Better Plan making – an engineered view
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Under the banner ‘Taking a View’,  from time to time, we’re pleased to publish articles by members on a subject of their choice, which they believe will be interesting to the wider membership.

With both the London Plan and Hammersmith’s Local Plan due to be rewritten shortly, and with all the noise being made about ‘The Planning System’ in recent months, here, our Chairman takes an engineered view. How can we write better planning documents to improve the ‘planning system’ ?

With the help of established methods, perhaps a dash of modern AI, this piece shows how plans can be substantially shorter and more precise, illustrated with a couple examples from the London Plan, and in a specific case, how loose wording is being taken advantage of at Earls Court.

If you have an article you would like to be considered, please contact .
Articles are unedited personal viewpoints, and may not always represent the views of the Society

The planning system has become the whipping boy of our new government, blamed for many of the country’s economic ills. The government wants to to ‘cut red tape to speed up growth’, and with the right tapes cut, that could definitely help.  There can be no doubt that in some cases planning applications are frustrated (in the legal sense), when objections are piled up, and the usual suspects marked down as NIMBY. But nationally there’s been a ‘presumption in favour of sustainable development’ for over a decade in the NPPF, and it’s even less of an issue in dense urban areas such as London because of the additional regional level represented by the Mayor’s London Plan.

Plan hierarchy

In this article, we dare to suggest that many of the problems lie closer to government, where the ‘red tape’ appears strongest, with recent announcements suggesting that they may have realised. A background can be found in A Brief History of Bureaucracy, while remembering that Einstein said ‘Bureaucracy is the death of all sound work’.

With the London Mayoral prerogative automatically mandated for projects of any size, supported by the option of call-in,  plus the largely unaffordable cost of (legal) challenge, there are actually vanishingly few opportunities for NIMBYs to stop a development blessed by the Mayor.  In extremis, this leads to Mayoral Opportunity Area developments like Nine Elms, Stratford, North Acton or indeed more locally, White City, where planning controls are more lax, especially on tall buildings, and locals haven’t been much considered. Earls Court is the next such Opportunity Area to be developed, and one in which we’re been actively engaged with several neighbouring societies.

Nine elms

Stratford (GLA)

White City Living

White City 2021

North Acton OPDC

Earls Court phase 1 proposed

A thoroughly unscientific review of preferences expressed on our Instagram feed over the last five years shows what real people like, and it’s not the images shown here, it’s rather closer to the CreateStreets or new urbanism view of the world, to the possible chagrin of some (male) architects.

Despite the government’s belief, with the NIMBY option already unavailable where housing demand is greatest, lining the barricades won’t work as a way to contest a poorly thought-through development.  But to improve them, we can and do suggest to developers, planners, local and Mayoral administrations, that they should be using the enormous accrued experience and skills freely available across the civic movement – help they claim to desperately need – and are required to properly consider under the 2011 Localism Act.

The implications for North Hammersmith of adoption of the OPDC Local Plan by Henry Petersen
Click on the image to open the pdf

Under the banner ‘Taking a View’,  from time to time, we’re pleased to publish articles by members on a subject of their choice, which they believe will be interesting to the wider membership.

Our member Henry Peterson has a a lifetime’s experience in the world of planning, and been a long-term adviser to affiliate St. Helens Residents Association and the Old Oak Neighbourhood Forum.  He’s written on OPDC matters extensively, including for us, and his comments were mentioned several times in the recent Local Plan adoption meeting.

Here he takes the long view of what’s happened at OPDC, specifically in its long Local Plan development and eventual adoption on 22nd June, with reference to the falling-out with CarGiant that unravelled its original aims, and suggests what the plan now means for North Hammersmith.

The alarming vision presented is a land-grab to replace the lost CarGiant area, coupled with yet more ultra high-rises on the horizon in North Acton, and indeed 15-20+ storeys all along the boundary of Wormwood Scrubs with poor local public transport, sufficient for LBHF’s leader to withhold his support for another likely overbuilt Mayoral project.

In Henry’s words: “One of London’s last large brownfield areas deserved better.” 

If you have an article you would like to be considered, please contact .
Articles are unedited personal viewpoints, and may not always represent the views of the Society

OPDC local plan

A further consultation stage ended on 5 July. This was made necessary because the Car Giant section of the OPDC area was ruled to be “undevelopable” for the duration of the Plan (as a result of no agreement with Car Giant) – so the quantum of development has to be shifted to the west of the area.

Our member Henry Peterson, on behalf of a coalition of local groups and civic societies, is maintaining that this should require a new Draft Plan, but the Inspector is unlikely to agree. The following is Henry’s synopsis of the case against the Plan, with any references referring to sections of the plan available here :

• With a continuing pandemic, 2021 is not the time to fix in place a Local Plan for one of the last large areas of largely undeveloped land in London.   Much is changing, in London’s population trends, commuting patterns, and the type of housing in which people want to live.
• The changes made to the 2018 version of the Local Plan are not small ones.  Entirely new locations have been earmarked for high density and high rise housing.  OPDC claim in its consultation material that ‘most of the Plan remains the same’. As a result, many local people have not caught up with the fact that proposals dating from 2018 are being substantially altered.
• New plans for Channel Gate with high density, high rise inserted into existing low rise residential areas have been inadequately consulted on and should not be introduced via a ‘modification’ at this late stage, ref MM/PS2/OPDC/P9/1
• OPDC continues to say that these locations for high density housing will be ‘well connected’.  In many cases this is not true.  With no new Overground or Underground stations, as originally proposed, these locations are poorly served by public transport – check the PTAL ratings. Extra buses on roads heavily congested are not much help. MM/PS2/OPDC/SP/25 and MM/PS2/OPDC/T/1
• The modified Plan does nothing to join up the existing residential areas on the west and east side of the Scrubs, for the next 20 years.   We are left with east-west connections through Harlesden or south of the Scrubs at Du Cane Road. Major Modification Figure/PS2/OPDC/PM2
• High density housing which is ‘car-free’ does not mean ‘vehicle free’.  This Plan does not reflect the rapid changes taking place on online sales and delivery traffic.
• High rise housing is not what many people want or need in 2021 onwards, given a cladding scandal and the risks of further future lockdowns.  Lifts and social distancing do not combine well.
• The 2018 Draft included a ‘major town centre’ at Old Oak North on the Car Giant land. This 2021 version refers at various points to ‘parts of a major town centre’.   The location of Channel Gate for ‘major town centre uses’ is not convincing.   North Acton is now largely redeveloped but attracts only fast food and chain café outlets aimed at students and a transient population. MM/PS2/OPDC/SP/19 and MM/PS2/OPDC/SP/14 6a.

More on the Old Oak Neighbourhood Forum to which Henry contributes.

Planning for the future

In March of this year the government promised legislation to improve the supply of new homes, including legislation on building safety, rental reform, social housing – and an update to the planning system.

Following this, a government White Paper Planning for the Future proposed very significant changes to the planning process for public consultation which closed last week.

Changes to the planning procedure

At present, LBHF planning applications are assessed against the development policies in the LBHF Local Plan, in the London Plan, and in the government NPPF (National Planning Policy Framework). The White Paper proposes a new approach:  a new form of Local Plan, replacing the current format of more abstract policy guidance, by a format with a prescriptive system of development rules and a design code. The Local Plan would also include borough zone plans, which would identify three categories of development:

1. Growth areas where ‘substantial development’ would be suitable (similar, we suggest, to Earls Court, Old Oak Common etc)
2. Renewal areas such as existing built areas where development is encouraged (Hammersmith Town Centre, for example)
3. Protected areas like conservation and heritage areas, green belt and parkland.

Planning zones

In Growth and Renewal areas, proposals which are compliant with the Local Plan in height, use-type etc, and compliant with the government NPPF rules, would be effectively guaranteed an automatic outline planning consent, providing a level of certainty in site purchase values. At the next stage, a full planning application,  with detailed proposals, would be granted consent if the proposals comply with the more detailed rules and design codes of the Local Plan.

Community involvement

Public consultation in the planning process would be limited to the stage when the new Local Plan is put together by the local authority: community involvement would be excluded from full planning application stage, because (it is argued)  the application would be assessed against rules which have already been agreed through public consultation.

The intention is to establish a clear set of planning rules, which are in line with government policy, and have been agreed through community consultation; armed with these certainties applications would avoid the ambiguities of policy interpretation and community objection which (it is said) can delay the full planning application stage.

Design codes

CreateStreets – Bonnington Square

To illustrate examples of acceptable design and styling, and to provide a basis of resolution of design disagreements, Design Codes would form part of the Local Plan, and would be reviewed through public consultation when the new Local Plan is being put together. Design codes would be coordinated with the government’s National Design Guide, itself heavily influenced by the CreateStreets campaign and to the emerging National Model Design Code. To help the process, a chief officer for design and place-making would be appointed within each local authority.

Civic Voice launched its Manifesto 2020-2023, 50 years after the Skeffington Report on Public Participation in Planning, which arose from growing concern about the top-down nature of post-war planning and development and growing interest in the idea of ‘participatory democracy’ (that ordinary people need to be engaged in decision-making rather than simply voting for representatives to make decisions on their behalf).

A Civic Voice members survey last year found that 80% of people feel that developers do not effectively engage with the community and 72% said the same about local authorities. Recent research by Grosvenor Britain & Ireland also found a significant distrust of the planning process within communities. Just 2% of the public trust developers and only 7% trust local authorities when it comes to planning for large-scale development.  

This week’s news concerning the housing minister, the role of large developers and oblique arguments about viability, plus the role of CIL, brings these issues into sharp focus

The Civic Voice ambition is to move away from ‘confrontation to collaboration’ and from ‘consultations to conversations’. Its manifesto consists of the following three key recommendations to the Government and to Local Authorities, which aim at placing Civic Societies like the Hammersmith Society at the heart of their communities:

1. Create a more ‘accessible, balanced and collaborative’ (ABC) planning system with communities at the heart.
2. Move towards a citizen-led, participative model of governance for our towns, cities and villages.
3. Ensure local authorities have the appropriate resources and proper powers to enhance the historic environment to make better places.

Following the workshop event on which I reported previously, I am delighted to report that Henry Peterson has received overwhelming support for his proposal for St Quentin and Woodlands Neighbourhood Plan (just over the border in Kensington) in the public ballot. Henry is now progressing that and a proposal for a plan at Old Oak Common. Meanwhile Charles Wagner and others are looking at a possible proposal around Barons Court area. More news in due course.