royal
would need to be considered as part of OPDCs Local Plan.
Agree. The figure will be amended and the northern edge of the freightliner terminal
will be identified as a sensitive location.
9.

Park Royal

Overview: Generally, consultees felt that the OAPF was too focussed on Old Oak
and that the Park Royal section warranted further work and additional detail.
Segro stated the importance of protecting the Park Royal Industrial Estate Strategic
Industrial Location (SIL) and that all steps should be taken to avoid any gradual
encroachment of non-SIL uses into this area.
Noted. PR1(a) provides guidance reflecting London Plan policy 2.17 regarding the
protection of Strategic Industrial Locations.
Segro noted that work undertaken by their consultants has shown that the Park
Royal Industrial Estate could accommodate 75,000 jobs and that further work on
employment capacity might be necessary and that further discussion with the GLA
and OPDC would be welcome.
Noted. The GLA understands that OPDC officers have liaised with Segro regarding
their capacity modelling and look forward to engaging with them during the
development of the Local Plan.
Segro asserted that the Park Royal section warrants additional detail, in particular on
the existing businesses in Park Royal. They requested that more information is
provided on the breakdown of businesses, which would show the huge number of
SMEs within the Estate, as well as large investment companies such as Segro. In
addition, they requested that the Park Royal section should recognise that the
employment offer in Park Royal is likely to be substantially different to that in Old
Oak and will generate its own demands. Further, Segro asserted that an
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independent study should be undertaken on Park Royal to assess its changing

growth dynamics and utilities, transport and logistics infrastructure requirements.
Agree. The GLA recognises that a stronger vision for Park Royal is required and will
be carrying out minor alterations to the vision and Park Royal Strategy to reflect this.
Specifically, these two sections will reflect guidance elsewhere in the OAPF and
existing guidance set out in the existing Park Royal OAPF (2010) for the following
themes:
- A clearer and stronger vision
- Definition the challenges and opportunities
- Identification what evidence based will be produced with timeframes and envisaged
methodology
- Skills and training
- Commitment to securing funding streams
- Design guidance (public realm and routes, public spaces, building heights)
- Land uses guidance
- Infrastructure guidance (transport and utilities)
- Placemaking guidance (Heart of Park Royal and wider Park Royal)
Disagree. The GLA Park Royal Atlas (2014) provides detailed information in relation
to the type and quantity of business within Park Royal which is reference within the
OAPF.
Residents requested that place-specific guidance be provided for the wider Park
Royal area.
Agree. The GLA understands that the OPDC is developing an Employment Land
Study, Park Royal Transport Study and Construction and Logistics Plan to inform the
OPDC Local Plan and support businesses within Park Royal.
a.

Land use in Park Royal

PRBG supported the protection of the Strategic Industrial Location land.

Guinness Ltd supported the continued target to deliver a minimum 1,500 homes and
10,000 jobs but noted that the Strategic Industrial Location (SIL) boundary in figure
48 was incorrect and required amending.
Noted.
Noted. Figure 48 will be amended.
Residents raised concerns regarding the intensification of employment uses and the
impact on local amenity and the transport network.
Noted. The OAPF states it proposes to minimise the generation of air pollution, both
during and post construction, making new developments air quality neutral or better;
E3 page 106 Air Quality Neutral is part of the London Plan Policy 7.14 and is
implemented through the SPG on Design and Construction and SPG and the Code
of Practice on Prevention of Dust from Construction, also implemented through an
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SPG. The GLA understands that the OPDC is developing an Employment Land
Study (which considers how intensification can be delivered), Park Royal Transport
Study, will be utilising the boroughs existing Air Quality Action Plans and
Construction & Logistics Plan to inform the OPDC Local Plan and manage impact on
residential amenity and the transport network.
b. Improving infrastructure in Park Royal
PRBG identify that utilities and transport infrastructure are not sufficient to support
existing businesses and envisaged future business growth and this should be
addressed as a priority. Concerns were also raised by the group regarding the
potential impact of construction at Old Oak on the local transport network.
Agree. Within PR2 and DL2, the OAPF provides guidance for improving utilities and
transport infrastructure. The guidance for Park Royal will be strengthened around the
following themes:
- A clearer and stronger vision
- Definition of the challenges and opportunities
- Identification what evidence based will be produced with timeframes and envisaged
methodology
- Skills and training
- Commitment to securing funding streams
- Design guidance (public realm and routes, public spaces, building heights)
- Land uses guidance
- Infrastructure guidance (transport and utilities)
- Placemaking guidance (Heart of Park Royal and wider Park Royal)
The GLA understands that the OPDC considers addressing existing issues in
relation to utilities and transport infrastructure within Park Royal to be a priority and is
developing a Park Royal Transport Study, Construction & Logistics Plan and Utilities
Strategy to inform the Local Plan and support the delivery of solutions.
Residents raised concerns regarding the relocation of waste uses from Old Oak into
Park Royal and that impacts on residents should be considered. Additional concerns
were raised regarding the impact of additional traffic on the road network. Support
was stated for the submitted Harlesden bypass proposal and further guidance for
walking and cycling routes to other residential areas and transport hubs.
Noted. The OAPF make reference for the need to consider residential amenity in
relation to the relocation of waste uses from Old Oak to Park Royal. The GLA
understands that the OPDC is developing a Park Royal Transport Study, will be
utilising the boroughs existing Air Quality Action Plans and Construction & Logistics
Plan to inform the OPDC Local Plan and manage impact on residential amenity and
the transport network. Additionally, the GLA understands that the OPDC Local Plan
will utilise evidence from current best practice including full enclosure for waste sites
to improve air quality.
c. Design in Park Royal

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Residents requested that further emphasis on utilising local heritage assets and
input from local people to inform the enhancement of Park Royal was sought.
Support was shown for improving the canalside environment.
Agree. The OAPF will be amended to make reference to London Plan policy 7.8 in
relation to heritage assets. The GLA understands that the OPDC will continue to
work with Historic England to develop the Heritage and Local Views Study to inform
the OPDC Local Plan.
Agree. The GLA understands that the OPDC is committed to engaging with the
residential and business communities within Park Royal during the development of
the OPDC Local Plan and in wider activities.
Noted.
d. Heart of Park Royal
ASDA noted that the identification of open space on their supermarket site would
impact on potential housing delivery.
Noted. The GLA considers that the indicative delivery of new public open spaces on
the current Asda site is appropriate for the establishing the principle of delivering
new open spaces. Should the Asda site be brought forward for development, the
location, design and quantity of new public open space would be defined through the
development management process. Any housing delivery would need to accord with
London Plan policy 2.17(C) and cannot have a negative impact on the functioning of
the adjacent Strategic Industrial Location designation. While residential delivery
would be acceptable in principle, it may not be the most appropriate location given
the surrounding context, as such commercial uses should be explored to strengthen
in the role of the Heart of Park Royal in supporting the business community. The
current Asda site could play a key role in achieving this vision.
Park Royal Business Group (PRBG) and Segro both support the aspiration for the
Heart. PRBG also requested that this should include flexible and affordable
workspace.
Noted.
Agree. Reference to flexible and affordable workspace will be made and the OAPF
amended accordingly.
Residents requested that development within the Heart address needs of local
residents as well as businesses and links to the Old Oak development are
maximised.
Agree. Reference to flexible and affordable workspace will be made and the OAPF
amended accordingly.
e. Wesley Estate

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Residents requested a clearer strategy for Park Royal and raised concerns that the
current level of guidance is insufficient for the Wesley Estate.
Agree. The GLA recognises that a clearer strategy for Park Royal is required and will
be carrying out minor alterations to the vision and Park Royal guidance to reflect this.
f. First Central Site
Guinness Ltd requested that the more detailed guidance on building heights for the
First Central site should be reinstated in this OAPF and that the current principle
PR1 fails to take account of the existing planning consents on the First Central site.
Further, Guinness Ltd requested that amendments be made to principle PR1(d) to
give greater emphasis to the potential for the site to accommodate residential uses.
Noted. The OAPF will be amended to reflect existing guidance in relation to building
heights for the First Central Site and its recent development history.
Agree. The OAPF will be amended to include a stronger reference to housing on the
First Central Site, were it to enable the delivery of significant public transport
improvements.
10.

Wormwood Scrubs

Overview: A number of representations were made by consultees in relation to the

Wormwood Scrubs section of the OAPF.
The London Assembly Labour Group expressed concerns regarding the potential for
Wormwood Scrubs being overwhelmed by new users.
Noted. The Wormwood Scrubs Act (1879) states that Wormwood Scrubs should be
held upon trust for the perpetual use thereof of the inhabitants of the metropolis for
exercise and recreation. Providing access to the Scrubs for the new residents and
workers within the Old Oak Common Opportunity Area accords with the Act. It is
acknowledged that the new population would likely result in a greater intensity of use
on the Scrubs and the GLA understands that OPDC is undertaking a Development
Infrastructure Funding Study, which will identify monies that can be spent on
enhancing the Scrubs to cater for this increased usage.
The Friends of Wormwood Scrubs, a local interest group, stated general support for
the Wormwood Scrubs Strategy but raised concerns regarding sensitive
enhancements to the Scrubs highlighting that the emphasis should be on ensuring
the Scrubs are more wild than tamed. The group also requested that the role of
Wormwood Scrubs Charitable Trust was emphasised. Only one new access point
was supported with locations suggested to the east of the proposed High Speed 2
station or at the north western corner of the Scrubs.
Noted. The GLA agrees that it is important to maintain the wild nature of the Scrubs
but considers that there may be parts of the Scrubs that will experience increased
usage as a result on development and that these locations may require harder
landscaping.
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Agree. The GLA considers that the WSCT is given adequate weight in the OAPF but
text will be inserted clarifying that any works to the Scrubs would also need to be
agreed by the London Borough of Hammersmith and Fulham.
Noted. The GLA considers that at least one access is required. Additional accesses
would need to be sensitively designed to minimise their impact on the Scrubs.
The group raised strong concerns regarding the potential impact of new accesses
and development of Old Oak on the character and biodiversity assets of the Scrubs.
Specifically the retention of the embankment along the northern edge was sought.
Noted. The Wormwood Scrubs Act (1879) states that Wormwood Scrubs should be
held upon trust for the perpetual use thereof of the inhabitants of the metropolis for
exercise and recreation. Providing access to the Scrubs for the new residents and
workers within the Old Oak Common Opportunity Area accords with the Act, but any
access would need to be sensitively designed to minimise its impact on the
ecological value of the Scrubs. The GLA understands that OPDC is producing a 3D
masterplan for the Old Oak area and as part of this, consideration would be given to
the retention of the embankment.
The group also identified that sections OO4 could contradict itself by seeking taller
building heights near the High Speed 2 station and lower building heights near
Wormwood Scrubs. For development along the current IEP depot, a maximum
height of 3 storeys was suggested
Noted. Further guidance on management of new high density development will be
included in the final OAPF. The GLA considers that the area around the station is an
appropriate location for tall buildings.
Residents requested that a maximum of two new access points to Wormwood
Scrubs from the north be provided and these to be located as far east as possible on
the Scrubs. Requests for the retention of embankment along its eastern edge were
provided.
Residents expressed strong concerns regarding the impact of tall buildings on the
Scrubs and considered that the biodiversity of the Scrubs would be negatively
impacted on through additional access points.
11.

Transport Chapter

Overview: Consultees were generally supportive of the approach outlined in the

OAPF to transport and the potential improvements to the public transport network.
TfL provided general support for the guidance on transport and committed to working
with the OPDC in delivering a series of studies including a Construction Logistics
Strategy and Park Royal Transport Strategy.
Noted. OPDC and TfL have jointly commissioned a Park Royal Transport Study and
will shortly begin work on developing a Construction Logistics Strategy
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QPR noted that upgrades in transport infrastructure outside of development sites,

particularly to pedestrian, cycle and bus facilities and connections, should be
designed to the same standards as those being provided within development sites.
QPR were also keen that an area wide travel plan be developed for the commercial
core of the Old Oak area.
Noted. A public realm strategy is being developed by OPDC and TfL and the
intention is that this will be applied to all parts of the OPDC area. An approach to
transport assessments and travel plans is being developed by OPDC. It is expected
that this will require co-ordination on an area-wide basis.
Local interest groups stated that the OAPF should be aiming for optimal connectivity,
providing better transport infrastructure and in particular, better local connections to
surrounding neighbourhoods.
Noted. Figure 57 shows an indicative route network including arrows to illustrate
connections to surrounding areas.
Residents asked for further information regarding assumptions in the transport
modelling with some disagreeing with the proposed scenarios. Residents also asked
that the structure of the chapter reflect the movement hierarchy stated in the Manual
for Streets and is linked to Lifetime Neighbourhoods. Residents suggested that the
transport scenarios should be more visionary and that less focus is put on
commuters and more on local communities. Concerns were raised that too many
options were presented and that the delivery of transport infrastructure should not be
at the cost of delivering new affordable housing.
Noted. Further information on transport modelling and the assumptions used are
included in the TfL Strategic Transport Study which was published alongside the
draft OAPF. The Vision and Objectives are set out on chapter 2 and includes
sections on maximising transport connections and integration with its surroundings
as well as the need for a mix of house types and tenures. The proposed approach to
transport is in line with the London Plan and is guided by the Mayors Transport Plan.
a.

Rail

Overview: Consultees were broadly in support of the proposals to enhance rail

connectivity in the area.
RB Kensington and Chelsea state that the OAPF should make reference to the
potential for rail connections to Kensal Canalside and a potential Crossrail station
and the opportunity this would bring to the area for intensified development.
Disagree. There are no current plans for rail connections to Kensal
Canalside. However, paragraph 8.31 states that Bus services will provide improved
connections linking Old Oak and Park Royal to surrounding neighbourhoods
including the potential to provide a direct link to the Opportunity Area at Kensal
Canalside.

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The Department for Transport requested that the OAPF clarify that the Crossrail link
to the West Coast Main Line is not currently a committed scheme and that a number
of proposed rail improvements would require detailed discussions with Network Rail
as they would impact on live rail infrastructure.
Noted. References to the potential link from Crossrail to the West Coast Main Line
are caveated by saying that it would be subject to a positive business case.
Agree. Section 8.12 states that any proposed work in and around Willesden Junction
station including links over rail lines will require liaison with the Network Rail Delivery
and Operations team. Wording will be added to the end of 8.9 to confirm the need
for liaison regarding improvements to the London Overground. All proposals for
improvements to the London Overground will be developed in close liaison with
Network Rail.
QPR supported the proposed upgrades to Willesden Junction station. QPR also
stated that having a high quality public transport offer will be critical in terms of
ensuring a high PT modal share from development.
Noted.
Local interest groups were supportive of proposals to improve rail connections in Old
Oak and Park Royal. There was particular support from the Campaign for Better
Transport and London Civic Amenity Society for proposals to provide new stations
on the London Overground network.
Noted.
Residents raised concerns regarding the potential impact of the Crossrail / WCML
intersection and impact on local communities and that the proposed Old Oak
Common Lane Overground station to be built early in the development before the
HS2 completion. Residents stated support for improvements to Willesden Junction
Station and new London Overground Stations alongside suggesting that support
should be given for additional Overground station at Western Circus to the south.
Noted. Work on the potential Crossrail/WCML link is still at a very early stage and a
number of alignment options are still being considered. If the scheme progresses to
detailed design stage, further work will be required to understand the impacts. During
this stage, the aim would be to optimise the solution to minimise any potential
adverse impacts.
Disagree. The Old Oak Common Lane Overground station cannot be constructed
until HS2 works in the area have been carried out so it would not be able to open
until 2026.
Disagree There are no proposals for a new Overground station at Westway Circus.
This is outside of the scope of the OAPF/OPDC and is therefore not considered as
part of this document.

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Residents also requested that development scenarios based on HS2 not proceeding
should be provided and further clarity on whether Old Oak Common Station would
act as a terminus for HS2 and where the location of the entrance to the station would
be.
Noted. All work on the Strategic Transport Study and the OAPF has assumed that
HS2 will go ahead as set out in the HS2 Bill. If there were to be any future changes
to the project these would need to be taken into account in the planning of the Old
Oak area.
Residents also identified that the rail loop along northern edge of Old Oak also
provides passenger transport and that the Dudding Hill line be reopened with a new
London Overground station proposed at Acton Lane alongside an extension to
Hounslow, Hendon and Mill Hill. Residents also requested that HS2 and Cross rail
services connect to Clapham Junction
Noted. Southern services do use the rail line along the northern edge of Old
Oak. There are no current proposals to reopen the Dudding Hill Line although this
possibility is not precluded if a business case for it was developed in the future. The
proposed London Overground station on the West London Line will provide
connections to Clapham Junction.
Other stakeholders requested further reference to the improved connections to
Heathrow Airport and that passenger interchange is made as easy as possible.
Noted. There are references to the connections that Crossrail will provide to
Heathrow and Reading in paragraph 8.2. Aspirations for passenger interchange are
set out in T1 (a).
b. Roads
Overview: Consultees were concerned that without adequate alternatives to travel by
private vehicles, development would put an increased pressure on the surrounding
road network.
Noted. Paragraph 8.24 states that Development proposals will need to demonstrate
that the impact on the road network can be managed in a way that mitigates the
negative impacts on traffic flow and junction capacity.
RB Kensington and Chelsea requested that the OAPF provide further clarity on the
impact that development would have on the road network and in particular, the
junctions highlighted in Figure 59.
Noted. Further studies planned or underway including the Park Royal Transport
Study, the Construction Logistics Strategy as well as further work to consider
potential improvements at A40 junctions. The studies will provide more information
on impacts on the road network as well as potential measures to reduce those
impacts. Paragraph 8.24 will ensure that the issue will also be addressed in
individual development proposals
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Quattro and Segro both asserted that the OAPF should ensure that any traffic
resulting from development should not impinge on existing businesses.
Noted. Paragraph 8.24 states that Development proposals will need to demonstrate
that the impact on the road network can be managed in a way that mitigates the
negative impacts on traffic flow and junction capacity.
The London Civic Amenity Society and Grand Union Alliance interest groups both
raised concerns about the potential impact of development on the surrounding road
network. Brent Cyclists interest group stated that as much should be done as
possible to minimise the number of trips made by private vehicles.
Noted. Paragraph 8.24 states that Development proposals will need to demonstrate
that the impact on the road network can be managed in a way that mitigates the
negative impacts on traffic flow and junction capacity.
Residents stated general support for a new road network but expressed strong
opposition to the expansion of Victoria Road as a dual carriageway and suggested
that one lane should be a designated construction lane, later to be used by buses.
Concerns were also raised that construction and new development will create further
congestion on the road network and that current traffic issues are not being
addressed. Further support was shown for a Harlesden bypass and for the eastern
access road into Old Oak from Scrubs Lane with further information requested for
the new road to the north of Wormwood Scrubs.
Noted. HS2 Ltd are developing proposals for Victoria Road. Although the road is
being widened as part of the HS2 proposals, GLA, TfL and OPDC would not support
a dual carriageway for general traffic and have pressed for priority to be given to
buses and cyclists. At this stage it is not envisaged that there will be more than a
single carriageway for general traffic.
Noted. Current traffic issues and those associated with construction will be
considered as part of work on the Park Royal Transport Study, A40 study and
Construction Logistics Strategy. Proposals for new or improved roads by local
business or residents groups will be assessed as part of these studies. With the
exception of Victoria Road where HS2 Ltd will be developing designs, no detailed
design work has yet been done for roads in and around Old Oak.
Residents stated that road improvements should not impact on residential amenity
and provided proposals for Atlas Road and Channel Gate Road to be reconfigured
for HGV access and replaced by a pocket park. Residents also suggested that the
taxi rank at Old Oak Common Station should be located below ground.
Noted. OPDC will develop a Construction Logistics Plan for the whole area.
However, it should be noted that HS2 will also produce its own plan and both
authorities will need to work together to ensure both plans achieve the best outcome
for the area. OPDC does not have direct control over the works and plans being
prepared by HS2 to deliver their rail line and station

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Noted. The design of the taxi rank at Old Oak Common station has been developed
by HS2 Ltd. TfL is in dialogue with HS2 Ltd to ensure that the design of the
interchange is optimised for all users.
c. Car Parking
Overview: Consultees generally felt that the approach to car parking would be an
important determinant on the amount of future road traffic in the area.
RB Kensington and Chelsea requested that specific mention should be made in this
section to electric vehicle charging and the importance of providing facilities for taxis
to reduce idling engines.
Noted. Electric vehicle charging points are already required by the London Plan and
minimum standards would apply to the OPDC area. Consideration of the need for
area specific guidance on this issue will be picked up as part of the Local Plan
process. Facilities for taxis to reduce idling engines isnt considered to be a direct
land use issue however, it is recognised that suitable taxi rank facilities will need to
be provided to reduce the time taxis spend driving around, in order to help reduce
emissions and enable drivers on the rank to be advised to avoid unnecessary engine
idling
QPR agreed that on-site car parking should be carefully controlled to help maximise
the extent of sustainable non-car travel. QPR also noted that importance of providing
car parking facilities for wheelchair users.
Noted. Car parking standards are set through the London Plan and will be applied
across Old Oak and Park Royal. These standards are currently set at a low level to
encourage alternatives to car travel. Priority will be given to disabled residents and
the only parking associated with new commercial development will be for use by
disabled people.
Guinness Ltd and Essential Living asserted that the approach taken to car parking in
the OAPF was not in accordance with the London Plan and should be amended.
Disagree. The recently adopted Further Alterations to the London Plan (March 2015)
sets maximum car parking standards in policy 6.13 and confirms that in locations
with high public transport accessibility, car free developments should be promoted
(while still providing for disabled people). Text in paragraph 6.43 further states that
Given the need to avoid over provision, car parking should reduce as public
transport accessibility increases. Modelling carried out as part of the Strategic
Transport Study demonstrated that low levels of car parking for new developments
will be essential to ensure that traffic congestion does not reach unacceptable
levels. It is therefore considered appropriate to put forward an approach to car
parking in the OAPF that reflects this evidence base.
Guinness Ltd requested that there should be an element of flexibility in any car
parking standards, taking into account a sites location, its PTAL and its impacts on
commercial viability. Aurora Property Group felt that parking standards should be

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more flexible in the early phases of development as these phases would have to be
built prior to the delivery of key pieces of public transport infrastructure.
Agree. The wording will be amended to indicate some flexibility, taking into account
location and access to public transport services. Propose insertion of There will be
some flexibility to take account of location and access to public transport services for
employment uses in parts of Park Royal which are furthest from rail and
Underground stations. at the end of paragraph 8.26.
Residents identified that current car parking in Park Royal is insufficient for
businesses and should be addressed and that by stating car parking guidance the
OAPF recognises that the development will have a negative impact on the local road
network.
Noted. Car parking in Park Royal will be considered as part of the Park Royal
Transport Study. The approach to car parking for new developments is designed to
minimise the impacts on the local road network.
d. Buses
Overview: There was broad support for the approach to improving bus connectivity in
the area.
RB Kensington and Chelsea requested that Figure 60 showing existing and
proposed bus routes should indicate which routes would be bus only and that the
text should indicate the potential for connections to Kensal Canalside Opportunity
Area.
Noted. It is too early to determine which routes will have bus priority although this
may be required on specific sections of route. Paragraph 8.31 refers to the potential
to provide a direct link to the Opportunity Area of Kensal Canalside.
New bus routes are supported, specifically from Old Oak to Harlesden and that a
new circular bus route in Old Oak should be explored.
Noted. The possibility of a direct bus connection from Old Oak High Street to
Willesden Junction station and Harlesden will be investigated. Paragraph 8.32 notes
that a bus only link could provide substantial benefits in terms of access to bus
services, journey times and operational efficiency. However, it is recognised that this
could pose engineering challenges and a feasibility study will be required to look at
the cost, design and engineering implications. Bus routes in Old Oak have yet to be
determined and will depend on the phasing of development and
infrastructure. However, a circular bus route is not envisaged as the most efficient
way to provide connections.
e. Walking and cycling
Overview: Walking and cycling was supported by consultees although concerns
were raised about the potential interaction of cycling with other modes.

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RB Kensington and Chelsea raised concerns regarding a potential cycle route on the
northern edge of the Grand Union Canal and the potential impact this might have on
Kensal Cemetery.
Noted. The pedestrian and cycle link shown on the north side of the canal does not
extend east of Mitre Bridge and so it wouldnt have an impact on Kensal Cemetery
Local interest groups were strongly supportive of proposals to improve cycling in the
OAPF. Brent Cyclists and Create Streets unequivocally supported the OAPFs
approach to cycling. There was particular support for improvements to cycling along
the Grand Union Canal and proposals for segregated cycleways, although some
interest groups noted the negative impact that cyclists can have on pedestrians,
especially along the canal.
Noted. The proposed designation of the Grand Union Canal as a Quietway will
provide improvements for users of the towpath.
Residents strongly requested that development within Old Oak is well connected to
the surrounding areas (specifically across the A40) and that access to Wormwood
Scrubs is demonstrated to be usable. Specific support was shown for improve
access from Old Oak and Wormwood Scrubs to North Acton and that this should be
continued to Horn Lane. Some residents did not support access from the proposed
Old Oak Common Station to Wormwood Scrubs while others requested further
discussions on the matter.
Noted. The potential for improved connections across the A40 will be considered as
part of the A40 study. The GLA considers it important that access is provided to the
Scrubs, and improving access to the Scrubs is in accordance with the Wormwood
Scrubs Act, which states that the Scrubs should be enjoyed in perpetuity by the
inhabitants of the metropolis. However, any access would need to respect the
Scrubs and be designed to ensure that its impact on ecology and biodiversity is
minimised. The Wormwood Scrubs Charitable Trust would need to agree any works
to the Scrubs.
Residents supported new walking and cycling routes along the canal and elsewhere
and asked that cycle routes should be segregated and additional Quietways
implemented. Concerns were raised with the potential use of tunnels to connect
transport modes.
Noted. The need for segregated routes will be examined on a case by case
basis. Sub-surface routes are proposed where this is required to make connections
to and between stations. They will be designed to a high quality and generous
dimensions with full accessibility so that they are suitable for all users. The aspiration
is to design the highest quality cycle network (akin to a TfL mini-holland scheme)
from the outset.
f. Construction and freight
Overview: Consultees recognised the importance of having strategies for
construction and supporting sustainable freight movements.
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HS2 Ltd request that this section clarify that control of construction logistics relating
to HS2 is a matter being dealt with through the parliamentary planning process and
not through planning policy and that the OAPF should not be used to seek changes
to HS2s Code of Construction Practice.
Noted. The policy and text do not seek changes to HS2s Code of Construction
Practice. Paragraph 8.53 confirms that the issue of construction transport is being
pursued by TfL as part of the HS2 petitioning process and that there will be
continuing discussions with HS2 Ltd on this issue. The GLA acknowledges that HS2
along controls its Construction Logistics proposals through its Code of Construction
Practice; however, the GLA is keen for HS2 to work with the GLA, TfL and OPDC to
design and implement a coordinated construction logistics strategy for the entire
area.
QPR noted that importance of managing construction activity in order to minimise
impacts on communities on and off site.
Noted. This issue will be addressed as part of the Construction Logistics Strategy.
Quattro stated that their presence in the area would be of benefit when considering
the management of construction traffic.
Noted The Construction Logistics Strategy will consider the scope for local
suppliers and contractors to reduce the need for construction transport.
Residents stated support for the use of the canal for freight purposes and the
proposals for freight consolidation centres.
Noted.
Strong concerns were expressed by residents regarding the impact of construction
on residential amenity and that further commitments should be made in the OAPF to
deliver a mechanism for engaging the residents on this matter and controls on
construction work. Residents asked that the protection of residential amenity is
referenced under principle T7 and that further guidance provide to work with
companies to minimise freight transport.
Agree - A Construction Logistics Strategy will be developed and the process of
overseeing the strategy will need to include input from representatives of local
businesses and residents. Point d of T7 will be amended to read Support the
provision and operation of measures to reduce freight trips, promote cleaner vehicles
(e.g. consolidation centres) and minimise any adverse impacts on local residents
and businesses.
12.

Environment Strategy

Overview: There was broad support for the inclusion of an Environment Strategy
chapter in the OAPF.

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The Environment Agency provided general support for the approach taken with
some suggested amendments in relation to waste management and green
infrastructure.
The London Assembly Labour Group requested that a stronger commitment to
delivering a sustainable development is made.
Noted. The OAPF Vision and Objectives states that Old Oak and Park Royal will be a
sustainable new development integrated into its surroundings. The GLA believes the OAPF
provides the framework for how this will be achieved and how the opportunities associated
with the OAPF can be maximised to fully integrate social, economic and environmental
benefits to produce exemplar sustainable developments. However the GLA accepts further
explanation of the objectives would help explain how this will be achieved. As part of its
evidence base for the local plan OPDC will undertake an Integrated Impact Assessment (IIA)
to assess the sustainability of its policies.

a.

Water

Thames Water is broadly supportive of the approach taken to water in the OAPF,
noting in particularly their support for the approach outlined towards Sustainable
Urban Drainage Systems (SUDS) and the commitment towards producing an
Integrated Water Management Strategy. Thames Water noted the importance, as
outlined in the OAPF, of ensuring that development manages surface water run-off
as close to source as possible and that development should aim to achieve
greenfield run-off rates for peak flow and volume control.
Thames Water noted that it will be essential for development in Old Oak to avoid
impact further down the Counters Creek catchment.
Thames Water also noted that Figure 64 includes an indicative water infrastructure
plan including potential pumping stations and that if any development is proposed
within 15 metres of a proposed or existing pumping station, the developer or local
planning authority should liaise with Thames Water to consider whether further
assessment is required.
The London Civic Amenity Society interest group commended the OAPFs approach
to water.
Residents requested that green walls/roofs and spaces be referenced in the use of
water management.
Noted. OPDC is committed to undertaking an Integrated Water Management Strategy which
will support Sustainable Urban Drainage Systems as outlined in paragraph 9.4. The outcome
of this work will be used to inform OPDC Local Plan for the area.

b. Waste
RB Kensington and Chelsea requested that text should be inserted in the OAPF
flagging the potential for the capacity of waste sites in Old Oak and Park Royal to
meet RB Kensington and Chelseas waste apportionment.

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Disagree. Any agreement to meet RB Kensington and Chelseas waste

apportionment would need to be agreed through discussions with OPDC in relation
to the Duty to Cooperate and OPDCs Local Plan.
The Environment Agency requested a detailed waste management strategy for each
building is provided for the development management process to support
sustainable management of waste. Specifically this requested that waste
management is coordinated with local authority services. The Environment Agency
also suggested that the OPDC work with the London Waste and Recycling Board to
establish best practice and that discussions are undertaken with the GLA to establish
a waste apportionment for the OPDC area.
Noted. Detailed waste assessments have been carried out for sites within the
London Boroughs of Ealing and Brent as part of the West London Waste Plan. A
decision to allocate OPDC a waste apportionment target would be taken on the next
review of the London Plan.
Quattro stated that the OAPF is currently showing predominantly residential
development on the Shield Site but that the West London Waste Plan identifies that
post HS2s construction, the waste recycling use will be reinstated and that the
OAPF should reflect this assertion. Quattro also requested that Quattro be added to
the list of waste sites in para 9.6 and that the Quattro site should be identified as
warranting Mayoral support with relocation in para 9.8.
Noted. Post HS2, there will be an opportunity to redevelop the Shield Site. In line
with the West London Waste Plan, this should look to reincorporate a waste facility.
Agree. Quattro will be added to the list of waste sites at paragraph 9.6.
The Grand Union Alliance, a local interest group, raised concerns that any proposals
for waste sites should be carefully planned and separated from residential areas.
Agree. Any proposals for new waste sites would need to be considered against
existing London Plan policy and the impact of residential amenity would be a key
consideration.
Residents requested that existing waste sites are relocated out of Old Oak and the
wider OPDC area. Concerns were raised that the West London Waste Plan may no
longer aligned to the London Plan (March 2015) and regarding the location of a
proposed school next to an existing waste site.
Noted. The OAPF proposes the relocation of waste sites out of Old Oak, but notes
that Powerday could remain and act as a waste management centre during and post
construction. The West London Waste Plan exceeds the targets set in the London
Plan (2015) and is therefore in conformity. Any proposals for educational facilities
adjacent to waste sites would need to be considered with regard to their amenity and
potential health impacts, in line with London Plan policy.
c. Air Quality

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The London Civic Amenity Society stated that the proposals in the OAPF were
inadequate for post-construction monitoring and mitigation.
Disagree. The OAPF states it proposes to minimise the generation of air pollution, both
during and post construction, making new developments air quality neutral or better; E3
page 106 Air Quality Neutral is part of the London Plan Policy 7.14 and is implemented
through the SPG on Design and Construction and SPG and the Code of Practice on
Prevention of Dust from Construction, also implemented through an SPG.
Environment Agency (EA) requested that sites should operate a robust dust management
plan which should feature no-idling, use of dust suppressants and a programme of regular
access road sweeping, in liaison with other operators and local authority as appropriate.
EA noted that none of the comments talk about a low emission zone. EA requested
consideration for OPDC to include low emission requirements and encouragement of LEVs,
whether that be a full blown LEZ, one aimed at specific vehicles, or more widely the adoption
of the principles of Low Emission Neighbourhoods (LENs) as per TfLs latest guidance or a
combination of these.
Agree. The OAPF states it proposes to minimise the generation of air pollution, both during
and post construction, making new developments air quality neutral or better; E3 page 106
Air Quality Neutral is part of the London Plan Policy 7.14 and is implemented through the
SPG on Design and Construction and SPG and the Code of Practice on Prevention of Dust
from Construction, also implemented through an SPG.

Residents requested that the OAPF provides a commitment that a dust management
plan is developed and that in minimising air pollution this should reference residential
amenity. Suggestions were made for vegetation and other innovative techniques to
mitigate the impact of construction on local residents. Residents also suggested that
the section be titled Air Quality and Noise.
Agree. The OPDC Local Plan will incorporate all aspects of existing Borough Air Quality
Action Plans particularly as it is located wholly within existing Air Quality Management Areas
(AQMAs). As part of the evidence base the Local plan will utilise best practice and guidance
for Low Emission Neighbourhoods.

d. Energy
Residents raised concerns that energy guidance is not supported by an evidence
base and that further exploration of whether local energy generation created from
waste would impact on residential amenity. Residents also requested guidance
relating to retrofitting existing structures.
Disagree. The London Plan sets London wide energy policies that OPDC must be in general
conformity with. As part of the supporting evidence for the Local Plan, OPDC is committed to
undertaking an Energy Strategy as outlined in paragraph 9.2 of the OAPF. The Local Plan
policies will be guided by best practice and specific guidance would be expected to be
delivered through an SPG.

e. Green infrastructure

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The Environment Agency suggested that green infrastructure is further integrated in

the built environment to contribute to biodiversity, health and well-being, air quality
and water management. They also suggested that the funding of green infrastructure
is embedded in any business planning.
Natural England requested that accessible green open spaces are delivered and that
green infrastructure is embedded within wider development. Concerns were raised
regarding some types of living roofs as having limited biodiversity value.
Local interest groups requested that greater emphasis be given to tree planting
within the green infrastructure section.
Residents requested that biodiversity surveys should be carried out and that a
commitment by local planning authorities is made to deliver new biodiversity spaces
and green infrastructure. Requests for safeguarding the biodiversity assets along the
canal were also stated. Residents support the proposal to protect Wormwood
Scrubs ecology but raised concerns about the impact of new accesses onto the
scrubs.

Noted. The GLA considers that the OAPF provides a strong starting point. As part of the
supporting evidence for the Local Plan a Green Infrastructure Strategy will be developed to
support delivery of exemplar Green Infrastructure across the OPDC.

f. Land Contamination
The Environment Agency supported the aspiration for the sustainable management
of contaminated land and suggested that a soil treatment centre is established.
Residents requested that the OAPF states that local planning authorities will work
together to address land contamination.
Agree. The GLA recognises that Land Contamination is an important issue. National
legislation and NPPF policy exists and will be applied but it is not necessary to replicate this
within the OAPF. London Plan Policy 5.21 requires LDFs to set out policies to address land
contamination. As part of the supporting evidence for the Local Plan a Land Contamination
Strategy will be developed to support the investigation, assessment and sustainable
management and remediation of contaminated land risks within the OPDC area.

13.

Delivery chapter

Overview: A number of consultees made representations on the Delivery chapter of

the OAPF, which are outlined below.
TfL acknowledged that a number of depots and stabling facilities will need to be
relocated and commits to working with the OPDC to deliver a long term solution.
However, the Department for Transport noted the complexities of moving such
infrastructure, especially the IEP depot.

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Noted. The GLA and OPDC will continue to work closely with TfL and the
Department for Transport to ensure the timely relocation of these depots to facilitate
the redevelopment of Old Oak.
The Department for Transport noted the work on the growth strategy and supported
its production.
Noted.
Cargiant support the approach outlined in the delivery chapter and supported a
comprehensive approach being taken to the masterplanning of the area. They noted
the importance of planning for utility infrastructure from the outset and the need for
open dialogue with utility providers. Cargiant also noted the importance of the work
that the GLA and OPDC are undertaking on the growth strategy. Cargiant
recognised the need for development proposals to be supported by necessary
infrastructure to support the needs of development, but noted that where early
development proposals carry an infrastructure burden this should be recognised as
part of scheme viability.
Noted.
QPR requested that principle DL1d make specific reference to a football stadium and
the Genesis site.
Agree. Text will be inserted under paragraph 10.7 referencing the potential for largescale catalyst uses and this will reference the potential for sports stadia to act as a
catalyst.
Segro requested that the Delivery Strategy include more detail on infrastructure
requirements in Park Royal.
Noted. Paragraph 10.1 notes that further work is being undertaken on infrastructure
requirements in Park Royal by OPDC and this will inform their Local Plan policies.
Local interest groups supported the provision of educational infrastructure in the area
and were supportive of proposals to relocate the Crossrail and IEP depots.
Noted.
Residents raised concerns that infrastructure may not be delivered due to the current
funding gap and that this may not deliver Lifetime Neighbourhoods. Residents
requested that the types of social infrastructure should be stated and that
assurances should be made that this would meet local need. Residents also wanted
confirmation that the social infrastructure being secured was adequate to meet the
needs arising from development and would not place a burden on existing
infrastructure in the surrounding areas. A request was made for the emerging
Development Infrastructure Funding Study to be made available to understand
infrastructure requirements

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Noted. Paragraph 10.1 notes the production of a Growth Strategy, which is

investigating ways of plugging any funding gap.
Noted. Social infrastructure types are stated in the social infrastructure section on
Page 122.
Noted. This is clarified in paragraph 10.34.
Noted. The Development Infrastructure Study (DIFS) will sit as evidence alongside
the Local Plan.
a.

Phasing

Cargiant asserted that the current phasing was overly ambitious and that within the
core area of Old Oak North, it would be unlikely that development would start pre2022. In contrast, QPR asserted that the OAPF should promote development across
the Old Oak area as early as possible.
Noted. The GLA understands the complexities of delivering development at Old Oak.
Further work on phasing will be undertaken by OPDC as part of its Local Plan, which
will include a 5 year housing supply trajectory.
QPR requested that text be inserted in para 10.13, which supports catalysts for early
regeneration, identifying that a football stadium would also be a beating heart and
identifier for the area. QPR also asserted that the delivery of Hythe Road
Overground station as early as possible would help with expediting development.
Disagree. The GLA considers the current wording, which identifies the potential for a
football stadium to act as an early catalyst for regeneration is sufficient.
Aurora Property Group disagreed with the statement in para 10.23 that without the
transport infrastructure identified in Figure 70 (Fixes and Principles), development in
Old Oak would not occur, whereas QPR supported this statement.
Agree, the wording will be amended to clarify that little development would be able to
occur without the provision of this infrastructure.
RB Kensington and Chelsea requested that the phasing of development on the
eastern part of North Pole Depot is brought forward to pre-2026.
Agree. The phasing will be amended to show North Pole East coming forward for
development pre-2026.
14.
Public drop-in sessions and other event attendance
Public drop-in sessions took place during March on the below days to enable local
people to discuss proposals and provide their views.

Tuesday 10 March, 3:30pm to 8pm All Souls Church, Harlesden, NW10 4UJ
Wednesday 11 March, 8:30am to 10:30am Holiday Inn Express, North
Acton, W3 6UP
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Saturday 14 March 10am to 3pm Linford Christie Outdoor Sports Centre,

Artillery Way, W12 0DF
Tuesday 17 March, 5pm to 8pm - Holiday Inn Express, North Acton, W3 6UP

In total approximately 180-200 people attended these events.

Officers also attended a number of other events to present and discussion the draft
OAPF.
15.

Queens Park Rangers Supporters summary

Queens Park Ranger (QPR) supporters submitted 3,414 responses containing

content. 3,333 stated support for QPR relocating to the Old Oak area with 81
responses against.
Noted.
16.

Appendices

HS2 Ltd objected to the inclusion of the GLAs petition items in an appendix to the
OAPF.
Agree. This will be removed as an appendix from the OAPF.
17.

Supporting Environmental Studies

Segro asserted that the Strategic Environmental Assessment (SEA) and Habitat
Regulations Assessment (HRA) should consider the different approaches to waste
required in Old Oak versus Park Royal. Historic England also suggested that
wording regarding the setting of assets and mapping of these should be reflected in
the SEA.
Noted. This would be considered as part of OPDCs Local Plan.

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Appendix A Response to the London Boroughs of Brent (LBB), Ealing (LBE) and Hammersmith and Fulham (LBHF). The table
below follows the structure of the draft OAPF and includes the comment from the relevant authority and the proposed GLA
response.

Page 258

Organisation

Comment

Theme

LBE

The labels should read Ealing Broadway not Ealing Station,

Southall not Southall Station

General

LBB

The London Borough of Brent strongly supports the proposal

to bring forward the comprehensive regeneration of Old Oak
and Park Royal in line with the objectives outlined in the
Opportunity Area Planning Framework (OAPF).

LBB

However, the Council feels the OAPF must be amended to

ensure the surrounding communities and Park Royal
businesses fully benefit from the regeneration of this area.
The Councils key areas of concern are summarised below
and a detailed response attached as Appendix A.

LBE

LBB

However, the current draft OAPF does not successfully

translate these aims in its detailed policies and, overall, the
document seems to have been compromised by its hurried
development.
The OAPF has been developed to an ambitious timetable.
The Council trusts future timescales will allow for a more
collaborative approach, and enable the development of a
policy framework focused on securing best practice.

Response
Agree. Change to be made
Noted.

General

General

General

General

Agree. Further guidance on Park Royal will be

included in the final OAPF. The OAPF will also set
out those more detailed policy areas that will be
developed over the coming year and included in the
OPDC local plan.
Disagree. The GLA considers that the guidance
stated within the OAPF reflects the Vision and
Objectives. The GLA acknowledges that the
document was produced in an efficient manner, and
has been informed by the June 2013 Vision
document and 2010 Park Royal OAPF, but this has
not resulted in the document being compromised.
Noted. The GLA acknowledges that the document
was produced in an efficient manner, having been
informed by the June 2013 Vision document and
2010 Park Royal OAPF with ongoing collaboration
with the local boroughs.

50

LBHF

The council is concerned that the OPDC is rushing the

process without adequate time to consider and comment on
the document which has changed significantly since the
Vision was drafted in February 2012.

Page 259
LBHF

The council is not convinced that an OAPF is required for

the Old Oak Common Opportunity Area in advance of a
Local Plan to be prepared by the OPDC.

LBHF

The draft OAPF provides no additional material policy

guidance to that already included in this councils draft Local
Plan and the Mayors London Plan adopted in March 2015.

LBHF

It would be useful for the reader if there was clarification

of the differences between the boxes highlighting principles,
proposals and key objectives. There does not seem to be a
consistent approach throughout the document regarding
these terms, for example is WS1 regarding Wormwood
Scrubs a proposal, principle or objective?

General

Disagree. The thought process behind the OAPF

has been in development over the past 4 years,
starting with the production of the Vision for Old Oak,
which was consulted on jointly by the GLA, TfL and
the three local authorities in 2013. This vision has
formed the starting point for the subsequent OAPF.
Key stakeholders have been involved in the
document's production. Prior to public consultation,
The GLA held weekly project group meetings with
the boroughs to discuss the content of the OAPF.
Key stakeholders in the public sector were also
provided draft copies of the OAPF for comment prior
to full public consultation.

General

Noted. The GLA is aware that OPDC is planning to

progress its Local Plan over the course of 2015/16;
however, preparing a Local Plan from scratch will
take some time to produce. The GLA therefore
considers it appropriate to produce a OAPF to
provide supplementary detail to London Plan policies
in order that this can be used by OPDC officers to
guide development and in the determination of
planning applications within the OPDC area.

General

Noted. The GLA considers that the OAPF does

provide additional material policy guidance,
particularly in terms of the approach to design,
placemaking, delivery and transport.

General

Agree. Changes to the OAPF will be made to clarify

what are principles and what are objectives.

51

 The supporting text in the OAPF, in a number of cases,

includes a requirement or a key point. This text should be
transferred to the key objective/principle boxes in order to
give it appropriate weight (see also comments below on
Document Status). Some examples of this are:

Page 260

LBHF

o Paragraph 5.10 last sentence

o Paragraph 5.50
o Paragraph 5.55
o Paragraph 5.61- second sentence

LBHF

The document would benefit from a glossary of terms to

provide more clarity, particularly in relation to the key points
and requirements, for example definition of green grid and
also the approach to sensitive areas identified in the Urban
Design Strategy

LBHF

A number of the Figures in the document are so vague that

they are relatively useless, for example Figures 15 and 16.

General

Disagree. As with Local Plans, guidance within the

OAPF is not constrained to text within principles and
objectives. Officers would be expected to reference
text within paragraphs as material guidance.

General

Noted. The OAPF will not include a glossary but text

will be inserted to clarify certain phrases and
terminology such as 'green grid' and 'sensitive areas'

General

Disagree. Figure 15 shows an illustrative crosssection of two roads and demonstrates how taller
elements on main thoroughfares can aid legibility.
This will be relocated adjacent to figure 13 for clarity.
Figure 16 is a map showing the places of Old Oak,
which sits alongside Principle D5.

52

LBHF

The document needs to be checked so that the area is

referred to as Old Oak and not Old Oak Common.

General

Agree. The London Plan Annex A defines the name

of the Opportunity Area as 'Old Oak Common' but it
is recognised that 'Old Oak' has become the
recognised name for the area and changes will be
made to the OAPF.

General

Agree. The OAPF clarifies that policy where more

detailed evidence is required would be established
through OPDC's Local Plan. The OAPF provides
detailed guidance where supporting evidence exists
but leaves areas where more detailed evidence
might be required to be dealt with through a future
OPDC Local Plan. The final version of the OAPF will
clearly set out what evidence will be produced as
part of preparing the Local Plan

There is an absence of key supporting evidence such

as Character Analysis Studies, Edges Studies, Retail Needs
studies and DIFs etc. to adequately support the OAPF which
results in a high level Vision document and is short of being
detailed enough to serve as supplementary planning
guidance. The council suggests that the OAPF is not adopted
but instead serves to inform the OPDCs Local Plan.

Page 261

LBHF

Organisation

Comment

Theme

LBE

In the context of these linked concerns about the strategy for

Old Oak and Park Royal Ealing considers it is particularly
important that the OAPF;
- Acknowledges the early nature of the work on Old Oak and
Park Royal and the need for substantial progress before
development proposals are brought forward.

Introduction

Response
Noted. This is acknowledged in paragraph 1.13

53

1. Disagree. The 4th tier of documents depicted in

figure 3 intentionally refers to 'Core Strategies /
Local Plans' and 'Other Borough Development Plan
Documents' which relates to the existing adopted
policies of the development plans of the respective
London boroughs. The figure will be amended as per
points 2 and 3 below.

Figure 3, page 10 It is recognised that the Figure is seeking

to provide a simple understanding of the existing and future
relationship between planning documents that will be a
material consideration in the determination of planning
applications in the area covered by the OAPF, however, this
figure is misleading for a number of reasons.

2. Noted. Figure 3 will be amended to define this

relationship.
3. Agree. Figure 3 will be amended to show
Supplementary Planning Documents to be below the
4th tier of documents and figure simplified to show
'Local Plans' and the West London West Plan.

Page 262

Firstly it fails to recognise the status of existing adopted

policies of the development plans of the respective London
boroughs within which it sits. Until the adopted OAPF is
replaced by the proposed Mayoral Development
Corporations Local Plan these plans are still part of the
Development Plan for the purposes of S38 of the 2004 Act.
Secondly it appears to suggest that the OAPF has fed into
existing Borough Local Plans. The dashed line between the
OAPF and Core Strategies should be removed or the
relationship between the OAPF and future plans be clarified
in a better way.

LBB

In addition, Core Strategies and Development Plan

Documents are components of Local Plans. Supplementary
Planning Documents should sit below Core Strategies and
Development Plan Documents, as they supplement these
policies. For accuracy and simplicity the diagram should be
amended to include one box for Borough Local Plans, rather
than three separate boxes for Core Strategies/Local Plans,
Supplementary Planning Documents and Development Plan
Documents.

Introduction

54

Agree. Arrows show the London Overground

connections to the north west and east but these will
be continued along the routes of the North London
Line and Watford to Euston Line.

Page 263

LBB

Figure 4, page 13 The focus of this figure is very much on

links to South London. At present this figure does not
illustrate how HS2 will link to wider routes to the north west
and east, and therefore the wider benefits for North London.
Overground links via Willesden Junction towards Watford
Junction, Barking and Stratford need to be illustrated here.

LBHF

Para 1.1 states that This draft Opportunity Area Planning

Framework (OAPF) provides supplementary detail to the
planning policies contained within Mayor of Londons Further
Alterations to the London Plan (2014) in the form of
Supplementary Planning Guidance (hereafter referred to as
SPG). However, the Mayor should be mindful not to allow
the document to stray into making new policies. The purpose
of SPG is to support statutory development plans, not act as
an alternative to the development plan.

Introduction

Noted. The GLA considers that this OAPF does not

set new policy but supplements existing policy in the
Mayor's London Plan.

LBHF

Para 1.1 following last sentence add This OAPF has

been prepared in accordance with the Greater London
Authority Acts 1999 and 2007 and the National Planning
Policy Framework.

Introduction

Disagree. This sentence is included in paragraph

1.2.

LBHF

Para. 1.9 considers the relationship of the draft OAPF with

other local authority planning documents. However, the
paragraph fails to acknowledge the existence of adopted
SPD which will be a material consideration in determining
planning applications.

Introduction

Disagree. Other borough SPDs are referenced in

Figure 3.

Introduction

Disagree. The diagram is a high level diagram

explaining the relationship of national, regional and
local guidance. OPDC's website clarifies what is and
is not part of OPDC's Development Plan. As this is
likely to be constantly changing, it is right for this to
be on the website where it can be regularly updated
rather than in a static document. However, further
clarity on this will be provided in the text.

LBHF

Figure 3 - needs to clearly set out which documents will

have weight in determining planning applications from 1 April
and which will fall away.

Introduction

55

Page 264

LBHF

P.12 - the document states that Old Oak could evolve and
change over the next 30 years. However in the opening
paragraph of the Vision, it is stated that over the next 20
years (the area) will make a major contribution to
strengthening Londons role. Clarification of timescales is
necessary here and throughout the draft OAPF because
what can be achieved over 30 years will be far different than
over 20 years. In particular, the proposed 24,000 homes will
not be achieved within 20 years. This council considers that
by 2035 an indicative total of 6000 new homes will have been
built in the Old Oak Core Area (OOCA).

Introduction

Agree. Changes will be made to the OAPF to clarify

that the OAPF look up to 2050, spanning a period of
35 years.

LBHF

Para 1.16 The Golden MileQ.add - in BrentfordQis also

in the vicinityQ

Introduction

Agree. Change will be made

Organisation

Comment

Theme

LBB

Environment Strategy, page 102- 107 Although the vision for

Old Oak and Park Royal is for the creation of a sustainable
new town, the OAPF lacks any sustainability standards. The
environment strategy chapter should include a strong
strategy for the achievement of sustainable development.

Response
Noted. The OAPF Vision and Objectives states that
Old Oak and Park Royal will be a sustainable new
town and will contribute to integrated and
sustainable communities. The GLA believes the
OAPF provides the framework for how this will be
achieved and how the opportunities associated with
the OAPF can be maximised to fully integrate social,
economic and environmental benefits to produce
exemplar sustainable developments. However the
GLA accepts further explanation of the objectives
would help explain how this will be achieved . As
part of its evidence base for the local plan OPDC will
work with London Sustainability Commission to
explore a Sustainable Development Strategy.

Vision

56

LBB

Investment in High Speed 2 and Crossrail provides a unique

opportunity to redevelop Old Oak and regenerate Park Royal.
Brent Council agrees these areas have a crucial role to play
in delivering housing and jobs for the benefit of wider
London. Accordingly, given the areas status Old Oak should
be an exemplar for future development in London.

LBE

In the context of these linked concerns about the strategy for

Old Oak and Park Royal Ealing considers it is particularly
important that the OAPF;
- Understands HS2 and the improved connectivity that it
brings will drive change throughout the area, including Park
Royal and its crucial economic role.

Vision

Noted. The GLA considers that both the London

Plan and OAPF provide guidance to deliver a high
quality environment that accords with Lifetime
Neighbourhoods that supports the delivery of the
London Plan housing and employment targets. To
ensure this aspiration is clarified, further information
will be provided within the design strategy.
Noted. The GLA considers that it has a thorough
understanding of the potential benefits that HS2 will
bring to both Old Oak and Park Royal.

Vision
Agree. The GLA recognises that a stronger vision for
Park Royal is required and will be carrying out minor
alterations to the vision to reflect this to:

Page 265

- Provide a clearer and stronger vision

- Define the challenges and opportunities
- Identify what evidence based will be produced with
timeframes and envisaged methodology
- skills and training
- commitment to securing funding streams
- Design guidance (public realm and routes, public
spaces, building heights)
- Land uses guidance
- Infrastructure guidance (transport and utilities)
- Placemaking guidance (Heart of Park Royal and
wider Park Royal)

The OAPF does not establish a strong vision for Park Royal.

LBB

Vision

57

Noted. The GLA considers that it has a

comprehensive understanding of the range of issues
impacting on businesses in Park Royal, based on
the Park Royal Atlas, and opportunities for future
development appropriate to the role of an
Opportunity Area Planning Framework.
It is not informed by an understanding of the range of issues
currently impacting on businesses operating in Park Royal, or
opportunities for its future development.

To help inform how Park Royal can be improved for

existing businesses and also to take advantage of
the significant new development on its own
doorstep, the GLA will provide a more
comprehensive Park Royal Strategy. This will clarify
how the existing borough Local Plan policies and
Park Royal OAPF (2010) will be reflected.
Vision

LBB

Noted.

Page 266
LBE

Ealing is broadly supportive of the proposed Vision and

Objectives of the draft OAPF, particularly where these reflect
continuing joint work between the GLA, MDC and the
Boroughs.

Vision
Agree. Objective 4 will be amended to reflect the
guidance stated in L3 regarding sensitive
enhancements to amenity assets such as
Wormwood Scrubs and the Grand Union Canal.

Vision, page 16 Harlesden is a district centre in the London

Plan town centre classification.

LBB

4. Consolidate: Greater emphasis should be placed on

enhancing, rather than merely safeguarding nearby amenity
assets which may well benefit from additional investment to
realise their full potential.

Vision

58

LBHF

The proposed minimum of 24,00 new homes over 20 years

will not be achieved. Officers consider that by 2035 an
indicative total of 6000 new homes will have been built in the
Opportunity Area.

Page 267
LBHF

The first paragraph of the Vision states that Old Oak and
Park Royal will be a sustainable New Town, but in the 4th
paragraph the document states that Old Oak will be a new,
well connected neighbourhood. Reference to New Town
implies that this might be designated under the New Towns
Act, which is presumably not the case. These are two
different concepts and require clarification. The council
considers that the vision should not refer to Old Oak being a
new town, rather it should integrate seamlessly with the
urban fabric of the surrounding boroughs. The OOCA and
Park Royal should have a symbiotic relationship with these
boroughs, for example sharing services and contributing to
each others needs. The Mayor of London will of course be
aware of the Duty to Cooperate and the duty on councils to
engage constructively, actively and on an on-going basis in
maximising the effectiveness of Local Plans relating to
Strategic matters which may impact on at least two
planning areas including in connection with infrastructure
which is strategic. This Duty will fall upon the MDC. This
council considers that the area should not be a sustainable
new town and everything possible, including meeting the
requirements of the Duty, should be done to ensure that it
performs as one piece of the jigsaw of areas that make up
London.

Vision

Agree. Change will be made to the Vision to clarify

that the Old Oak and Park Royal area is not a 'New
Town' as defined by the New Towns Act, but that the
scale of development proposed at Old Oak would be
equivalent to that of a new town. The GLA agrees
that it is important for Old Oak to be connected into
its surroundings.

Vision

Agree in part. The OAPF will be amended to state

that it covers up to 2050. The homes target for the
plan period would be defined by OPDC as part of its
Local Plan preparation.

59

LBHF

The document should confirm how National Planning Policy

requirements on housing especially with regard to affordable
housing will be met by the OPDC.

Vision

Disagree, the OAPF has to be in conformity with the

London Plan. The OAPF provides little detail on
affordable housing as the position in the London
Plan is clear and this would apply to the area. OPDC
will through their Local Plan define their own
affordable housing target and the LBHF would have
the opportunity to comment on this during its public
consultations.

Page 268

Disagree. Affordable housing should be based on

need but viability is also a consideration in the
identification of an affordable housing target.
However, this is not something that can be set
through an OAPF and would be a matter for OPDC's
future Local Plan.
To support clarity, the OAPF will set out how the
OPDC will:

Vision

- undertake its Strategic Housing Land Availability

Assessment and supporting typology work
- develop the OPDC Local Plan affordable housing
policies
- define what existing guidance exists for affordable
housing
- define the Mayor's and Government's position on
foreign investment

LBHF

Needs to be clear that that new housing should be designed

to meet the needs of London residents and not overseas
investors who may leave new housing unoccupied for long
periods.

Vision

Agree. The OAPF will be amended to encourage

developers to sign up to the Mayoral Concordat to
market homes first, or first equal, to Londoners.

LBHF

4th Para. add dates for delivering the 24,000 homes &
55,000 jobs by. When could this happen.. by 2050?

Vision

Agree. Yes, by 2050 and the OAPF will be revised to

clarify this.

LBHF

affordable housing provision should be based on need, and

the social infrastructure should be provided to meet this
need. The amount of affordable housing should not be
predicated on the level of physical and social infrastructure in
the area. The council wishes to be fully engaged in
objectively assessing housing need.

60

Page 269

LBHF

How will this new part of London compare/relate to other

Opportunity areas in West London/ across London?

LBHF

P.17, Figure 6 - The council considers that Figure 6 is

misleading and requires amendment and this is also true of
Figure 10 Land Uses. In particular, the large area shown as
the focus for town centre uses gives the impression that
there could be a mega-sized town centre stretching over
approximately 1/3 of the OOCA. Notwithstanding the broad
definition of town centre uses, the geographical spread of
town centre uses within the OOCA will not be on this scale.
Subsequent policy, particularly para.4.1 would imply that
higher densities and taller buildings would be appropriate
over the whole of this town centre area.

LBHF

Also in Figure 6, the green grid symbol leading into

Wormwood Scrubs and St Marys Cemetery gives an
impression of a significant incursion into these areas of open
space (see also Figure 23). Both areas of open space are
subject to policies that protect open space, as well as the
character of these areas, and any proposals affecting these
areas must be designed and implemented in such a way that
does not detract from their character and function.

LBHF

There is no provision in these sections to protect and

enhance the existing natural and heritage values in the area
(Wormwood Scrubs and the Grand Union Canal in
particular). It is suggested that suitable amendments are
made. The council considers that protection of existing
natural /heritage values is not the same as safeguarding the
nearby amenity assets such as Wormwood ScrubsQ
referred to in Point 4 of the Objectives.

Vision

Noted. How Old Oak and Park Royal relates to the

other Opportunity Areas is set out in paragraphs
1.15 / 1.16 and figure 4. This will be expanded to
define the role of Opportunities Areas in playing a
key part in supporting London's growth.

Vision

Agree. The area shown on each figure as 'focus for

town centres' is drawn flexibly to allow for different
alignments of the High Street. This approach is
clarified in the Old Oak High Street Place. Para 5.12
of the OAPF clarifies that retail provision should
cater for the day to day needs of development. Para
4.1 does not state that the area described as being
appropriate for town centre uses is also appropriate
for taller densities and buildings. However, the GLA
agrees that this could currently be misinterpreted
and the area shown as being appropriate for town
centre uses will be revised and made smaller.

Vision

Agree. The diagram is showing connections

between green spaces, not incursions into them.
The rest of the OAPF is clear relating to the
character and protection to Wormwood Scrubs and
St. Mary's Cemetery. However, the OAPF will be
revised to include a statement clarifying this and that
any accesses to existing open spaces would need to
be determined through future detailed design in
consultation with local residents.

Vision

Agree Objective 4 (consolidate) states that new

development should safeguard nearby amenity
assets such as Wormwood Scrubs and the Grand
Union Canal, but this wording will be strengthened to
reference sensitive enhancements to amenity
assets.

61

Page 270

Organisation

Comment

Theme

Response

LBE

Box L2: the sentence beginning There will be

opportunitiesQ should have one repetition of where
possible deleted.

Land use

Agree. Change to be made

LBB

10.45, page 124 The measures proposed to secure

employment opportunities for local people, both during and
post contraction is welcomed. This is a key priority for Brent
Council. There is an opportunity to engage with local
colleges, including the College of North West London which
provides construction and building services training.

Land use

Noted. The GLA understands that the OPDC is

committed to working with local education providers
to help delivery training and employment
opportunities.

LBB

Figure 10, page 23 Employment uses have been omitted

from the key.

Land use

Noted. Error to be corrected

62

LBB

5.3, page 32 It is noted London Plan policies on levels of

affordable housing will apply. Brent has one of the most
acute set of housing needs in the whole of London. It is
essential that Old Oak plays its part in meeting this housing
need and the council expects a full range of genuinely
affordable housing product within the new developments and
for Brent to have significant nomination rights into the
scheme. The Council expects the Local Plan to set policies to
secure an appropriate housing mix in terms of affordable,
tenures and size.
It must be ensured Old Oak High Street complements
Harlesden town centre, and is not detrimental to its viability. It
is therefore essential the quantum of retail floorspace is
identified through a Retail Needs Study which takes into
account existing levels of provision. Reference to
comparable developments, such as Vauxhall Nine Elms
which includes 60,000sqm of retail floorspace, prejudges the
outcome of the Retail Needs Study and should be removed.
Vauxhall Nine Elms does not adjoin a district centre and is
therefore not a relevant comparison.

Land use

LBE

The emphasis at para 5.12 on the local nature of retail at Old

Oak is welcomed. Development resulting from the OAPF
should not result in changes of the retail hierarchy in West
London or impact on the development of neighbouring town
centres. Measures should be taken to control the size of
units and in particular restrict the development of comparison
retail.

Land use

LBB

Land use

Noted. OPDC's Local Plan would include a suite of

policies on housing dealing with affordability, size,
mix and tenure. Any approach to affordable housing
would need to be agreed by OPDC Board, which
has representatives from the three local authorities.

Page 271

Agree. The GLA understands that OPDC has

commissioned a Retail and Leisure Needs Study
and that the London Boroughs of Brent, Ealing,
Hammersmith and Fulham and Royal Borough of
Kensington and Chelsea have been invited to
steering group meetings. The table on page 35 will
be removed.
Noted. The GLA understands that OPDC has
commissioned a Retail and Leisure Needs Study
and that the London Boroughs of Brent, Ealing,
Hammersmith and Fulham and Royal Borough of
Kensington and Chelsea have been invited to
steering group meetings. As per para 5.12 of the
OAPF, the study is seeking to identify the proportion
of retail required to cater for the day to day needs of
development and not impact negatively on nearby
retail centres. The study is also looking into the split
between convenience and comparison retail and will
be making recommendations on unit sizes.

63

LBB

5.11, Page 35 As stated in the OAPF it must be ensured

retail development complements existing centres such as
Harlesden, and is not detrimental to its viability. It is therefore
essential the quantum of retail floorspace is identified through
a Retail Needs Study which takes into account existing levels
of provision. The inclusion of a table with comparable
developments and the quantum of retail proposed prejudges
the outcome of the Retail Needs Study and should be
removed. Old Oak is bounded by Harlesden District Centre
and is in close proximity to the Wembley Opportunity Area
and Shepherds Bush Metropolitan Centre. In contrast there
are no district, major or metropolitan centres in close
proximity to Vauxhall Nine Elms, therefore in this context
there is a need for significant retail floorspace. This
development is therefore not comparable due to its very
different context.

Land use

LBB

Figure 39, page 56 Figure 39 indicates the majority of Old

Oak High Street, which is approximately 1.5km long, would
be in active commercial use. It is questioned if this is viable,
as without a significant draw the town centre will primarily
serve residents, employees and commuters. Proposals for
Old Oak High Street need to be refined once a Retail Needs
Study and viability testing has been undertaken. It may be
more realistic to focus town centre uses in frontage adjoining
the station.

Land use

Page 272

LBB

5.10 page 34 Whilst recognition of the relationship of

proposed new retail floorspace to Harlesden Town Centre is
welcomed, greater emphasis should be placed in the OAPF
on the need for good connections and complementary role by
changing the last sentence in the 2nd bullet point to Retail
near to Willesden Junction should must also connect in to
retail provision in Harlesden Town Centre and complement
its offer.

Land use

Agree. The suggestion changes the emphasis from

'should' to 'must'. This change will be made as the
GLA recognises that it is imperative that retail
around Willesden Junction connects in with retail in
Agree. The development of a significant amount of
new homes with a large new residential population
and employees could bring significant benefits to the
existing surrounding centres. To ensure this it is
vitality important that good quality connections are
achieved between this site and its surrounding
areas.
The GLA understands that OPDC has
commissioned a Retail and Leisure Needs Study
and that the London Boroughs of Brent, Ealing,
Hammersmith and Fulham and Royal Borough of
Kensington and Chelsea have been invited to
steering group meetings. The table on page 35 will
be removed from the OAPF to avoid comparisons
with other Opportunity Areas where retail provision
might have exceeded that of the day to day needs of
the development.
Noted. The GLA understands that OPDC has
commissioned a Retail and Leisure Needs Study
and that the London Boroughs of Brent, Ealing,
Hammersmith and Fulham and Royal Borough of
Kensington and Chelsea have been invited to
steering group meetings. As per para 5.12 of the
OAPF, the study is seeking to identify the proportion
of retail required to cater for the day to day needs of
development and not impact negatively on nearby
retail centres. Active frontages in the OAPF are not
limited to retail and also cover leisure, general

64

employment uses, social infrastructure and transport

uses.

Page 273

LBB

LBE

Grand Union Canal, page 62 63 This figure indicates a

significant quantum of active frontage along the canal. It is
questioned if this is viable, particularly given the scale of
commercial development proposed along Old Oak High
Street. There are numerous examples of waterfront schemes
in London where such commercial units have remained
vacant. To ensure this is not the case at Old Oak the
quantum needs to be informed by market testing. It may be
more appropriate to focus such active uses along sections of
the canal adjacent Old Oak Station which will benefit from a
higher level of footfall.
There is little attempt to address the proposals that have
been made for a stadium on the site despite the very public
nature of QPRs recent proposals. It is understood that this
specific proposal may have gone quiet or even fallen through
but the OAPF is dangerously vague on how a stadium
application would be treated and does not acknowledge the
knock-on effects that it will have. The Key Objectives for Old
Oak North and para 5.34 of the supporting text both mention
the desirability of a stadium as a catalyst use, however the
land take is not understood as having much of an impact on
the rest of the proposed development scheme. Amenity
space is already scarce in Old Oak and would be significantly
reduced by a stadium, limiting the development potential of
the site as a whole. It is important that the OAPF is clear
about this reduction in development capacity both to secure
high quality development and to make explicit to potential

Land use

Noted. The GLA understands that OPDC has

commissioned a Retail and Leisure Needs Study
and that the London Boroughs of Brent, Ealing,
Hammersmith and Fulham and Royal Borough of
Kensington and Chelsea have been invited to
steering group meetings. As per para 5.12 of the
OAPF, the study is seeking to identify the proportion
of retail required to cater for the day to day needs of
development and not impact negatively on nearby
retail centres. Active frontages in the OAPF are not
limited to retail and also cover leisure, general
employment uses, social infrastructure and transport
uses.

Land use

Noted. Para 5.15 specifically references the QPR

proposals, whilst 5.14 deals with the potential for
large-scale uses, such as football stadiums, to act as
catalysts for regeneration. Text will however be
added to para 5.14 clarifying that any provision of
catalyst uses should not be at the expense of
meeting the London Plan's homes and jobs targets
for the area and should not be at the expense of the
provision of other necessary infrastructure to support
development such as public open space.

65

applicants the costs of this type of development.

Land use

LBHF

Landownership Map needs to sit in this section or early on

in the main body of the document.

Land use

Agree. The land ownership map will be included in

the introduction chapter.

Page 274
LBB

Figure 20, page 37 Reference is included to the potential for

a variety of large scale uses, such as a football stadium. The
illustrative masterplan does not allow for a use of such a
scale. If such a proposal did come forward there would be
significant implications for the provision of open space,
employment levels and the form and function on the route
network. This would render the illustrative masterplan and
much of the OAPF unworkable. Further masterplanning work
is needed to provide adequate guidance should such a
scheme come forward.

Noted. Text will be added to para 5.14 clarifying that

any provision of catalyst uses should not be at the
expense of meeting the London Plan's homes and
jobs targets for the area and should not be at the
expense of the provision of other necessary
infrastructure to support development such as public
open space. The masterplan in the OAPF is for
indicative purposes only. Many forms of
development could come forward that may be
considered acceptable but it is not appropriate for
the OAPF to illustrate each and every permutation.
Any application proposing a large scale catalyst use
would be assessed on its individual merit, in
accordance with the Development Plan and this
OAPF.

66

Page 275

LBHF

Para. 3.3 should refer to Figure 9 not Figure 6.

Land use

Agree. Change to be made

LBHF

P. 21, Figure 9 explain HF2, E9 etc. in key.

Land use

Agree. Change to be made

LBHF

P. 22, L3: Wormwood Scrubs - whilst this council welcomes

the statement that the Wormwood Scrubs Charitable Trust
will be involved in agreeing changes, it considers that
Hammersmith and Fulham Council should also be
specifically mentioned. Wormwood Scrubs is a West London
resource and many borough activities are carried out there.
This is also a Duty to Cooperate issue as it relates to
infrastructure which affects more than one authority.

Land use

Agree. Change to be made

Land use

Agree. Principle L1 on page 22 clarifies the

approach to regeneration catalysts and further
guidance is provided on this at paras 5.14 and 5.15
of the OAPF. This further guidance on catalyst uses
will be flagged in this section

LBHF

P.23, Figure 10 expand on potential for catalyst - explain

why this is considered a catalyst.

67

Page 276

LBHF

Figure 10 - Dotted red line around Kensal OA needs

explanation in the key.

Land use

Agree. Change to be made

LBHF

P.32, i. The Vision document stated up to 24,000

homes how is this justified and how can this be delivered
over the 20/30 year life of the plan? Suggest that this is
amended to less prescriptive and to read around or
estimated at 24,000 new homes.

Land use

Disagree. The London Plan annex A states that

homes targets are minimum targets.

Land use

Agree. Change to be made

Land use

Noted. The GLA concurs that OPDC under the Duty

to Cooperate should engage with local authorities on
housing matters but does not consider that the
OAPF should be required to reference this. The
OAPF will however, reference that any OPDC
affordable housing policy and evidence base would
need to accord with national and regional policy

LBHF

LBHF

P.32 OOA1 point a. Amend to read Proposals should

contribute towards the comprehensive regeneration of the
Old Oak Area to help deliver:Q..
Para. 5.1 - 5.3. The Mayor will appreciate that planning for
housing is a strategic matter and subject to the Duty to
Cooperate. Under this Duty councils should engage
constructively, actively and on an on-going basis in
maximising the effectiveness of Local Plans relating to
Strategic matters which may impact on at least two
planning areas. Confirmation of how National Planning Policy
Framework and National Planning Policy Guidance
requirements on housing will be met by the MDC would be
helpful, especially with regard to housing issues such as
affordability it would assist both the MDC and other

68

boroughs in ensuring requirements relating to the Duty to

Cooperate and to objectively assessed need are met.

Page 277

LBHF

LBHF

Para.5.2 should make clear that new high quality housing

should be designed to meet the needs of London residents
and not overseas investors who may leave new housing
unoccupied for long periods.
Para. 5.3 - the document states that The Local Plan would
also set a level of affordable housing for this area. This
required level of affordable housing will need to take account
of the level of physical and social infrastructure needed to
support this level of development. The council considers that
this sentence gives the wrong emphasis affordable housing
provision should be based on need, and the social
infrastructure should be provided to meet this need. The
amount of affordable housing should not be predicated on
the level of physical and social infrastructure in the area. The
council wishes to be fully engaged in objectively assessing
housing need.

Land use

Agree. The OAPF will be amended to encourage

developers to sign up to the Mayoral Concordat to
market homes first, or first equal, to Londoners.

Land use

Agree. Affordable housing should be based on need

and viability. The OAPF will clarify that need is also
a factor in setting an affordable housing target.

69

Page 278

LBHF

As with Figure 6 (see above comments), Figure 18,

although intended to be general, gives too much
geographical emphasis to town centre uses. The council
considers that any new centre in this area should fit in with
the surrounding town centre hierarchy. There should not be a
new megasized town centre. The figure implies that 1/3 of
the Old Oak Common area (excluding Wormwood Scrubs)
will be in town centre uses. The draft OAPF says itself that
Town centre uses should be located close to areas with the
greatest pedestrian flows and accessibility namely around
public transport hubs and along main streets therefore
these uses should not be shown spread out over 1/3 of the
area.

LBHF

Para. 5.11 - The council notes that the document states in

that The future level of retail will be assessed in greater
detail through a Retail Needs Study that would be
undertaken as part of a future Local Plan by the proposed
Old Oak and Park Royal Mayoral Development Corporation
(OPDC). Under the Duty to Cooperate this council would
wish to be fully involved in all aspects of this study.

LBHF

P.34, para 5.1 refers to comparable this should refer to

other opportunity areas rather than the term comparable
unless you can explain why they are directly comparable

Land use

Agree. The area shown on each figure as 'focus for

town centres' is drawn flexibly to allow for different
alignments of the High Street. This approach is
clarified in the Old Oak High Street Place. Para 5.12
of the OAPF clarifies that retail provision should
cater for the day to day needs of development and
not negatively impact on nearby retail centres.
However, the GLA agrees that this could currently
be misinterpreted and the area shown as being
appropriate for town centre uses will be revised and
made smaller.

Land use

Noted. The GLA understands that OPDC has

commissioned a Retail and Leisure Needs Study
and that the London Boroughs of Brent, Ealing,
Hammersmith and Fulham and Royal Borough of
Kensington and Chelsea have been invited to
steering group meetings

Land use

Agree. The table on page 35 will be removed from

the OAPF to avoid comparisons with other
Opportunity Areas where retail provision might have
exceeded that of the day to day needs of the
development.

70

Page 279

LBHF

P.35, Table - add Old Oak at the top so you clearly see the
difference against the other opportunity areas

Land use

Agree. The table will be removed from the OAPF.

LBHF

P.35, Table how are they comparable to Old Oak when

VNEB is in CAZ?

Land use

Agree. The table will be removed from the OAPF.

Organisation

Comment

Theme

Response
Noted. The GLA considers that the guidance stated
within the OAPF reflects the Vision and Objectives.
However, further emphasis will be provided to aid
clarity and reference will be made to policy 7.7
setting out a commitment to exemplary architecture
and design made. The GLA will also clarify this
guidance and publish background information
utilised to support the approach.

LBB

Although it is an objective to secure best practice in

architecture and urban design this is not reflected in the
OAPF.

The GLA understands that the OPDC will be

establishing its own Place Review Group to ensure
design and broader placemaking excellence is
achieved.
Design

71

Disagree. The GLA considers that the content of the

draft OAPF to be high-quality with the extent and
level of guidance provided being appropriate to the
document's status as Supplementary Planning
Guidance providing supplementary detail to the
planning policies contained within the London Plan.

Page 280

Disagree. The GLA acknowledges that the

regeneration of Old Oak presents a number of
challenges with the central aim of the OPDC to
address these. The GLA considers that both the
London Plan and OAPF provide guidance to delivery
a high quality environment within Old Oak.
Specifically, the GLA considers that the delivery of
public open space to be central to creation of
sustainable communities and a successful new
urban neighbourhood. The OAPF sets out the
principles for delivering new open spaces which are
appropriate to the role of an OAPF. The OAPF also
sets out the principles for building heights and
densities to meet the minimum targets set out in the
London Plan to deliver a high quality urban
neighbourhood. Both these elements will be integral
components of the forthcoming OPDC Local Plan.

LBE

Notwithstanding the outline nature of OAPF guidance, the

draft OAPF seems to be both flawed and limited in its
prescriptions for the main development sites at Old Oak
Common. Old Oak is a highly constrained location for
development and the main effect of this has been to limit
public and open space and drive up building heights. As it
stands, development proposed by the draft OAPF is not
considered to offer the quality of environment necessary on
such an important site.

The GLA understands that the OPDC will be

establishing its own Place Review Group to ensure
design and broader placemaking excellence is
achieved.

Design

72

LBB

LBB

Page 281
LBB

LBB

The route layout in the illustrative masterplan creates

triangular blocks. These are inefficient and can limit the type
of development. Has consideration been given to the
feasibility of building over the railway tracks? Alternatively
the layout of the street network, in particular Old Oak High
Street, should be looked at again to ensure efficient use of
space.
Figure 23, page 38 This figure would benefit from labelling to
give it context.

Design Chapter, Page 36 44 It is an objective of the

Development Corporation to ensure world class architecture,
place making and urban design. This objective is not
reflected in the OAPF. There is little emphasis on design
quality and placemaking. The relatively self-contained nature
of Old Oak core area provides a unique opportunity to create
a new sustainable high quality place which is an exemplar for
future development in London. As a starting point the design
strategy should set out how world class architecture will be
achieved and the mechanisms and innovative approaches
which will be put in place to require developers to achieve the
highest design quality.
Figure 24 and 25, page 41 These illustrative cross sections
need to correspond to a plan view with the cross sections
labelled on them.

Noted. The draft OAPF illustrative masterplan

depicts indicative development plots framing
movement routes, based on accessibility to public
transport, with development proposals expected to
demonstrate how development of sites are optimised
in accordance with London Plan policy 2.13(B)(b).
Design
Noted. Appropriate references to the comparisons
will be made in OO2.
Design
Noted. The GLA considers that the guidance stated
within the OAPF reflects the Vision and Objectives.
However, further emphasis will be provided to aid
clarity and reference will be made to policy 7.7
setting out a commitment to exemplary architecture
and design made. The GLA will also clarify this
guidance and publish background information
utilised to support the approach.
The GLA understands that the OPDC will be
establishing its own Place Review Group to ensure
design and broader placemaking excellence is
achieved.
Design

Design

Disagree. The GLA considers figures 24 and 25 to

provide sufficient detail to illustrate OO3. To ensure
clarity with regard to design of the high street, figure
25 will be removed.
Agree. Further labelling will be provided.

LBB

Figure 13, page 26 It is not clear what this figure is

illustrating.

Design

73

Disagree. The GLA considers that the Design

Strategy has been informed by an analysis of the
existing context, as set out in Appendix 3 Contextual Analysis, appropriate to the role of an
OAPF.

The design chapter is not informed by an analysis of the

existing context and places little emphasis on design quality
and placemaking.

LBB

However, the GLA will clarify how this process has

informed the development of the Strategy and will
publish background information utilised to support
the approach.
Design
Agree. Amendments will be made to figure 28
clarifying the indicative boundary of the Old Oak
South place.

Page 282

LBE

It is noted that the boundaries of the Old Oak South area

appear to run across those of the sub areas in the current
scheme of delegation between Ealing and the OPDC. It is
suggested that the Old Oak sub area is expanded to include
the land immediately north of the Central Line at North Action
so that the delegation sub areas match the character sub
areas set out in the OAPF.

Design

LBHF

P.28, D5 Place making section needs to recognise existing

communities on the edge of Old Oak, e.g. College Park, and
the impact that the new development will have on these
communities and ensure that these areas are enhanced and
a sense of place fostered.

Design

Agree. Paragraph 4.5 will be amended with

reference made to existing neighbourhoods.

LBHF

P.26, Figure 12 what do the green lines on the edge of

buildings represent and what do the green lines in the street
represent?

Design

Noted. A key will be provided illustrating the potential

for building and street greening.

LBHF

Diagram 15 and Diagram 13 should sit next to each other

on the same page to make sense.

Design

Agree. Change to be made

LBHF

P.28, D5: Place making: Retitle Places

Design

Disagree. The GLA considers the title to be

appropriate.

LBHF

P.29, Figure 16- Labelling the map is probably more helpful

then having a key

Design

Noted.

74

Design

Noted. Development will be required to accord with

D3, OO4 and London Plan policy 7.7.

LBHF

The successful transition at the edges would help in

assimilating the new scheme into the wider area. The new
development would have a greater potential to be seen as a
new part of the existing wider townscape context, rather than
one that has been imposed on the area. The form, scale and
grain of the local townscape should be taken across this
area, to achieve a more comfortable transition at the edge.
This would confine the impact of the proposed grander scale
beyond towards the centre of the site, to mid and long
distance views, leaving the local townscape relatively
unharmed.

Design

Noted. Development will be required to accord with

D3, OO4 and London Plan policy 7.7.

LBHF

P.37, Figure 20- the dotted lines around white colour areas
next to HS2 station need to be explained in key.

Design

Agree. Change to be made.

LBHF

P. 41, figure 24: Illustration showing High Street cross

section These figures are too prescriptive and dont allow
for flexibility and should be removed.

Design

Disagree. The GLA considers Figure 24 to provide

useful illustration of implementing existing and
emerging street design guidance.

LBHF

Figure 25: Illustration showing indicative eastern elevation

of Old Oak High Street This figure is not a fair reflection of
the site as its shown at the widest point and does not show
topography/ level changes. This cross section indicates
massing that has not been tested.

Design

Agree. Figure 25 will be removed

LBHF

P.42, Para.5.23 state that This guidance presents the

current positionQ what is the current position based on?

Design

Noted. The current position refers to the draft OAPF.

Page 283

LBHF

The aim of developing a sense of place at Old Oak is

supported. Making a meaningful place which connects to the
surrounding townscape will be one of the main challenges. In
this respect, it is important that the new development has a
dialogue with the surroundings, particularly at the edges, and
that the scale and form of the adjoining townscape is taken
into the site, rather than the new scale of the wider
redevelopment brought to the edges.

75

Page 284

LBHF

Consultation questions Q5 This is a leading question and

also fails to ask a question about building heights and
densities.

Design

Noted.

LBHF

P.43, Figure 26 add word Harlesden next to station

logos. The figure is titled Building Heights and densities but
doesnt show heights. Retitle as sensitivities.

Design

Agree. Change to be made and Harlesden will be

added to figure. Figure title will be altered.

LBHF

Q6 - Yes - View from Scrubs near northern edge looking

north at the station site

Design

Noted. This suggestion will be used to inform further

the OPDC Heritage and Local Views Study
supporting the forthcoming Local Plan

Design

Disagree. The location of views provides appropriate

guidance for an OAPF. Further detailed work will be
undertaken for the OPDC Heritage and Local Views
Study supporting the forthcoming Local Plan.

LBHF

P. 44, figure 27: Local views these should show the

direction of the view.

76

Page 285

LBHF

P.44, d after ground level activities add taking into

account daylight, sunlight and overshadowing issues.

Design

Agree. Changes to be made.

Organisation

Comment

Theme

LBB

Reference to improved links to Harlesden is welcomed. It is

crucial that links to the town centre are strengthened to
enable businesses and residents to benefit from the
regeneration of Old Oak.

Response
Noted.

Connections

LBE

In the context of these linked concerns about the strategy for

Old Oak and Park Royal Ealing considers it is particularly
important that the OAPF;
- Gives a clear indication of the particularly constrained
nature of Old Oak, which is entirely cut off both from its
surroundings and the rest of the OAPF area, and
acknowledges particular challenges that this creates for the
new community.

LBE

The conception of Grand Union Street as a strong,

continuous route through Old Oak is welcomed but this also
serves to highlight the limited success in overcoming
severance between the development area and its
surroundings. Old Oak remains bisected and entirely
circumscribed by railway lines and it is notable that no use of
decking is proposed in the OAPF to overcome this constraint
at key points. Decking is far from a universal solution but the
lack of amenity space at Old Oak and the excess of railway
lines suggest it is worth active consideration. Work
commissioned by Ealing found that decking at North Acton
could be economic while at the same time funding the
improvement of the underground station, and it is noted that
White City OAPF also incorporates decking as part of the
urban design strategy.

Noted. This information is provided within the

Delivery Strategy and Appendix 3.

Connections
Disagree. The GLA acknowledges that the
regeneration of Old Oak presents a number of
challenges with the central aim of the OPDC to
address these. Part of this will be to consider at a
greater level of detail how connectivity can be
improved. In some places this may include bridges
or decking over rail tracks and rail infrastructure
where this is practical and viable. The OAPF does
not preclude the use of decks if shown to achieve a
successful solution. The GLA and TfL are currently
petitioning HS2 to secure suitable works are
installed as part of the construction of the HS2
station and track to enable Over Station
Development.
Connections

77

LBE

Ealing is pleased that its continued success in securing

regeneration in this area is acknowledged by the delegation
of applications back to the Borough. The Old Oak
development and particularly the improved connectivity that
will result from the proposed Overground station offer
considerable opportunities to continue this growth.
Development here has been generally organic, working with
the established grain of the streets and emphasising small
floor plates that increase permeability. The gyratory road
layout in this area is a longstanding constraint in improving
circulation and the pedestrian environment and Ealing is
currently working with TfL to explore less disruptive
alternatives.

Noted.

Connections
Noted. This is depicted in Figures 20 and 23.

Page 286

LBB

To fully integrate these plots into the surrounding area a

vehicular access is needed from Harrow Road to Willesden
Junction. There is also an opportunity to link the premises to
the pedestrian and cycle network with a link via Clifton Road.

Connections
Noted.

LBB

Station Road is the most direct access from Old Oak to

Harlesden Town Centre. To ensure links to Harlesden are
enhanced it is crucial Willesden Junction station is orientated
to front Station Road and promote onward links to Harlesden.

LBB

The form of route from Willesden Junction to Harrow Road

needs to be shown, as this is not an existing link.

LBB

Old Oak North, Figure 29 As with figure 34 should include

arrows indicating links to surrounding area including
Harlesden Town Centre.

Connections
Connections

Disagree. This is identified as a secondary street in

figures 20 and 23 with guidance stated in OO3
Agree. Amendment to be made

Connections

78

LBB

5.34, page 50 This paragraph states non-residential uses

could connect into Harlesden Town Centre. It is crucial links
to the centre are strengthened to enable businesses and
residents to benefit from the regeneration. To accord with the
OAPF vision to benefit Harlesden non-residential uses must
connect to Harlesden Town Centre. Emphasis should also be
placed on improving connections through enhancements to
signage and public realm, alongside redevelopment of
Willesden Junction station.

Agree. Stronger wording to be provided to support

the connection to Harlesden Town Centre

Connections
Agree. Amendment to be made

LBB

Figure 40, page 57 This figure should include arrows

indicating links north to Harlesden Town Centre.
This figure omits a proposed north-south connection across
the canal shown in the previous Park Royal OAPF figure 26.

LBB

Scrubs Lane, Figure 45, page 64-65 As commented in

relation to Old Oak North it is unclear how the development
fronting Scrubs Lane will be accessed and serviced. Further
work is required to establish how these plots will connect to
the wider route network.

LBB

Page 287

LBB

The current Park Royal OAPF includes a plan of existing and

proposed strategic routes and connections across Park
Royal. This is a useful diagram which provides clarity to
developers. PR2 only includes reference to the introduction
of pedestrian and cycling routes along main roads and the
Grand Union Canal. This is a reduction in routes when
compared to the current OAPF, and would result in reduced
permeability across Park Royal. If a modal shift is to be
achieved which takes pressure off the existing road network,
it is crucial pedestrian and cycle connections to existing
stations are improved. Figure 26 from the current Park Royal
OAPF should therefore be updated and included in this
chapter, and connections sought on this basis.

Connections
Agree. Amendment to be made
Connections
Noted. The GLA considers the level of guidance
provided to be appropriate to an OAPF.

Connections
Agree: The Park Royal Transport Study will consider
the need for connections and will use information
from the Park Royal OAPF as one of the base
documents to inform this.

Connections

79

LBB

In addition links to Wormwood Scrubs are limited to one

access point. A further access point is required for residents
living to the east.
Appendix 2, page 8 Diagram showing movement north-south
and view of station omitted.

Connections

Organisation

Comment

Theme

LBB

Furthermore, from the illustrative masterplan it appears much

of Old Oak will be deficient in green space when assessed
against benchmarks in the London Plan. Given the density of
development proposed it is crucial sufficient amenity space is
secured to provide opportunities for recreation.

Public realm/open
space

LBB

Page 288

LBE

LBB
LBB
LBB

There are serious concerns over the quality of public and

open spaces at Old Oak and the effects that this will have on
quality of life for future residents. This site is unusually
constrained and isolated by road and railway infrastructure
and it is essential that it properly connects and integrates
with its complex surroundings.
Figure 20, page 37 The public civic space shown on the
figure adjacent Willesden Junction is unclear as it is
obscured by text.
From the shading it is not clear if the space in front of
Willesden Junction station is civic or green amenity space.
Para 4.1, page 26 An explanation is needed of what is meant
by green grid. Text should cross-reference figure 14.

Connections

Noted. This suggestion will be used to inform future

work being undertaken by the OPDC with regard to
Wormwood Scrubs.
Agree. Amendments to be made.

Public realm/open
space

Response
Noted. The GLA considers that the delivery of public
open space to be central to creation of sustainable
communities and a successful new urban
neighbourhood. The OAPF sets out the principles for
delivering new open spaces which are broadly
appropriate to the level of development and the role
of an OAPF. The GLA understands that the OPDC
will be developing an Open Space Strategy to
support the quantity and quality of open space to be
provided by development within the Local Plan.
Noted. The GLA considers that the delivery of public
open space to be central to creation of sustainable
communities and a successful new urban
neighbourhood. The OAPF sets out the principles for
delivering new open spaces which are broadly
appropriate to the level of development and the role
of an OAPF. The GLA understands that the OPDC
will be developing an Open Space Strategy to
support the quantity and quality of open space to be
provided by development within the Local Plan.
Noted. Amendment to be made

Public realm/open
space
Public realm/open
space
Public realm/open
space

Noted. Amendment to be made

Noted. Definition to be provided with cross
reference.

80

Noted. The Green Grid in Figure 14 is intended to be

indicative and will be amended to depict this. The
GLA understands that the OPDC will be developing
an Open Space Strategy and evidence base relating
to biodiversity to inform the detailed design and
implementation of the green grid.

Figure 14, page 27 The proposed green grid appears to

follow the line of the highway network. It is unclear how such
a route could make a significant contribution to green
infrastructure. The green grid should be based on an
assessment of existing biodiversity including Sites of
Importance for Nature Conservation and Wildlife Corridors,
and be developed with a view to enhancing these existing
links. It would be more appropriate for the canal, along which
improved green space is proposed, forms part of a green
grid.

Page 289

LBB

The extension of a green grid from Willesden Junction to

Harlesden Town Centre via Station Road is supported. There
is an opportunity to build on existing tree planting to further
enhance this as a green link.

LBE

Old Oak Common itself is clearly the hub of the OAPF area,
and one of the most promising development sites in London
given the prominence of the HS2 Station within the city and
the UK as a whole. Unfortunately the quality of the urban
realm that is proposed here does not seem to equal this
status, and there are concerns that development quanta are
driving design and layout to the detriment of this future
community.

LBHF

P.26 D1: Public Amenity add point that Proposals should

be designed to address ongoing maintenance and have no
revenue implications on the local authority.

Public realm/open
space
Noted. The GLA considers that both the London
Plan and OAPF provide guidance to deliver a high
quality environment that accords with Lifetime
Neighbourhoods that supports the delivery of the
London Plan housing and employment targets. To
ensure this aspiration is clarified, further information
will be provided within the design strategy.
Public realm/open
space

Public realm/open
space

Noted. The management and maintenance of future

amenity spaces will need to be carefully considered
and planned. Within current budget constraints, it is
recognised that additional costs to local authorities
will be a challenge. Any decisions regarded revenue
and maintenance of infrastructure in Old Oak and
Park Royal would need to be discussed and agreed
by OPDC Board. Further work on this will be carried
out as part of a Public Realm Strategy.

81

Public realm/open
space

Noted. Reference to be made.

LBHF

P.26, Streets and Public Realm add point to address point

that Proposals should be designed to address ongoing
maintenance and have no revenue implications on the local
authority.

Public realm/open
space

Noted. The management and maintenance of streets

and public realm will need to be carefully considered
and planned. Within current budget constraints, it is
recognised that additional costs to local authorities
will be a challenge. Any decisions regarded revenue
and maintenance of infrastructure in Old Oak and
Park Royal would need to be discussed and agreed
by OPDC Board. Further work on this will be carried
out as part of a Public Realm Strategy.

LBHF

Figure 14: The green grid: difficult to read the existing

connections.

Public realm/open
space

Agree. Will be removed from key

LBHF

Figure 14: key shows new and existing amenity spaces. St

Marys Cemetery is not defined as an existing amenity space
and the plan needs to be amended.

Public realm/open
space

Noted. Image will be clarified defining St. Mary's

Cemetery as a public amenity space.

Public realm/open
space

Disagree. To aid clarity, reference will be made to

London Plan Table 7.2 Public open space
categorisation and relevant Green Grid SPG
guidance.

LBHF

P.26 D1: Public Amenity iv) : refer to Grand Union Canal

Page 290

LBHF

P.38, table set out the size of the spaces required.

LBHF

P.38, 002: Public Amenity Space - There is inadequate

recognition of the Nature Conservation Area of Metropolitan
Importance designation along the Grand Union Canal and
the potential impact of greater recreational use on this nature
conservation area. This table needs to set out size of space
required and the guidance/ standards which need to be
applied to provision of the space.

Public realm/open
space

To aid clarity to OO2, reference will be made to

London Plan Table 7.2 Public open space
categorisation and relevant Green Grid SPG
guidance.

LBHF

P.38 and 39- reference to station squares in table on

page 38 but key in Figure 23 page 29 refers to public civic
spaces.

Public realm/open
space

Agree. Changes to be made.

LBHF

P.38, c) - add but will explore opportunities for appropriate

greeningQ after the words hard landscaping

Public realm/open
space

Agree. Changes to be made.

Noted. Reference will be made to the biodiversity

value of the Grand Union Canal within the
supporting text of E5: Green infrastructure.

82

LBHF

P. 40, table 003: Streets and Public Realm a. Old Oak

High Street and Old Oak Common Station.
o Setting a 25m width will encourage developers to push for
inappropriate heights along the High Street. Proper
consideration has not been given to how this one street width
will impact on the way other streets will look across the rest
the development.
o Whilst the TfL and other guidance to support the 25m is
given and considered by GLA officers to be evidence - it is
not. It is guidance which can be applied as good practice but
here it needs to be considered in relation to the wider
comprehensive development of this specific site. LBHF
officers suggest taking out this figure and completing urban
design studies required to support the Local Plan before
including a figure for width or height in the OAPF.
o It would be helpful to show the streets(described in text in
the table) on a plan

Public realm/open
space

Organisation

Comment

Theme

LBB

In places the guidance is contradictory; for example,

Willesden Junction station is bounded by sensitive areas,
where the guidance states lower heights will be appropriate,
but it is also identified as appropriate for higher elements due
to its accessibility.

Building heights

Page 291

LBHF

P.29 Figure 23 need to show station square/ public civic

space to the north of the Hythe Road station (as well as the
south side).

Public realm/open
space

Agree. Changes to be made.

Agree. The GLA considers that the guidance stated

in OO3(a) envisaging the High Street to be
'approximately 25 metres with opportunities for
variation responding to functions and built form'
provides a useful approximation for the
implementation of existing and emerging street
design guidance. However, to enable appropriate
flexibility in the delivery of the High Street and
adjacent buildings and spaces over the lifetime of
the plan, reference to 25m in OO3(a) will be
removed alongside guidance for Old Oak High
Street.
Disagree. The GLA considers Figure 24 to provide
useful illustration of implementing existing and
emerging street design guidance.

Response
Agree. The GLA will clarify this guidance and publish
background information utilised to support the
approach.

83

LBB

London Plan policy 7.7 states tall and large buildings should
generally be limited to centres that have good access to
public transport; however, this is just one aspect of the policy
to be considered. It needs to be made clear that building
heights around Willesden Junction should be informed by a
detailed analysis of the surrounding context, in particular the
impact on the two storey town houses to the north. In
accordance with London Plan policy tall buildings should be
required to achieve the highest standards of architecture.

Agree. Although the OAPF does not seek to repeat

guidance within the London Plan, reference will be
made to policy 7.7. The GLA will also clarify this
guidance and publish background information
utilised to support the approach.

Building heights
Disagree. The GLA considers the guidance set out
in the OAPF for potential locations for taller buildings
OO4 is appropriate in responding to access to public
transport and meeting the London Plan housing
target for Old Oak.

Page 292
LBE

Old Oak is also constrained by its surroundings with almost

every edge of the development being acknowledged as
sensitive by the sub area diagrams and the masterplan on
p43. This seems to have driven a strategy of crowding taller
elements toward the centre of the site focussing on the HS2
Station and Old Oak High Street to compensate for the
development lost at the edges. Unfortunately this strategy
makes a transition between the heights at the centre of the
site and its edges even more difficult to accomplish, and
there are considerable concerns about the treatment of
development adjacent to existing residential enclaves at
Wells House Road and Old Oak Lane.

Noted. The OAPF will continue to provide guidance

requiring development to respond to sensitive
locations and responding to destinations, including
stations and the High Street. The GLA will further
clarify this guidance and publish background
information to support the approach.
Further guidance setting out how development
should respond to existing residential communities
will be set out in the Local Plan and further
supplementary guidance if required.

Building heights

84

LBB

OO4, page 42 Willesden Junction is bounded to its north and

west by sensitive areas, where the guidance states lower
heights will be appropriate, but it is also identified as
appropriate for higher elements due to its accessibility. This
is contradictory and in practice it is unclear which guidance
will take precedence.

Agree. The GLA will clarify this guidance and publish

background information to support the approach.

Building Heights
Agree. Although the OAPF does not seek to repeat
guidance within the London Plan, reference will be
made to policy 7.7 and a commitment to exemplary
architecture and design made. The GLA will also
clarify this guidance and publish background
information utilised to support the approach.

Building Heights

LBB

It is unclear what is meant by longer term views in OO4, part

c. If this is the views identified in figure 27 this needs to be
made clear.

Building Heights

Page 293
LBB

London Plan policy 7.7 states tall and large buildings should
generally be limited to centres that have good access to
public transport; however, this is just one aspect to be
considered. It needs to be made clear in OO4 that building
heights at Willesden Junction should be informed by the
surrounding context, in particular the impact on the two
storey town houses to the north. In accordance with London
Plan policy 7.7 it should state tall buildings are to incorporate
the highest standards of architecture and materials and
should not affect their surroundings adversely in terms of
microclimate, overshadowing, noise and reflected glare. Tall
buildings are only to be considered in areas whose character
would not be affected adversely by the scale, mass or bulk of
a tall building. The SPG is to supplement the London Plan,
and accordingly OO4 should reflect the criteria in London
Plan policy 7.7 and acknowledge appropriate heights cannot
be determined until a thorough design exercise is
undertaken.
OO4 should cross reference policy D3 on building heights
and densities.

LBB

Building Heights
Agree. The supporting text for OO4 will reference
D3.
Noted. OO4(c) will be amended to state "longer
distance views"

85

Page 294

LBB

Para 5.25, page 42 The inclusion of height comparisons from

other opportunity areas is not useful, as these heights are
based on their context. Although it is not stated which
opportunity areas the heights relate to it is assumed it is
opportunity areas within Central London, whereas much of
the OAPF area falls in Outer London boroughs. Heights in
Old Oak should be based on a detailed analysis, including
consideration of local context and views. It would be of
greater benefit to reference the London Plan density matrix.

LBB

Q5, page 42 Station approach will be a key entrance to

Willesden Junction and the Old Oak core area, and as such
exemplary architectural standards should be sought in this
location. However, it is not accepted in all cases taller
elements are acceptable at entrance points. Taller elements
should be subject to the requirements of London Plan policy
7.7 and relevant policies in the OAPF.

LBB

Figure 26, page 43 To the east of Old Oak core area

properties within a 0.5km radius are identified as sensitive to
tall buildings, whilst to the north only properties within 0.2km.
Given the area to the north is dominated by two storey town
houses, and of a similar character to properties to the east
and for example more likely to be impacted upon by
shadowing, there is no logic to this distinction. The area
identified as sensitive to the north needs to be extended and
must encompass Harlesden Conservation Area.

LBB

OO5, page 44 Greater clarification is required as to what

informed by local views means. To be consistent with
London Plan policy 7.7 OO5 needs to state proposals should
not adversely impact on local or strategic views. To enable
the MDC Planning Committee and officers to determine if
OO5 has been satisfied developers proposing tall buildings
should be required to submit a views study and 3D model.
This requirement should be included in supporting text.

Noted. The GLA will provide alternative comparisons

based on high density development and publish
background information to support the approach.

Building Heights
Noted. The OAPF will remove guidance related to
entrance points. Guidance for architectural
standards will continue to be provided within the
London Plan and where relevant the Housing SPG.

Building Heights
Noted. The 0.5 km radius responds to the Grade I
registered Park and Garden of Historic Interest at
Kensal Green Cemetery and is considered to be
appropriate for the significance of this heritage
asset.
Agree. The area identified as sensitive to the north
of Old Oak will be expanded to reflect Harlesden
Conservation Area.
Building Heights
Noted. The GLA considers that the statement
"informed by local views" gives appropriate guidance
for an OAPF to shape development.

Building Heights

Agree. Although already managed by the

Environmental Impact Assessment process, the
supporting text will be amended asking applications
for tall buildings to be supported by views
information.

86

LBB

Reference needs to be included to the role taller buildings

have in acting as a landmark from the surrounding area.

Building Heights

LBB

5.26, page 44 First sentence needs rewording. Delete for

the.

Building Heights

LBB

Old Oak North page 49 Land fronting High Street Harlesden

should be identified as a sensitive edge in this figure, as it is
in figure 26.

Agree. Reference will be made to the potential for

taller buildings at appropriate locations to support
local legibility.
Agree. Words will be deleted
Agree. Sensitive location to be amended

Building heights

Page 295
87

Noted. The GLA will publish contextual information

used to support the design strategy.

Design Strategy, page 25-29 Although policy D3 states

buildings should be mindful of their context, the OAPF
includes no analysis of the character of the surrounding area.
This analysis should form the basis of the design strategy.
Without such analysis the design strategy provides generic
policies which are not specific to Old Oak and Park Royal. In
determining appropriate heights and densities it needs to be
acknowledged the OAPF area is not in a Central London
context. It also falls within two Outer London boroughs. To
the north the Old Oak is bounded by low density two storey
terraced town houses on Tubbs Road, to the east St Marys
Cemetery, to the south Wormwood Scrubs and to the west
North Acton and two storey terraced properties. This context
differs significantly to opportunity areas such as Nine Elms
therefore a different approach is needed.

Disagree. The GLA considers that the structure of

the Design Strategy is appropriate and that the
guidance provided is appropriate for an OAPF. The
London Plan provides guidance for each of the
suggested themes with the OPDC Local Plan
envisaged to address these issues in more detail
supported by a robust evidence base.

Page 296

This chapter should be more focussed on achieving design

quality. Suggest restructuring this chapter around the
following themes:-

LBB

Architecture and Townscape how will the development be

integrated into its setting? How functional and attractive will
the development be?
Movement & Legibility how will the development be
accessible for all? Will it encourage public transport use?
Will it be well connected to important destinations and
routes?
Space & Enclosure will the development reinforce the
building line or erode it? Will it enclose the streets or public
space?
Mixed uses and tenures what will the development do to
promote mixed uses and tenures?
Adaptability and Resilience how could the development
be adapted to a new use or uses if conditions change, for
example commercial to residential or vice versa. Will the
development contribute to tackling climate change, for
example SUDS, green roofs, solar panels, etc.
Resources and Efficiency will the development use
resources efficiently in construction and operation?

Building heights

88

LBB

Page 297
LBB

D3, page 28 D3 states proposals should deliver greater

heights and densities than the surrounding existing context. It
is appreciated that there is a need to optimise land use;
however, taken out of context this suggests a blanket
increase in densities across Old Oak. As identified later in the
OAPF Old Oak core area is surrounded by sensitive
locations, including a number of conservation areas. As set
out in point c buildings should be mindful of their context,
therefore greater heights and densities may not be
appropriate on all sites. Part a of policy D3 should therefore
state proposals should deliver greater heights and densities
than the surrounding existing context, where appropriate.

D3, page 28 D3 is not consistent with London Plan policy 7.7

(Location and Design of Tall and Large Buildings), as it does
not fully reflect the criteria in this policy. The policy states tall
buildings are to incorporate the highest standards of
architecture and materials and should not affect their
surroundings adversely in terms of microclimate,
overshadowing, noise and reflected glare. Tall buildings are
only to be considered in areas whose character would not be
affected adversely by the scale, mass or bulk of a tall
building. Reference is also needed to the London Plan
density matrix. Greater guidance is also required as to how
tall buildings integrate with surrounding buildings and the
public realm at street level. The SPG is to supplement the
London Plan, and accordingly D3 should reflect the criteria in
London Plan policy 7.7.

Noted. D3(c) will be amended to state " buildings

that are mindful of their context, in particular
sensitive locations in the surrounding area where
lower densities may be appropriate."

Building heights
Disagree. The GLA considers that D3 is consistent
with London Plan policy 7.7. Although the OAPF
does not seek to repeat guidance within the London
Plan, reference will be made to policy 7.7. The GLA
will also clarify this guidance and publish
background information utilised to support the
approach.
However, the supplementary text will be amended to
make reference to London Plan policy 7.7 and table
3.2 the Sustainable residential quality (SRQ) density
matrix.

Building heights

89

LBB

Page 298
LBE

D3, page 28 The OAPF identifies sensitive locations in the

surrounding area but, in accordance with London Plan policy
7.7, it should also identify sensitive, appropriate and
inappropriate sites for tall buildings within Old Oak and Park
Royal. This will need to be informed by a detailed design
analysis and greater understanding of the local context.

Open and green space are at a particular premium at Old

Oak and while the attempts both to link to Wormwood Scrubs
and generate a continuous network of public spaces is
welcomed this effort is threated by the scale of the proposed
development. Tottenham Court Road is offered as a
comparison to the main street proposed at Old Oak High
Street as having a comparable width of 25m. However, this
comparison is misleading because the planned heights,
quoted as from 10 storeys at the shoulder are far in excess
of those typical of Tottenham Court Road. The Mayors own
urban design advice in the Character and Context SPG
recommends the widely acknowledged rule of thumb of a 1:1
ratio of building height to street width to allow an adequate
balance between street enclosure and openness. Overall,
this advice and the design guidance on pages 35-44 seems
to raise expectations of development yield too high without
the support of sufficiently detailed urban design work.

Disagree. London Plan policy 7.7 (A) provides

strategic guidance. As such the need to identify
appropriate, sensitive and inappropriate locations
refers to a London wide context. London Plan policy
7.7 (C) (a) considers Opportunity Areas to be
appropriate for tall and large buildings. Policy 7.7(E)
provides guidance for local planning frameworks
which does not relate to OAPFs. The GLA considers
the guidance stated in the OAPF for building heights
and densities to be the appropriate approach in
supplementing the London Plan.
The GLA will publish background information utilised
to support this approach.
Building heights
Noted. The GLA considers that the guidance stated
in OO3(a) envisaging the High Street to be
'approximately 25 metres with opportunities for
variation responding to functions and built form'
provides a useful approximation for the
implementation of existing and emerging street
design guidance'. However, to enable appropriate
flexibility in the delivery of the High Street and
adjacent buildings and spaces over the lifetime of
the plan, reference to 25m in OO3(a) and 10 storeys
in OO4(a)(ii) will be removed.
Agree. The references to Tottenham Court Road will
removed and alternative comparisons provided.

Building heights

90

LBHF

LBHF

P.28, D3 Building Heights & Densities a) - add where

appropriate at the end of point a)

P.28, D3 Building Heights & Densities a) - add should be

carefully managed after Greater heights

P.28, D3 Building Heights & Densities c) - at end of

sentence add and local and wider townscape views

LBHF

There are concerns that the site as a whole is being over

developed, the heights alluded to around the site are not
desirable and are considered to be much too tall for their
London context. Any development here needs to integrate
into this part of west London. Tall buildings in particular will
be visible from all over London, therefore it is essential that
these tall buildings are marking a place with an real and
unique identity. Ideally this would be some form of publically
accessible use such as a stadium. There is a danger that Old
Oaks only identity would be as a high rise housing
development.

LBHF

The proposed massing is not coherent with appropriate

scale of a High Street. These heights need better
justification.

Page 299

LBHF

Building heights

Noted. D3(c) will be amended to state " buildings

that are mindful of their context, in particular
sensitive locations in the surrounding area where
lower densities may be appropriate."

Building heights

Agree The OAPF will made reference to London

Plan policy 7.7 to provide appropriate levels of
guidance for the delivery of building heights and
densities.

Building heights

Disagree. The GLA considers OO4(c) and OO5 to

provide sufficient guidance to inform building heights
and densities in relation to views. Reference to this
guidance will be made in D3.

Building heights

Noted. The GLA considers the guidance for

development in the OAPF to be appropriate in
meeting London Plan targets and meeting London
Plan policy 2.13 (B)(b). Building heights will be
subject to D3 and OO4 alongside London Plan
policy 7.7 with D5 seeking the delivery of successful
placemaking.

Building heights

Noted. The GLA will clarify this guidance and publish

background information utilised to support the
approach.

91

Building heights

LBHF

The scale of the proposed new buildings in this area needs

to be significantly reduced, and their form should allow for
both physical and visual permeability at the edges, rather
than present a wall of building which would serve to detach
the new development from its context to the detriment of
both.

Building heights

The GLA will publish background information utilised

to support this approach.

LBHF

P. 42, table 004: Building Heights and Density i.e.

sensitive areas should specify the highly sensitive Grand
Union Canal Conservation Area. Not only is it a heritage
asset but also a much used public space, recreational facility
and thoroughfare. It provides a valued breathing space in
the city and should be protected from being overshadowed
by buildings to the south. Building heights on both sides of
the canal need to respond sensitively to the narrow width of
the canal.

Building heights

Agree. Grand Union Canal to be referenced

Page 300

LBHF

There is a lack of townscape justification for taller buildings

at the entrances. Greater massing at gateway sites have
already been highlighted at the public transit nodes. Having
taller buildings at entrances too is over the top and lacks an
evidence base. These sites maybe suitable for some
buildings of architectural value, however increased massing
at some of these sites could be harmful to the character of
Scrubs Lane, the conservation areas and surrounding views
and urban fabric. The site should seamlessly integrate into
the surrounding context.

Noted. The OAPF will remove guidance related to

entrance points.
Disagree. The GLA considers the indicative scale for
development in the OAPF to be appropriate in
meeting London Plan targets and meeting London
Plan policy 2.13 (B)(b). Building heights and
densities will be subject to D3 and OO4 (specifically
OO4(a)(iv)) alongside London Plan policy 7.7 with
D5 seeking the delivery of successful placemaking.
However, visual permeability into the site is
supported and wording will be included to address
this.

92

Page 301

LBHF

P.42, ii. Old Oak High Street - The onus would be on the
developer to justify their proposals with their supporting
studies. Approximate 10 storey height is extremely tall and is
not coherent with appropriate scale of a High Street. These
heights are not typical of a High Street anywhere in the UK
and need better justification. 10 storeys at shoulder height is
likely to result in a wall massing - which also contradicts the
statement below in ii) 2nd Para.

Building heights

Noted. Guidance will be amended to remove

reference to 10 storeys and reflect potential
densities and precedent typologies to enable
appropriate flexibility in the delivery of the High
Street over the lifetime of the plan.

LBHF

Para. 5.24 Entrance Points The presence of an entrance

is not a sound justification for a tall building. Reference to
entrances being defined by buildings which could be of some
height should be removed. Entrance points within the OAPF
should seek good architectural quality not just at entrances
but throughout the site. A paragraph also needs to be
inserted here about the edges of the site.

Building heights

Noted. The OAPF will remove guidance related to

entrance points.

LBHF

Para. 5.24 Entrance Points delete and there may be

opportunities for taller elements.

Building heights

LBHF

Para. 5.25 Height Comparisons Delete this text as it is not

appropriate for crude, untested example and suggested
precedent. Heights at other Opportunity Areas doesnt justify
heights at Old Oak. Each Opportunity Area is unique and in
different parts of London. Examples of heights arent named
and is misleading. Using the same broad brush approach for
each OA fails to respond to local context, this should be
removed.

Building heights

Organisation

Comment

Theme

Noted. The OAPF will remove guidance related to

entrance points.
Agree. The GLA will provide alternative comparisons
based on high density development and publish
background information to support the approach.

Response

93

LBB

Figure 27, page 44 Includes some listed buildings in the

surrounding area, but omits the following:-Church of our Lady
of Willesden, List Entry ID 1064217Stonebridge Park Public
House, List Entry ID 1078882Brent Viaduct, List Entry ID
1078890Roundwood Park, List Entry ID 1001556Church of
St Matthew, List Entry ID 1359020Church of St Mary, List
Entry ID 1359036

Agree. Amendments to Figure 27 to be made.

Heritage
Agree. Reference to be made in Appendix 3

LBB

Appendix 3, page 11 Reference to Canal Cottage a locally

listed building within Park Royal is omitted.

Heritage

Page 302

Noted. The GLA considers that the guidance stated

in D4 is appropriate to the role and function of an
OAPF. The GLA has worked with Historic England to
develop the Old Oak Outline Historic Assessment
which provides an overview of heritage assets within
Old Oak. The GLA understands that the OPDC will
continue to work with Historic England to develop a
similar assessment for Park Royal for the Heritage
and Local Views Study to inform the OPDC Local
Plan. The OPDC intends to develop a Local List and
will work with the local boroughs in its establishment.

D4, page 28 D4 needs to be based on an understanding of

the heritage assets within and bordering the OAPF area.
Through discussions with English Heritage and the boroughs
the contribution of these assets needs to be assessed to
ensure they are conserved in a manner appropriate to their
significance. In particular within Brent there are examples of
industrial heritage in Park Royal and on land surrounding
Willesden Junction. The council would want to be actively
involved in assessing the significance of these buildings with
a view to reviewing the local list.

LBB

D4 should include reference to proposals enhancing built

heritage assets and their setting, in accordance with London
Plan policy 7.8.
4.4, page 28 This omits Canal Cottage on Twyford Abbey
Road, which is locally listed.

LBHF

P.28, D4 Built Heritage - Proposals should also seek to

enhance place making.

LBB

Agree. The OAPF will be amended to make

reference to London Plan policy 7.8 in relation to
heritage assets.

Heritage
Agree. Reference to be made in paragraph 4.4.
Heritage

Heritage

Disagree. D5 sets out guidance for proposals to

contribute to the creation and improvement of locally
distinct places.

94

Page 303

LBHF

P.28, sensitive locations needs explanation here or in a

glossary on approach to defining sensitive edges/ locations
as its not clear.

Heritage

Agree. Definition of sensitive locations will be

provided.

LBHF

P.28, para 4.4, last sentence: needs to refer to working

with Local authorities (as well as English Heritage) in
designating conservation areas and a Local List.

Heritage

Agree. Working with Local Authorities will be

inserted

Organisation

Comment

Theme

LBB

Key objectives, page 48 The objectives for Old Oak North

currently lack any reference to impact on the surrounding
residential communities. Key objectives for this area should
include Development should be mindful of existing
residential communities to the north including on Tubbs
Road, Station Road and Nightingale Road. In objective 5
specific reference should be included to improving links with
Harlesden, to be consistent with the overarching vision to
benefit Harlesden centre.

Old Oak North

LBB

Old Oak North, Figure 29, page 49 The vision set out in the
OAPF is to create a well connected neighbourhood that is
integrated into its surroundings. With this in mind access
arrangements to the plots of land off Scrubs Lane and
Harrow Road needs to be resolved. At present these parcels
of land appear to be isolated from both Old Oak and
Harlesden, and it is unclear how they connect to the
surrounding route network. Given that there are proposals for
residential development on these sites and commercial
premises fronting onto Scrubs Lane, consideration needs to
be given to how servicing and residential access will be
balanced. In turn the impact this will have on Scrubs Lane
and junctions in Harlesden Town Centre needs to be
considered.

Response
Agree. This text will be inserted into the OAPF and
reference will be made to improving links to
Harlesden.

Noted. The GLA would expect the plots on Harrow

Road to be developed, access coordinated with the
potential wider development of Willesden Junction
Station and be accessed off Harrow Road. It is not
the purpose of the OAPF to provide detailed
solutions to how this could be achieved. Any
application would be assessed on its own merit and
in line with the transport chapter of the OAPF,
schemes would need to mitigate any impact on the
wider highway network.

Old Oak North

95

Agree. Amendments will be made to the figure.

In addition the following amendments are needed to figure 29

for clarity and consistency: Land fronting High Street Harlesden should be identified as
a sensitive edge in this figure, as it is in figure 26.
The form of route from Willesden Junction to Harrow Road
needs to be shown, as this is not an existing link.
As with figure 34 should include arrows indicating links to
surrounding area including Harlesden Town Centre.
From the shading it is not clear if the space in front of
Willesden Junction station is civic or green amenity space.

LBHF

P.48: The council considers that a key objective for Old Oak
North should be integrating the MDC area with the existing
College Park area. It is important that this residential area on
the boundary of the OOCA benefits from the regeneration
that will take place in the opportunity area. In addition, given
that other Figures in the draft OAPF have identified green
grid symbols extending across Scrubs Lane into St Marys
Cemetery, it is surprising that there is no reference in this
section.

LBHF

P.49, Figure 29: Powerday and EMR site boundaries are

not shown but it is premature to show a street within the
Powerday site in Figure 29 given that the OAPF indicates
that Powerday may remain on its existing site. Explanation of
why these sites are a potential catalyst for regeneration
needs to be set out.

Page 304

LBB

Old Oak North

Old Oak North

Agree. Reference to improving connections between

College Park and the OAPF area will be added. The
figures for the places are more detailed than the
overarching image that shows the 'green grid' and it
is not considered appropriate for these images to
replicate the green grid.

Old Oak North

Disagree. The OAPF explains in chapter 9, para 9.7

that the Powerday site could remain in the area, but
equally, in the latter phases it could be brought
forward for development and the GLA therefore
considers it appropriate to include the site within the
masterplan to provide planning guidance for the
design of the site.

96

Page 305

LBHF

P.50, Figure 29a & Para. 5.36: Square add size in the
text and reference to any proposed development to provide X
size park to the north of the canal in para 5.36

Old Oak North

Disagree. The GLA does not consider it appropriate

to define the size of the square given the indicative
nature of the masterplan and related images.
However, the OAPF will be amended to refer to the
Green Grid SPG and London Plan hierarchy of open
spaces as set out in table 7.2.

Organisation

Comment

Theme

Response

LBHF

The council notes key objective 9 on page 52 that

development should provide an edge and new access points
into Wormwood Scrubs whilst respecting its character and
ecological value. The open space is of course Metropolitan
Open Land and common land.

Old Oak South

Noted.

LBHF

The key objectives should also acknowledge the need to

respect the canal, which has conservation area status and is
designated as a nature conservation area of metropolitan
importance in the councils Local Plan.

Old Oak South

Agree. Text will be added referencing the need for

development to respect the canal.

Old Oak South

Disagree. Approximate dates for relocating the

Crossrail depots are provided in para 5.41.
Timescales for the relocation of the IEP depot have
not yet been set.

LBHF

P.52, key objective, 7 relocation of depots state date.

97

Page 306

LBHF

P.53, Figure 34
o outline the boundary of the Shield Site, IEP depot, Crossrail
depots etc. (this is where a land use/ landownership plan at
the beginning of the document would help)
o the edge along the southern side needs to be shown as
sensitive right up to borough boundary to the east.
o Key to show what do the white dotted areas on the plan
represent.
o Wormwood Scrubs and little Wormwood Scrubs should be
marked on
o Boundary of Wormwood Scrubs should be marked on so it
is clear that the proposed road is not on the Scrubs land.

Old Oak South

LBHF

P. 54, para 5.40 Such a high degree of accessibility

justifies high density... need evidence to support this
statement PTAL as well as and contextual urban design
studies.

Old Oak South

Agree. A land ownership plan will be included within

the introduction chapter
Noted. London Plan policy 2.13(B)(b) seeks to
optimise residential and non-residential output in
opportunity areas alongside policy 3.4 which
requires local context and character to be
considered. The GLA will clarify this guidance and
publish background information utilised to support
this approach.

LBHF

P. 54, para 5.40 reference to Genesis and North Pole

depot sites - need to be shown on figure 34 or refer to map
in Delivery section that identifies development sites.

Old Oak South

Agree. Genesis site will be added to figure 34.

LBHF

P.54, text box This statement is not supported by

evidence. Delete as there is no explanation as to why these
are considered precedents and directly comparable to Old
Oak.

Old Oak South

Disagree. The GLA considers the precedents to be

useful comparisons for how new employment
provision could be delivered within Old Oak South.
The GLA will publish background information utilised
to support the approach and understands that the
OPDC will be undertaking further evidence base to
inform the OPDC Local Plan.

Organisation

Comment

Theme

Response

98

LBB

5.47, page 56 Reference is included to East Village, however

no further reference is included to this area in the document.
For this reference to be relevant an image or description of
East Village is needed.

Agree. An image of East Village will be inserted into

the document.
Old Oak High Street
Disagree. The OAPF cannot set new policy to deal
with the takeaways, betting shops or pawnbrokers.
This would be dealt with as part of OPDC's Local
Plan and is being considered as part of OPDC's
Retail and Leisure Needs Study.

Page 307

LBB

5.48, page 56 Typical London High Street uses needs

defining. This could include a range of uses including
takeaways, pawnbrokers and betting shops.

LBB

Should Old Oak High Street be made a vehicular route there

is a risk it would become a through route for the surrounding
residential development. Retaining this route as pedestrian,
cycle and bus only, would create a pleasant environment and
help further promote the use of sustainable modes of
transport.

LBHF

P. 56, Key Objectives 4 and 7 25m street widths

considered much too wide and too prescriptive. Increased
building heights are likely to create a poor quality pedestrian
environment and tall buildings may create sunlight
penetration issues for the public realm.

LBHF

Para. 5.46 - last sentence needs rewording. A balance

needs to be struck to create a usable active space that is an
efficient thoroughfare for pedestrians and cyclists

However, the OAPF will be amended to state a

"sustainable typical high street" to reflect aspirations
for a high quality and diverse offer"
Old Oak High Street
Noted. The text currently acknowledges that further
work on the potential for Old Oak High Street to be
vehicular would be necessary but the GLA
acknowledges the risks associated with this being a
through route.
Old Oak High Street

Old Oak High Street

Noted. The GLA considers that the guidance stated

in OO3(a) envisaging the High Street to be
'approximately 25 metres with opportunities for
variation responding to functions and built form'
provides a useful approximation for the
implementation of existing and emerging street
design guidance. However, to enable appropriate
flexibility in the delivery of the High Street and
adjacent buildings and spaces over the lifetime of
the plan, reference to 25m in OO3(a) will be
removed alongside guidance for Old Oak High
Street.

Old Oak High Street

Disagree. The GLA considers that the current

wording is sufficient identifying the pros and cons of
the parts of the High Street being vehicular.

99

Page 308

LBHF

Para. 5.49 prevailing shoulder height implies that other

heights on the high street will be even taller. This heights are
inappropriate.

LBHF

P 57, figure 39 Tottenham Court Road is not a

comparable road as its prevailing shoulder height is 6 floors
with some taller elements. There arent any UK examples of
the proposed heights. This new high street typology needs
more research and a robust evidence base.

LBHF

In respect of active frontages in the MDC area, it is

important that the location, scale and offer of the frontages
reflects the function of the area as a place to live, work and
move through, and as a major transport interchange. At
present it appears that active frontages have been drawn
quite widely without first establishing the scale of retail need
in the area.

LBHF

The OAPF fails to adequately recognise the role of

established retail centres in the surrounding area, such as
Shepherds Bush Metropolitan centre, which will also play an
important role in providing facilities for the incoming
population of the area. Whilst it is important that the area can
sustain itself in terms of local amenities, there must be
acknowledgement in the OAPF that the new development in
this area must integrate with its surroundings.

Old Oak High Street

Noted. Guidance will be amended to reflect potential

densities and precedent typologies to enable
appropriate flexibility in the delivery of the High
Street over the next 20 years.

Agree. The references to Tottenham Court Road will

be removed and alternative comparisons provided.
Old Oak High Street

Disagree. Active frontages would not just constitute

retail and will cover uses such as leisure, social
infrastructure, culture and offices and employment.

Old Oak High Street

To clarify this definition, a definition will be provided

in the supporting text.

Old Oak High Street

Disagree. The land use section identifies that retail

provision within the OAPF area should be for the day
to day needs of development and should not impact
negatively on nearby centres.

100

LBHF

It is anticipated that the transport interchange for Hs2 will

incorporate convenience retail and other uses for people
travelling through the area. How this complements the offer
proposed on the high street should be carefully considered in
order to achieve the appropriate blend and positioning of
town centre uses. The future management of the proposed
town centre uses is also an important consideration in order
to retain diversity and balance in the offer being provided.

Old Oak High Street

Noted. The GLA understands that OPDC has

commissioned a Retail and Leisure Needs Study
and that the London Boroughs of Brent, Ealing,
Hammersmith and Fulham and Royal Borough of
Kensington and Chelsea have been invited to
steering group meetings. This study will recommend
an appropriate quantum of retail that can be
provided within impacting on the viability of nearby
retail centres. The study will also make
recommendations on qualitative measures to ensure
the long term vitality and viability of any retail.

Organisation

Comment

Theme

Response

Page 309

LBHF

P.58 - Key Objectives - Expand to include need for through

route to Scrubs Lane and provide emergency access.

Old Oak Common

station

Disagree. Noted: Through the HS2 petitioning

process TFL/GLA is seeking a through route to
Scrubs Lane. If a connection to Scrubs Lane is not
provided, the GLA recognises the negative impact
on wider placemaking aspirations this will have.

LBHF

P.58, Para 5.54 - Heights, Scale , massing needs to be

mindful of impact om Wormwood Scrubs

Old Oak Common

station

Agree. Text will be inserted noting that development

on or around the station would need to respect
Wormwood Scrubs

LBHF

P.58, Para 5.55 southern access need to acknowledge that

the access would need to be designed sensitively and not
have any adverse impact on Wormwood Scrubs.

Old Oak Common

station

Agree. Text will be inserted to clarify this.

Old Oak Common

station

Agree. Text will be added to explain the dotted land,

which is the intermodal interchange for the Old Oak
Common station. Wormwood Scrubs will also be
annotated on the image

LBHF

Figure 41 explain white dotted plots of land. Add

Wormwood Scrubs.

101

Page 310

Organisation

Comment

Theme

LBE

North Acton has an established and highly successful

concentration of student housing, and this is seen as a first
step toward securing a potential university use. Ealing has
noted elsewhere the need for an industrial and employment
strategy for Park Royal and teaching and research functions
here could function as a catalyst of development much as a
stadium is suggested to do at Old Oak. The preference in
Para 5.60 for a greater mix of residential uses is noted but
seems rather perfunctory given the large number of
conventional residential units already built or at the
application stage and the lack already noted of a broader
strategy for Park Royal.

North Acton

Organisation

Comment

Theme

LBE

The aspiration for active uses and environmental

improvement of the canal is supported but explicit mention
should be made of the Conservation Area that covers its full
extent.

Grand Union Canal

Response
Agree. The objectives will be amended to make
specific reference to the potential for student
housing and education related uses in North Acton.
The OPDC will further develop policy for Park Royal
in its Local Plan.

Response
Agree. The OAPF will be revised to reference the
conservation area designation along the Grand
Union Canal.
Noted. The GLA will publish contextual information
used to support the design strategy including how
the scale of development could respond to the
Grand Union Canal. The GLA understands that the
OPDC will be undertaking additional design
evidence base to inform its Local Plan.

LBE

Finding a scale of development that responds to the canal

will be very difficult in the Old Oak area and at the edges of
Old Oak where this core links to the rest of the blue network.

Grand Union Canal

LBHF

P 62, Grand Union Canal - the Grand Union Canal

Conservation Area is historically important and are distinctive
in character. Any development that meets these needs to be
sensitive to their character and any massing within the site
needs to be sensitive to the views from it.

Grand Union Canal

Noted

LBHF

key facts - needs to recognise that the Grand Union Canal

is Nature Conservation Area of Metropolitan Importance.

Grand Union Canal

Agree. The OAPF will make reference to the Grand

Union Canal being a Nature Conservation Area of
Metropolitan Importance

102

Page 311

LBHF

Vision need to make reference to conservation area

status and respecting its location.

Grand Union Canal

Agree. Vision will reference canal being a nature

conservation area and the need for development to
respect its location

LBHF

Figure 43 - The photo of Kingsland Basin is not a good

example of canalised development in a Nature Conservation
Area

Grand Union Canal

Disagree. The GLA considers the precedent of

Kingsland Basin to be an appropriate comparison.

LBHF

Para. 5.68 refers to the need to work with Canals and

Rivers Trust. However, there are other important bodies,
such as the Environment Agency and English Heritage.

Grand Union Canal

Noted. The OAPF makes particular reference to the

Canals and River Trust as they are the landowner
for the canal.

LBHF

Para. 5.71 delete last sentence which starts -however,

there will be opportunities for taller elementsQ. Any
developer should provide justification for taller buildings and
it is unnecessary for the document to make this statement.

Grand Union Canal

Disagree. The GLA considers that paragraph 5.71

provides appropriate information to inform the
opportunities for taller elements along the Grand
Union Canal within the wider Old Oak context.

LBHF

Figure 44, the bridges across the canal in the old oak area
should be red in colour.

Grand Union Canal

Agree. The diagram will be amended to highlight

existing and proposed bridges

Organisation

Comment

Theme

Response

LBHF

P.64, Key Facts needs to acknowledge that it is partially

in a conservation area

Scrubs Lane

Agree. Change to be made.

Scrubs Lane

Agree. Change to be made.

LBHF
LBHF

P.64 need to mention relation to College Park residential

area and the need to integrate in a sustainable way with
College Park - which is adjacent to OPDC boundary.
P 64, Scrubs Lane - The character of Scrubs Lane needs to
be protected. It is located next to St Marys Conservation
Area and has an industrial character that is unique to the site.
The proposed extension to the conservation area reflects
this.
Key Objectives 5. add and SUDs at the end of point.

Scrubs Lane
Scrubs Lane

Noted.
Agree. Change to be made.

LBHF

Key Objectives 9. add pedestrian/ vehicle before the

word entrances

Scrubs Lane

Agree. Change to be made

LBHF

103

Scrubs Lane

Disagree. The figures for the places are more

detailed than the overarching image that shows the
'green grid' and it is not considered appropriate for
these images to replicate the green grid.

LBHF

Figure 45 Sensitive edges approach to sensitive edges

needs to be set out as in supporting text - not clear from
diagram.

Scrubs Lane

Noted. Guidance for sensitive edges is set out in

OO4 and will be expanded to aid clarification.

Organisation

Comment

Theme

LBE

The lack of plans for Old Oak Lane is characteristic of the

failure of the OAPF to set out a clear strategy for employment
uses in Park Royal as a whole. This area is both sensitive,
being home to two conservation areas in the form of the
Grand Union Canal and the railway cottages, and a focus of
significant change due to the clearing of the industrial sites
during HS2 construction. Existing uses are predominantly
road transport based, with a large bus garage among the
current occupiers, and reflect a currently poor environmental
quality and isolated location. This however will change
radically by the time the HS2 construction sites become
available in 2026, with direct access via Midland Terrace to
the planned Overground Station, improved transport links
and urban realm immediately to the north at Willesden
Junction, and numerous pedestrian and cycle links to Old
Oak and North Action. In this context it is inadequate simply
to say that the SIL designation will be safeguarded and that
current industrial uses will be replaced. It is clear that the
profile and character of this area will have significantly
improved and it will have gained the capacity to support
much higher density and value employment uses than is
currently the case.

Old Oak Lane

Page 312

LBHF

P.65, Figure 45 should also recognise that St Marys

Cemetery is a nature conservation area of metropolitan open
space. As stated in the comment for Old Oak North, it is
surprising not to see any symbol for the proposed green grid
in this figure .

Response
Noted. The GLA wishes to protect the Park Royal
Estate for industrial uses and focus the
dedesignation of SIL to locations of good public
transport accessibility. The HS2 work sites are
unlikely to have good public transport accessibility
levels and can make a valued contribution to the
jobs target within the Park Royal Industrial Estate,
which is identified in the London Plan and needing to
provide 10,000 additional jobs. The GLA therefore
does not consider it appropriate to identify these
sites for potential SIL dedesignation. However,
further detail will be provided regarding the potential
uses along Old Oak Lane.

104

Agree. The OAPF will identify the potential for

intensification of employment uses along Scrubs
Lane.

LBE

Old Oak Lane is also very exposed to the consequences of

increasing road traffic that will result from development
around the HS2 Station and there are concerns over the road
access point proposed in this area. Traffic impacts on Old
Oak Lane Conservation Area are a longstanding problem
and detailed proposals should make every effort to limit traffic
growth and mitigate its effects.

LBE

With regard to terminology it is recommended that the term

Island Triangle is avoided as it lacks both widespread
recognition and geographical precision. Old Oak Lane
Conservation Area is defined in policy and the term is used in
Ealings adopted Local Plan.

Old Oak Lane

Organisation

Comment

Theme

Page 313

LBE

It will constitute, along with the sites north of the mixed uses
at North Acton Station, part of a transition zone of more
intensive employment uses that are still within easy walking
distance of railway links, and the more extensive and road
traffic based uses in the centre of Park Royal. The Old Oak
Lane sites in particular are subject to assembly and clearing
due to HS2 construction works and the failure to set out a
strategy for environmental and economic improvement
therefore has a double opportunity cost. It is acknowledged
that the ELR is currently being completed and that this will
provide a better basis for strategic planning in Park Royal,
however, the low ambition expressed for this area sets a
dangerous precedent for future iterations of the plan.

Old Oak Lane

Noted. The GLA is aware of the traffic problems
along Old Oak Lane and the need to mitigate this is
noted in para 5.83. The OPDC are commissioning a
Park Royal Transport Strategy, which will further
investigate potential mitigation measures that could
be implemented along Old Oak Lane.
Old Oak Lane
Agree. Amendments will be made to the OAPF,
changing 'Island Triangle' to 'Old Oak Lane
Conservation Area'

Response

105

Page 314

LBE

Park Royals importance as a source of employment and

economic activity and a reserve of land for strategically
important uses is well established. The continued protection
of this area as Strategic Industrial Land (SIL) is supported,
but this designation will not insulate the area from changes
brought by HS2 or the massive redevelopment planned by
the OAPF.

LBE

The publication of the Park Royal Atlas in time to inform the

OAPF is welcomed, and the current work on the Employment
Land Review will provide a better basis to begin strategic
planning in Park Royal.

LBE

The recent Inspectors Report on the Further Alterations the

London Plan (FALP) made clear that it is only an interim
statement on the strategic planning of London and that most
of the fundamental questions of how London will adapt to its
current growth in population and employment have yet to be
answered. There is significant capacity for Park Royal to
lead the strategic discussion on the role of SIL in London and
to ensure that this area of policy is well developed in the next
London Plan. It seems clear that the policy underpinning SIL
will need significant review, and similar to the changes
apparent at Park Royal, this land use will need a greater
strategic lead from public authorities. With the co-incidence
of the OPDC local plan, the continuing shifts in employment
and logistics in London and the full review of the London Plan
there will never be a better opportunity for a plan led
approach to industrial development in London.

Noted. The GLA recognises the opportunities and

challenges presented by the redevelopment of Old
Oak and the potential impacts on Park Royal. The
GLA considers that the OAPF provides the
appropriate level and extent of guidance for
Supplementary Planning Guidance to capture the
benefits and manage impacts on Park Royal.
However, this guidance will be coordinated and state
within the Park Royal Strategy to support clarity. The
GLA understands that the OPDC is committed to
working with stakeholders to ensure Park Royal
continues to thrive as London's most successful
industrial location.
Park Royal
Noted.

Park Royal
Noted. The GLA will work closely with colleagues in
the OPDC to coordinate work in developing the
OPDC Local Plan and the next iteration of the
London Plan. The GLA understands that the OPDC
is committed to ensure Park Royal continues to
thrive as London's most successful industrial estate.

Park Royal

106

LBE

Park Royal does not offer the development quanta of the

main Old Oak site but neither will it benefit from benign
neglect. The London Plan evidence base and Ealing's own
Employment Land Review among others have identified
measurable challenges to the area's crucial employment and
business services offer, and these have been exacerbated by
an unsympathetic permitted development regime. There are
substantial development opportunities for a university, health,
research or other employment use to lead development in a
way that complements Park Royal's existing skills and
industrial services.

LBE

Development to facilitate long-term business spinoff is an

essential outcome of the project if it is to benefit Park Royal
as well as the immediate station site.

Noted. The GLA understands that the OPDC has

commissioned an Employment Land Review to
supplement the GLA's Park Royal Atlas and support
the OPDC's Local Plan to ensure that Park Royal
continues to thrive as London's most successful
industrial estate.
Agree. The GLA understands that there is significant
interest from a number of sectors to locate to Old
Oak and Park Royal that would benefit the existing
uses. The GLA will continue to work with the OPDC
and the boroughs to explore these opportunities.
Park Royal

Park Royal

Agree. The GLA considers is critical that Park Royal

benefits from the regeneration of the OPDC area
and understands that this is a key role of the OPDC.

Page 315

Noted. Further clarification of the guidance for the

Brunel Road industrial estate will be provided in the
OAPF.

LBE

Treatment of the Brunel Road industrial estate is vague and

seems to be a hangover of earlier iterations of the OAPF in
which the Overground link was presumed to cut through this
site. Given that this will not now occur, and development at
this location is dependent on the completion of development
adjoining the Scrubs, it is Ealings view that this site should
not now be marked for release from SIL.

Disagree. Given the location of the Brunel Road

industrial estate, the GLA needs to consider the
development potential of the site. The GLA
understands that the OPDC is developing an
Employment Land Review which will inform the
OPDC Local Plan and the designation of SIL.
Park Royal

107

Agree. The GLA recognises that a stronger vision for

Park Royal is required and will be carrying out minor
alterations to the vision and Park Royal Strategy to
reflect this. Specifically, these two sections will
reflect guidance elsewhere in the OAPF and existing
guidance set out in the existing Park Royal OAPF
(2010) for the following themes:

Page 316

- Provide a clearer and stronger vision

- Define the challenges and opportunities
- Identify what evidence based will be produced with
timeframes and envisaged methodology
- skills and training
- commitment to securing funding streams
- Design guidance (public realm and routes, public
spaces, building heights)
- Land uses guidance
- Infrastructure guidance (transport and utilities)
- Placemaking guidance (Heart of Park Royal and
wider Park Royal)

LBE

The treatment of the Park Royal SIL in the draft OAPF is

disappointing and reflects the overly hurried nature of the
documents preparation and a lack of strategic perspective
on this vitally important business and employment area of
London.

Disagree. The GLA acknowledges that the

document was produced in an efficient manner, and
has been informed by the June 2013 Vision
document and 2010 Park Royal OAPF, but this has
not resulted in the document being compromised.

Park Royal

108

Page 317

LBE

LBE

Part of this appears to derive from the misconception of

Strategic Industrial Land as a safeguarding designation.
This is not a good understanding of the policy and it is
notable that the London Plan makes no use of this term in
relation to SIL. Safeguarding implies either the restriction of
development in an area or its retention for a specific project,
such as the HS2 safeguarding sites currently defined within
Park Royal. Neither of these usages is a good way of
conceiving of the role of planning in industrial and
employment areas in London, which is a complicated mix of
securing the industrial baseline of land supply, allocation of
strategic functions such as waste necessary to support the
running of the city, and driving the growth of business and
economic development. While the draft OAPF makes
reference to these roles separately, it is clear that the need to
bring them together at Park Royal has not driven the plans
for this area.
Relocation within Park Royal of the existing uses at Old Oak
is one of the important ways that these two areas can
support each other during the current period of change.
However, the proposed hierarchy expressed at para 5.8
which preferences relocation within Park Royal, then West
London, Greater London, and finally the South East of
England , misunderstands both the needs of business and
the role of planning. Locking uses within a given area or
imposing a bureaucratic sequential test on their movement
serves neither an industrial baseline nor an economic
development function. If the operational needs of a business
that serves London do not require that it locates within the
city then that is a decision that the business itself is best
placed to reach, and one which benefits London as a whole.
Equally, if land-hungry uses are displaced by more efficient
employment and economic uses then this provides clear
economic benefits.

Noted. To ensure consistency with terminology

within L2 and London Plan policy 2.17, PR1 will be
amended to state "The GLA will continue to protect
existing Strategic Industrial LocationsQ"

Park Royal
Disagree The information provided in paragraph 5.8
is not intended to lock in uses within a given area
nor impose a bureaucratic sequential test and
should be read with paragraph 5.9 which sets out
the need to consider the specific operational needs
of the business. To clarify this information,
paragraph 5.9 will be amended to refer to the need
to work with businesses.

Park Royal

109

LBE

There is, as was mentioned in the general comments at the

beginning of this representation, a clear need for SIL policy to
evolve and Ealing does not underestimate the work that
needs to be done to achieve an employment land strategy
that can encourage economic growth and the efficient use
land while maintaining essential service and logistic uses.
However, the draft OAPF does not seem to acknowledge this
need and leans on the extant SIL to support development at
Old Oak without harnessing strong the impulse of change
affecting Park Royal.

Noted. The GLA will work closely with colleagues in

the OPDC to coordinate work in developing the
OPDC Local Plan and the next iteration of the
London Plan. The GLA understands that the OPDC
is committed to ensure Park Royal continues to
thrive as London's most successful industrial estate.

Park Royal

Page 318
110

LBE

It is also strongly recommended that the OPDC pursues an

Article 4 direction as soon as possible to prevent the
fragmentation of the SIL that will result from the plethora of
recent permitted development rights attaching to the office
and industrial premises that make up the bulk of properties in
Park Royal.

Page 319
LBE

A significant spatial aspect is already apparent in the effects

that HS2 will have on industrial uses in Park Royal. Those
sites, mainly in the east of the SIL, which will benefit from
new transport infrastructure and a relationship with the hub of
business, services and population at Old Oak will be subject
to significant intensification. The OAPF already notes the
benefits that this can offer to the small businesses that form
the backbone of Park Royal. However there is no mention of
the need to shape this change by targeting particular
business sectors in which there is existing strength or
significant opportunity and which can help business
clustering, the provision of incubator and shared facilities,
and the development of growth sectors.
Several of the sites in Park Royal, such as the retained SIL
north of North Acton Station, and the HS2 construction sites
at Old Oak Lane, offer specific development opportunities for
flagship tenants that can bring new sectors to Park Royal.
It is not enough simply to draw a line around Park Royal,
protect it and consider that the job is done. If the OAPF
makes no case for the strategic importance of Park Royal,
that is to say of its role as an agglomeration of businesses
that benefit by their proximity and their relationship to
surrounding uses, then there is little basis for the growth and
change in the area.

Agree. The GLA recognises that a stronger vision for

Park Royal is required and will be carrying out minor
alterations to the vision and Park Royal Strategy to
reflect this. Specifically, these two sections will
reflect guidance elsewhere in the OAPF and existing
guidance set out in the existing Park Royal OAPF
(2010) for the following themes:
- Provide a clearer and stronger vision
- Define the challenges and opportunities
- Identify what evidence based will be produced with
timeframes and envisaged methodology
- skills and training
- commitment to securing funding streams
- Design guidance (public realm and routes, public
spaces, building heights)
- Land uses guidance
- Infrastructure guidance (transport and utilities)
- Placemaking guidance (Heart of Park Royal and
wider Park Royal)
Agree. The GLA understands that the OPDC will be
developing an Employment Land Review and Future
Growth Sectors Study to inform the OPDC Local
Plan which will identify potential existing sectors
expecting growth and new sectors.

Park Royal
Noted. The GLA understands that the OPDC will
consider this approach to help protect existing SIL
within Park Royal.

Park Royal

111

Agree. The GLA recognises that a stronger vision for

Park Royal is required and will be carrying out minor
alterations to the vision and Park Royal Strategy to
reflect this. Specifically, these two sections will
reflect guidance elsewhere in the OAPF and existing
guidance set out in the existing Park Royal OAPF
(2010) for the following themes:

Page 320

LBB

This section should also draw on the Park Royal Atlas and
Employment Land Demand Study to provide greater context
and help inform a vision for Park Royal. This should include
an outline of businesses sectors currently operating within
Park Royal, and projected future growth sectors and
opportunities.

LBB

Figures on current employment levels should be included to

act as a base line when monitoring employment growth
against London Plan targets. Employment figures are
referred to in the transport chapter but not here.

- Provide a clearer and stronger vision

- Define the challenges and opportunities
- Identify what evidence based will be produced with
timeframes and envisaged methodology
- skills and training
- commitment to securing funding streams
- Design guidance (public realm and routes, public
spaces, building heights)
- Land uses guidance
- Infrastructure guidance (transport and utilities)
- Placemaking guidance (Heart of Park Royal and
wider Park Royal)
Park Royal
Agree. Employment baseline information will be
provided in the Park Royal Strategy
Park Royal

112

Agree. The GLA recognises that a stronger vision for

Park Royal is required and will be carrying out minor
alterations to the vision and Park Royal Strategy to
reflect this. Specifically, these two sections will
reflect guidance elsewhere in the OAPF and existing
guidance set out in the existing Park Royal OAPF
(2010) for the following themes:
- Provide a clearer and stronger vision
- Define the challenges and opportunities
- Identify what evidence based will be produced with
timeframes and envisaged methodology
- skills and training
- commitment to securing funding streams
- Design guidance (public realm and routes, public
spaces, building heights)
- Land uses guidance
- Infrastructure guidance (transport and utilities)
- Placemaking guidance (Heart of Park Royal and
wider Park Royal)

Unless the Park Royal chapter is greatly improved, the

existing Park Royal OAPF must be retained, as without it
there will be an absence of detailed planning guidance for
this area.

Page 321
LBB

Park Royal

113

Agree. The GLA recognises that a stronger vision for

Park Royal is required and will be carrying out minor
alterations to the vision and Park Royal Strategy to
reflect this. Specifically, these two sections will
reflect guidance elsewhere in the OAPF and existing
guidance set out in the existing Park Royal OAPF
(2010) for the following themes:

Page 322

- Provide a clearer and stronger vision

- Define the challenges and opportunities
- Identify what evidence based will be produced with
timeframes and envisaged methodology
- skills and training
- commitment to securing funding streams
- Design guidance (public realm and routes, public
spaces, building heights)
- Land uses guidance
- Infrastructure guidance (transport and utilities)
- Placemaking guidance (Heart of Park Royal and
wider Park Royal)

LBB

D5, page 28 Specific place guidance is needed for Park

Royal. At present the policies within the Park Royal chapter
are not sufficient to ensure development at Park Royal
contributes to placemaking.

Park Royal

114

Agree. The GLA recognises that a stronger vision for

Park Royal is required and will be carrying out minor
alterations to the vision and Park Royal Strategy to
reflect this. Specifically, these two sections will
reflect guidance elsewhere in the OAPF and existing
guidance set out in the existing Park Royal OAPF
(2010) for the following themes:

Page 323

LBB

Park Royal, page 70-77 Brent Council is disappointed that

this section does not go further to set a strong vision for Park
Royal. The guidance for Park Royal lacks detail, and is a
step back from the current Park Royal OAPF. It is a concern
that when this OAPF supersedes the current Park Royal
OAPF existing detailed guidance will be lost. Unless this
chapter is greatly improved the existing Park Royal OAPF
must be retained.

- Provide a clearer and stronger vision

- Define the challenges and opportunities
- Identify what evidence based will be produced with
timeframes and envisaged methodology
- skills and training
- commitment to securing funding streams
- Design guidance (public realm and routes, public
spaces, building heights)
- Land uses guidance
- Infrastructure guidance (transport and utilities)
- Placemaking guidance (Heart of Park Royal and
wider Park Royal)
Park Royal

115

Page 324

LBB

Further work needs to be undertaken with Brent and Ealing

Council and the Park Royal Business Group to strengthen
this chapter. This chapter needs to be informed by an
understanding of the issues currently impacting on
businesses in Park Royal. Reference is made in passing to
the need for improvements to the road network, public
transport and broadband connectivity, but there is no clear
strategy for how these issues will be resolved, particularly as
the Transport Chapter omits Park Royal. Issues which need
to be acknowledged and addressed through the OAPF
include the need for meeting space and hotel development to
serve businesses, and a strategy to improve feelings of
safety and security.

LBB

Park Royal In accordance with Brents Core Strategy Policy

CP12 PR1 should state residential development at First
Central will be supported where it enables the delivery
significant public transport improvements. This is included in
paragraph 6.7 however PR1 refers only to walking and
cycling access.

LBB

PR1: Land use, page 70 In addition to the intensification of

land, the use of Park Royal can be optimised by allowing for
24 hour operation. Park Royal is largely isolated from
residential development and therefore lends itself to such
practices. To support this policies need to allow businesses
to operate flexibly, having regard to surrounding uses, and
also ensure the creation of a safe environment.

Noted. The GLA considers that it has a

comprehensive understanding of the range of issues
impacting on businesses in Park Royal and
opportunities for future development appropriate to
the role of an Opportunity Area Planning Framework.
Minor alterations to the Vision will be carried out to
reflect this in the OAPF. The GLA understands that
the OPDC will be developing a Park Royal Strategy
to support the OPDC Local Plan which will
coordinate various strands of the Park Royal
Transport Strategy, Utilities Strategy and other
strategies to support Park Royal.
Agree. The GLA recognises that clearer guidance for
Park Royal is required and will be carrying out minor
alterations to reflect this.
Park Royal
Agree. The OAPF will be amended to include a
stronger reference to housing on the First Central
Site, were it to enable the delivery of significant
public transport improvements.
Park Royal
Noted. The GLA understands that the OPDC is
developing a Park Royal Transport Study which will
consider 24 hour operation having regard to
surrounding uses.

Park Royal

116

LBB

Specific reference is included to broadband connectivity;

however, there are capacity issues in Park Royal with other
forms of infrastructure particularly energy and drainage. This
needs to be acknowledged in PR2. A cross reference is
needed to the environment strategy and delivery strategy
chapters, which propose further studies to identify how
capacity issues will be addressed.

LBB

PR3: Public Amenity Space, page 74 The table in PR3

suggests amenity space will only be sought in the Heart of
Park Royal. Opportunities should be sought to secure
amenity space across wider Park Royal as part of
developments to provide an attractive working environment.

Agree. Reference will be made to the need to

address over utilities capacity issues within the
supporting text for PR2 with relevant cross
references made.

Park Royal

The GLA understands that the OPDC is establishing

a Utilities Panel to ensure issues are addressed.
Noted. To ensure consistency with guidance for the
whole of the OPDC area, references will be made to
D1 and relevant London Plan policies with clarity
provided for a specific Park Royal context.

Park Royal

Page 325
117

Agree. The GLA recognises that a stronger vision for

Park Royal is required and will be carrying out minor
alterations to the vision and Park Royal Strategy to
reflect this. Specifically, these two sections will
reflect guidance elsewhere in the OAPF and existing
guidance set out in the existing Park Royal OAPF
(2010) for the following themes:

PR4: Streets & Public Realm, page 74 For Park Royal to

remain competitive it is important it provides a high quality
and attractive environment for businesses and their
employees. The design chapter for Park Royal lacks detail,
and does not place enough focus on high quality design. It
should be expanded to include the following:-

Page 326
LBB

Gateways and entrance points as set out in the current

Park Royal OAPF page 55 - 59.

Existing tall buildings and locations appropriate for tall

building using figure 27 in the existing Park Royal OAPF as a
starting point.

Buildings should address the street and have defined

entrances.

Developments should deliver an attractive public

realm, with space for employees, to create a desirable work
environment. Proposals should include integrally designed
landscaping and coordinate landscaping with adjoining sites
to maximise local amenity.

Public realm should be designed to improve feelings of

safety, incorporating adequate lighting and following secured
by design principles.

Streets should be legible and incorporate signage.

As far as is possible buildings should be designed

flexibly so they can adapt to meet changing needs as
business evolves, particularly where being built speculatively.

In accordance with London Plan policy 5.10

development should incorporate urban greening. The quality
of the environment at Park Royal is to be improved through
tree planting, soft landscaping, green roofs and walls. Green
infrastructure can deliver multiple benefits in terms of air
quality and as part of Sustainable urban Drainage Systems.

- Provide a clearer and stronger vision

- Define the challenges and opportunities
- Identify what evidence based will be produced with
timeframes and envisaged methodology
- skills and training
- commitment to securing funding streams
- Design guidance (public realm and routes, public
spaces, building heights)
- Land uses guidance
- Infrastructure guidance (transport and utilities)
- Placemaking guidance (Heart of Park Royal and
wider Park Royal)

Park Royal

118

Noted. The GLA considers that it has a

comprehensive understanding of the current and
future context in and around the Heart of Park Royal.
The GLA understands that the Heart of Park Royal
plays an important role in providing services of the
wider industrial area and residential communities
and should continue to do so but not to the detriment
of the functioning of designated SIL.

LBB

Page 327

LBB

LBB

Heart of Park Royal, Page 76 - 77 This chapter needs to be

informed by a greater understanding of the current and future
context, including the future of Asda and Middlesex Hospital.
As stated previously Park Royal is lacking in good quality
meeting space and hotel accommodation to serve
businesses. A key objective for the Heart of Park Royal
should be to provide these facilities to serve businesses.
Q7, page 76 Policy PR3 of Brent Councils Site Specific
Allocation DPD allocates land off Acton Lane for hospital
expansion and an element of key worker or supported
housing where this benefits from proximity to the hospital.
Conventional residential development will not be acceptable
in this location.

The GLA understands that the OPDC will be

developing a Character Study to inform the OPDC
Local Plan and will be engaging with relevant
stakeholders to inform this and other activities.
Park Royal
Agree. The objectives for the Heart of Park Royal
will be amended to reflect this.
Park Royal
Noted. The guidance for the Heart of Park Royal will
be amended to reflect this existing guidance.

Park Royal
Noted. The guidance for the Heart of Park Royal will
be amended to reflect this existing consent.

LBB

Key worker housing has already been delivered and there is

an existing consent in place for extra care housing on land
next to the Victoria Centre on Acton Lane. Application
number 13/1296.
A suitable transition will be required between the Strategic
Industrial Location and supported housing.

Park Royal

Noted. The guidance for the Heart of Park Royal will

be amended to be consistent with PR1.

Organisation

Comment

Theme

Response

LBB

Park Royal

119

Page 328
LBHF

The council is concerned that Wormwood Scrubs will be

used to provide open space to support Old Oak development
proposals and developers will fail to provide adequate open
space north of the Grand Union Canal (an area which is
identified in LBHFs Core Strategy to be deficient in access to
open space). Heavy reliance on the Scrubs to provide
recreational space for intensified development would
adversely affect the character and amenity of the Scrubs.
The OAPF must set out amount of open space and play
space that needs to be provided by proposed development
(within the development sites north of Wormwood Scrubs) to
ensure there isnt an over reliance on Worm wood Scrubs as
the amenity space for the significant increase in projected
new homes and people in the area.

Noted. The GLA considers that the quantum of

public amenity space shown in the illustrative maps
is appropriate for level of development and the role
of the OAPF as Supplementary Planning Guidance
to the London Plan. Providing definitive amounts of
public open space is not appropriate, however the
OAPF will be amended to refer to the Green Grid
SPG and the hierarchy of spaces set out in table 7.2
of the Local Plan. The GLA understands that the
OPDC will be undertaking additional detailed work
related to public amenity space provision to support
the OPDC Local Plan. However, further work on the
Green Grid and amenity space will be carried out as
part of the public realm strategy. This will also
include more detailed proposals for the Park Royal
area.

Wormwood Scrubs

With regard to concerns relating to the potential

contribution of Wormwood Scrubs to public amenity
space provision for development in Old Oak, D1 and
OO2 set out how the GLA expects proposals to
deliver new public amenity space in addition to
Wormwood Scrubs. The GLA understands that the
OPDC Local Plan will provide further detailed
guidance for how development will be expected to
deliver new public amenity space supported by an
Open Space Strategy.

120

Page 329

Wormwood Scrubs

Disagree. The OAPF sets out indicative locations for

social infrastructure. Wormwood Scrubs provides
viable playing fields that are often not used in
weekdays and it would sensible to investigate the
potential for a new secondary school within the
OAPF area to use these facilities. However, any
decision to locate a school in the indicative location
shown and make use of the playing pitches in
Wormwood Scrubs would need to be taken in
discussion with the Wormwood Scrubs Charitable
Trust and the London Borough of Hammersmith and
Fulham.

LBHF

Under the proposed arrangements WSCT would work with

LBHF regarding Linford Christie Stadium but with the OPDC
for the Scrubs where the related sports facilities are located.
The OAPF needs to recognise this relationship.

Wormwood Scrubs

Agree. It will be clarified that the Linford Christie lies

to the south of Wormwood Scrubs and does not fall
within the OPDC boundary, but does fall within the
responsibility of the WSCT.

LBHF

Although not a Place this section needs some key facts

clearly setting out ownership, relationship of the OPDC to
the Wormwood Charitable Trust, site size, MOL designations,
Wormwood Scrubs Act etc.

Wormwood Scrubs

Agree. A key facts box will be added to the

Wormwood Scrubs section.

LBHF

As currently drafted, this section is relatively short and

would benefit from further development. In particular, more
emphasis could be given on nature conservation.
Hammersmith and Fulham council have designated the
Scrubs as a nature conservation area of Borough-wide
Grade 1 importance and the council would encourage the
MDC to replicate this designation in the emerging Local Plan
for the MDC Area.

Wormwood Scrubs

Agree. Further clarity will be provided on the nature

designations identified by LBHF in Wormwood
Scrubs.

LBHF

Identifying the location of a potential new school on the

edge of the Scrubs suggests that the Scrubs would be used
by the school. Playing field requirements for new schools to
support the 24,000 new homes would be another pressure
on the Scrubs.

121

Page 330

LBHF

The council supports the inclusion of a reference to the

Metropolitan Open Land (MOL) designation of the Scrubs in
the supporting text of this section, but an acknowledgement
of what this actually means would be beneficial, for example
in such locations there is a general presumption against
development.

LBHF

Other sections in the draft OAPF have a vision and key

objectives, but these are missing for Wormwood Scrubs. To
ensure consistency of approach with other sections, the
council considers that a Vision is required. In accordance
with the Duty to Cooperate, the council would expect to be
consulted and engaged on this matter. In this context, the
council would like to see Hammersmith and Fulham included
by name in point (f) on page 80.

LBHF

Whilst just outside the MDC boundary, there is no mention

of Little Wormwood Scrubs in the Strategy. Little Wormwood
Scrubs is a Local Park and an area that is designated by
Hammersmith and Fulham as a nature conservation area of
Borough-wide importance, and the OAPF and emerging
Local Plan should make sure that nature conservation in this
area is appropriately considered. The same would also apply
to St Marys Cemetery which is also a protected nature
conservation area to the east of the MDC boundary.

LBHF

Relationship to Linford Christie Stadium and the linked

activities need to be recognised.

LBHF

P.80, Para 7.5, 5th bullet point needs to include Little

Wormwood Scrubs

Wormwood Scrubs

Agree. The text will clarify what a MOL designation

means for the Scrubs.

Wormwood Scrubs

Agree. The OAPF will reference the London

Borough of Hammersmith and Fulham under point
(f) on page 80. The GLA do not consider there to be
a need to have a separate vision for Wormwood
Scrubs as Principle WS1 clearly sets out the
strategy the GLA would take for Wormwood Scrubs.

Wormwood Scrubs

Noted. The OAPF recognises both these spaces in

Figure 27 and will provide further clarity regarding
improving access to Little Wormwood Scrubs.

Wormwood Scrubs

Agree. Change to be made to reference the Linford

Christie stadium and that its changing facilities are
used by those using the Scrubs for sport and that
links between the two are important

Wormwood Scrubs

Agree. Reference will be added to considering

relationship between Wormwood Scrubs and Little
Wormwood Scrubs.

122

LBHF

Organisation

Page 331

LBB

LBB

P.81 Figure 53 needs to show:

o Linford Christie Stadium
o Little Wormwood Scrubs
o Boundary of Wormwood Scrubs needs to clearer to show
that the proposed road does not encroach on scrubs.

Comment
The transport studies which have informed the OAPF focus
on Old Oak. Given the significant pressure the scale of
development will place on junctions in the surrounding area
further analysis is required on the need for improvements to
the wider road network. It is disappointing this information
was not available to inform the framework, as without it the
OAPF does not set out a clear strategy to address capacity
issues.
It also lacks clarity on how bus routes, and the walking and
cycling network will improve connectivity within Park Royal.

Wormwood Scrubs

Theme

Agree. Change to be made to show Linford Christie

stadium and Little Wormwood Scrubs. Para 7.6
clarifies that development is not in the Scrubs but on
rail or industrial land.

Response
Noted A Park Royal Transport Study has been
commissioned by OPDC and TfL which would inform
future Local Plan policy developed by OPDC.

Transport

Transport

Noted A Park Royal Transport Study has been

commissioned by OPDC and TfL which would inform
future Local Plan policy developed by OPDC.

123

Page 332

LBE

LBE

Planned highways and road access points seem also to work

counter to the aim of improving integration between Old Oak
and its surroundings by encouraging high usage arteries that
risk being dominated by vehicular traffic. The aim to divert as
much traffic as possible to public transport and
pedestrian/cycle modes is strongly supported by Ealing, and
these should be further backed up by active limits on the
number of parking spaces provided and pedestrianisation of
streets. There is a unique opportunity to set an example at
Old Oak not merely for low car housing but for a low car
settlement with a full range of functions and broad
accessibility to the whole city. Conversely, failure to achieve
very low car parking provision and car transport usage at a
site which is the centre of so much public transport
investment will damage the prospects of traffic reduction
schemes all over London.
The need for bus access to Old Oak is understood and
supported, however the very extensive highway network that
is envisaged by the draft OAPF will also be difficult to support
in a high density development. In the absence of other
measures to improve the quality of the built environment, and
public space in particular, consideration should be given to
the exclusion of road traffic from more of the streets in Old
Oak, this will increase the space for pedestrians and cyclists,
and compensate in part for the cramped nature of the site.

Noted. The OAPF does state that there would be

controls on car parking and that this would be 0.2
spaces per unit and that as many journeys as
possible should be made by public transport, walking
or cycling. The GLA disagrees that the approach
outlined in the OAPF relies on arterial roads and
paragraph 8.21 states that Measures to prioritise
bus movements, provide segregated facilities for
cyclists and create pedestrian priority areas will be
needed. This provide scope for road traffic to be
excluded from specific areas

Transport
Noted. Paragraph 8.21 states that Measures to
prioritise bus movements, provide segregated
facilities for cyclists and create pedestrian priority
areas will be needed. This provide scope for road
traffic to be excluded from specific areas

Transport

124

Page 333

LBB

PR2: Infrastructure, page 73 PR2 includes reference to

improvements to the road network being focused along four
main roads, however, as acknowledged in the transport
chapter detailed work is required to identify the full extent of
transport impacts across Park Royal and also identify how
adverse impacts will be mitigated. This chapter should
acknowledge that further work is required, and that this will
provide greater clarity on where improvements are needed.
The focus of improvement works will therefore be subject to
the outcome of this work. This policy could potentially limit
the extent of improvement works unless this reference is
included.

LBB

There are current capacity issues at road junctions in the

Heart of Park Royal. A wider transport study is needed to
identify how these issues can be addressed. In addition
there is a need to improve public transport and
pedestrian/cycle links to relive pressure on the road network.

Noted A Park Royal Transport Study has been

commissioned by OPDC and TfL which would inform
future Local Plan policy developed by OPDC.

Transport
Noted A Park Royal Transport Study has been
commissioned by OPDC and TfL which would inform
future Local Plan policy developed by OPDC.
Transport
Noted.

LBB

T1, page 84 Brent Council welcomes acknowledgement of

the need to improve capacity and access at Willesden
Junction station. Willesden Junction Station is a critical
commuter station for Brent residents and for many years to
come will be the primary public transport gateway to the Old
Oak regeneration area. Willesden Junction station needs
considerable early improvements and investment if it is to
provide a credible gateway to Old Oak and this must be a
shared delivery priority for regeneration in the area. The
redevelopment of Willesden Junction will be critical to
creating improved links to Harlesden. The reconfigured
station should be orientated to include a more direct access
on to Station Approach. This would also enable sites
surrounding Willesden Junction to be brought forward for
development.

Transport

125

Page 334

LBB

Reference is made to a potential link from Crossrail to West

Coat Main Line (WCML) potentially stopping at Wembley
Central. This link would be of significant benefit to both Brent
residents and the delivery of regeneration at Old Oak,
therefore stronger emphasis on the importance of this link is
required. In general terms, this link would allow Brent to be
better interconnected with the rail network, reduce time
savings on travel and ease congestion at Euston. The council
is concerned without this link commuters will instead drive to
Old Oak or Willesden Junction to access the station, placing
further pressure on the road network and car parking
provision. As the transport chapter indicates if the road
network around Old Oak and Park Royal is to cope with the
increased level of development it is crucial the use of public
transport is facilitated.

LBB

T2, page 88 Brent council welcomes the inclusion of an eastwest highway link from Old Oak Lane to Harrow Road. This
will improve east-west connectivity and has potential to
alleviate pressure on Tubbs Road.

LBB

This omits Park Royal. Given the transport issues already

facing Park Royal and the increased pressure due to
development at Old Oak it is crucial Park Royal is fully
considered. The existing Park Royal OAPF Transport
Strategy should act as the starting point.

Noted. Paragraph 8.4 identifies the potential for a

link from Crossrail to the West Coast Main Line
which could provide additional connections and
specifically names Wembley Central. The link is not
a funded or committed scheme and would require a
positive business case so the wording is considered
appropriate at this stage

Transport

Transport

Noted. However, the potential for this connection be

able to accommodate vehicles would require further
investigation in terms of its deliverability and impact
on the wider highway network.
Noted A Park Royal Transport Study has been
commissioned by OPDC and TfL which would inform
future Local Plan policy developed by OPDC.

Transport
Agree. Change to be made

LBB

Figure 55, page 85 Typo in title proposed

Transport

126

Page 335

LBB

Para 8.24, page 88 As stated further analysis is needed to

identify where improvements are required on the surrounding
network. It is disappointing this information was not available
to inform the OAPF, as it may well have implications for the
proposed route network. It is crucial it is clear what
improvements are required and how they will be delivered.
This must be set out in the Local Plan and taken account of
in calculating CIL.

LBB

T3 Car parking, page 90 If this section in its entirety only

applies to Old Oak, as seems to be the case, this needs to
be made clear. Clarification is needed as to which car
parking standards will be applied at Park Royal, including in
First Central and the Heart of Park Royal. In considering
parking levels at Park Royal current reliance on vehicles
needs to be a shift due to improved public transport.

LBB

The car parking levels proposed for Old Oak appear to only
allow for disabled parking and therefore be promoting car
free development. If this is the case this needs to be made
clear.

LBB

T4, page 90 The strong demand for taxis and private hire
vehicles around the Old Oak station will place significant
pressure on the transport network. The OAPF needs to be
informed by an understanding of where the main drop off and
pick up points will be. From the OAPF it is unclear to what
extent taxi and private hire vehicles have been factored into
the transport study.

LBB

Figure 59, page 91 Figure 59 is entitled road junctions

experiencing delays. It needs to be made clear if this is
based on current situation or as a result of scale of
development at Old Oak.

Agree. Impact on the surrounding network will be

considered more fully as part of the Local Plan but
the Old Oak Transport Study did assess this and
Figure 59 indicates the junctions that might be
impacted by development in Old Oak. Any
Regulation 123 list would need to consider what
enhancements might have to be made to these
junctions.
Transport
Noted - A strategy for car parking in Park Royal will
be developed as part of the Park Royal Transport
Study

Transport

Transport

Disagree. This is the case for the commercial

elements but the parking standards for residential
allow for a small proportion of non-disabled car
parking.
Disagree. At this stage, designs of the HS2 station in
the Hybrid Bill are only indicative. As Schedule 16
proposals come forward from HS2, the
appropriateness of taxi and private hire vehicle drop
off would need to be considered by the relevant
determining authority.

Transport
Agree. Change to be made

Transport

127

Noted A Park Royal Transport Study has been

commissioned by OPDC and TfL which would inform
future Local Plan policy developed by OPDC. An
indicative future bus network for Park Royal would
be considered as part of the OPDC's Local Plan.

Page 336

LBB

T5 Buses, page 92 Text refers to improving bus connections

linking Old Oak and Park Royal to the surrounding area,
however, the supporting figure does not include Park Royal.
To address pressure on the road network there is a need to
improve bus links throughout Park Royal, particularly
connections to stations. Figure 24 of the current OAPF
includes an existing and proposed bus network. This should
be updated and included here.

LBB

For neighbouring areas such as Harlesden to benefit from

the regeneration at Old Oak it is crucial frequent bus links
between the two areas are secured. It is not sufficient to
identify the roads which buses will navigate alone. There
needs to be a clear strategy to promote frequent bus services
which connect to the surrounding area. This figure should
indicate bus routes and their destinations. Figure 24 in the
Park Royal OAPF is indicates how this could be illustrated.
Supporting text needs to emphasise frequent services will be
secured.

LBB
LBB

T6 Walking, page 95 To improve connectivity there needs to

be investment not only in Old Oak but also to the pedestrian
and cycle network in the surrounding area. Figure 61 does
not indicate how links will be secured in Park Royal. See
previous comments on Park Royal section, page 73.
An explanation of mini Holland is required.

Transport
Transport

LBB

Para 10.29, page 120 Reference should be included to the

opportunity for a Crossrail link to Wembley.

Transport

Transport
Disagree. If the figure were to show destinations in
would have to show a much wider geography and
the focus on the immediate area would be lost. As
applications come forward there would need to be
much more detailed discussions with London Buses
to discuss the locations for bus stops, frequency of
service, specific bus routes and destinations and
many other factors.

Transport
Noted A Park Royal Transport Study has been
commissioned by OPDC and TfL which would inform
future Local Plan policy developed by OPDC

Agree. A definition of mini-Holland will be provided.

Disagree. Paragraph 8.4 already identifies the
potential for a link from Crossrail to the West Coast
Main Line which could provide additional
connections and specifically names Wembley
Central. The link is not a committed scheme and
would require a positive business case so the
wording is considered appropriate at this stage

128

LBB

The proposal to redevelop Willesden Junction station is also

welcomed. Willesden Junction station needs considerable
early improvements and investment if it is to provide a
credible gateway to Old Oak and this must be a shared
delivery priority for regeneration in the area. The
redevelopment of Willesden Junction will be critical to
creating improved links to Harlesden.

LBHF

The OPDC should work closely and in partnership with the

council in the developing transport impact studies and in
developing transport related proposals for the area. Any
proposals should aim for the maximum proportion of journeys
to be made by walking, cycling or public transport, and
adequate measures should be taken to mitigate any possible
adverse impacts on the local road network.

Noted.

Transport

Page 337

Transport

Noted. The GLA shares the aspiration of LBHF that

as many journeys as possible should be made by
walking, cycling or public transport and that
adequate measures should be taken to mitigate any
possible adverse impacts on the local road network.

LBHF

It is understood that the OPDC have the powers to adopt

private streets as part of eth public highways. LBHF would
want to be involved in any decision to adopt highways and
this should be reflected in the drafting of the OAPF.

Transport

Agree. Reference will be made to the fact that any

decision to adopt streets would need to be made in
collaboration with the local authority.

Organisation

Comment

Theme

LBB

E2 Waste, 9.8, page 104 Any relocation should also be in

accordance with the West London Waste Plan where it falls
within this area. In the first instance relocations should
explore the suitability of relocating to designated and existing
waste sites, as identified in the Waste Plan.

Waste

Response
Agree. The GLA understands that the OPDC will
adopt waste plans and safeguard sites for waste
management . Well regulated waste activities are
essential for achieving and developing circular
economy objectives . OPDC are happy to discuss
relocations as outlined in paragraph 9.8 of the
OAPF.

129

LBB

Waste management, including the provision of recycling

facilities, can be challenging in high density developments
such as that proposed at Old Oak. To ensure developments
contribute to meeting recycling targets and achieve the
highest levels of sustainability clear guidance is required and
innovative solutions should be sought. In this regard the
London Waste and Recycling Board have recently produced
useful guidance on Waste Management Planning Advice in
New Flatted Properties. In agreeing schemes it is important
the MDC work with borough Waste and Recycling Units, who
will ultimately be responsible for servicing the developments.

LBE

Fig 65 currently identifies all existing sites in the Old Oak

area, but only shows the allocated sites in the wider Park
Royal area.

LBB

1.9, page 11 The MDC can choose to adopt documents post

its establishment on the 1st April. Brent Council has been
assured the West London Waste Plan will be taken to the
MDC Board for adoption. Therefore it is not the case that
DPDs would only have the material weight contingent with
the stage that the document reached upon the MDCs
establishment. This needs to be clarified here.

Disagree. The OAPF does not seek to repeat

guidance within the London Plan, specifically in
relation to Waste policies 5.16 to 5.19. which sets
out criteria for waste management and recycling .
However existing guidance and best practice will be
used as part of the evidence base to develop strong
waste management policies within the OPDC local
plan supported by an Integrated Waste
Management Strategy.

Waste
Noted. All waste sites in Park Royal will be identified
Waste
Agree. Amendments to be made.

Page 338

Waste

130

Page 339

LBHF

The EMR and Powerday waste sites are located in the

north of H&F and both sites fulfil the councils waste
apportionment needs. The proposed MDC would cover both
these sites and the GLA plan to relocate both facilities to
elsewhere within Park Royal. The MDC would have its own
waste apportionment target, that would be based on the
percentage of land taken from each Local Authority. In H&F,
this would result in a 20% reduction in the boroughs waste
apportionment target but through our Local Plan, we would
be unable to identity either the Powerday or EMR waste sites
as contributing to this need. For this reason the council
considers that the OPDC should actively seek measures to
meet the councils waste apportionment targets and meet
any costs which the council may incur. Discussions with the
GLA/MDC have been ongoing for nearly two years on this
issue and we are still no further forward regarding an
agreement The Draft OAPF should set out a clear policy on
waste apportionment reflecting the comments above.

LBHF

The council considers that the section should make it clear

that Hammersmith and Fulham is not part of the West
London Waste Authority, but is within a different waste
authority. This council requests that discussions are held
with the GLA and/or MDC and with the other boroughs in the
Western Riverside Waste Authority as soon as possible and
on an ongoing basis to ensure that a satisfactory outcome
regarding waste is achieved. Consideration of preparing and
undertaking joint approaches for the preparation of planning
policies, for example on waste, is a key part of the Duty to
Cooperate.

Waste

Noted regarding apportionment but Disagree

regarding costs. The GLA understands that OPDC
will cooperate with boroughs and the GLA to ensure
that Boroughs apportionment targets are met as
stated in paragraph 5.80 of the London Plan.

Waste

Agree. The OAPF will be amended to reference

Hammersmith and Fulham as part of the Western
Riverside Waste Authority. The GLA understands
OPDC will cooperate with London Boroughs on
waste management issues as stated in paragraph
5.80 of the London Plan.

131

Organisation

Comment

Theme

LBB

E1 Water, page 102 In addition to flood risk reference should

be included to drainage capacity and surface water flooding.

Environment

Page 340

LBB

9.18, page 107 Development proposals that give rise to air

pollution will be encouraged to find mechanisms are put in
place to ensure they are air quality neutral. This needs to be
worded more strongly to be consistent with London Plan
policy 7.14 which states development proposals should be at
least air quality neutral and not lead to further deterioration
of existing poor air quality. The majority of the OAPF area is
in an Air Quality Management Area therefore there needs to
be a strong onus on ensuring air quality does not deteriorate
further.

LBB

9.22, page 108 The Energy strategy will be used rather than
should be used to inform local plan.

LBB

E5 Green Infrastructure, page 109 It would be beneficial to

include a map showing existing Sites of Importance for
Nature Conservation and Wildlife Corridors, and the
proposed green grid to indicate where enhancements could
be best focused to improve ecological connectivity. This
would also give an indication to developers of ecological and
nature conservation areas to be enhanced and retained.
Consideration should be given to how the proposed green
grid in the OAPF area links to the wider All London Green
Grid.

Response
Disagree . The GLA believes the OAPF states flood
risk and drainage capacity will be addresses. In
addition the OPDC are committed to undertaking an
Integrated Water Management Strategy which will
support Sustainable Urban Drainage Systems as
outlined in paragraph 9.4.
Disagree . The OAPF states it proposes to minimise
the generation of air pollution, both during and post
construction, making new developments air quality
neutral or better; E3 page 106
Air Quality Neutral is part of the London Plan Policy
7.14 and is implemented through the SPG on Design
and Construction and enforced by planning
authorities.
The OPDC local plan will incorporate all aspects of
existing Borough Air Quality Action Plans particularly
as it is located wholly within existing AQMAs

Environment
Agree. Change to be made
Environment
Agree. The OAPF will be amended to illustrate sites
of importance for conservation biodiversity and
proposed green grid. The GLA considers that the
OAPF provides a strong starting point , and as part
of the supporting evidence for the Local Plan a
Green Infrastructure Strategy will be developed to
support delivery of exemplar Green Infrastructure
across the OPDC.

Environment

132

LBHF

Page 341
LBHF

Para. 9.25 Green Infrastructure states that the core

development site itself should be designed to accommodate
as much of the day to day recreational demand as possible.
The council agree with this statement and consider that this
principle should apply to all forms of infrastructure, physical
and social.

P.110 Section E6: This section is just a description of the

stages for the assessment and remediation of land
contamination. It contains no context for why such
assessments are done and it contains no guidance for the
development of that area. It should include reference to
other legislation relevant to land contamination, notably Part
IIA of the Environmental Protection Act 1990, relevant Local
Authorities Policies and specific industry standards and
codes of practice.

Environment

Noted. The GLA considers that the OAPF provides a

strong starting point. As part of the supporting
evidence for the Local Plan a Green Infrastructure
Strategy will be developed to support delivery of
exemplar Green Infrastructure across the OPDC.

Environment

Disagree. The GLA recognises that Land

Contamination is an important issue. National
legislation and NPPF policy exists and will be
applied but it is not necessary to replicate this within
the OAPF. London Plan Policy 5.21 requires LDFs to
set out policies to address land contamination. As
part of the supporting evidence for the Local Plan a
Land Contamination Strategy will be developed to
support the investigation, assessment and
sustainable management and remediation of
contaminated land risks within the OPDC area.

133

Page 342
LBHF

LBHF

LBHF

The draft OAPF document (page 6) states that the

Integrated Impact Assessment (IIA) and other documents
have been used to inform the content of this planning
framework. Section E6 poorly reflects the consideration
given in the IIA to land contamination. For example, the IIA
identifies the following points which have not been included
in the draft OAPF document:
o The role of the NPPF in addressing land contamination
(para 1.22); Note: the NPPF is not mentioned in the draft
OAPF document.
o that land contamination and its remediation will have
cumulative impacts (para 3.49);
o the risks associated with contamination during construction
(para 3.56);
o the risks to water resources, notably groundwater (Table
3.13); and
o the need to mitigate impacts on good quality soils from
development (Table 6.1).
Other subjects in the IIA which are related to land
contamination but have not been considered in the draft
OAPF document include water resources and demolition.
Sections 5, 6 and 7: Old Oak Strategy, Park Royal Strategy
and Wormwood Scrubs Strategy - These sections are
inconsistent in their content and style. For example, the
subsection on the area of Old Oak North (page 48) identifies
that land is expect to be contaminated and remediation
works will be required. The other sections and sub-sections
do not even include such a basic assessment.
Noise (which also includes vibration) is barely mentioned
within the main document or supporting reports: with the
exception of a short general statement within the Integrated
Impact Assessment draft document (section 3.70-3.73, pp
61-62 - which has very basic information on the existing
noise levels in the area), and a brief acknowledgement that

Environment

Environment

Environment

Disagree. The GLA recognises that Land

Contamination is an important issue. National
legislation and NPPF policy exists and will be
applied but it is not necessary to replicate this within
the OAPF. London Plan Policy 5.21 requires LDFs to
set out policies to address land contamination. As
part of the supporting evidence for the Local Plan a
Land Contamination Strategy will be developed to
support the investigation, assessment and
sustainable management and remediation of
contaminated land risks within the OPDC area.

Agree. Text will be inserted to reflect that

contaminated land in Old Oak South is likely to be a
significant issue.
Disagree. The OAPF does not seek to replicate
London Plan Policy . The London Plan contains
Policy to reduce and manage Noise. Policy 7.15
concerns the identification and nomination of new
quiet areas in line with Defras draft noise action plan
for agglomerations . Policy 5.17f addresses how

134

noise during the construction phases will have an impact in

the short-term, and a single comment on page 61 of the
main OAPF document (in relation to noise from two roads in
North Acton), there is no substantial information or comment
on noise.

LBHF

Whilst detailed information would not be expected at this

stage, it would not be unreasonable to expect some overarching principals, proposals or strategy to have been
developed and included within the Environment Strategy of
the main document (alongside air quality, for example).

waste management operations should be evaluated

against the environmental impact on surrounding
areas, particularly noise emissions, odour, air
quality.

Environment

Disagree. The OAPF does not seek to replicate

London Plan Policy . The London Plan contains
Policy to reduce and manage Noise. Policy 7.15
concerns the identification and nomination of new
quiet areas in line with Defras draft noise action plan
for agglomerations . Policy 5.17f addresses how
waste management operations should be evaluated
against the environmental impact on surrounding
areas, particularly noise emissions, odour, air
quality.

Page 343
135

 The development opportunity clearly has implications in

terms of noise:

Page 344

o Noise from construction activity in the opportunity area

affecting receptors neighbouring the area, and future
occupants of the area as the work on differing phases
progress.
o Noise generated by existing sources of noise (rail, road,
industry, both within the opportunity area and adjoining it)
affecting areas of new residential and commercial occupiers.
o Noise from new sources of noise affecting existing
neighbouring receptors and any proposed new residential
and commercial occupiers.

LBHF

Clearly these issues will need to be considered in detail as

the project progresses, but a statement outlining what any
proposals for the project should seek to achieve in terms of
creating an acceptable noise environment for new and
existing occupants would be expected along with further
information on the likely adverse impacts. Any noise
proposals should align with the Noise Policy Statement for
England and the NPPF, as well as other London-wide and
local policies regarding noise, and look to achieve the
established WHO and British Standards health-based
standards.

Environment

Disagree. The OAPF does not seek to replicate

London Plan Policy . The London Plan contains
Policy to reduce and manage Noise. Policy 7.15
concerns the identification and nomination of new
quiet areas in line with Defras draft noise action plan
for agglomerations . Policy 5.17f addresses how
waste management operations should be evaluated
against the environmental impact on surrounding
areas, particularly noise emissions, odour, air
quality.

136

Environment

Organisation

Comment

Theme

LBB
LBB

Figure 70, page 119: Typo key a little more flex on location
and design.
Figure 70, page 119: Harlesden should be labelled on map.

Delivery
Delivery

LBB

10.35, page 122 All schools within the OAPF area must
provide high quality facilities and aim for educational
excellence. If social infrastructure is not of a sufficient
standard this will place pressure on existing infrastructure in
neighbouring boroughs. Brent believes that all new school
provision needs to be to the highest educational standards
possible. To this end we are anxious about the specific
proposal for an all through four form entry primary and
secondary school. The Borough already has a number of all
through schools and our current policy is to review progress
in respect of educational standards within these schools
before committing support for further all through
arrangements.

Delivery

Page 345

LBHF

With regard to light, there is no mention of this within the

documents and a statement acknowledging that lighting, in
terms of any new source of light affecting existing or future
occupants, will be considered is desirable.

Disagree. Government guidance ( sections 101 to

103 of the Clean Neighbourhoods and Environment
Act 2005 ) sets out how new developments may
have implications for light pollution and how action
can be taken by local authorities when artificial light
is a statutory nuisance. It is not appropriate to
replicate this in the OAPF. However the GLA
understands that OPDC will, as part of the Local
Plan evidence base explore the need for a Light
Strategy or Action Plan.

Response
Agree. Change to be made
Agree. Change to be made
Noted. 10.34 identifies that social infrastructure will
be contingent on the new resident and worker
population in the area. The GLA notes LB Brent's
concerns regarding all-through schools. Any
discussions relating to the provision of educational
facilities within the Opportunity Areas would need to
be carried out in tandem with the local educational
authorities.

137

Page 346

LBB

Furthermore the indicative location of the school indicates the

school would lack facilities and sports provision, instead
relying on the Scrubs for open space. There is a clear
potential for conflict here as the Wormwood Scrubs Strategy
indicates its ecology is to be protected and enhanced. As
there is no access to the Scrubs from the east school groups
would have to access the nearest playing pitch provision via
Scrubs Lane, a busy A road. This is not a workable solution.

LBB

The OAPF includes reference to the need for a one form

entry expansion of an existing primary school. The closest
school in proximity to the north of Old Oak, Harlesden
Primary School, expanded from 1 form entry to 2 form entry
in September 2014. The school would not withstand further
expansion. The schools within the wider planning area have
already expanded or are faith schools not controlled by the
council. Therefore there is no capacity for further expansion.

LBB

The future Local Plan must allocate school sites, taking into
account the need to provide high quality facilities, and the
existing pressure on schools in the surrounding area.

LBB

10.38, page 122 Expansion of existing ambulance stations,

police stations and Park Royal Fire Station within Brent must
be subject to further detailed discussions with service
providers and the council. Account needs to be taken of
providers service delivery plans.

Disagree. The OAPF sets out indicative locations for

social infrastructure. Wormwood Scrubs provides
viable playing fields that are often not used in
weekdays and it would sensible to investigate the
potential for a new secondary school within the
OAPF area to use these facilities. However, any
decision to locate a school in the indicative location
shown and make use of the playing pitches in
Wormwood Scrubs would need to be taken in
discussion with the Wormwood Scrubs Charitable
Trust and the London Borough of Hammersmith and
Fulham.
Delivery
Noted. Para 10.36 explains that any existing school
expansion would be dependent on further work to
identify the ability of any premises to expand. If there
are no schools in the vicinity capable of expansion
then the developer would be required to make onsite provision.
Delivery

Delivery

Noted. OPDC would as part of its Local Plan

consider the need for the allocation of land for
school sites.
Agree. Text will be inserted clarifying the need for
detailed discussions with service providers and the
councils and the need to consider providers' service
delivery plans.

Delivery

138

LBB

10.40, page 122 Emphasis needs to be placed on achieving

a standard of residential development which provides a high
quality of life. When assessed against open space
benchmarks in the London Plan much of Old Oak core area
will be identified as deficient in open space. In accordance
with London Plan policy 7.18 open space needs to be better
planned for. A greater emphasis should therefore be placed
on securing amenity open space within developments, and
these standards must be set out in the OAPF. In addition
play space standards should be set out here.

LBHF

Figure 72/para.10.40 Social infrastructure. There does not

appear to be adequate open space/public amenity space
shown. The allocation seems to be very reliant on
Wormwood Scrubs and on areas designated as Nature
Conservation Areas. There needs to be a clear statement or
policy indicating the amount of open space that will be sought
as part of the development. Paragraph needs to be
expanded to state that infrastructure needs to be designed
and delivered so that there is no financial burden on the local
authority.

Page 347
LBB

The aim must be to create a truly sustainable development

which offers a high quality of life for residents. To achieve
this it is essential sufficient social infrastructure is secured.
Assumptions are made around expanding existing facilities in
the surrounding area, including schools and emergency
service infrastructure. It cannot be assumed that existing
infrastructure has capacity to expand to accommodate the
needs which will arise from development at Old Oak. This
needs to be ascertained through detailed discussions with
service providers. In the case of Brent Council, the primary
schools within the surrounding area do not have scope for
further expansion.

Agree. The OAPF will refer to the precedents in the

Green Grid Supplementary Planning Guidance and
the Open Space Hierarchy in the London Plan.
Although not referenced in the OAPF, the Mayor's
Play and Informal Recreation SPG (2012) is a
material consideration in the determination of
planning applications across London. OPDC's Local
Plan would also contain detailed guidance on the
provision of amenity space and play space in
developments.
Delivery
Noted, the OAPF states in para 10.36 that any
existing school expansion would be dependent on
further work. Similar text will be added in relation to
emergency services.

Delivery

Delivery

Agree. The OAPF will refer to the precedents in the

Green Grid Supplementary Planning Guidance and
the Open Space Hierarchy in the London Plan. The
management and maintenance of streets and public
realm will need to be carefully considered and
planned. Within current budget constraints, it is
recognised that additional costs to local authorities
will be a challenge. Any decisions regarded revenue
and maintenance of infrastructure in Old Oak and
Park Royal would need to be discussed and agreed
by OPDC Board.

139

Page 348

LBHF

P.114. In DL1, bullet point b, suggest replacing ensure

with demonstrate as a proposal cannot reasonably ensure
joined up working. Also in bullet point c, suggest deleting
everything after public sector assets as this repeats what is
said in DL1 bullet points a and b.

Delivery

Agree. Change to be made to point b). The text in

point c) will remain as it is especially important that
the public sector is aligned in its strategy for bringing
forward its assets.

LBHF

P. 114, Para. 10.1 does not mention transport

infrastructure, which is a key item of infrastructure (see para
6.6 and PR2 on page 73).

Delivery

Disagree. The need for transport infrastructure is

covered in detail in paras 10.23 to 10.32.

LBHF

P.118, DL2. The specific identified infrastructure and/or

infrastructure improvements needed in Park Royal as listed
in relevant OAPF proposals are not identified in Fig 70. It is
unclear why this is the case as the identified infrastructure
needed in the Park Royal area quite clearly satisfy the fixes
criterion referred to in paragraph 10.22.

Delivery

Disagree. Para 10.1 clarifies that this chapter

focusses on infrastructure required around Old Oak
and notes that delivering and securing infrastructure
will be equally important in the Park Royal industrial
estate. The GLA is aware that OPDC are
undertaking further work looking at what
infrastructure will be required in Park Royal and this
will be included in OPDC's Local Plan.

LBHF

P. 118, para 10.21 Needs to emphasise that the that

physical infrastructure such as bridges, roads, improvements
to train stations provide access and help to unlock potential
development sites.

Delivery

Agree. The text will be revised to clarify the

importance of this infrastructure.

Delivery
Delivery
Delivery

Noted. At the time of the production of the OAPF,

LBHF did not have an adopted CIL. It would also
take a while for the OPDC to adopt CIL and
therefore, the OAPF acknowledges that S106 will
form an important tool for the delivery of
infrastructure in the area. The OPDC is aware of the
limits on S106 pooling, but it also aware that for
major development projects, in-kind infrastructure
secured through S106 agreements is often a better
mechanism for delivering on-site infrastructure and
the merits of this approach versus securing monies
through CIL.
Agree. Change to be made
Agree. Change to be made

LBHF
LBHF
LBHF

The OAPF appears to favour the use of S106 obligations

and correspondingly understates the role of CIL as the
mechanism for the MDC to provide the required infrastructure
(e.g. Policy DL2 and the Transport policies). Moreover, the
OAPF does not appear to consider the impacts of the
impending limitations on the use of S106 obligations in
seeking the identified infrastructure, which by their scale are
generally more suited to being provided via CIL.
Figure 70 add logos for stations
Figure 71 add logos for stations

140

LBHF

LBHF

The OAPF is not informed by a DIF study, which would

normally identify specific requirements to support
development, the council is not in a position to respond other
than to say that we would like to work closely in developing
the DIFs work and agreeing and prioritising infrastructure.

The OPDC must work closely and in partnership with the

council to ensure that any proposals are designed to
consider ongoing maintenance and that they do not have an
implication on revenue budgets

Page 349
LBHF

The OAPF appears to favour the use of S106 obligations

and understates the role of CIL as the mechanism for the
MDC to provide the required infrastructure. The OAPF does
not appear to consider the impacts of the impending
limitations on the use of S106 obligations in seeking the
identified infrastructure, which by their scale are generally
more suited to being provided via CIL.

LBHF

From 1 April LBHF still continues to manage all services but

will no longer be the CIL setting and charging authority and
therefore could have new infrastructure imposed upon it
without the revenue to adequately deliver the service. LBHF
will have no input into the prioritisation of infrastructure
although it will inherit and be responsible for this
infrastructure when the OPDC is dissolved.

Delivery

Noted.

Delivery

Agree. The management and maintenance of

infrastructure will need to be carefully considered
and planned. Within current budget constraints, it is
recognised that additional costs to local authorities
will be a challenge. Any decisions regarded revenue
and maintenance of infrastructure in Old Oak and
Park Royal would need to be discussed and agreed
by OPDC Board.

Delivery

Noted. At the time of the production of the OAPF,

LBHF did not have an adopted CIL. It would also
take a while for the OPDC to adopt CIL and
therefore, the OAPF acknowledges that S106 will
form an important tool for the delivery of
infrastructure in the area. The OPDC is aware of the
limits on S106 pooling, but it also aware that for
major development projects, in-kind infrastructure
secured through S106 agreements is often a better
mechanism for delivering on-site infrastructure and
the merits of this approach versus securing monies
through CIL.

Delivery

Noted. The management and maintenance of

infrastructure will need to be carefully considered
and planned. Within current budget constraints, it is
recognised that additional costs to local authorities
will be a challenge. Any decisions regarded revenue
and maintenance of infrastructure in Old Oak and
Park Royal would need to be discussed and agreed
by OPDC Board.

141

Page 350
LBHF

The OAPF needs to recognise the role of the council and

set out how it intends to work with the council to deliver
infrastructure and any impact on services arising from this
infrastructure. LBHFs ability to promote and comply with its
council wide duties will be severely undermined with a
negative effect on how the council properly and appropriately
discharges its functions and how it is perceived to be
operating. e.g.
1. Affordable housing provisions, including nomination rights
of occupiers on its housing register, viability review
mechanisms are of paramount importance to the councils
role as housing authority.
2. Highway Authority a) highways works agreements often
secured through the planning obligation (being equally a site
specific mitigation measure but also requiring the permission
of the highway authority). ; b) provisions relating to the
construction, dedication and adoption of highway and
changes to road systems will require the councils signature
as highway and road authority;
3. Education Authority provisions relating to education
facilities will be critical.
4 Local authority for Public Health provisions relating to
health care and community facilities will be important
5 Local authority responsible for open space through open
space byelaws; and byelaws generally, open space
provisions will be of importance
6 Local authority responsible for safety of sports stadia;
7 Economic and employment provisions council key role in
developing provisions to secure apprentices, training and
contracts for local providers in relation to development. Its
involvement in negotiating the terms of the s.106 agreement
will be important to promote the councils core objectives.

Delivery

Noted. The GLA recognises that it is important for

OPDC to engage with the local authorities,
particularly when it comes to the provision of
infrastructure and ensuring that the ongoing
management and maintenance costs can be met. In
respect of housing, OPDC is establishing a Housing
Panel, where issues such as a nomination rights
would be discussed. In respect of highway works
(including adoption), education, health and open
space the management and maintenance of
infrastructure will be carefully considered and
planned. Within current budget constraints, it is
recognised that additional costs to local authorities
will be a challenge. Where appropriate, maintenance
and management arrangements will be secured via
S106 agreements. Any decisions regarded revenue
and maintenance of infrastructure in Old Oak and
Park Royal would need to be discussed and agreed
by OPDC Board, in consultation with the local
authorities. With regard to the safety and security of
sports stadia, LBHF would be consulted on
application and OPDC case officers would need to
consider representations made by the local
authorities on safety and security. With regard to
training and employment, OPDC's Local Plan will set
out the approach to securing training and
employment benefits for surrounding residents,
including apprenticeships.

142

Delivery

LBHF

The council needs to be fully involved in discussions

concerning proposals which could potentially impact on any
council services and maintain that it is essential for the
council to be co-signatories to any s106 agreements.

Delivery

LBHF

The council would like clarification on how the OPDC

intends to work with LBHF to deliver infrastructure which will
have implications on revenue budgets needs to be
addressed. LBHF want a statement added to the draft
planning framework that the infrastructure should have no
revenue implications on the Borough.

Delivery

Page 351

LBHF

The council is concerned that:

o it cannot ensure the best outcome for our residents
o Any infrastructure secured by OPDC would not fully
consider councils financial position or factor in budgetary
constraints.

Noted. The management and maintenance of

infrastructure will be carefully considered and
planned. Within current budget constraints, it is
recognised that additional costs to local authorities
will be a challenge. Where appropriate, maintenance
and management arrangements will be secured via
S106 agreements. Any decisions regarded revenue
and maintenance of infrastructure in Old Oak and
Park Royal would need to be discussed and agreed
by OPDC Board.
Noted. The borough does not need to be a signatory
to S106 agreements in order to secure commitments
and contributions that relate to Council services.
OPDC will seek to ensure that S106 agreements
mitigate the local and borough-wide impact of
development schemes to the Councils satisfaction.
Contributions towards Council services will be
secured in accordance with development plan policy
and transferred by OPDC to the borough as
appropriate. The Council will also benefit directly
from additional revenue generated by new
development in the form of Council tax, business
rate receipts and the New Homes bonus.
Noted. The management and maintenance of
infrastructure will be carefully considered and
planned. Within current budget constraints, it is
recognised that additional costs to local authorities
will be a challenge. Where appropriate, maintenance
and management arrangements will be secured via
S106 agreements. Any decisions regarded revenue
and maintenance of infrastructure in Old Oak and
Park Royal would need to be discussed and agreed
by OPDC Board.

143

LBHF

The OPDC must work closely and in partnership with the

council to ensure that any proposals are designed to
consider ongoing maintenance and that they do not have an
implication on revenue budgets.

Delivery

Noted. The management and maintenance of

infrastructure will be carefully considered and
planned. Within current budget constraints, it is
recognised that additional costs to local authorities
will be a challenge. Where appropriate, maintenance
and management arrangements will be secured via
S106 agreements. Any decisions regarded revenue
and maintenance of infrastructure in Old Oak and
Park Royal would need to be discussed and agreed
by OPDC Board.

Page 352
144

Agenda Item 11

Subject:

Old
Oak
and
Park
Royal
Development
Corporation
Local

Development
Scheme


Meeting
date:

28
July
2015

Report
to:

Board

Report
of:

Chief
Executive
Officer



For
Decision

________________________________________________________________________



This
report
will
be
considered
in
public

________________________________________________________________________



1

Summary

1.1

This
report
provides
an
overview
of
Old
Oak
and
Park
Royal
Development

Corporations
(OPDC)
Local
Development
Scheme
(LDS),
which
sets
out
a

programme
for
the
adoption
of
its
development
plan
documents
(DPDs)
and
other

non-development
plan
documents
such
as
the
Community
Infrastructure
Levy
(CIL).

Recommendations

The
Board
is
invited
to:

2.1

Note
the
recommendation
of
the
OPDC
Planning
Committee
to
publish
the
Local

Development
Scheme;

2.2

Approve
publication
of
the
Local
Development
Scheme;
and

2.3

Delegate
authority
to
the
Head
of
Planning
to
make
minor
amendments
before

publication
of
the
Local
Development
Scheme
to
incorporate
comments
from
the

OPDC
Board
and
Planning
Committee.

Background

3.1

On
1
April
2015,
the
OPDC
was
established.
On
this
date,
OPDC
became
the
local

planning
authority
for
the
area,
taking
on
planning
functions
normally
available
to
a

London
borough,
including
plan
making
powers
and
determination
of
planning

applications.
The
OPDC
also
has
powers
to
be
the
Community
Infrastructure
Levy

(CIL)
setting
and
charging
authority.
In
becoming
a
local
planning
authority,
OPDC

has
subsumed
the
planning
functions
of
the
London
Boroughs
of
Brent,
Ealing
and

Hammersmith
and
Fulham
for
the
land
within
its
area.

Page 353

3.2

As
part
of
this
OPDC
must
prepare
a
Local
Plan,
a
Community
Infrastructure
Levy

(CIL),
a
Local
Development
Scheme
(LDS)
and
a
Statement
of
Community

Involvement
(SCI).
This
paper
provides
detail
on
the
content
of,
and
the
process
of

preparing
OPDCs
LDS.



LocalPlan

3.3

As
a
Local
Planning
Authority,
OPDC
has
a
duty
in
accordance
with
the
Town
and

Country
Planning
(Local
Planning)
(England)
Regulations
2012
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.

3.4

The
National
Planning
Policy
Framework
(NPPF)
sets
out
the
government's
planning

policies
and
how
these
are
expected
to
be
applied,
whereas
the
London
Plan
sets
out

an
integrated
economic,
environmental,
transport
and
social
framework
for
the

development
of
London
over
the
next
20
-
25
years.
Together,
these
documents
form

part
of
the
Development
Plan
for
the
OPDC
Area.
Until
OPDCs
Local
Plan
is
formally

adopted,
the
development
plans
prepared
by
Brent,
Ealing
and
Hammersmith
and

Fulham
will
continue
to
be
used
alongside
the
NPPF
and
the
London
Plan
when

making
planning
decisions.
Once
adopted,
the
Greater
London
Authoritys
(GLAs)

Old
Oak
and
Park
Royal
Opportunity
Area
Planning
Framework
(OAPF)
would
also

have
substantial
material
weight
in
the
determination
of
planning
applications.




CommunityInfrastructureLevy

3.5

The
Planning
Act
2008
and
the
Community
Infrastructure
Levy
Regulations
2010
(as

amended)
provide
local
planning
authorities
with
the
power
to
prepare
and
adopt
a

Community
Infrastructure
Levy
(CIL)
for
their
areas.

3.6

The
adoption
of
a
CIL
allows
local
authorities
in
England
and
Wales
to
raise
funds

from
developers
undertaking
new
build
projects
in
their
area.
The
money
can
then
be

used
to
help
fund
a
wide
range
of
infrastructure
that
is
needed
as
a
result
of

development
including
road
schemes,
flood
defences,
schools,
hospitals
and
other

health
and
social
care
facilities,
park
improvements,
green
spaces
and
leisure
centres.

3.7

Although
not
formally
part
of
the
Development
Plan
for
the
area,
CIL
will
be
a
key

delivery
mechanism,
by
helping
to
ensure
that
new
infrastructure
is
provided
in
a

timely
way
in
order
to
support
the
level
of
growth
that
is
being
planned
for.
An

Infrastructure
Delivery
Plan
will
also
be
prepared
as
part
of
the
evidence
base
for
the

CIL
and
the
Local
Plan.

3.8

In
London,
the
Mayor
has
already
introduced
a
CIL
which
came
into
force
on
1
April

2012,
which
will
be
used
to
provide
finance
towards
the
delivery
of
Crossrail.
Once
a

CIL
Charging
Schedule
has
been
adopted,
the
OPDC
CIL
will
be
collected
in
addition

to
the
Mayoral
CIL.

Page 354

Local
Development
Scheme

4.1

The
OPDC
is
required
to
produce
a
Local
Development
Scheme
(LDS)
under
Section

15
of
the
Planning
and
Compulsory
Purchase
Act
2004
(as
amended).
It
is
required
to

publish
this
on
its
website
and
to
update
it
on
a
regular
basis.

4.2

The
Local
Development
Scheme
sets
out
the
indicative
timetable
for
the
OPDCs

development
plan
documents
(DPDs)
other
non-development
plan
documents
such

as
the
Community
Infrastructure
Levy
(CIL)
and
Supplementary
Planning
Documents

(SPDs).

4.3

The
OPDCs
LDS
sets
out
an
achievable
programme
for
the
production
of
its
Local

Plan
and
CIL,
which
is
considered
to
be
reasonable
and
comparable
to
the
production

of
Local
Plans
and
CIL
charging
schedules
by
other
local
authorities
(see
below
table).

The
programme
allows
for
above
the
minimum
statutory
consultation
periods.
The

timetable
envisages
consultation
on
the
first
draft
of
the
Local
Plan
and
CIL
charging

schedule
in
December
2015

January
2016.
This
allows
for
adequate
lead
in
time
to

produce
both
drafts
and
informally
engage
with
relevant
stakeholders
such
as
the

three
local
authorities.
The
programme
also
allows
sufficient
time
for
the
production

of
necessary
supporting
evidence
documents
in
order
that
these
documents
can

inform
the
consultation.
The
programme
envisages
consultation
on
the
second
draft

in
June
-
July
2016.
This
allows
sufficient
time
to
consider
comments
received
as
part

of
the
first
consultation
and
for
finalising
supporting
studies.
The
programme
allows

for
a
reasonable
time
period
between
consultation
on
the
second
draft
concluding

and
the
Local
Plan
and
CIL
being
submitted
to
the
Secretary
of
State.
The

programme
for
Examination
in
Public
and
subsequent
adoption
is
largely
dictated
by

the
Planning
Inspectorate
and
it
is
likely
these
dates
may
shift,
but
the
programme

below
is
considered
reasonable
and
comparable
to
the
programmes
for
other
known

Local
Plans.

Date

December
2015-

January
2016

June-July
2016

Local
Plan

Regulation
18
consultation

(first
draft
Local
Plan)

Regulation
19
consultation

(pre-submission
consultation)

September
2016
Submission
to
Secretary
of

State

January
2017

Examination
in
public

March
2017

Adopt

4.4

Community
Infrastructure
Levy

Regulation
15
consultation

(preliminary
draft
charging
schedule)

Regulation
16
consultation
(draft

charging
schedule)

Submission
to
Secretary
of
State

Examination
in
public

Adopt

The
LDS
has
a
section
on
Neighbourhood
Plans,
which
would
form
part
of
the

Development
Plan
for
the
area.
The
section
notes
that
application
for
a

Neighbourhood
Area
and
Forum
for
Harlesden
has
recently
been
submitted
to
the

OPDC
and
the
London
Borough
of
Brent
with
an
intention
to
develop
a

Neighbourhood
Plan.

4.5

The
LDS
sets
out
a
programme
for
the
Statement
of
Community
Involvement
(SCI).

The
SCI
is
being
considered
under
item
7
of
the
planning
committee
agenda.
The

programme
is
set
out
in
the
below
table.
The
programme
assumes
the
SCI
is
adopted

Page 355

before
the
first
consultations
on
the
Local
Plan
and
CIL,
providing
stakeholders
with

certainty
on
how
OPDC
will
consult
and
engage
during
its
consultations.





Preparation

N/A

4.6

Public

Consultation

August-October

2015

Adoption

November
2015

The
LDS
contains
a
section
on
Supplementary
Planning
Documents
(SPDs).

The

section
explains
that
there
are
currently
3
SPDs
being
considered
for
the
OPDC
area

but
that
it
is
not
a
requirement
under
the
Planning
and
Compulsory
Purchase
Act

2004
(as
amended)
to
publish
programmes
for
these.
However,
in
order
to
be
as

transparent
as
possible,
once
dates
are
firmed
up
for
the
production
of
these

documents,
future
iterations
of
the
LDS
could
include
information
on
the
timescales

for
the
production.

Planning
Committee
Recommendation

5.1

6

6.1

On
15
July
2015
OPDC
Planning
Committee
considered
the
Local
Development

Scheme.
OPDC
Planning
Committee
commended
the
programme
outlined
in
the

Local
Development
Scheme
and
made
a
recommendation
that
OPDC
Board
publish

the
document.


Financial
Implications

There
are
no
direct
financial
implications
for
the
OPDC
arising
from
this
report.

7






Legal
Implications

7.1

8

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

legal
framework.


Appendices

Appendix
A:
Local
Development
Scheme

Background
Papers

None





Report
originator:

Tom
Cardis,
Principal
Strategic
Planner,
OPDC

Telephone:


020
7983
5552

Email:



tom.cardis@opdc.london.gov.uk

Page 356

AppendixA

Old Oak and Park Royal Development Corporation (OPDC)

Local Development Scheme (LDS)
July 2015
Status
This Local Development Scheme (LDS) has been prepared in accordance with the
requirements of section 15 of the Planning and Compulsory Purchase Act 2004 (as
amended). The Act requires the LDS to be revised at such times as the Local
Planning Authority considers appropriate.
Section 19 of the Planning and Compulsory Purchase Act 2004 (as amended)
requires Development Plan Documents (DPDs) to be prepared in accordance with
the LDS. As such, progress made against the LDS will be monitored, and a report,
known as the Authority Monitoring Report (AMR), will be published annually.
Purpose and Scope
This Local Development Scheme (LDS) is the Old Oak and Park Royal Development
Corporations (OPDCs) two-year project plan for the production of the Local Plan.
The purpose of the LDS is to describe the progress of the Local Plan and other
planning policy documents OPDC is preparing and to provide up-to-date information
so that interested parties will know when they will have an opportunity to participate
in the plan-making process. This LDS includes:
-

A brief description of the local planning documents to be prepared by OPDC,

including the identification of which of these documents will be Development
Plan Documents (DPDs), and the content and geographic area to which they
which they will relate;
The planned timetable for preparation and revision of each DPD and the key
milestones to be achieved;
the project plan for the preparation of non-development plan documents which
will support the Local Plan, including the Statement of Community
Involvement and Supplementary Planning Documents; and
the project plan for the preparation of the Community Infrastructure Levy
Charging Schedule.

What is OPDC?
On 1st April 2015 OPDC came into force. On this date, OPDC became the local
planning authority for the area, taking on planning functions normally available to a
London borough, including plan making powers and determination of planning
applications. OPDC also has powers to be the Community Infrastructure Levy (CIL)
setting and charging authority.

Page 357

In becoming a local planning authority, OPDC has subsumed the planning functions
of the London Boroughs of Brent, Ealing and Hammersmith and Fulham for the land
within its area. A map of the OPDC area is provided at Appendix 1.
OPDCs Local Plan
As a result of the transitional arrangements in OPDCs Planning Functions Order,
until OPDC adopts its own Local Plan for the OPDC area, Local Authority
Development Plan Documents (DPDs), with the weight of the stage at which they
had reached on 1st April 2015, will apply to the areas that they cover.
This includes the following:
London Borough of Brent

Core Strategy

Site Specific Allocation DPD

Draft Development Management Policies DPD

Saved UDP Policies

Policies Map

West London Waste Plan

London Borough of Ealing

Development (Core Strategy) DPD

Development Management DPD

Development Sites DPD

Draft Planning for Schools DPD

Policies Map

West London Waste Plan

London Borough of Hammersmith and Fulham

Core Strategy

Development Management Local Plan

Proposals Map

Draft Local Plan

The London Plan also forms part of OPDCs development plan. It sets the overall
strategic plan for London, and it provides a fully integrated economic, environmental,
transport and social framework for the development of the capital to 2036.

Page 358

The table below sets out proposed new DPDs being produced by OPDC, their role
and content, geographical coverage and timescales for adoption.
a
Document
OPDC
Local
Plan

Policies
Map

West
London
Waste
Plan

Role and
Content
Sets out
the vision,
objectives
and core
policies for
the area
Illustrates
DPD
policies
Identifies
possible
sites for
managing
the area's
waste

Coverage

Preparation

Entire
OPDC
Area

JulyNovember
2015

Entire
OPDC
Area

JulyNovember
2015

OPDC
area
within
London
Boroughs
of Brent
and
Ealing

N/A

Consultation
(Reg 18)
December
2015
January
2016

Consultation
(Reg 19)
June-July
July
2016

Submission

Adoption

September
2016

March 2017

December
2015
January
2016
N/A

June-July
July
2016

September
2016

March 2017

N/A

N/A

July 2015

Neighbourhood Plans
The Localism Act 2011 amended the Town and Country Planning Act (1990) to
make provision for the preparation of Neighbourhood
Neighbourhood Plans by Neighbourhood
Forums. These Plans
lans can set planning policies to guide future
future development in a
defined Neighbourhood Area and must be in general conformity with national policy
as well as the London Plan
an and Local Plan. A Local Planning Authority must adopt a
Neighbourhood Plan as part of its development plan if it passes with a majority vote
in a local referendum.

Page 359

An application for a Neighbourhood Area and Forum for Harlesden has recently
been submitted to the OPDC and the London Borough of Brent with an intention to
develop a Neighbourhood Plan once designated. This LDC will be updated to reflect
timescales for the development of this Neighbourhood Plan.
Other Non-Development Plan Documents
Supplementary Planning Documents (SPDs)
OPDC may prepare SPDs to support the implementation of Local Plan policies. In
order that there may be flexibility in the planning system to respond to changing
circumstances, it is not a requirement to include detailed information about what
SPDs will be prepared and when in a LDS; however, in the interests of transparency,
OPDC will commit to publishing a programme for the production of SPDs in future
iterations of the LDS, when their timescales for production are more fixed. OPDC
currently proposes to produce 3 SPDs:
1. Section 106 SPD this would sit alongside the Community
Infrastructure Levy Charging Schedule and would be programmed to fit
with the Community infrastructure Levy adoption timescales.
2. Integrated Public Realm SPD - there are no firm timescales for the
production of the SPD at present but its adoption would need to follow
that of OPDCs Local Plan.
3. Park Royal SPD - there are no firm timescales for the production of the
SPD at present but its adoption would need to follow that of OPDCs
Local Plan.
Statement of Community Involvement
The Statement of Community Involvement (SCI) sets out how stakeholders and the
community as a whole will be involved in the process of preparing the Local Plan,
Supplementary Planning Documents, Neighbourhood Planning as well as outlining
how they will be consulted on planning applications. The SCI has the status of a
special (Non Development Plan) Local Development Document.
The timescales for the production and adoption of OPDCs SCI are set out in the
table below.
Preparation
N/A

Public
Consultation
August-October
2015

Adoption
November 2015

Community Infrastructure Levy

The Planning Act 2008 and the Community Infrastructure Levy Regulations 2010 (as
amended) provide local planning authorities with the power to prepare and adopt a
Community Infrastructure Levy (CIL) for their areas.

Page 360

The adoption of a CIL allows local authorities in England and Wales to raise funds
from developers undertaking new build projects in their area. The money can then be
used to help fund a wide range of infrastructure that is needed as a result of
development including road and transport schemes, flood defences, schools,
hospitals and other health and social care facilities, park improvements, green
spaces and leisure centres.
Although not formally part of the Development Plan for the area, CIL will be a key
delivery mechanism, by helping to ensure that new infrastructure is provided in a
timely way in order to support the level of growth that is being planned for. An
Infrastructure Delivery Plan will also be prepared as part of the evidence base for the
CIL and the Local Plan.
In London, the Mayor has already introduced a CIL which came into force on 1 April
2012, which will be used to provide finance towards the delivery of Crossrail. Once a
CIL Charging Schedule has been adopted, OPDC CIL will be collected in addition to
the Mayoral CIL.
OPDCs programme for preparation of the CIL Charging Schedule is set out in the
table below.
Preparation
July-November
2015

Consultation
(Reg 15)
December 2015
January 2016

Consultation
(Reg 16)
June July
2016

Submission Adoption
September
2016

March 2017

Authority Monitoring Reports

Under the Town and Country Planning (Local Planning) Regulations, 2012 local
planning authorities are required to monitor the targets and indicators associated
with the policies and proposals within their Local Plan, as well as progress against
the milestones set out within the LDS. There is no longer a requirement that a
monitoring report be produced on an annual basis and submitted to the Government.
However, as CIL Regulations 2010 set out that receipts and spending should be
publicised for each reporting year OPDC will combine both requirements within the
Authority Monitoring Report. This will be produced annually, and will include:
-

Progress on the timetable and milestones identified for the preparation of the
Local Plan;
The performance against relevant targets and indicators associated with the
Local Plan, when adopted; and
Report on the CIL monies collected and that have been spent in providing
infrastructure, once OPDCs CIL has been adopted.

How to get involved

The best way to stay informed about the progress on the preparation of OPDCs
development plan documents, supplementary planning documents and the CIL
Charging Schedule is to be registered on the consultation database. This way, you
will receive direct notification of all upcoming consultation events.
Page 361

You can register on the database by contacting the OPDC team:

By email: info@opdc.london.gov.uk
By telephone: 0207 983 5723
You can also follow the OPDC on Twitter @OldOakParkRoyal.
Please also contact us if you would like your details amended or you would like to be
removed from the database.

Page 362

Appendix 1: OPDC Boundary

Page 363

This page is intentionally left blank

Page 364

Agenda Item 12

Subject:

Crossrail
Old
Oak
Common
Depot

Meeting
date:

28
July
2015

Report
to:

Board

Report
of:

David
Hughes,
Director
of
Major
Sponsorship,
Transport
for
London



For
noting

________________________________________________________________________



This
report
will
be
considered
in
public

________________________________________________________________________



1

Summary

1.1

This
report
is
intended
to
provide
the
OPDC
Board
with
an
update
on
work
that

Transport
for
London
(TfL)
is
undertaking
to
evaluate
options
for
the
long
term

future
of
the
Crossrail
Depot
at
Old
Oak
Common.

1.2

A
supplementary
report
is
included
in
Part
2
of
the
agenda,
as
it
contains
exempt

supplementary
information.
The
information
is
exempt
by
virtue
of
paragraph
3
of

Schedule
12A
in
that
it
contains
information
relating
to
the
business
affairs
of

Transport
for
London.

Recommendations

The
Board
is
invited
to:

2.1

Note
the
contents
of
this
paper.

Background

3.1

During
the
development
phase
of
the
Crossrail
Project
(early
2000s),
extensive
work

was
undertaken
to
identify
a
suitable
location
for
the
principal
Crossrail
Depot
and

Stabling
Facility.
The
outcome
of
this
work
led
to
the
Crossrail
Depot
being
located
at

Old
Oak
Common
(as
confirmed
in
the
Crossrail
Act
2008)
due
to
the
availability
of

sufficient
land
and
the
proximity
of
the
site
to
the
new
Crossrail
tunnels.

3.2

Whilst
TfLs
main
focus
is
on
the
successful
delivery
of
the
Crossrail
Project
for
the

opening
of
the
new
tunnels
in
December
2018,
in
recognition
of
the
proposals

contained
within
the
Old
Oak
and
Park
Royal
Opportunity
Area
Planning
Framework

(OAPF),
TfL
is
considering
potential
long
term
options
for
the
Crossrail
Depot
to

support
the
objectives
of
the
OPDC.

Page 365

Feasibility
Work

4.1

The
basis
for
the
current
work
is
to
consider
the
technical
viability
of
a
number
of

options
and
to
identify
any
showstoppers.
The
work
is
being
conducted
on
the
basis

that
any
options
would
be
long
term
and,
if
progressed,
must
not
have
any
adverse

impacts
on
the
successful
delivery,
maintenance
and
operation
of
Crossrail
services.

Financial
Implications

5.1

The
Depot
feasibility
study
will
be
undertaken
in
line
with
the
currently
set
2015-16

and
2016-17
budgets.
Future
years
budget
requirements
will
need
to
be
agreed
via

further
OPDC
budget
setting
process.

Legal
Implications

6.1

No
particular
legal
implications
arise
from
the
report
at
this
stage
and
it
is
consistent

with
the
Corporations
legal
framework.

Appendices

None

Background
Papers

None



Report
originator:

Alexandra
Reitman,
Programme
Manager,
OPDC

Telephone:


020
7983
4804


Email:



alexandra.reitman@opdc.london.gov.uk

Page 366

Agenda Item 13

Subject:

OPDC
Growth
Strategy
Submission

Meeting
date:

28
July
2015

Report
to:

Board

Report
of:

Chief
Executive
Officer



For
noting

________________________________________________________________________



This
report
will
be
considered
in
public

________________________________________________________________________



1

Summary

1.1

This
report
updates
on
discussions
with
Government
since
the
submission
of
the

OPDCs
Growth
Strategy
for
Old
Oak
and
Park
Royal
on
the
30
April
2015.

1.2

A
supplementary
report
is
included
as
Part
2
of
the
agenda,
as
it
contains
exempt

supplementary
information.
The
information
is
exempt
by
virtue
of
paragraph
3
of

Schedule
12A
in
that
it
contains
information
relating
to
the
business
affairs
of
the
Old

Oak
and
Park
Royal
Development
Corporation.

Recommendations

The
Board
is
invited
to:

2.1

Note
the
updates
contained
within
this
report.

Background

3.1

As
reported
to
the
Board
on
18
May
2015,
the
OPDC
submitted
a
Growth
Strategy
to

central
government
on
30
April
2015.
The
submission
of
the
Strategy
followed
the

recommendations
of
the
HS2
Growth
Task
Force
to
develop
local
growth
strategies
to

unlock
regeneration
potential
at
the
HS2
stations.

3.2

The
Growth
Strategy
set
out
the
scale
of
potential
regeneration
at
Old
Oak
as
set
out

in
the
Draft
Opportunity
Area
Planning
Framework
of
up
to
24,000
new
homes
and

55,000
new
jobs;
a
potential
development
programme
for
the
area;
likely
investment

needs,
and
possible
funding
and
financing
options
for
the
required
infrastructure.

3.3

The
Growth
Strategy
is
informing
discussions
within
Government
in
preparation
to
the

Comprehensive
Spending
Review
2015
and
Autumn
Statement.

Page 367

Update
on
the
Strategy

4.1

Since
submission
of
the
Strategy,
OPDC
has
been
in
active
dialogue
with
officials
at

the
Department
of
Transport
(DfT)
and
the
Department
of
Communities
and
Local

Government
(DCLG)
to
respond
to
requests
for
further
information,
and
clarify
what

support
would
be
needed
from
Central
Government
to
enable
delivery
of
the
potential

regeneration
benefits
at
Old
Oak
and
Park
Royal.

4.2

During
these
discussions,
OPDC
has
consistently
emphasised
the
need
for
a
long
term

coordinated
approach
to
the
development
of
the
site,
and
a
clear
and
joined
up

strategy
in
relation
to
the
public
sector
owned
land.

4.3

Several
different
scenarios
for
how
the
required
site
infrastructure
might
be
financed

have
been
explored,
as
well
as
conversations
regarding
the
other
commitments
that

Government
may
need
to
make
to
help
facilitate
development.

4.4

As
the
Mayors
Development
Corporation
for
the
area
and
local
delivery
body,
OPDC

has
promoted
a
strong
role
for
the
Corporation
in
the
delivery
of
the
development
and

infrastructure.
This
has
been
received
well
by
officials
as
this
supports
the

Governments
localism
drive.

4.5

Officials
within
the
DCLG
are
now
finalising
their
proposals
for
the
forthcoming

comprehensive
spending
review,
for
consideration
by
their
Ministers,
and
for

subsequent
submission
to
HM
Treasury,
in
advance
of
the
spending
review.

4.6

Further
detailed
work
will
now
be
undertaken
by
the
Government
officials
to
consider

the
practicalities
of
the
proposals
under
consideration,
to
enable
a
Government

decision
on
how
they
might
best
support
the
delivery
of
the
regeneration
of
Old
Oak

and
Park
Royal
in
the
early
autumn
2015.

4.7

OPDC
anticipates
this
will
likely
involve
a
strong
role
for
OPDC,
and
OPDC
officers
will

proactively
support
government
officials
over
the
summer
to
secure
the
best
possible

outcome
for
local
residents
and
businesses,
and
the
most
appropriate
role
for
the

OPDC
in
bringing
forward
the
significant
regeneration
potential
at
Old
Oak
and
Park

Roya..

4.8

It
is
envisaged
that
OPDC
Board
will
be
presented
with
the
outcomes
of
this
work,
and

the
proposed
implications
for
OPDC
in
September
or
October
2015,
for
discussion
and

decision,
as
appropriate.

Financial
Implications

5.1

The
Growth
Strategy
financial
implications
will
be
reviewed
in
line
with
the
currently

set
2015-16
and
2016-17
budgets.
Future
years
budget
requirements
will
need
to
be

agreed
via
further
OPDC
budget
setting
process.

Legal
Implications

6.1

No
particular
legal
implications
arise
from
the
report
at
this
stage
and
it
is
consistent

with
the
Corporations
legal
framework.

Page 368

Appendices

None

Background
papers

None






Report
originator:

Alexandra
Reitman,
Programme
Manager,
OPDC

Telephone:


0207
983
4804


Email:



alexandra.reitman@opdc.london.gov.uk

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